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#1 Posted : 08 October 2005 08:37:00(UTC)
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Posted By Steve P UK We're aiming to replace asbestos cement sheets on a school roof in England, built in 1955. There's some suggestion that some sheets have become porous - is that likely, or is it condensation? I assume it might be advisable to replace glass fibre insulation in the roofspace at the same time, but would any special cleaning of the roofspace be advisable? Finally, is there a product that can directly replace the sheets without altering the steel roof structure (sheets are just bolted in). We'll engage the local authority architect to supervise, but I'm trying to work out a budget price.
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#2 Posted : 08 October 2005 10:10:00(UTC)
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Posted By Adrian Watson Dear Steve, The sheets are most probably affected by condensation. If they do need replacing, they can be easily replaced by cropping the bolts and lifting them down. There are many cement substitutes out there. Fibreglass is good, but what about fire resistance and surface spread of fire; and degredation due to exposure to UV? The job can be done by any competent contractor. Working at height is the biggest issue, with waste disposal a close second. Regards Adrian Watson
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#3 Posted : 08 October 2005 10:14:00(UTC)
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Posted By Steve P UK Thanks. Working at height isn't a problem, easy access of an adjacent flat roof into to the roofspace, and sheets can be unbolted from underneath. Ideally we want new sheets in new material in exactly the same profiles (a mansard roof so the sheets are not just corrugated but bend).
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#4 Posted : 08 October 2005 12:00:00(UTC)
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Posted By Kevin Thomas Hi Steve Yes A/C sheets can get porous over time and leak You should also have a Type 3 Asbestos survey before any major refurbishment work starts which will help with budgeting. If you wish to discuss this further give me a call 07782647336 Kevin
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#5 Posted : 08 October 2005 12:35:00(UTC)
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Posted By Dave Wilson AS I WORK IN THE ASI INDUSTRY YOU DO NOT SPECIFICALLY HAVE TO HAVE A TYPE 3 SURVEY DONE, (Reg 4 CAWR 02) is a duty to manage not to survey!!! MDHS 100 tells you how to do this P402 and UKAS accredited as the minimum, I would not use a non UKAS accredited company to do any type of Asbestos Survey, trhis is what the HSE recommend see thier www. You will of course have to find out if the sheets contain Asbestos by sampling, or you can assume they do contain asbestos, and take the relevant precautions. For info they will probably contain anything up to to 25% with Chrysotile (White) being the dominant Fibre, however both Amosite and Crocidolite were used in A/C around the time scale you are suggesting . You do not need a licensed contrctaor to do the work however, whoever you do employ they will need training in removal and the precautions to take when working with asi, that includes PPE / RPE, prevnting exposyre, Disposal of waste at preventing the spread, ie spraying with surfactants etc Look on the HSE www for the amount of IN and PN served on contractors and schools for non compliance when undertaking this work. If you want any further advice email me.
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#6 Posted : 08 October 2005 13:04:00(UTC)
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Posted By steven bentham I agree with whats been said and I have also seen asbestos cement sheet roofs overclad with modern panels
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#7 Posted : 08 October 2005 14:24:00(UTC)
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#8 Posted : 08 October 2005 16:24:00(UTC)
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Posted By PaulA Kevin, Giving advice for a type 3 survey to be carried out for the removal of Asbestos sheeting material such as this on this forum will undoubtably lead to further bad press of those crooks giving advice relating to the CAW Regs. Please get yourself a copy of the MDHS 100 and read the parts relating to work with Asbestos sheets... it is clearly laid down. I carry out surveys as a P402 and have dealt with clients that have been whitewashed over this regulations duties. Regards PaulA
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#9 Posted : 09 October 2005 21:09:00(UTC)
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Posted By Linda Crossland-Clarke Hi all, ..and don't forget, it'l cost you a wadge of money to get insurance to work with asbestos and you'l need an appropriate qualification in to be able to get the insurance in the first place. Regards. Linda. SHE Knows.
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#10 Posted : 10 October 2005 21:21:00(UTC)
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Posted By Kevin Thomas Paul A I do have a copy of the MDHS100 and am fully aware under the CAW Regs there is a duty to manage. You may want to read your copy and pay perticular attention to section 6 and I qoute ASBESTOS MANAGEMENT PROGRAMMES In order to have an effective asbestos management programme, it is necessary to establish clear lines of responsibility for the programmes management and implementation. A survey to the premises MUST be undertaken to locate and assess the ACM's. The results of the survey must be recorded in an easily retrievable form, which can then be used to make a risk assessment and draw up a management plan. I am fully aware the MDHS100 is a guidance document, but would be seen as good practice when followed. Food for thought Regards, Kevin
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#11 Posted : 10 October 2005 22:02:00(UTC)
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Posted By Bill Fisher Steve The respondents to your enquiry have rattled through the Regs and Guidance, and indeed had the usual diagreements along the way, but have not actually given you a clear line to follow. Get a copy of HS (G) 127 "Asbestos Essentials" (£8.50) which explains how to approach such "non-licenced asbestos work". The introduction will introduce you to important thinking and actions in preparation of having the work done. The flow chart on page 5 will guide you to choice of contractor (Licenced or not). Task Guidance Sheet A14 (page 52) will tell you what has to be done, how and with what equipment. Based on your enquiry I am certain that you will not have the necessary expertise in-house and you will either have to find a Contractor trained for "non-licenced asbestos work" - the training requirements are listed in L27 "Work with asbestos which does not normally require a licence - 'Control of asbestos at work regulations 2002'" Reg 9 and paras 52 to 60 - or go for a Licenced Contractor, but this will incur a higher rate. Above all ensure the work is managed in a professional manner, HSE are hitting asbestos misdemeanors hard. Regards Bill
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#12 Posted : 10 October 2005 22:04:00(UTC)
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Posted By Bill Fisher Steve The respondents to your enquiry have rattled through the Regs and Guidance, and indeed had the usual disagreements along the way, but have not actually given you a clear line to follow. Get a copy of HS (G) 127 "Asbestos Essentials" (£8.50) which explains how to approach such "non-licenced asbestos work". The introduction will introduce you to important thinking and actions in preparation of having the work done. The flow chart on page 5 will guide you to choice of contractor (Licenced or not). Task Guidance Sheet A14 (page 52) will tell you what has to be done, how and with what equipment. Based on your enquiry I am certain that you will not have the necessary expertise in-house and you will either have to find a Contractor trained for "non-licenced asbestos work" - the training requirements are listed in L27 "Work with asbestos which does not normally require a licence - 'Control of asbestos at work regulations 2002'" Reg 9 and paras 52 to 60 - or go for a Licenced Contractor, but this will incur a higher rate. Above all ensure the work is managed in a professional manner, HSE are hitting asbestos misdemeanors hard. Regards Bill
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#13 Posted : 11 October 2005 16:24:00(UTC)
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Posted By Dave Wilson L27 & L28- as well I would love to recommend that all buildings have a type 3 / 2 survey and ALL asi is removed by a licensed contractor as I would make Millions!! Reality read L27 & L28 along with the task manua; and you cant go wrong
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#14 Posted : 11 October 2005 22:57:00(UTC)
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Posted By Bill Fisher Dave L28 - "Work with asbestos insulation, asbestos coating and asbestos insulating board - 'Control of asbestos at work regulations 2002'" does not apply to asbestos cement. In the section "Application", Section 2 clearly states that "It does not apply to work involving: (a) asbestos cement;" Bill
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#15 Posted : 12 October 2005 00:28:00(UTC)
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Posted By Dave Wilson Yeh I know thought it would be better if you nunderstood the whole picture and not just cement products as there are a lot of things out there which although are very high risk do not fall under licensable and some which are very low risk, which do!
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#16 Posted : 12 October 2005 08:29:00(UTC)
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Posted By Steve P UK So, to summarise, dismantling the AC sheets is covered by L27 and doesn't need a licensed contractor, but someone trained in removing AC (and it's easier to use a contractor already trained than training someone specially and getting insurance). Would we need to sample, or, as we're taking the right precautions, do we even need to know if there's any Amosite and Crocidolite content? And I assume it's safe to assume the insulation need not be replaced (though we might want to) and no special cleaning in the roofspace is needed.
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#17 Posted : 12 October 2005 14:50:00(UTC)
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Posted By Dave Wilson Nearly there mate, Ensure that you follow the 'Task manual' and ensure that the correct RPE (Face fit tested) and Coveralls (Type 5 fibreproof)are used. Disposed of as Haz Waste. Have to ensure that you clean as you go, do a final clean and that no debris is left behind. (Do not 'legally' require clearance) Must used Type 'H' vacuums to clean and it is advisable to have a suitable decontamination or other facilities to ensure employees can clean Ensure that you do not expose your employees or others to Asbestos and prevent the spread of fibres (Reg 10 & 15) Your people should be trained and the the waste must go to landfil (Stable Non Reactive Haz Waste cell) with HAZ Waste Regs Consignemnt note. Carrier must have VALID Waste carrieres licence to do this. Waste should be double bagged in UN waste sacks and transported in a closed container If the roof is provided as weathering and does not have any other properties (fire break etc) then it would have to be replaced with a like material which give at least the same property otherwise put up what you want. If a non licensed contractor is used ensure they have the correct PI and EL Insurance. Hope that helps
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#18 Posted : 12 October 2005 14:57:00(UTC)
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Posted By Neil Gwinnutt s
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#19 Posted : 12 October 2005 16:02:00(UTC)
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Posted By Robert K Lewis MDHS 100 is about the methods for determining asbestos and provides guidance that Type 3 surveys must be done for all major refurbishment or demolition. Find me an inspector who will not expect one in this situation. It is not about surveying the WHOLE building in this case only the affected area. How can you manage if you are not sure what is there. Emergency plans in case of finding suspect materials is not a replacement for good management techniques. That is to say a proactive stance searches for the problems before exposing any person to potential risks. Bob
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#20 Posted : 12 October 2005 18:26:00(UTC)
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Posted By Steve P UK Why would a survey be needed? It's not demolition, nor major refurbishment (which surely anticipates destructive work which would disturb materials that may contain asbestos). We know from previous surveys that this is asbestos, which is why we're removing it! Having decided to remove asbestos, surely we aren't required to have a survey just because, on the basis of the previous survey, we've decided to get rid of it.
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#21 Posted : 12 October 2005 18:41:00(UTC)
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Posted By Bill Fisher Steve I go along with Dave's summary. As for sampling/surveying, you need do no more on this occassion. You have determined it is asbestos and the survey will no doubt confirm it is traditional sheets with chrysotile. If you were going to get rid of the building I would have advised a Type 3 (destructive) because of age and presence of sheets, however you are not so forget it and get going! Regards Bill
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#22 Posted : 12 October 2005 19:00:00(UTC)
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Posted By Dave Wilson Here here, show me anywhere in the CAW Regs that says you shall do a type 3 survey! MDHS 100 recommends it (Guidance) Remember Reg 4 is about managing and not surveying or removing. You can do a pure assumptive survey and assume that it is all Asi and treat accordingly! and you can use MDHS 100 to assume a Chrysotile contemt of any thing up to 25%. Word of caution though if the underside is treated or there is another material on the underside then I would get that sampled first. If it is plain old Asbestos Cement roof sheets and you have access to both sides, and that is all it is, then 'crack on', survey not required!
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#23 Posted : 12 October 2005 21:58:00(UTC)
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Posted By Adrian Watson Dear All, This is getting silly! No where in the regulations does it require that a survey be carried out. Why do you want to survey for asbestos materials that are plain to see. Regulation 4 of CAAW 2002 requires that materials presumed to be asbestos be trated as such unless there is evidence to the contrary. The work can be done by any competent contractor, provided that they work in accordance with the CAAW Regulations 2002. Measures need to be taken to prevent exposure to asbestos and also prevent the spread of asbestos. Work must be done in accordance with a plan of work. RPE only needs to be worn if the control levels are likely to be exceeded. Cutting bolts and lifting sheets down does not and is not likely to exceed the control limits. Regards Adrian Watson
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#24 Posted : 12 October 2005 23:08:00(UTC)
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Posted By Bill Fisher Adrian You say "The work can be done by any competent contractor," but what Dave and I have done is put the meat into what is "competent" in this situation - ie training which includes practical demonstration. As for your comment "Cutting bolts and lifting sheets down does not and is not likely to exceed the control limits." is potentially reckless in todays climate. Your comment takes no account of weathering or the friable nature of the sheets through age. Indeed go to the Task Manual I referred to earlier, it states under "Personal protective equipment (PPE) . Disposable overalls fitted with a hood. . Waterproof clothing may be required outside. . Boots without laces (laced boots can be difficult to decontaminate). . Disposable particulate respirator (FF P3). " So, Steve, I repeat, read Asbestos Essentials and in reality ignore all the tangents created on this Thread. If you are really uncertain read the book, essentially copy the content, choose a potential contractor (remember "competence") and have a chat about your plans with your local Inspector, he'll support you. Regards Bill
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#25 Posted : 13 October 2005 00:08:00(UTC)
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Posted By Adrian Watson Bill, I am not being reckless! I can assure from experience that even with weathered sheets, it is virtually impossible to get anywhere near to the control limits by cropping bolts and lifting asbestos cement down whole. Regards Adrian.
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#26 Posted : 13 October 2005 07:44:00(UTC)
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Posted By Bill Fisher Adrian To clarify I did not say you were "reckless" merely that your view not to wear RPE was "potentially reckless". That is based on the current claim culture, the individual's concerns over asbestos in general, the HSE's clear statement that RPE was essential. Steve is uncertain of work with asbestos therefore it is incumbent upon us to direct him to the solution that will keep people safe and the HSE off his back: follow the advice in the Task Manual. Regards Bill
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#27 Posted : 13 October 2005 09:19:00(UTC)
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Posted By Robert K Lewis I would argue that removal of a roof and replacement may well be major refurbishment and as such you need to take a hard look at what you are doing and providing you are confident that you will disturb nothing other than the sheets then go ahead without the survey. If however you find something unexpected then be prepared to explain to the HSE why you thought it unnecessary to follow what is recognised guidance in an HSE document. Major refurbishment unfortunately is not defined anywhere and I find many organisations trying to argue that there has to be a near demolition situation before they need to do anything. I know of one contractor who came close to prosecution in 2003 because a type 2 survey was done for a refurbishment which detected only a board under the window sill; he later found asbestos around the window head seal, which had not been identified in the survey - the rope contained primarily crocidolite. The duty to manage extends to the contractor when he takes over a specific area by virtue of a contract (CAW reg 4(1)a) and this means that s/he must be satisfied that there is no reason to suspect the presence of any ACM and that s/he knows the location of any ACM present. Reg 11 of CDM is clear in its intention that the client should supply relevant information that he has or can reasonably obtain. If nothing happens and no asbestos is found then your %ges have worked out. If they fail and something is found then the HSE may well be very excited. Bob
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#28 Posted : 13 October 2005 10:41:00(UTC)
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Posted By Peter MacDonald Can I just add that you do not require to double bag asbestos cement waste for transport. The most important hazard to address is working at height without a doubt and to this end chose a competent contractor with a good track record. Carry out a simple vendor assessment and then let the suitable contractor get on with it. It's no big deal, really. the stuff's practically harmless if its chrysotile anyway. Refer to reply number one and don't let the scare-mongers cost you a fortune. Peter
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#29 Posted : 13 October 2005 11:20:00(UTC)
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Posted By Bill Fisher Peter "practically harmless", says who? I repeat in this day of compensation, awareness, concern ets I am concerned that many people just gloss over a) the risk - albeit not as bad as crocidolite, and b)the general concern on asbestos - immaterial of the type. Regards Bill
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#30 Posted : 13 October 2005 12:01:00(UTC)
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Posted By Adrian Watson Bill, Thanks for the clarification. My stance is simple; as professionals we should carry out risk assessments rather of the tasks at hand rather than slavishly follow "guidance." As such, if there is no exposure to concentrations to asbestos in the air why wear respiratory protection? Is this to prevent any potential future claims or is it done to appease the enforcers? Furthermore, I also recognise that asbestos is not by itself dangerous; being an inanimate substance, it does not do anything by itself. It is what we do with it that makes it dangerous or not! Additionally, not all types of asbestos are equally harmful when inhaled. So yes low levels of chrysotile, bound inside a dense product treated with a modicum of respect can be harmless. Regards Adrian
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#31 Posted : 13 October 2005 12:02:00(UTC)
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Posted By Adrian Watson Bill, Thanks for the clarification. My stance is simple; as professionals we should carry out risk assessments of the tasks at hand rather than slavishly follow "guidance." As such, if there is no exposure to concentrations to asbestos in the air why wear respiratory protection? Is this to prevent any potential future claims or is it done to appease the enforcers? Furthermore, I also recognise that asbestos is not by itself dangerous; being an inanimate substance, it does not do anything by itself. It is what we do with it that makes it dangerous or not! Additionally, not all types of asbestos are equally harmful when inhaled. So yes low levels of chrysotile, bound inside a dense product treated with a modicum of respect can be harmless. Regards Adrian
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#32 Posted : 13 October 2005 12:17:00(UTC)
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Posted By Robert K Lewis Adrian Yes Risk Assessment is beneficial but I think one has to balance in the equation the risk of not knowing everything, ie the unknown unknowns. To pass off the MDHS as merely guidance that can be accepted or rejected simply because one feels the RA is sufficient is to overlook the emphasis placed on it by the HSE. If one remembers that the requirements are HASAWA fundamentally then in the event of failure then one is going to need to show that what was done was equal or better than the published information. He who puts people to work must also manage the risks is the old maxim and remains true today. It is no use saying I did not know that there could have been other ACM present after it is discovered - at that point section 2 or 3 have been breached and it is a difficult road to demonstrate that all sfrp was done to prevent an exposure. I am not saying however that a survey is essential simply that it has to be considered clearly and consciously by the person managing. Bob
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#33 Posted : 13 October 2005 12:35:00(UTC)
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Posted By Bill Fisher Adrian Sorry to do this to you but I emphatically disagree with you - "Additionally, not all types of asbestos are equally harmful when inhaled. So yes low levels of chrysotile, bound inside a dense product treated with a modicum of respect can be harmless." Change "harmless" to "negligable" then I might go along with you. Regards Bill
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#34 Posted : 13 October 2005 19:29:00(UTC)
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Posted By Dave Wilson listen folks we are getting embroiled here in semantics. If you can crop bolts and remove whole, then I would agree! However I have never ever evre seen this happen, some sheets get broken some fall out and some just drop and smash on the ground!!! Wear RPE!!!!, why have the HSE served immediate PN on contractors for not doing this when removinmg AC? Simple! REG 10 & 15 reduce exposure ""SFAIRP"" £50 to get fully kitted and spured (inc Face Fit) is this SFAIRP? I suggest so, Remember as well, Reg 5 talks about ID of Asbestos and if content not known, must assume the worst ie Blue & Brown. Our company do this type of work on a daily basis and unless it is one or two sheets you will never get them all out whole, that is unless you want to do about 4 or 5 a day and pay lots of money. Chrysotile is the least dangerous of all Asi however quite a bit of Chrysotile it is contaminated with Tremolite (in low quantities)and this is 800 times more hazardous than Chrysotile and nearly twice as bad as Crocidolite (Blue). As far as double bagging it goes, claptrap!!!! You tried taking asbestos in any form to a landfill unbagged and ask to dispose of it?? It is classeed as Haz Waste under Haz Waste Regs and must be treated as such. Again the HSE have served immediate PN on conractors carrying waste AC not bagged, and they always look in the back of our vehicles for it. I agree that it is not always done but this does not make it right and if caught the HSE / EA or the Police will prosecute if found on the highway. 500kg in the vehiclemk must display the Orange Rectangle (330kg for Amphiboles). Trust me guys I work for a well respected Asbestos Removal, Management and Surveying company and we get at least 20 visits a year from the HSE / LA, problem with unlicensed work is that the HSE/LA do not know it is going on (no FODASB5), so all the prosecutions and IN / PN have been as a result of information given or by chance, eg drive by.
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#35 Posted : 14 October 2005 09:01:00(UTC)
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Posted By Robert K Lewis Dave W Strictly AC sheet which is a) fundamentally chrysotile; and b) Non Friable can be sent to a moncell site provided it is not mixed with active waste because it is classed as Non-reactive Hazardous waste. Put any biodregadable (active) material in with it and you are now under the consignment note system of the new Hazardous Waste regs and all they entail. Here is the rub - some plastics are biodegradable and I seem to recollect some asi bags being sold as environmentally friendly on this basis. Whatever the disposal route all the ducks, ignoring any avian flu, must be in a row for the final disposal point before you start wark, or allow it to start. Bob
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#36 Posted : 14 October 2005 10:30:00(UTC)
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Posted By Dave Wilson yeh but all asi goes this route, it is even has its own EWC code from the list as does the overalls and tak rags. You can take asi to the tip mixes with other construction waste but if you mention the asi content it will be treated as hazardous at the landfill. Alternatively if you are a private domestic dwelling you can take it to the civic amenity site and just dump it Free of Charge with no special precautions, you can also remove your old boiler lagging or sprayed flock in your own house without any precautions as well! Funny old game!
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#37 Posted : 14 October 2005 10:52:00(UTC)
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Posted By Peter MacDonald 1. Bill. It's more or less harmless at low exposure levels because chrysotile fibres dissolve in lung fluid. Tyvek suits and Sunstrom half masks (face fit tested of course) is adequate protection. If you try and debolt a AC sheet and transfer it to ground level whole and compare the associated risks in manual handling (a standard AC sheet is very heavy), working at height, to exposure to AC dust I defy you to ascertain that the dust is the highest priority. 2. Dave. I send AC Cement panels to various landfills around the UK without double bagging all the time. That is a fact! Peter
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#38 Posted : 14 October 2005 12:03:00(UTC)
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Posted By Robert K Lewis Dave W I hope you are not suggesting that it is thrown into the skip mixed with other active wastes. I am surprised that you have not had a few refused loads, especially as now only monocell sites and Hazardous waste sites can accept it. Can you provide info on the tips which can segregate it out for you and accept everything as they would be useful to know? Bob
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#39 Posted : 14 October 2005 12:14:00(UTC)
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Posted By Fran Holt now now lads! chill out, this isnt a battle over who knows more about asbestos and its removal. The original question has been answered so why not take your bickering off into private emails? I am a surveyor/analyst (fully qualified, insured etc before i get grilled), do removal etc etc but wont be posting for fear of reprisals! Think sausages, its friday.
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#40 Posted : 14 October 2005 13:03:00(UTC)
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Posted By Dave Wilson Bob, what I was saying is this is how some less respectable construction contractors get rid of it, dont declare the asi content, therefore non haz waste. Chelston Meadow will not take anything unless it is double bagged!! and will not take AC from outside its catchment area, only take fibrous on certain days etc etc. each landfill to its own I suppose.
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