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#1 Posted : 31 October 2007 16:27:00(UTC)
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Posted By jase37
Can anyone help. I'm currently reviewing procedures for the testing of artex for the presence of asbestos.

Does anyone know of any reports that discuss whether post 1999 properties tested for the above have had positive results?

Thanks,

Jase
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#2 Posted : 31 October 2007 16:51:00(UTC)
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Posted By Dave Wilson
It is extremely unlikely that any Asbestos is in any UK property after 1st Jan 2000.

In the Regs (Reg 4) it talks about duty to manage and assessing whether you have asbestos and in what condition etc eg surveying

However it does say that if you have 'Strong evidence to the contrary' that asbestos is not present then you can do that.

I would suggest that since Asbestos has been totally banned in all building materials in the UK since end of 1999 this is 'Strong Evidence' to say that there is NO asbestos in your property = NO Asbestos Survey!

Don't let a surveying company tell you different. PS we do surveys and this is what we tell clients - One side of A4, make the statment and hey presto Asbestos Management Plan!
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#3 Posted : 01 November 2007 12:12:00(UTC)
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Posted By Mart
We have found ACM's in post 2000 year properties, and have been led to believe that old stock materials have been used. Never assume is my advice.

Mart
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#4 Posted : 01 November 2007 13:20:00(UTC)
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Posted By Dave Wilson
I agree to a certain extent, however if this has been done then it was illegal to do so!

How far do you take it? You have got to draw the line some where and I would still stick with my original posting.
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#5 Posted : 01 November 2007 14:55:00(UTC)
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Posted By Doug Kelly
Not forgetting the 'derogations' in the Schedule to the Asbestos (Prohibition) (Amendment) Regulations 1999, a number of ACM remained/remain 'legal'

http://www.opsi.gov.uk/SI/si1999/19992373.htm
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#6 Posted : 01 November 2007 15:08:00(UTC)
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Posted By CFT
It will be Chrysotile if you have any, it will range from around 0.05% to approx 2.8% content, it is unlikely that post 84 (disappeared rapidly in 78/9/80) artex will be part of the ACM family and since 2006 it was declassified as requiring licensed contractors for removal.

If your question was aimed at removal then DON'T do it dry under any circumstance, white is the least invasive of the common three and has a 'floppy' consistency under a microscope; do it dry however and the mess is unimaginable.

You can have it tested if you wish but a pound to a pinch says it'll be free of the big A.

Covering up is still the easiest method.

All the best

CFT
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#7 Posted : 02 November 2007 08:37:00(UTC)
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Posted By Robert K Lewis
I totally agree with DW we are able to make a clear statement for all 2000 onwards buildings that there is ne reason to suspect the presence of ACM in a new structure. The phasing out of ACMs commenced many years previously and only the cement boards finally disappeared in 1999 but that was the formal end, practically 1998 probably saw the last of all but a few %ge points of the previous annual total.

Bob
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#8 Posted : 02 November 2007 16:17:00(UTC)
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Posted By Adrian Watson
Cement boards were not produced after 1990; although some were still in stock.

Regards Adrian
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#9 Posted : 05 November 2007 15:48:00(UTC)
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Posted By Thos G
I worked in social housing repairs and maintenance for several year. The housing stock was of various ages from Georgian/Victorian upto present day.
We had no way of knowing when texture coatings were applied to these properties.
Over the last couple of years when we had texure coated ceilings to remove/repair we worked on the premise 'if suspect then treat as ACM'.
We used to have the material laboratory tested which involved the licensed specialist taking 5 samples (4 corners and 1 centre of ceiling).
Invariably when a ceiling came back postive for ACM it was generally that 1 or 2 of the five samples showed abestos as present.
When we got a negative result the report came back with a BIG disclaimer i.e. if the samples were taken from other areas of the ceiling then we may have got positive results.
It was decided that the testing could prove asbestos content but could not prove it asbestos free.
We then decided that all texture coated surfaces would be treat as ACM. Control measures, staff training, disposal etc then came in....
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#10 Posted : 05 November 2007 16:13:00(UTC)
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Posted By Dave Wilson
Good idea, however this is an extremely expensive approach and really necessary, as you can get the info in a number of ways.

All asbestos surveying companies put this in, as the only sure way of finding ALL ACM's in a building is to dismantle it brick by brick.
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#11 Posted : 05 November 2007 17:10:00(UTC)
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Posted By jase37
Thanks for your responses. It does seem like it is a difficult subject with arguements both for and against testing post 99.

As a company we have come across 2004 new build domestic premises having artex containing asbestos. Unfortunately it does seem that the implementation of the legislation had the presumption that the use would just stop, not considering that either surplass supply or imported rogue batches may be used. Would have been good to see the labs monitoring the year of the properties that the samples were taken from to give a clear picture of what was being used.

I'm still left with the same question as from experience I know that it has been used up to at least 2004. The question is actually regarding a 3rd party company carrying out the surveys and not testing post 99.

If the result of exposure was evident on the following day, would the number of post 99 samples go up?

Is 'reasonably practicable' justified in this case with the cost of sampling when aware of several positive results?

Thanks,

Jase



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#12 Posted : 05 November 2007 21:52:00(UTC)
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Posted By Adrian Watson
If buildings built in 2003 were coming back with artex as containing asbestos I would:

1) suspect cross contamination in sampling or analysis;

2) be making action against the contractor to remove the asbestos, if there was no cross contamination of the samples.

Regards Adrian
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#13 Posted : 05 November 2007 22:03:00(UTC)
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Posted By Bruce Sutherland
Are you sure over the dates?

We have found things like vinyl floor nosing - presumably an import in 2002 new build - with my anorak hat on what you are suggesting - is potentially quite ( quick understatement) important ........ I can think of quite a few people who would be interested.

CFT your artex concentrations differ from what would normally be expected ... about 4% for ceilings and 2% for walls - different mixes apparently - would be grateful for your source

Regards


Bruce
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#14 Posted : 06 November 2007 09:41:00(UTC)
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Posted By jase37
The 2004 property was in Leeds. We had a Surveyor carry out testing on the property and another property from the 80's on the same day. The tests came back with a positive for the 2004 property and so a retest was carried out on both as it was thought they may have been mixed up. The sample again came back positive for the 2004 property.

We do have other examples which I am currently digging out.

Since this we have always tested the artex prior to commencing works, no matter the age of the property.

Jase
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#15 Posted : 06 November 2007 09:58:00(UTC)
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Posted By Dave Wilson
Just a few comments.

If this artex contains asbestos it was illegal to put it in.

Asbestos prohibition regs have been repealed.

Artex IS NOT De licensed per se as ALL Asbestos work is now licensable unless Reg3(2) applies, this is the risk based approach and not product specific. See para 37 of the ACoP (L143)regarding artex.

This is where the HSE are coming from.

IT IS UP TO THE EMPLOYER to decide as a result of the Risk Assessment REG 6 in particular paras 64 - 67 whiter the Control Limit will be exceeded and if it is then that work automatically becomes licensed as Reg 3(2) will not apply.
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#16 Posted : 06 November 2007 11:11:00(UTC)
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Posted By CFT
Hello Bruce

I'll argue the point that ceilings are generally 4%, when containing white asbestos; they are IMO, not. Manufacturers data varies greatly but no where is it set in stone that 'about' 4% is the datum line. I will agree that there are higher levels than I detailed in an earlier post but I intended those stats to be the from and to for the majority of containing situations.

Much study over the years has never revealed about 4% per se. As always, I stand to be corrected if you have evidence to support the about 4% 'for all' cases of artex ceilings and that there are no lower levels I will be duly corrected.

With respect

CFT
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#17 Posted : 06 November 2007 12:33:00(UTC)
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Posted By Bob Youel

caught a builder recently trying to use some old asbestos sheets [he had them in his store for years and they were in tip top condition] in a new build - so don't always think that buildings are safe after certain dates
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#18 Posted : 06 November 2007 12:37:00(UTC)
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Posted By CFT
Dave

Not certain I agree; textured coatings have indeed been de classified as no longer requiring a HSE licensed asbestos removal company, RA and task specific MS can ensure it is removed (if it must be) by wet methods, this in itself does not make it a licensed product for removal as per 2006 regs, otherwise what is the point in de-declassifying it?

With full acknowledgement to the HSC/HSE I quote the following non-copyright statement;

'In practice, most work that currently needs to be done under licence will remain licensable. Based on new research, HSC proposes that work on textured decorative coatings containing asbestos, will not need to be done by a licensed contractor. Risks from these materials are much lower than previously thought: estimated to be 1000 times less than that for other licensable materials, and lower than that from work with asbestos cement which doesn’t require a licence.'

I will acknowledge that employers utilising their own workers on their own premises are now no longer exempt from the licensing requirements, and that the regulations require mandatory training for anyone liable to be exposed to asbestos fibres at work, this includes maintenance workers and others who may come into contact with or who may disturb asbestos, as well as those involved in asbestos removal work; so whilst this is a requirement I don’t agree that all removal is licensed per se.

CFT
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#19 Posted : 06 November 2007 13:20:00(UTC)
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Posted By Dave Wilson
CFT,

I agree however only if as a result of the Risk Assessment the Control Limit will not be exceeded.

I quote

"In general, regulation 3(2) will apply to work with textured decorative coatings containing asbestos and asbestos cement.

However the risk assessment may identify factors that lead to the conclusion that the control limit could be exceeded or the exposure would not be sporadic and low intensity and in this case the exemptions would not apply.

Such factors might be a much higher proportion of asbestos in the material than normal, the material being more friable than normal and the best available method of work could result in exposure which could not be considered to be
sporadic and low intensity or the control limit being exceeded"

In about 99% of the case this would be true, however the employer must make a statement to why he thinks this exemptions apply and I quote again

"To decide whether or not the control limit is likely to be exceeded, it is first necessary to know what concentration of asbestos fibres are likely to be present in the air. It will be necessary to confirm the estimated exposures by measurement, using an appropriate method (sec paragraphs 328-338) unless there is already
sufficient, relevant and reliable data available. A summary of this data and the
source from which it was derived should be included in the assessment.

Employers must ensure that whoever carries out the assessment and provides advice on the prevention and control of exposure is competent to do so in accordance with regulation 10. This does not necessarily mean that particular
qualifications are required. However, whoever carries out the assessment should:
(a) have adequate knowledge, training and expertise in understanding the risks from asbestos and be able to make informed and appropriate decisions about
the risks and precautions that are needed;
(b) know how the work activity may disturb asbestos;
(c) be familiar with and understand the requirements of the Asbestos
Regulations and this ACOP;
(d) have the ability and the authority to collate all the necessary, relevant
information; and
(e) be able to assess other non-asbestos risks on site.

67 To be suitable and sufficient, the risk assessment should include:
(a) for non-licensed work, a statement of the reasons why the work with asbestos will fulfil the conditions for regulation 3(2) to apply and will not therefore be work which requires a licence;
(b) a description of the work (eg repair, removal, encapsulation of ACM,
maintenance and testing of plant and equipment contaminated with ACMs), and the expected scale and duration;
(c) a description of the type(s) of asbestos present and the results of any analysis or a statement that the asbestos is not chrysotile alone;
(d) a description of the quantity, form, size, means of attachment, extent and
condition of any ACMs present;
(e) details of expected exposures, noting:
(i) whether they are liable to exceed the control limit and the number of
people likely to be affected
(ii) the level of the expected exposure, so that suitable respiratory protective
equipment (RPE) can be assessed and selected;
(iii) whether anyone other than employees may be exposed, and their
expected exposures;
(iv) whether intermittent higher exposures may arise and their expected
frequency and duration; and
(v) results already available from air monitoring in similar circumstances;
(f) the steps to be taken to control exposure to the lowest level reasonably
practicable, for example for licensable work, the type of controlled wetting
and method of application, the use of local exhaust ventilation (LEV) (eg
shadow vacuuming), glovebag and wrap and cut and for non-licensable
building work, the use of low dust methods, shadow vacuuming, wetting etc
(see paragraphs 155-189);
(g) the steps taken to control the release of asbestos into the environment, for
example enclosures with negative pressure and entry and exit procedures.
Where it is not considered practicable to use an enclosure, a full justification
is required, and what action should be taken if an accidental release was to
occur;
(h) details of the decontamination procedures including the use of hygiene units
where appropriate;
(i) procedures for the selection, provision, use and decontamination of personal
protective equipment (PPE) which includes respiratory protective equipment
(RPE);
(j) procedures for the removal of waste and contaminated tools and equipment
from the work area and the site;
(k) procedures for dealing with emergencies, including, for example, those associated with working in confined spaces;
(l) any other information relevant to safe working practices such as other
significant non-asbestos hazards like working at heights or in confined spaces; and
(m) management arrangements ensuring that risks are adequately controlled during the work.
68 The findings of the assessment detailed in paragraph 67 are all deemed to be
'significant' and must be recorded as required by regulation 6(1 )(b).

You have to jump through these hoops to satisfy the Reg 3(2)and this is only for UNLICENSED WORK.

Its easy to say that its not licensed however there is more to this than meets the eye, it is quite involved.

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#20 Posted : 06 November 2007 14:23:00(UTC)
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Posted By CFT
I am going to slightly re-word so that any confusion is understood by persons with a textured scenario; artex etc has been classed as not requiring mandatory licensed removal compared to many other ACM's; there are however certain conditions that should be met before diving in and removing it 'willy nilly'.

There, that's it.

CFT
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#21 Posted : 06 November 2007 14:25:00(UTC)
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Posted By Dave Wilson
Nice one! I agree whole heartedly.
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#22 Posted : 06 November 2007 17:02:00(UTC)
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Posted By Doug Kelly
Jase

I would re-iterate Bruce's massive understatement - there will be a lot of interest generated by your findings. I'm sure the Asbestos Liaison Group / ARCA / ACAD and others would welcome the opportunity to investigate e.g. whether it is a 'local' factor or has more widespread sinister implications. This issue could have a radical impact on asbestos survey strategies / management plans and so on. I strongly suggest you 'go public' on what you have found (assuming you haven't decided to do that already).

It would be interesting to see where this leads.
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#23 Posted : 07 November 2007 12:54:00(UTC)
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Posted By Dave Wilson
MDHS 100 gives advice on when it is reasonable to assume that asbestos is NOT PRESENT

"Presumption or identification of ACMs 10 An experienced, well-trained surveyor, familiar with the range of asbestos products, can usually, by inspection alone, say that a material can be ‘presumed’ to contain asbestos. This presumption can only be tested by laboratory analysis of representative samples of the material. A low magnification stereo microscope examination of the sample followed by polarised light microscopy (PLM) of selected fibres, as outlined in MDHS 77,10 is the most widely used and cost-effective method in current use. In the absence of analytical evidence, many non-asbestos materials will also be presumed to contain asbestos, unless there is other strong evidence to support a reasoned argument that they are highly unlikely to contain asbestos
.
11 This therefore creates two levels of presumption: one where there is a 'strong presumption' that the material does contain asbestos but a laboratory identification has not been undertaken to confirm this; and a default situation where it must be 'presumed' to contain asbestos because there is insufficient evidence to suggest that it is not an ACM. An example of a 'strong presumption' would be thermal insulation on a pipe where fibres are clearly visible and have the appearance of asbestos but no sample analysis has been undertaken. Where similar construction exists and laboratory analysis of one of the materials has confirmed the presence of asbestos, there is a strong presumption that the other similar materials also contain asbestos. Materials where no asbestos fibres are visible but asbestos is known to have been commonly used in the manufactured product at the time of installation (eg floor tiles, ceiling tiles and insulating boards) will be presumed to contain asbestos. A reasoned argument to suggest that a material does not contain asbestos would be:
¦ non-asbestos substitute materials were specified in the original architect's/quantity surveyor’s plans or in subsequent refurbishments;
¦ the product was very unlikely to contain asbestos or have asbestos added (eg wallpaper, plasterboard etc);
¦ post-1985 construction (for amphibole asbestos-containing materials such as asbestos insulation board, see Table 1);
¦ post-1999 construction (some chrysotile products were prohibited in 1993 and nearly all were prohibited in 1999!
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