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Posted By PhilP We have over 300 properties that had a "type 2" survey carried out in 1996 creating a log book and register for each site. This Type 2 was before MDHS 100 and we are now being advised by our property consultants that this does not meet current guidance and we should commission a Type 2 across all the estate again.
I do not think that MDHS 100 is retrospective and our current survey is still adequate and cannot find guidance on frequency of re-surveying.
I think it is a way of obtaining more money which would best be used towards managing asbestos already identified by out 1996 survey.
Appreciate other views comments on this?
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Posted By Chris L You do not need to re-survey simply based on the fact that your surveys pre-date MDHS100.
In accordance with CAWR2002 & now CAR2006 you should have been regulary re-inspecting your asbestos materials and updating their risk-assessments as required, and unless you have found glaring omissions in your survey reports there is no need to do them again.
If you haven't been carrying out your reassessments, then your fastest route to compliance with CAR2006 may be to get your property stock re-surveyed, although of course this depends upon the size of your estate, and your own knowledge and time availability - you may be able to do it yourself.
No clear-cut answer, as every estate is different.
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Posted By Mitch Phil,
Ask your consultants why it doesn't comply with current guidance, remember guidance can come from a number of quarters. You should review and update your management plan as required I see no need for another survey unless you are concerned about the competency/thoroughness of the original surveyors.
Mitch
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Posted By Chris121 do not pay for re-sampling again! The previous type 2 report should have identified asbestos containing materials on the premises and certificates of analysis from a UKAS accreditied lab should be contained within the reports for verification preferably.
I presume the consultants are recommending a re-survey as prior to MDHS100 there was no need to undertake material and priory assessments of ACM's and therfore the recording format of the surveys might not comply with the current standards.
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Posted By Robert K Lewis PhilP
I am a little worried however as your posting implies the survey and register are all you have in place. The duty is now to have a management plan in place and the monitoring and review of ACMs should be part of that. Unless you undertake a type 3 survey then you are unlikely to improve significantly the quality of information you already have.
Bob
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Posted By PhilP Thanks for the replies.
We do have a management plan and monitoring, this is carried out by the same consultants who are telling us we require to carry out the new surveys.
Phil
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Posted By Mitch Then yes you are being ripped off
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Posted By Doug Kelly Unless there is a basis to lack confidence in your original survey data, I don't see why anyone should insist you must re-survey your properties. If you have a management plan, and have undertaken re-inspection and review, it isn't clear how a re-survey would provide further useful information.
It might be prudent to check that the surveys weren't 'qualified', for example some surveyors would exclude bitumen-based products, floor tiles, textured coatings etc. on the basis that they were low risk. It was also common for extensive 'caveats' to be inserted into reports to cover all sorts of items. This could include things like fire doors, gaskets and so on, where sampling could damage the effectiveness of the product.
Overall, having satisfied yourself that your existing data was (and remains) valid, you could put your views to HSE/EHO and ask for guidance.
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Posted By Chris L Their advice certainly doesn't appear sound based on what you've told us.
If there was a doubt about the standard of the surveys they should have raised this initially, long before carrying out your reassessments etc. and if they're saying that those reassessments aren't up to scratch, well....
How long have they been working for you? Is it time for a second opinion?
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Posted By Robert K Lewis PhilP
Are you saying that these people are running your management plan or just do the monitoring for yourselves?
If the former you need to take back control. If the latter they should then follow your instructions. Are they trying to say that they have reason to believe there is additional asbestos?
Bob
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Posted By PhilP They deal with all our property management/maintenance and so have control of the management systems.
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Posted By Chris L In that case you need to ask why this has suddenly cropped up after they have been managing the asbestos ok up until now.
They need to justify why you should go down this route - they may have a valid reason, but it would be interesting to know what it is.
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Posted By Chris Harrison as an experienced and trained asbestos surveyor i would tend to agree with your gut feelings.
ask them why they think the type 2 surveys should be redone? if they have no faith in their own type 2 surveys or the way that the surveys were carried out I would start to ask why.
if you have had the type 2 surveys carried out identifying what suspected asbestos is in situ, it may be prudent to pick a few properties at random from your property manifest and have a different company carry out a type 2 survey, see if they come up with anything different.
its always possible with this type of survey to identify different items or even the same materials and categorise the associated risk differently, that will change with experience. but if the use of the properties is the same and you are managing i.e. reducing the risk over time I can think of no logical reason to survey the whole lot again, except as you say to make money.
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Posted By NickW In fairness to the company in question, an asbestos survey carried out 'back in the day' was very different to what you would expect now.
For example when our firm surveyed for asbestos in the mid 1990's we werent picking up lower hazard items such as sinkpads and toilet cisterns. Also we, and our reputable competitors now have UKAS accreditation to ISO 10720 (as recommended but not legally required) in HSG 227. I would wager that an audit of a site would quite quickly prove that the surveys are not compliant with this standard if they were conducted 10 years or so ago. Another important practical consideration is that asbestos surveyors now should be making detailed descriptions of each room, noting construction of all elements. This gives rise to a big thick document which most clients ignore initially as they just flick to the summary to find 'what have I got? where is it? do I need to do anything about it?' which is understandable. However you would be suprised to find how useful this seemingly pointless information is for the future use and intepretation of the document. For example if our surveyor notes that the walls in room A are plasterboard, the floors are quarried slate etc this would be common sense to many people but not to all and given that the regs reqire the presumption of asbestos in the absense of strong evidence otherwise, an atual commment in the report saves the client and the asbestos consultant a lot of hassle, time and phonecalls.
Also have you got marked up building plans? we rarely did these all those years ago but now its standard service. They are very useful for the layperson to understand.
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Posted By Rodger Alan Ker Let me first declare an interest. I am a H&S Consultant for an asbestos services and project management company.
Your properties last surveyed for asbestos in 1996. That is TWELVE YEARS AGO! Would you like to travel in a car that had not been serviced or maintained in twelve years.
There must have been changes/alterations made to these building in that time.
Your main concern should be that you are almost certainly not complying with Regulation 4 of the Control of Asbestos Regs 2006 "The Duty to Manage".
HSE Inspectors have a guidance (52 pages) to assist them in the enforcement of this duty.
I have produced for my clients an 8 page synopsis of this document, it makes interesting (frightening) reading.
If you would like a copy, e-mail me.
Rodger Ker
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