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Posted By Robert S Randall
My reading of CAW 2002 reg 8 leads me to the conclusion that there is a duty to notify HSE of ANY work involving potential exposure to asbestos unless that exposure is likely to be less than the action level or the work is covered by the 1983 Licensing regs.
However I am being told by sources that this does not apply to work with asbestos cement but only to asbestos insulating board (AIB) or other types of asbestos.
From my reading the 2002 regulations do not make this distinction. The definition given in the regs for asbestos is
“asbestos” means the following minerals, that is to say, crocidolite, amosite, chrysotile, fibrous actinolite, fibrous anthophyllite or fibrous tremolite or any mixture containing any of those minerals;
Am I missing something or do others agree that all work must be notified?
Bob Randall
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Posted By Chas
If the exposure exceeds or is likely to exceed an action level, the regs in CAWR on notification, designated areas and medical surveillance apply. Refer to HSG 189/2 Working with Asbestos cement
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Posted By Robert S Randall
Thanks Chas, that is exactly what I thought but was not the advice that I got from my local HSE inspectorate.
The next question following from that is if there is any reliable way of guestimating whether the exposure is likely to exceed the action level?
Work with this material could vary from cutting a few holes in it to a complete strip down. One obviously cannot measure the fibres per millilitre before the work takes place; so how does one estimate the likely exposure?
Bob
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Posted By Chas
Further to my earlier response, I suspect that the people you are talking to are confusing what is or is not a licensable activity with what is a notifiable activity.
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Posted By Chas
I sent my second posting before reading your reply. If you get a copy of HSG 189/2 it gives some estimates of expected exposure levels when working with asbestos cement for you to use in your risk assessment process.
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Posted By kelvin
Hello there,
From experience notifyable removal of asbestos is when it must be carried out by a liscenced removal contractor. Generally a composite material i.e. bitumen products, vinyl tiles, cement products, reinforced PVC products, resin based materials, mastics etc do not require removal by a liscenced contractor. The liscenced contractor if compotent will notify the HSE prior to works being undertaken. I realise that you are not specifically talking about removal, however if works are likely to disturb non-composite materials i.e. lagging, AIB, teaxtile, packing, loose asbestos ect then these items should be removed prior to works commencing.
There are plenty of guidence notes on asbestos but through experience there are no specific guidlines to say yay or neigh. For example textured coating or 'artex' contains normally less than 5% of chrysotile and can be classed as highly friable therefore removal is notifyable. After much dispute with clients and the HSE solutions for artex removal it is usually left up to the competent persons descretion. I believe problems like this are being reviewed and suitable criterias will be established.
Hope this helps
kelvin
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Posted By Chas
Kelvin,
Eventhough the activity involving asbestos cement may not be licensable, it may however be notifiable if the action levels are likely to be exceeded, by whoever is undertaking the work. The CAW 2002 Regs still apply even if the work in non licensable.
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Posted By Robert S Randall
Thanks Kelvin and Chas,
I am inclined to agree with Chas re the distinction between a licensable activity and a notifiable activity. Even if an activity is not licensable it may still be notifiable if the exposure is likely to exceed the action levels.
Bob
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Posted By Ron Hunter
HSE Publication HSG189/2 gives some pointers for typical exposure levels for discrete tasks.
Where in doubt, it may be necessary to have some exposure monitoring conducted by competent persons to inform your risk assessment.
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Posted By Dave Wilson
You need to read Work with asbestos which does not normally require a licence (4th Ed) Approved Code of Practice L27 HSE 2002 ISBN 0 7176 2562 1.
Basically from the ACoP
(a) any work with AC (Asb Cement) (eg cleaning, painting, repair or removal of AC materials and demolition or dismantling of structures containing AC
(b) any work with materials of bitumen,plastic, resins or rubber which contain asbestos, the thermal and acoustic properties of which are incidental to its main purpose (eg activites as above for AC) and
(c) minor work with Asbestos insulation, asbestos coating and Asbestos Insulating Board (AIB) which because of its limited extent and duration does not require a licence (eg drilling holes, reoairing minor damage, painting, removal of a single panel of AIB.
MINOR WORK is classed as where either
(a) any person who carries out the work spends less than a total of 1 hour in any seven days; or
(b) the total time spent n the work by all people working on it does nor exceed 2 hours.
More extensive work under reg 3 of 83 licencing regs, requires a licence from the HSE and ACOP L28 applies. (unles work is carried out by employers with their own workers working on their own premises)
Notification applies only for the first time at the employers premises if it is liable to expose employees to levels aove the appropriate action level.
My take is if you are painting etc and not doing anything which will disturb it then no need to notify, but if you are doing anything which could release fibres then notify.
Hope that helps.
So if it is more than any of the above then you will need a Licenced asbestos removal contractor to do the work for you or have y
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