Posted By Jonathan Sandler CMIOSH
Has anybody had a chance to read the CD on the proposed Asbestos Regs all 280
+ pages?
Should the HSC merge all Asi regs into one regulation, is this a step in the right direction?
Has anybody read the one page Janet and John version or replied back to Murray Clark yet?
Interested in hearing your views.
Happy new one!!!!!!

Posted By Adrian Watson
Dear Jonathan,

Yes I am that sad person who has read the proposed regulations! These proposals are good in theory but I don't think that these regulations do the job. This is mainly because the wording of the proposed regulations is amongst the worst that I have ever seen and it tries to things that the directive did not aim to do!

Firstly, the HSE are trying to Gold plate the Directive again and have changed the words of the directive, when they wrote the regulations.

Secondly, the Regulations and ACoP are incompatible; HSE are trying to reintroduce the ALR, which are material based, into the new regulations, which are risk based.

Thirdly, there are also some daft items such as putting a 10 min control limit in the ACoP - It's daft because the level of detection of the analytical method is higher than the limit!

Fourth, some parts of the regulations are possibly ultra vires for a variety of reasons; including the fact that there is no capability in the HSE Act for making regulations about quality!

I could go on. However, I suggest that any body who has not read this the proposals should do so, rather than read the notes at the front as these do not accurately reflect the main document.

Regards Adrian Watson

PS. A Happy new year to you all!

Posted By Dave Wilson
As I work in the ASI industry these regs are a good thing as it pulls all the legislation together, however there are parts which are a step to far.
BAD
Not to bang on about TC but unlicensenced and untrained at the momemnt are then going to be allowed to remove this and the draft talks about Enclosures, two stage airlock, negative pressure etc to remove TC, will never happen in a million years, just pull it down lads1

Good
Also there will be a specific requirement to ensure that ALL and I mean ALL persons who work in contstruction and the allied building trades will require training, good for me as I can do this.

I sometimes get the feeling that employers on the whole think that the 'asi regs' apply to the asi industry and not to themselves, I have lost count of the amount of times in the last year wher jobs under CDM have never even had a Survey done, so Client and PS stops work and then delays ensue and the ASI company is then put under pressure to strip and remove tomorrow!!!

Good

New means to count fibres, as only ASI Fibres will be counted and not all fibres.

Dont know

Reducing the AL and CL to 0.1 for all fibres, if Chrysotile is not bad then why have the same level as amphiboles?????

This is a disaster waiting to happen if the CD satys like this and this Government will have a lot of explaning to do in the future.