Managing asbestos in premises
Candidates for this Advanced Proficiency Module must already hold either the P405 or alternatively the CoC (Asbestos).
To provide a practical knowledge and the skills to be able to manage asbestos in premises and to provide a basic knowledge of asbestos management plans, policies and procedures, their implementation and checks on effectiveness.
Health and Safety at Work etc Act 1974
- Discuss the basic concepts of this enabling legislation with particular reference to employer's responsibilities for asbestos.
Review all the relevant current regulations on asbestos:
- Control of Asbestos Regulations 2012 especially the Duty to Manage Asbestos in Non-Domestic Premises
- Management of Health and Safety at Work Regulations (1999)
- Hazardous Waste Regulations 2005
- Construction (Design and Management) Regulations 2007
- Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013
- Personal Protective Equipment Regulations 1992
Approved Codes of Practice
- Discuss the provisions of the Approved Code of Practice for the CAR and the status of the ACOP (1).
- Discuss the provisions of the various guidance documents which can be used to aid the management of asbestos including the implications of common parts of domestic premises. This should also include use of the HSE website and the various management web tools available on the HSE website.
Health Effects of Asbestos
- Describe the full range of health effects ranging from the benign (pleural plaques) to the terminal (mesothelioma) in the light of results from epidemiological studies carried out on asbestos workers.
Use of Asbestos, Types and Characteristics
- Use the HSE and/or the DETR as a primary source of information on products and their locations in buildings. Explain the physical and chemical properties of asbestos which have determined the use to which it has been put by industry.
- Discuss the uses and composition of asbestos products likely to be used or found inside buildings.
Management of Asbestos in Premises
- Discuss why asbestos has to be managed, the main target groups along with who is designated as the duty holder.
- Consider the definition of a duty holder and others (in addition to staff) who may have duties under Control of Asbestos Regulations 2012, Regulation 4.
Developing an Asbestos Management Strategy.
Identify the purpose of a management strategy and using HSE (10) identify the 7 key steps required for management of ACMs and how these may differ between organisations and the factors which may affect this:
- Current management of ACMs
- Size, complexity and type of organisation
- Types of ACMs present
The strategy should consider the differences between the domestic and non-domestic sector and the requirements when working in the domestic sector.
- Who should manage the ACMs within the premises? Identify the key roles and responsibilities plus the types of resources which will be required. Resources will include skills, training, authority and any necessary support.
Management and Organisation of Work Activities within Asbestos Containing Premises
Asbestos in Premises
- Confirm what you already know about the ACMs on your premises.
Identify the methods which can be used to confirm current information:
- Original construction drawings
- Previous survey data
- Asbestos removal records
- Age profiling of buildings and likely uses of asbestos
Types of Work
- Identify the different types of work, activities and actions which may disturb ACMs. Discuss appropriate methods and various approaches to control these activities and work to prevent or minimise exposure risks.
Initial inspection of damage.
- Identify the purpose of this initial inspection, the differences between this and an asbestos survey and also how it may fit into an overall management plan.
The Asbestos Management Plan
Develop a Strategy for Compliance
- Describe the range of techniques that can be used to plan a comprehensive strategy to ensure that all asbestos risks, whether short or long term are effectively managed.
- Use of surveys, survey types, survey planning and setting priorities for sequence of surveys.
- Survey reports, their use and compilation of an asbestos register.
- Consider the implications of not surveying (i.e. presumptive surveys), restricting surveyed areas and the use of caveats.
Priority Assessment of ACMs.
- Describe in detail the importance of priority assessments, stressing that it is not simply whether the ACM will release fibres that determines the risk to health. A risk assessment which includes the material assessment along with factors such as, maintenance activities, likelihood of disturbance, human exposure potential and occupant activity, must be carried out to set priorities for management of the ACMs.
Management Plan Development
Develop a long term management plan. The management plan must be clear and unambiguous. It should set out the strategy by which ACMs will be managed including:
- The details of how the location and condition of known or presumed ACMs are recorded
- The use of priority assessments and priority assessments scoring
- Decisions about management options including the rationale
- A timetable for action showing short term and long term objectives
- Monitoring arrangements
- Roles and responsibilities of staff
- Training arrangements for employees and contractors
- A plan of implementation of new procedures, including those for external contractors
- The mechanism for passing information about the location and condition of ACMs to those who need it
- Procedures for dealing with licensed and non-licensed products
- Who will oversee the quality of entries made on the management plan
- A procedure for review of the plan, including a timetable and quality control
The strategy should also recognise that the duty to manage requirements cover more than just buildings.
Management Plan Implementation
Discuss the types of considerations which should be included when making arrangements for the implementation and on-going maintenance of the management plan such as:
- Monitoring the action plan to make sure that all remedial work has been adequately carried out
- Monitoring of ACMS or presumed ACMs left in place and the frequency
- Updating the asbestos register following repair/removal of ACMs
- On-going communication/training of maintenance workers/contractors
- Continued awareness amongst all employees regarding management of asbestos and use of any applicable procedures
- Monitoring of the implementation timetable
- Lessons learned following incidents and accidents involving ACMs
- Strategies for dealing with asbestos incidences
- Independent quality assurance checks on standards of work including removal/repair of ACMs, surveying and analytical works.
Management Plan Review
Discuss the requirements to thoroughly review the management plan every 12 months as a minimum. This should critically review all the management processes and their effectiveness as well as the overall progress made against the implementation timetable. For example you should find out:
- If the plan is referred to in safe systems of work
- How the plan is communicated to maintenance workers, others working in the vicinity of asbestos, and external contractors
- If the plan is referred to in specifications for tenders, where appropriate
- If emergency plans/contingency procedures refer to the management plan
- If local emergency services are aware of the presence of asbestos in buildings
- If any changes are required as a result of independent quality checks
The review should also consider testing the plan to determine if work would be initiated without due consideration of the asbestos register and other requirements contained within, including appropriate provision of information.
Controlling Work on the Fabric of the Building or Services
Accessing & Working within Areas Containing ACMs
- Discuss the need to have a system in place to control any maintenance or building work on the fabric of the building or services and how this may take various forms depending upon the size and complexity of the organisation. For example the system would identify key roles and responsibilities, how information regarding ACMs is provided, the use of permits and the control of contractors on site.
Accessing & Working within Areas Containing ACMs
- Discuss the types of ACMs which may be encountered along with appropriate methods for maintenance staff (including in-house staff and external contractors) to access these areas and work safely.
- The use of PPE to protect the individual along with controls to prevent or minimise exposure, prevention of the spread of contamination and also suitable decontamination methods should be included.
- Discuss how to ensure the controls used are sufficient.
- Discuss the approach when determining if the works are subject to the requirements to use a licensed asbestos removal contractor or whether it can be undertaken by normal maintenance staff. This should also consider the additional arrangements and requirements when dealing with notifiable non licensed work.
- With reference to CAR 2012 discuss the various types of training including when and for whom each type would be applicable and the requirements for training needs analysis.
- The requirements for the duty holder to ensure authenticity of training provided to contractors and its suitability.
Selecting Competent Organisations
- Discuss suitable approaches to be considered when selecting organisations for undertaking asbestos removal/repair works, asbestos surveys, asbestos testing and air monitoring including 4 stage clearance testing.
- The requirements to ensure competence of the individuals on site along with independence of organisations from each other should also be considered.
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