A comprehensive guide to Managing Asbestos in premises

This is a free-to-download, web-friendly version of HSG227 (first edition, published 2002). This version has been adapted for online use from HSE’s current printed version.

You can buy the book at www.hsebooks.co.uk and most good bookshops.

ISBN 978 0 7176 2381 5 Price £12.50

This guidance is aimed at people who have a duty to manage the risks from asbestos–containing materials in the premises, ie building owners, tenants and anyone else who has any legal responsibilities for workplaces. The guidance expands on that given in the free leaflet A short guide to managing asbestos in premises, INDG223(rev3) - it will be useful to those in more complex organisations.

HSE Books Page 1 of 85

© Crown copyright 2002

First published 2002 Reprinted 2004

ISBN 978 0 7176 2381 5

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This guidance is issued by the Health and Safety Executive. Following the guidance is not compulsory and you are free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law. Health and safety inspectors seek to secure compliance with the law and may refer to this guidance as illustrating good practice.

Contents Flow chart 6

Introduction 9 What does this guidance do? 9 Who this guidance for? 10 Background information for using this guidance 11 What does the law require? 14 What is asbestos? 16 The health effects of asbestos 16 Damaged asbestos 16 Where in premises can asbestos be found and what does it look like? 18

Developing an asbestos management strategy 20 Who should manage the ACMs on my premises? 20 Immediate action (steps 1–3) 20 Continuing actions (steps 4–7) 24

Case study 1: Local authority: London Borough of Islington 34 Case study 2: A National Health Service Trust: Tees and North East Yorkshire 36 Case study 3: A large chemical company: BP Chemicals 38 Case study 4: Facility management: Drivers Jonas facility management 40

Appendix 1: Planning surveys 42 What type of survey to carry out 42 Selecting a surveyor 43 Information gathering 44 Reporting format and medium 46

Appendix 2: Survey report, material assessment and algorithm 47 Survey report 47 Material assessment and algorithm 48

Appendix 3: Priority assessment and algorithm 49 Maintenance activity 51 Priority assessment algorithms 52

Appendix 4: Worked examples of priority assessments 55 Example 1: Primary school 55 Example 2: Chemical plant 59 Example 3: Hospital 64

Appendix 5: Management options and selection of management options 69 Management options 69 Measures needed in all cases where ACMs are present 70 Options for managing the condition of your ACMs 71 Selection of management options 73

Appendix 6: Managing asbestos contractors and analytical laboratories 76 Selecting licensed contractors 78 Asbestos removal work, what to expect 80 Asbestos removal methods 81 Enclosures 82 Viewing panels 82 Monitoring the contractor 82

Selecting analytical laboratories 82 Managing asbestos repair/removal contracts 83

References 83

Further information 85

THE 10 KEY FACTS

■■ If you don’t manage asbestos in your premises, you could be putting your employees’ and other peoples’ health at risk. ■■ Exposure to asbestos occurs when you or others disturb it, releasing fibres into the air we breathe. ■■ Asbestos in good condition should be left in place and managed. ■■ Most work on asbestos requires a licence, but some minor work on asbestos can be done without a licence if the correct precautions are followed. ■■ Regulation 4 of the Control of Asbestos at Work Regulations is a duty to manage, not a duty to survey. ■■ You don’t always have to do a survey, but you do have to manage your asbestos-containing materials (ACMs). ■■ A bad survey is worse than not carrying out a survey. ■■ Managing asbestos means maintaining your (ACMs) in good condition to protect two groups of people: –– those who work on the fabric of the building (electricians, plumbers etc); and –– those who work in the building (eg plant and office workers, cleaners etc) who may come into contact or work near ■■ damaged or deteriorated ACMs. ■■ Damaged or deteriorated ACMs should be repaired or removed, or isolated until remedial action can be taken. ■■ Your Asbestos Management Plan: –– is your way of ensuring that your employees or others do not disturb your ACMs; –– can take many forms and need not be complex, but it does need to be effective.

Figure 1 Flow chart

Confirm what you already know about Step 1 the ACMs on your premises, and review how you are currently managing them (see paragraphs 39–41).

Prevent work on your premises that may Step 2 disturb the fabric of the building until measures to control the risk have been implemented (see paragraphs 42–46).

Carry out an initial inspection for damage Step 3 and disturbance of materials and take immediate action to control these (see paragraphs 47–55).

Step 4 Develop a strategy for compliance (see paragraph 56­–74).

Carry out a risk assessment of your ACMs Step 5 to set priorities for management (see paragraphs 75–77).

Develop a long-term management plan Step 6 (see paragraphs 78–84)

Monitor and review the management plan Step 7 (see paragraphs 85–90).

Flow chart The flow chart and these explanatory notes provide a general overview of the actions that you may need to take immediately and continuing actions that you may also need to take to effectively manage your asbestos-containing materials (ACMs). The extent to which you will need to carry out these actions will depend on your current management of ACMs and the size and complexity of your premises. Larger, more complex premises are likely to need to take all these steps to effectively manage their ACMs, whereas small and straightforward premises should be able to do less. Paragraphs 6 to 9 provide advice on what is likely to be required for small and straightforward premises, for example, a small retail premises.

Immediate actions

Steps 1 to 3 are the initial steps you should take to protect the health of your employees and others. They are designed to help you stop ACMs being damaged and disturbed now (Step 2), and immediately find any ACMs that are already damaged (Step 3).

■■ Step 1: Confirm what you already know about the ACMs on your premises, and review how you are currently managing them (see paragraphs 39–41). Reading these steps and the guidance in full will help you to do this. This will help you to decide how much more you need to do to manage your ACMs and will provide information to assist you in doing this.

■■ Step 2: Prevent work on your premises that may disturb the fabric of the building until measures to control the risk have been implemented (see paragraphs 42–46). The purpose of this step is to make sure that workers do not work on ACMs with out taking the proper precautions. This means any work, such as drilling, breaking, removing, sawing etc that could disturb the material. You should therefore not allow any work on the fabric of any building under your control, including piperuns, undercrofts etc, until you have put in place measures to control the risk. These will be short-term measures, until you have developed and implemented your management strategy.

■■ Step 3: Carry out an initial inspection for damage and disturbance of materials and take immediate action to control these (see paragraphs 47–55). This step is asking you to inspect your premises for damaged materials that may contain asbestos. Workers, during routine day-to-day activities, may be exposed to asbestos disturbed into the air they breathe if they or others disturb ACMs. This is a quick inspection to find out whether there are any problems that need dealing with now, but it is not intended to constitute a full assessment for the presence of asbestos on your premises. Typical examples to look out for include significantly damaged wall or door panels, or pipework insulation that has deteriorated or been damaged. If you find any damaged materials, you should consider whether they contain asbestos and take appropriate action to remove, repair or isolate them. If you find many, you may need to prioritise these using the algorithms referred to in Step 5.

Continuing actions

■■ Step 4: Develop a strategy for compliance (see paragraph 56-74). Steps 2 and 3 looked at minimising any immediate risks to health. You should now have stopped uncontrolled work on ACMs and found any damaged ACMs. You may still not know where all your ACMs are. In time, you will have to know where they are, or presume they are in places where you cannot conclude they are not. Managing asbestos means preventing your employees and others from breathing in asbestos fibres. Assessing your employees’ and others’ exposure to asbestos and therefore complying with your legal duties can be achieved in different ways: –– You could survey your premises, identify all ACMs, take any necessary actions and put in place a system to manage your remaining ACMs. –– Alternatively you could simply presume that all your building materials contain asbestos and when any maintenance or building work is needed, take a sample (see page 14) of the material for analysis, or work on it as if it was asbestos. You may still have carried out a damage and disturbance inspection as in Step 2. –– You could use/obtain other strong evidence (such as plans and building specifications) that show the materials, or some buildings do not contain asbestos. You would need to be certain for these materials or buildings that the information is accurate and up to date. –– You could do a combination of these. Survey and/or sample in some buildings or parts of buildings and leave others, depending on their occupancy.

■■ Step 5: Carry out a risk assessment of your ACMs to set priorities for management (see paragraphs 75–77). If you have carried out survey work, either determining whether materials contain asbestos or identifying those that may do so, you will need to set priorities for risk management. You may have found materials that need to be repaired or removed as a result of their condition or because of future planned work (eg refurbishment). You may not be able to tackle these all at once and therefore need to set priorities. Algorithms (see paragraphs 14-17) are provided to help you with this.You may also find these useful for setting priorities if you have found several ACMs requiring action during your ‘damage and disturbance inspection’ (Step 3).

■■ Step 6: Develop a long-term management plan (see paragraphs 78–84). The above steps should have taken you a long way towards preventing exposure to asbestos. But, you need to ensure that you continue to manage your ACMs, ensuring that you know the condition and location of all your ACMs in the long term and that this information is passed on to those liable to disturb them. You may need a paperwork or electronic system to record the ongoing condition of your ACMs. You also need to make sure that the system you have put in place to stop uncontrolled work on ACMs continues to be effective. Your employees and anyone else working on your site need to know their responsibilities, what action they should take if they find damaged or deteriorated ACMs, and how to work safely on them. As long as you have ACMs in your premises, you need to have an effective management plan to minimise exposure to asbestos.

■■ Step 7: Monitor and review the management plan (see paragraphs 85– 90). You should review you management plan periodically to make sure that it is still preventing uncontrolled work on ACMs. You also need to be sure that you are continuing to minimise your employees’, and others’, exposure to asbestos from damaged and deteriorated ACMs. This periodic review of your management plan should typically be done once every six months or where there is a significant change to the structure of the organisation, or personnel responsible for its implementation.

Introduction A new duty to manage asbestos in non-domestic premises has been included in the Control of Asbestos at Work Regulations. This requires dutyholders to:

■■ assess whether premises contain asbestos; ■■ assess the risk from asbestos; and ■■ take action to manage the risk from asbestos.

What does this guidance do?

1 Workers in the building and allied trades are exposed to asbestos fibres every time they unknowingly work on building materials that contain asbestos, or carry out work without taking the correct precautions. This exposure can result in the development of asbestos-related diseases, depending on the level, duration and frequency of exposure. This includes minor work, such as installing a new light fitting, through to any major refurbishment or demolition work. Their work can also potentially put others at risk who are in the building.

If you don’t manage the asbestos-containing materials in your premises, you could be putting your employees’ and other peoples’ health at risk.

2 This guidance tells you how to prevent, or, where this is not reasonably practicable, minimise exposure to this group of workers and other employees by managing the asbestos-containing materials (known as ACMs) on your premises. The guidance contains details on:

■■ the main factors that determine the risk that ACMs in your premises present to employees and others; ■■ the immediate steps that should be taken to prevent exposure to asbestos; and ■■ how to develop a longer term plan to manage the ACMs in your premises.

You don’t have to do a survey, but you do have to manage your ACMs.

3 This guidance also includes appendices on:

■■ surveying to find asbestos in buildings; ■■ how to assess the risks from the asbestos; ■■ the options available for the management of the ACMs present; ■■ deciding which management option is appropriate; and ■■ information on selecting surveyors, consultants and licensed asbestos removal contractors.

4 The guidance also contains case studies to show real examples of approaches to the management of ACMs. There are many ways of managing ACMs in premises and this guidance talks about the range of approaches. But, it is important to realise that there is no one system that fits all. You should use this guidance to help you develop a system that works for you, keeping the two target groups you are trying to protect in mind, that is those exposed:

■■ during maintenance and building activity on ACMs; and ■■ during the normal occupancy of the building from damaged and deteriorated ACMs.

Who is this guidance for?

5 This guidance is for those who have a duty to manage the risks from ACMs in premises. This is primarily those who have maintenance and repair responsibilities for the premises through a contract or tenancy. Where there is no contract or tenancy the duty falls to the person in control of the premises. It is also for people who are owners, and sub-lessors of premises which they lease out, managing agents, and others such as architects, surveyors and facilities managers etc, who have a role in the management of premises or who may have relevant information about them. It contains useful guidance for organisations that own and manage rented domestic housing stock such as local authorities and housing associations, who will have to apply the duty to the common parts of housing.

But I’m only a small business, is there a lot I need to do?

6 This guidance expands upon the advice in the free leaflet A short guide to managing asbestos in premises.1 It will be of most use to those in more complex organisations, or those in large, older buildings likely to contain substantial quantities of ACMs who need more detailed guidance.

7 In general, the smaller your business or premises is, the more straightforward the actions you need to take. Managing asbestos in such premises need not always involve major surveys or complex management plans. In fact a few simple steps may be all that is required as long as they are effective in stopping anyone from disturbing asbestos. For example, the owner of a small retail premises or a farm may find it very simple to comply with their duties under this regulation. They could inspect their buildings themselves to check the condition of any materials potentially containing asbestos, and if they have no immediate plans to have maintenance work carried out they can presume that the materials contain asbestos without any analysis being made. They would need to repair or, in exceptional cases, remove any damaged materials, either presuming they contain asbestos or checking them first. More serious work (see paragraphs 19 to 23) would have to be done by licensed asbestos contractors, but lower risk work, such as repairs to asbestos cement, can be carried out either by in house staff or a building contractor (provided they work to the standards set out in Asbestos essentials2,3 and HSG 189/14). They would then have to record what they have done.

8 They would then need to make sure that building and maintenance workers, and any other person likely to disturb the material, are warned that it may contain asbestos. Finally, they would need to monitor the condition of the building materials to ensure they do not deteriorate.

9 As the owner or occupier of a small premise, you may not need to read all of this guidance, but you will find parts of it useful. This guidance describes where asbestos is found, its health effects, how we make decisions about the risks to health and so on. Reading this guidance and