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Posted By Stephen R Robinson
One of clients is asking an interesting question. Following the delivery of an Asbestos survey, the client asked if damaged Asbestos requiring remediation is reportable to RIDDOR? My guess would be no on account that exposure at the time of damage is unquantifiable.
May I ask others for their thoughts?
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Posted By Mark Simpson
I would say no, but it should be actioned within the duty holders management plan & if it it prevents a danger of exposure it should be made safe (removed or repaired etc).
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Posted By steven bentham
No.
Not unless your employee(s) have died of an asbestos related disease.
RIDDOR is about specified injuries, death or specified dangerous occurences.
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Posted By Ron Hunter
RIDDOR lists as a dangerous occurence (and therefore reportable) "The accidental release or escape of any substance in a quantity sufficient to cause the death, major injury or any other damage to the health of any person"
RIDDOR guidance specifically includes asbestos within the definition of 'substance'.
There is no 'safe limit'(c.f. COSHH w.e.l.) for asbestos exposure.
Discuss?
There would (I suggest) be little merit in reporting under RIDDOR in the circumstances you describe, however, should an actual and real time accidental disturbance of any 'higher risk' ACM (AIB or worse, but perhaps not Asbestos Cement or other material where the asbestos is strongly bonded into the substrate) arise in your workplace, then it should be reported?
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Posted By Adrian Watson
Dear Ron,
There are limits for asbestos; there are the action and control limits. However, these are not dividing lines between safe and unsafe levels of exposure; but then neither are WELs!
In respect of asbestos, recent evidence is that you need a cumulative exposure of around 1 fbr/ml/year for there to be a risk of disease. This I suggest is not going to be reached by a solitary exposure of around the control limit, of 0.2 fbr/ml for amphiboles, let alone a disturbance of a AIB tile. The HSE in their EMM for asbestos state that the risk of serious health effects is possible at exposure to multiples of the control limit. RIDDOR lists as a dangerous occurence (and therefore reportable)
As Riddor requires the reporting of "The accidental release or escape of any substance in a quantity sufficient to cause the death, major injury or any other damage to the health of any person" I would not never recommend reporting it below the Control Limit and I would seriously suggest that it should be reported only if it exceeds the action limit of 48 fbr/ml hours, irregardless of the type of the asbestos, as this level that requires medical surveillance to be provided.
Regards Adrian Watson
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Posted By steven bentham
Its not reportable under RIDDOR
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Posted By Ron Hunter
Thanks for your response Adrian, and I hope Stephen won't mind this 'takeover' of his thread. My thought is that control and action limits are part and parcel of planned work activities, where exposure levels will either be measured or based on previously measured levels, or taken from HSE guidance - all of this being averaged over a 12 week period.
The accident or emergency by its very nature doesn't allow for any 'prediction' of level of exposure. Note that HSC proposals (CD205) propose the adoption of one control limit of 0.1 fibres per c.c. averaged over a continuous period of only 4 hours.
The 'Dangerous Occurence' of course, will usually affect those not in the industry, more usually it will be the tradesman and other building occupants.
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Posted By steven bentham
Okay, if you don't believe me, try reporting it then!
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Posted By Paul Oliver
It can't be that hard to fill in an F2508 and pop it in the post, or fax!!!!!
Also, in some circumstances you will need to inform your current insurance company, if you have had an uncontrolled release.
:-)
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Posted By Ron Hunter
Steven: I have already done so. The F2508 report was accepted.
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