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#1 Posted : 18 August 2006 13:33:00(UTC)
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Posted By Nicholas Morris
A niggling query from one of my (non H&S) auditors: we have no asbestos at two of our sites, do we need a register (even if its says we have none), and should we provide asbestos awareness training? Common sense says no, maybe just a statement on file to this effect, but this does not seem enough for this particularly pedantic individual!
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#2 Posted : 18 August 2006 13:59:00(UTC)
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Posted By Dave Wilson
Yes you need a one pageer, as this is your proof and No you do not need the training if your people will not come into contact with any Asbestos
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#3 Posted : 18 August 2006 14:51:00(UTC)
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Posted By Salus
Hi Nick, how do you know if you have no asbestos containing materials on site?, probally because you had a survey carried out by a competent person.
Use the survey result for your site for the OTT auditor.

For the other sites which I presume contain some asbestos products,
When you mention training for employees, what type of work do they carry out,only if they are likely to encounter any asbestos containing materials while carrying out their work will they require any training. Office staff will not require it.

You may also need a procedure for employees to follow if they accidently discover any material they think may contain asbestos which is not known about.

You can carry out your own training for asbestos cement just follow the guidance for basic training in HSG210 asbestos essentials
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#4 Posted : 19 August 2006 09:46:00(UTC)
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Posted By Is Kismet
So in the case of a new build he/she needs an asbestos register - I don't think so.

What we are saying on this thread is that if something is self evident, we have to provide a piece of paper confirming it is self evident!

Do we not need to get some things in perspective?
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#5 Posted : 19 August 2006 13:01:00(UTC)
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Posted By Bruce Sutherland
I agree with Mr Wilson - the duty to manage would be best met in an audit situation with proof that a competent person has identified there were no ACM .... I can be a real anorak and bore you with new buildings dating from 2002 whihc do contain ACM ... verge packing AC and stair nosings in particular - nothing particularly exciting and certainly not on the specification... just no one told the roofer not to use AC and no one checked that the vinyl bought on the world market did not contain asb.... deep joy

Bruce
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#6 Posted : 15 September 2006 09:17:00(UTC)
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Posted By Nicholas Morris
Thanks to earlier contributors, I think the consensus is that for our 2 non-asbestos sites we don't need training or a register, simply a statement from our builder or similar to the effect that we have none. Regarding our 3rd site, we are not the owner, we rent from a landlord. We have 2 engineers who are likely to do work involving drilling into walls etc. What are our requirements in this respect please?
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#7 Posted : 15 September 2006 09:31:00(UTC)
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Posted By garyOrange
My understanding is that there is no legal requirement for a asbestos "register" the requirements of CAWR require that an assessment, i.e a survey is carried out and that "information" on the presence and type of asbestos is made available to employees and others who may be affected by it. This can be in the form of a "register" if you wish to create one, but it can also be in other forms as well. In our company information on asbestos materials are made available to our engineers by means of an electronic system. Individual reports are filed in the building H&S file, along with management plans if needed and they act as the information required under CAWR.

Having spoken to the HSE on this point they are happy that our information is in an electrocnic format and not labelled as a register.

Gaz
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#8 Posted : 15 September 2006 09:49:00(UTC)
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Posted By TBC
As regards to your 3rd building, I would suggest a Type 2 survey and if any ACM is found - build up a register and include a plan of the building marking the locations of ACM. This register to be made available to any engineers, contractors and IT personnel (cabling etc) and labels on the ACM material. Staff consultation to inform of the findings and reassure employees.

Based on your findings you may wish to encapsulate if appropriate or remove the ACM completely to do away with the need to monitor.
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#9 Posted : 15 September 2006 14:34:00(UTC)
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Posted By Robert K Lewis
To extend the posting of TBC,if the 3rd building was constructed after 1998 then you can ignore the need for any survey as the use was banned in newbuild. The issue of the landlord is by and large irrelevant with respect to the areas you occupy. You are in control and therefore you must manage.

Also with respect to the other two sites - unless they are post 1998 construction or you have had a complete type 3 survey the new regulations will expect you to manage them as having asbestos unless you can demonstrate the non-existence of ACMs. This may be the route your auditor is taking.

You will need to train the relevant staff and the October 2006 regulations will specifically require competent persons to train and formal certification for such workers as your engineers who could foreseeably encounter ACMs during work.

Bob
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#10 Posted : 15 September 2006 15:22:00(UTC)
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Posted By Adrian Watson
Dear Nicholas,

A number of points, you are not required to survey; you are required to make reasonable checks to determine whether your buildings contain asbestos. If they may contain asbestos you have a duty to inspect your premises to determine the type, location and condition of any asbestos containing materials present. You are also required to put in place a written management plan, implement it, check that it is effective and occasionally review it.

Your problem is that if you are challenged as to how you know your buildings do not contain asbestos you have no objective evidence to support your opinions. Furthermore, if you can spout off the reasons why you believe that your building do not contain asbestos can everybody come to the same opinion if you are not present? For that reason it is simpler to record your reasons in a simple document, stating I am of the opinion that this building does not contain asbestos for the following reasons.

Regards Adrian Watson

PS Make sure that you are competent to make that assessment!
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