Posted By admin on January 19, 2010
The main regulation is the Control of Asbestos Regulation (CAR) of 2006. This regulation, in simple terms, says that:
- There must be a defined Duty Holder empowered to be responsible for all asbestos related issues. This is usually the land owner though depending on the lease it can be the operator
- The Duty Holder must survey all non-domestic buildings
- To find and identify all the reasonably accessible asbestos containing materials (ACMs)
- Record their condition in an Asbestos Register
- Write a management plan based on the risk associated with the ACMs detailed in the Asbestos Register
- Advise all involved of the management plan, and implement a system controlling access to the ACMs
In this post I will explain what is meant by non-domestic buildings, who has responsibility to manage the ACMs, how the survey should be carried out and by whom, and how ACMs should be managed. Again, this article will be aimed at farm buildings and infrastructure rather than general industrial premises.
A standard asbestos farm barn. Removal is not required but annual monitoring is.
This is only a brief guide; it is not a complete guide to managing asbestos in non-domestic buildings, nor is it a complete guide to health and safety responsibilities when on a farm. For more information on the survey and management of asbestos containing buildings please read and understand the Approved Code of Practice L127 ‘The Management of Asbestos in Non-Domestic Premises’ which is available from HSE Books.
What is meant by non-domestic premises?
Quite obviously it does not cover a domestic house, but where a building such as a barn has been converted or split into flats then the communal areas, such as foyers, corridors, lifts and lift shafts, staircases, boiler houses, vertical risers, gardens, yards and outhouses, are covered and so need to be surveyed. Common areas are not shared rooms such as kitchens or communal dinning rooms and lounges in shared housing or sheltered accommodation.
Who has the responsibility to manage the asbestos?
This is the Duty Holder who is the entity that has control of the repair and maintenance of the building, so it can be an individual such as a farmer, or a Company, or a tenant or a managing agent. This can at times be complicated and so should be expressly detailed in the documentation. A typical area of complication is a large building such as a farm yard that has been split into a number of different units some of which have been sold some of which have been rented out, with the tenants having different contracts with the building owner. Undoubtedly this will leave grey areas, such as party walls where it is not clear who has responsibility for the repair and maintenance. It will not be acceptable for some of the structure not to be surveyed, all those who might possible have responsibility must work together to ensure that the survey is carried out or they must treat the non-surveyed areas as containing asbestos unless they have good reason to believe otherwise. The owner may pass the repair and maintenance to a managing agent in which case it will be their responsibility to ensure that the survey is carried out and the management plan written. Where a premises is empty and unoccupied the duty holder is still the entity in control of the premises.
Who should carry out the Survey?
The Duty Holder must use a competent surveyor to carry out the survey in accordance with MDHS100 ‘Surveying, sampling and assessment of asbestos containing materials’ available from the HSE. The surveyor must be adequately trained, be able to demonstrate independence, impartiality and integrity and have an adequate quality management system. The usual way of ensuring that the surveyor is competent is to employ one that has personal P402 certification for asbestos surveying from the BOHS. All of the surveyors working for AsbestosGuide are fully P402 compliant.
The Survey
All non-domestic buildings must be surveyed and this to include fixed plant and machinery, but not those such as trucks that only come onto the premises from time to time. It should be noted that many old tractors and other old farm machinery are quite likely to contain asbestos in gaskets, brakes, clutches, under spray, etc. This may need to be checked. The survey needs to be carried out on the premises and their surrounds. Quite how far the word surrounds covers is unclear. In the past asbestos cement pipes were used as field drains particularly where they drained into ditches, The view from the HSE is that the surveyor can not be expected to survey for buried land drains but where the farmer or surveyor notices asbestos cement pipes used as drains this should be noted on the plans, especially when they are on or above the surface.
Many farmers have water or sewage pipes running across their land, some of which will be asbestos cement pipes. Since these pipes are under the control of water boards or sewage companies it is their responsibility to survey and manage them and not the farmers. There is an argument to say that the water or sewage company should advise the farmer of where any asbestos cement pipes are on his land although the risk from the asbestos even if the pipes are dug up is probably too small to be measurable unless they are aggressively abraded, or damaged during excavations.
Asbestos siding on a barn. Again, no removal is required just active monitoring.
The first task for the surveyor is to obtain or create a drawing of the premises and surrounds being surveyed. He should then check all drawings or paper work for indications of ACMs; check where possible with designers, builders and relevant employees and check for refurbishment or repairs, which may contain ACMs. Following this deskwork all the buildings, plant and surrounds should be thoroughly inspected, but before work starts a risk assessment should be carried out and method statements written on how to reduce the risks found. Typical risks on a farm are; working at heights, working in confined spaces, working near large animals, breathing in asbestos fibres, contact with hazardous chemicals, etc. During the survey the drawings and other papers provided should be checked for accuracy. Where ACMs are found they should be clearly marked on the drawings plus their condition should be recorded. Since it is likely that these drawings will be used by employees who do not have a good knowledge of the building trade or its terminology it is important that the recording is done in such a ways as to
ensure that the non-expert understands no only that asbestos is present but exactly where it is present. Where access is not gained to any area and so it is not surveyed this must be clearly marked on the drawing and that area must be treated as if there is asbestos present unless there is good reason to believe other wise.
Recognising ACMs on farms
It is sometimes difficult to tell the difference between an asbestos cement product and a low-density insulation board, but there are a few rules that can be followed. The ACM will be asbestos cement if:
- the product has been used as a roofing or cladding product, open to the weather. Manufacture of all low density asbestos products was stopped in the late 70’s and since they were not weather resistant, if they had been fixed outside they would have broken down long before now.
- the product is moulded as low-density products were not moulded, except
as half rounds for pipe lagging.
- the product is in sheet form and has been used as animal pens or in wet areas. Low-density products were not robust enough to be used as animal housing nor could they withstand wet conditions without breaking down.
When cementitious products like asbestos cement were manufactured, they generally had a cement-rich surface. The asbestos fibres were encapsulated within. Thus, occupants of buildings with asbestos cement sheet or slate roofs are unlikely to be at any greater risk than people outside in the fresh air. The small quantities of fibres released during natural weathering are unlikely to be dangerous but significant and possibly dangerous amounts of fibre can be released if the products are subject to any abrasive cleaning or working. It is therefore important to use the correct techniques and working practices when handling asbestos cement ACMs.
An example of an asbestos pipe in acceptable condition when used for irrigation.
Non-asbestos alternatives to asbestos cement began to be introduced to the UK market in 1984, but asbestos cement products continued to be supplied into the UK market until 1999. So any product that looks like asbestos cement that was supplied prior to 1984 will contain asbestos, any product supplied after 1984 until 1999 could be an ACM. Unless one can find an identification mark on the product it is not possible for the layman to look at a sheet and tell whether it contains asbestos or not and in many cases even an expert can not tell without finding the mark or having a sample analysed. The manufacturers’ mark on profiled sheets is indented into the overlap of the side lap roll, it will normally, in code form, give the name of the manufacturer, the date of manufacture, the shift and possible the machine it was made on. If it contains asbestos it will contain the letters AC if it is non-asbestos it will contain the letters NT. With slates the mark was ink jetted on to the back of approximately one in twenty products, with the same letters denoting whether they contain asbestos not. Finding these marks can be a problem, with slates a quantity will need to be removed before the mark is found and so unless you have good reason to believe that they are non-asbestos they should be treated as asbestos cement ACM. For roofs fixed after 1984, when the slates could be asbestos cement or non-asbestos, looking at the original specification may help but a number of specifications were changed by the roofing contractor because asbestos cement slates were cheaper than their non-asbestos alternatives, and the client and designer were not necessarily notified of the change. It may therefore be necessary if one has to work on these products to either treat them as ACMs or arrange for a sample to be removed and analysed by a competent laboratory.
With Profiled sheets identification is not a lot easier, although the sheets should have originally carried the indent on the overlap roll this did not always happen or the imprint is too vague to be read. There is also the problem that unless the roof is relatively resent it will be dirty and covered in moss and lichens, which will once again make the marks harder to read. It should of course be remembered when accessing the roof to check for the mark that both asbestos cement and unreinforced fibre cement sheets are very fragile and so protection must be provided to the operative to ensure that he cannot fall through the product, a far more immediate and serious risk than the risk of catching an asbestos related disease. In the mid 1990s some profiled sheet manufacturers started to inkjet the underside of their sheets with the production mark. On a single skin construction this should be seen from ground level and again if there is the letters AC in the mark then it is an ACM if the letters NT are in the mark then the product does not contain asbestos. For other moulded products the position of the mark will vary, with some having no mark, where there is a mark the same lettering applies. Very few flat sheet products will have any marks.
Information the survey report should contain:
- The report must record in detail the position the type and the condition of ACMs. All areas not surveyed must be presumed to contain asbestos unless there is good reason to believe otherwise.
- It should provide details of the risk associated with the ACMs found. .
Asbestos cement in good condition does not easily release fibres unless it is aggressively abraded, Asbestos cement that has been badly attacked by acids or alkalis may easily release fibres. It is sometimes assumed that asbestos cement cannot release fibres unless it is abraded, this is normally the case, but there have been situations where the lack of ventilation in a cattle building that had far too many cattle in it and was very infrequently cleaned out, had such aggressive condensate to be formed that the cement had been eaten way on the underside of the sheet, to such an extent that all that was left was pure asbestos mats hanging down from the roof sheeting. Obviously a very high-risk area where no one should be allowed in such buildings with out full protection.
What should be done with the report?
The report should be kept in a prominent position for the life of the buildings, revised when conditions change, available for anyone using the building to read and based on the report a management plan for the ACMs must be written and acted upon.
Managing asbestos containing materials
The management should be based on the risk level associated with the situation, with the underlying theme being:
- ACMs, which are sound, undamaged and not releasing fibres, should not
be disturbed; their condition should be monitored on a regular basis.
- Where possible damaged materials should be repaired and then protected
as necessary, provided that the repair or sealing will be durable and not
likely to be disturbed.
- Removal should only be performed where repair is not possible or the
material is likely to be disturbed.
- A plan must be written, which sets out the risks and how those risks will be
minimised.
- Normally it is necessary to check what type of asbestos the ACMs contain but with asbestos cement because the fibres are locked onto the matrix of the product, the HSE has agreed that under normal conditions there is no requirement to check the type. Though usually the type of fibre is ascertained during the analysis.
Based on the risk, decisions will have to be taken as to what action needs to be taken with each ACM. Often as asbestos cement products age they harden and so even an old product is unlikely to release fibres unless it is strongly abraded. There are though very rare situations such as the one mentioned above where chemicals can attack the product and leave raw asbestos behind. When this happens the product must be safely removed and replaced. This would be a very high priority. If any action is taken it must be recorded and the original report amended accordingly.
Where buildings or plant do contain ACMs it is a good idea to set controls on maintenance or building work, such as, no work must be started with out the written authority of the building controller. Consideration should be given to labeling all ACMs, although on a typical working farm building this is probably not required as the ACMs will be fairly obvious. The risks from the ACMs should be regularly re-assessed, with working farm buildings unless there have been changes to use, this re-assessment probably needs to be every year.
Category: Agriculture, Asbestos, AsbestosGuide, Law |
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Tags: Agriculture, Asbestos, AsbestosGuide, HSE, Law, Surveys
