Asbestos: The survey guide

This is a free-to-download, web-friendly version of HSG264 (Second edition, published 2012). This version has been adapted for online use from HSE’s current printed version.

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ISBN 978 0 7176 6502 0 Price £17.50

This heavily illustrated publication replaces and expands on MDHS100, Surveying, sampling and assessment of asbestos-containing materials. It is aimed at people carrying out asbestos surveys and people with specific responsibilities for managing asbestos in non-domestic premises under the Control of Asbestos Regulations 2012. The book covers competence and quality assurance and surveys, including: survey planning, carrying out surveys, the survey report and the dutyholder’s use of the survey information. It includes extensive appendices and references.

HSE Books

© Crown copyright 2012

First published 2010 Second edition 2012

ISBN 978 0 7176 6502 0

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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.

HSE would like to acknowledge the contributions from the following individuals and organisations in preparing this guidance:

ALcontrol On-Site Services Asbestos Control and Abatement Division (ACAD) Asbestos Removal Contractors Association (ARCA) Bill Sanderson (Bureau Veritas UK Ltd) British Institute of Facility Management British Occupational Hygiene Society Jean Prentice (McCrone Consultancy LLP) Nottinghamshire County Council Peter Irvine (Tetra Consulting) Royal Institute of Chartered Surveyors United Kingdom Accreditation Service Workplace Environment Solutions Ltd

Contents How to use this guidance 4

1 Introduction 6 Legal requirements 7 Appointed person 10 Health and safety issues 10

2 Competence and quality assurance procedures 11

3 Asbestos surveys 16 Purpose 16 Presumption or identification of ACMs 17 Types of survey 18 Survey restrictions and caveats 21 Survey strategy 22

4 Survey planning 25 Dutyholder’s planning 25 Surveyor’s planning procedure 26 Step 1: Collect all the relevant information to plan the survey 26 Step 2: Consider the information (desk-top study) 28 Step 3: Prepare a survey plan (including how data will be recorded) 29 Step 4: Conduct a risk assessment for the survey 30

5 Carrying out the survey (surveying) 32 Introduction 32 Bulk sampling strategy 34 Bulk sampling procedures 36 Bulk sampling 37 Material assessment 39

6 Survey report 41 Executive summary 41 Introduction 41 General site information 41 Survey results 42 Conclusions and actions 44 Bulk analysis results 44

7 Dutyholder’s use of survey information 46

Appendix 1: Refurbishment and demolition surveys 48

Appendix 2: ACMs in buildings listed in order of ease of fibre release 52

Appendix 3: What ACMs look like and where to find them 57

Appendix 4: Material assessment algorithm 67

Appendix 5: Example of a survey and sampling equipment checklist 68

Appendix 6: Quality assurance and quality control 69

References 71

Further Information 73

How to use this guidance Green summary boxes: This publication has specific guidance for clients/ dutyholders in green boxes:

Box 1: The purpose of an asbestos survey.

Box 3: What the client/dutyholder should do to check the competency of the surveyor.

Box 4: Areas to be inspected as part of a management survey.

Box 6: Information the client/dutyholder should expect from the surveyor.

Box 9: Information required for a management survey.

Box 10: Information required for a refurbishment or demolition survey.

Box 11: What the client/dutyholder should do to check the accuracy of the survey report.

Blue summary boxes: This publication has specific guidance for surveyors in blue boxes

Box 2: Survey key points.

Box 5: Information the surveyor needs from the client.

Box 7: Information to be collected by the surveyor.

Box 8: Example of a systematic survey inspection.

Box 1: The purpose of an asbestos survey

■■ To help manage asbestos in your premises. ■■ To provide accurate information on the location, amount and condition of asbestos-containing materials (ACMs). ■■ To assess the level of damage or deterioration in the ACMs and whether remedial action is required. ■■ To use the survey information to prepare a record of the location of any asbestos, commonly called an asbestos register,* and an asbestos plan of the building(s). ■■ To help identify all the ACMs to be removed before refurbishment work or demolition.

*Note: the information in the register should be used to inform the risk assessment (eg consider who could disturb asbestos on your premises), and to establish the management plan to prevent such a disturbance.

Box 2: Survey key points

■■ Be aware that the survey is essential for the client/dutyholder to successfully manage asbestos. ■■ All asbestos should be located as far as reasonably practicable within the survey type. ■■ Ensure that the appropriate survey is undertaken for the client’s needs. ■■ Avoid caveats. ■■ Ensure the survey is reported in a format that can be used to prepare an asbestos register and building plan. ■■ Inform the client that the survey is not the end point in managing asbestos.

1 Introduction 1 This guidance has been prepared by the Health and Safety Executive (with the help of others, see Acknowledgements) to help people carrying out asbestos surveys and those with specific responsibilities for managing the risks from asbestos in non-domestic premises under regulation 4 of the Control of Asbestos Regulations 2012 (CAR 2012).1 It is also designed to provide guidance in situations where surveys may be carried out for other purposes, eg for ‘managing’ asbestos in domestic premises under wider health and safety legislation and for meeting the requirements of the Construction (Design and Management) Regulations 2007 (CDM).2 It complements and supports other guidance on managing asbestos.3-5

2 Large amounts of asbestos-containing materials (ACMs) were used for a wide range of construction purposes in new and refurbished buildings until 1999 when all use of asbestos was banned. This extensive use means that there are still many buildings in Great Britain which contain asbestos. Where asbestos materials are in good condition and unlikely to be disturbed they do not present a risk. However, where the materials are in poor condition or are disturbed or damaged, asbestos fibres are released into the air, which, if breathed in, can cause serious lung diseases, including cancers.

3 Workers who disturb the fabric of buildings during maintenance, refurbishment, repair, installation and related activities may be exposed to asbestos every time they unknowingly work on ACMs or carry out work without taking the correct precautions. The purpose of managing asbestos in buildings is to prevent or, where this is not reasonably practicable, minimise exposure for these groups of workers and other people in the premises. To prevent this exposure, information is needed on whether asbestos is, or is likely to be, present in the buildings, so that an assessment can be made about the risk it presents and appropriate measures put in place to manage those risks.

4 This guidance is aimed at:

n Surveyors who carry out asbestos surveys. It sets out how to survey premises for ACMs. In particular, it specifies the methodology to use in carrying out surveys and how to report and present the results. It also gives advice on how to recognise and sample suspected ACMs. In doing so, the guidance builds on and updates MDHS100 Surveying, sampling and assessment of asbestos- containing materials, which it replaces. It also contains a specific section which outlines the survey strategy to use when surveying large numbers of similar properties (eg domestic housing). n Those who commission surveys (eg clients/dutyholders). It sets out how to decide what type of survey is appropriate, how to select a competent surveyor, what the client should expect from a surveyor and what the client should provide to the surveyor. It also highlights issues (eg restricted access, excluded areas and other caveats) which not only reduce the effectiveness of the survey, but also have serious implications for managing asbestos. It also explains what checks should be made on the survey report to ensure its validity and accuracy (ie ‘contract management’).

5 The guidance will also be useful to building professionals, such as architects, designers, building surveyors and particularly demolition and asbestos removal contractors. For example, architects and building surveyors need to be aware of the requirement to carry out asbestos buildings surveys (and indeed can advise on the need for an asbestos survey before refurbishment and demolition projects). They should also be aware of the various types of surveys and be able to review

completed surveys. Contractors need to be able to interpret asbestos surveys so that refurbishment or demolition can be planned and carried out safely.

6 The guidance does not cover airborne sampling or surveying contaminated land. These are specialised subjects outside the scope of this document.

Legal requirements

The duty to manage asbestos in non-domestic premises* 7 Asbestos, a category 1 human carcinogen, is subject to two sets of regulations – REACH (the Registration, Evaluation, Authorisation and Restriction of Chemicals Regulations 2007)6 and, CAR 2012. REACH prohibits the importation, supply and use of asbestos. CAR 2012 covers work with asbestos, and licensing of asbestos-removal activities. Regulation 4 of CAR 2012 contains an explicit duty on the owners and occupiers of non-domestic premises, who have maintenance and repair responsibilities, to assess and manage the risks from the presence of asbestos (the duty is summarised in Figure 1). The risks will vary with circumstances and can arise from normal occupation of a building or from inadvertent disturbance during the repair, refurbishment and demolition of premises. The risk assessment will be used to produce a management plan which details and records what actions to take to manage and reduce the risks from asbestos.

8 The requirements are placed on ‘dutyholders’, who should:

■■ take reasonable steps to determine the location of materials likely to contain asbestos; ■■ presume materials to contain asbestos, unless there are good reasons not to do so; ■■ make and maintain a written record of the location of the ACMs and presumed ACMs; ■■ assess and monitor the condition of ACMs and presumed ACMs; ■■ assess the risk of exposure from ACMs and presumed ACMs and prepare a written plan of the actions and measures necessary to manage the risk (ie the ‘management plan’); and ■■ take steps to see that these actions are carried out.

Appoint person to ‘manage’ asbestos

No Find out if ACMs present: Record: Asbestos Record Check plans/drawings register plan/drawing Carry out survey

Yes

No further action RECORD: Prepare asbestos register

Are ACMs liable to be disturbed? Carry out Who can be exposed? risk assessment Prioritise

ACMs in good condition

Monitor Prepare management plan

Damaged ACMs Maintenance work - Train staff - Manage contractors - Checked all work against Repair/remove Manage plan/register - Control of work itself: - Asbestos essentials - Compliance with CAR

Figure 1 Summary of the main steps in managing asbestos

*The term ‘premises’ has a specific definition under health and safety legislation and includes vehicles, vessels, aircraft, installations on land and offshore, tents and moveable structures. While in most cases the survey will only be needed on existing buildings (including basements, cellars, tunnels, undercrofts etc) and the surrounding site, there may be some situations where there are hidden underground structures or pipes which may only come to light when refurbishment or demolition work is to take place. These should be included in the survey as appropriate.

9 To manage the risk from ACMs, the dutyholder will need to:

n keep and maintain an up-to-date record of the location, condition, maintenance and removal of all ACMs on the premises; n repair, seal or remove ACMs if there is a risk of exposure due to their condition or location; n maintain ACMs in a good state of repair and regularly monitor their condition; n inform anyone who is liable to disturb the ACMs about their location and condition; n have arrangements and procedures in place so that work which may disturb the ACMs complies with CAR 2012; and n review the plan at regular intervals and make changes if circumstances change.

Management of asbestos in domestic premises 10 The ‘duty to manage asbestos’ requirements of regulation 4 of CAR 2012 do not normally apply to domestic premises. However, the requirements do apply to common parts of premises, including housing developments and blocks of flats, but do not place any direct duties on landlords for individual houses or flats. Examples of common parts would include foyers, corridors, lifts and lift shafts, staircases, boilerhouses, vertical risers, gardens, yards and outhouses. The requirements do not apply to rooms within a private residence which are shared by more than one household, such as bathrooms, kitchens etc in shared houses and communal dining rooms and lounges in sheltered accommodation.

11 The Health and Safety at Work etc Act 19747 section 2, requires all employers to conduct their work so their employees will not be exposed to health and safety risks, and to provide information to other people about their workplace which might affect their health and safety. Section 3 places duties on employers and the self- employed towards people not in their employment and section 4 contains general duties for anyone who has control, to any extent, over a workplace. In addition, the Management of Health and Safety at Work Regulations 19998 require employers to assess the health and safety risks to third parties, such as tenants who may be affected by their activities, and to make appropriate arrangements to protect them.

12 These requirements mean that organisations such as local authorities, housing associations, social housing management companies and others who own, or are responsible for, domestic properties, have legal duties to ensure the health and safety of their staff (and others) in domestic premises used as a place of work. As employers, the organisations also have duties under the general requirements of CAR 2012 to identify asbestos, carry out a risk assessment of work liable to expose employees to asbestos and prepare a suitable written plan of work.

Construction work 13 CDM requires arrangements to be in place to deal with asbestos during construction work, including refurbishment and demolition. Where construction or building work is to be carried out, the CDM client must provide designers and contractors who are bidding for the work (or who they intend to engage) with project-specific information about the presence of asbestos, so that the risks associated with design and construction work, including demolition, can be addressed. It is not acceptable to make general reference to hazards that may exist. Therefore, site-specific asbestos surveys should be carried out in advance of construction work to make sure that the information is available to those who need it.

Appointed person

14 To help comply with the legal requirements and to ensure that ACMs in premises are properly managed, dutyholders should identify a person (and in some cases a deputy) within their organisation who will be responsible for that management. An appointed person will be essential where the dutyholder has a large or complex building portfolio. The appointed person will need the resources, skills, training and authority to ensure that the ACMs are managed effectively. Part of their responsibilities will include managing the survey, including contractual and reporting arrangements, quality and subsequent use of the data.

15 The survey data and information will be used to complete an asbestos register and building diagram(s) showing the ACM locations. It will also feed into the risk assessment, which will be used to develop the management plan. The dutyholder needs to establish clear lines of responsibility for asbestos management and implementation of the plan.

Health and safety issues

16 Surveying and sampling ACMs can give rise to exposure to asbestos. These work activities are covered by the more general requirements of CAR 2012. The regulations require employers to carry out a risk assessment (regulation 6) and prepare a plan of work (regulation 7), setting out the control measures and personal protective equipment (PPE) to be used. The regulations also require that adequate information, instruction and training (including refresher training) (regulation 10) are given to the sampling personnel. Training should meet the requirements for non-licensable asbestos work as set out in the Approved Code of Practice, Work with materials containing asbestos. Sampling ACMs is, however, exempt from the regulations covering licensing (regulation 8), notification of work with asbestos (regulation 9) and health surveillance (regulation 22) by virtue of regulation 3(2), as the exposure is sporadic and low intensity and is unlikely to exceed the control limit. Other hazards may also be present, such as working at heights and electrical cables. A risk assessment will need to be carried out before starting work on site (see paragraphs 83–87). It should include any safety aspects and record any safety protocol to be observed on site as well as fire alarm and evacuation procedures.

Asbestos surveying and sampling is likely to be ‘work’ with asbestos and therefore will require a risk assessment and a plan of work (method statement) under CAR 2012. Some activities may also involve physical work with asbestos (eg moving asbestos insulating board (AIB) ceiling tiles) and will require similar consideration.

Some direct work on asbestos to support the survey may have to be carried out by a licensed asbestos contractor (see Appendix 1, paragraphs 6 and 7).

2 Competence and quality assurance procedures 17 Surveys can be carried out by in-house personnel or a third party. In each case, the surveyor must be competent to carry out the work required. To be competent, the ‘surveyor’