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#1 Posted : 08 August 2005 11:09:00(UTC)
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Posted By Geoff Dicker To give some background - I represent a local authority who employs contractors to clear flytipped material from our highways. We often come across what are suspected Asbestos Containing Materials, mainly corrugated roofing, but insulation board and other suspect material have been found. Our contractors are registered under environmental legislation as waste carriers and also have the requisite consignment notes in line with the hazardous waste regulations. The interface between H&S and Environmental legislation is confusing and I would be grateful if anyone out there could help me resolve the following questions :- Should these contractors be licensed under the Asbestos (Licensing) Regulations by the HSE? It could be construed that by handling the suspected ACM's that they are "working with asbestos," - they do have proper PPE by the way. Should the vehicles be plated and labelled under the Carriage of Dangerous Goods by Road Regulations, and what training should the drivers have? Should we be testing the materials before handling them to prove exactly what they are? Thanks in advance. Geoff
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#2 Posted : 08 August 2005 12:08:00(UTC)
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Posted By Jasonjg Hi Geoff you and many LA's have my sympathy on this one and i hope someone gives you much more clear and precise info than I can. I try not to speculate but this is a pet subject we are currently discussing. Are LA employees at risk as they are winging it through this area. Is it rules for one and rules for the other? Someone I once worked for, seen a potential business opportunity in this area and we therefore set out to discover the pro's and cons. The cons and risks caused me to not want to get involved in the venture. I cannot recall everything we discovered through multiple conversations between HSE and EA but here is a mixture of what we discovered and what we was steered into considering by many CONFUSED HSE and LA officials. Just ask them about the following points and listen to the erms hmmms sighs. These paragraphs may sound like I want to rain on your day but consider the severity and cost implications should you get not get it 100% right and a employees start to get exposed and then discover this should have been avoided. In fact imagine the bad press. Ok Ok LA's have done this for years, but as you already know, but I think this is still coming to that bubbling point as the blissfull blind eye looks your way. 1. (Carriage) I think! this was over 300kg, lots of specifications about containers and vehicle cleaning etc even with small quantities. 2. Fly tipping of asbestos waste is going to increase this year (gut feeling of a numerous amount of people I have talked too) This mainly being due to very hefty price and minimum quantities allowed to be dumped. LA should consider increasing fines where Asbestos is concerned just to cover the cost of picking it up as you will see. 3. Perfect world = you know your staff know what they are picking up and can therefore take the precautions. They know the difference between friability and fibres being carried on cloths and hovering in vehicles. Real world = many LA may be exposing staff and staff members families to unnecessary exposures of Asbestos fibres i.e. Do your staff actually pickup broken AIB and bag it to the van then unload etc. What about pipe lagging or removed coated ceiling beams. How do LA make their assessments at the time of pickup? I have a well-known fly tipping lane near me and I have never seen any LA workers in Head to toe PPE when picking this waste up. Maybe they are safe in the outside air hmmm. 4. How do you store i.e. On your own site? Mixed in same bin as corrugated lower risks waste or do you double bag the waste and have special carrying containers in van and on site. 5. On 402 course we was told we had to go straight to waste site and tally our records to prove we went straight there. 6. As I believe it, you can work with higher risks asbestos for a one-hour period in 7 days. Anymore than this then you need a licence. 7. Van cleaning??????? Sorry for ruining your day but you have raised va ery valid question as to how LA's actually deal with Asbestos waste that is not the simple corrugated roofing sheets.
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#3 Posted : 08 August 2005 12:14:00(UTC)
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Posted By Jasonjg Just re-read your post and realised you have done the best thing and contracted the work out. Sorry thought the LA was doing the work. A freind of mine also contracted it out as it was a severe pain in the you know what. Good luck
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#4 Posted : 08 August 2005 16:54:00(UTC)
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Posted By Adrian Watson Dear Geoff, All work with asbestos must be done in accordance with CAW 2002. Only work with asbestos insulation board, asbestos coatings and asbestos insulation has to be done by a lisenced contractor. In most circumstances the waste collector will not need to be licensed under the licensing regulations as the works will be of short duration. For major tips it may be worthwhile having a contingency plan in place with a licensed contractor on hand. As a precautionary measure I would contact HSE to agree a protocol, because you don't want to wait 2-3 days sorting out a notification with waste being spread about. Hope that this helps. Send me an email with a telephone number if you want to discuss this further. Regards Adrian Watson
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