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Posted By Neil Prince
Hi,
I am currently working as CDMC on a project that entails an asbestos removal contractor replacing a roof that is made from asbestos cement and a sprayed (amosite) coating to the underside. All the correct notifications have been conducted. During this a method statement was produced. The contractor is now making amendments to this in what he calls risk assessment to change the practice of wrapping the cement sheets (with amosite residue) to now just moving the sheets from the roof by hand handing them down from the first floor to personnel on the ground floor. The sheets could still be wrapped at ground level and taken from the roof by tele lift. All the guidance within the ACOP (CAR 2006 & Asbestos essentials) recommends the wrapping of sheets.
To my mind they have changed the original method statement to save time and not as a risk assessment. When I bring up the fact that they have deviated from the method statement I am advised that I cannot under my remit, comment or challenge them as I am not a license holder and they are able to do this without informing the HSE. Does anyone have any experience of this? Also could they offer any advise as to how to move forward on this.
Regards
Neil Prince
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Posted By CFT
Neil
On the basis you need something put into place quickly, talk to the client who in turn can talk to the PC (or you can with the clients best interests in place) and ask them to suspend work pending a satisfactory outcome.
In all honesty this is not at all uncommon and it's the 'ol sprat to catch a mackerel' trick which is one of the oldest in the book; so often this 'amendment to procedure' via RA or MS upgrade (cough cough)is completely missed, thankfully you are on hand and have immediately noticed the change to submitted schedule/scope of works.
The PC can inform them that the approved SoW is the one they will accept and any 'amendment' may exclude them from the contract (period)it usually works.
CFT
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Posted By Andrew M
Neil,
Good advice from CFT.
Remember, the risk assessment is a legally binding document and the deviation from any control measures it dictates will be treated as a breach by the HSE.
The question is does the PC have the authorisation to 'amend' the risk assessment?
If not then there can be no change in the process.
Andrew
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Posted By Rodger Alan Ker
Neil
You semm to be involved in a problem that is partially outside of your control.
I am presuming that as well as being a CDMC for this particular project, you are also a "Safety Professional" (while not necessarily acting in a safety adviser role on this project).
You will no doubt be aware that as CDMC you do not have to approve the PC's Construction Phase Plan, nor do you have to supervise or monitor work on site.
However, the safety professional in you obviously says I cannot let unsafe or unacceptable practices go unchecked.
You need some specialist help in this matter.
If you would like to give me a call, I will be happy to provide you with some, I hope, useful information.
Rodger Ker
Tel: 07747 567066
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Posted By Dave Wilson
Hang on a moment chaps.
Part of the conditions of having an asbestos licence is that a Site Specific MS / Plan of works, call it what you want, MUST be sent to the HSE AT LEAST 14 days in advance of the work commencing
The HSE DO NOT approve these MS.
As this 'notification' is in advance of the work starting and therefore site conditions may / could have changed the Licensed contractor is allowed to change this on site, HOWEVER if it involves a "MAJOR" Change then the Licensed Contractor must re notify the HSE and the 14 days starts again.
See
http://www.hse.gov.uk/asbestos/alagann8.pdf
and
http://www.hse.gov.uk/ab...gs/alg/licence/02-05.pdf
"Minor changes" can be done on site and the MS changed accordingly that's why there is an amendments section.
The HSE would take a very serious view if this was a "MAJOR" deviation from the original MS and would serve a PN on the contractor concerned.
As far as challenging them goes, if you wish to have 'CONTROL' of a licensed contractor and will involve directing work practices then you have to have a 'Supervisory Licence' from the HSE.
If you think that this is a 'MAJOR' change then I would suggest that you approach them and ask why this was done and what the potential fibre release could be when undertaking the work in this manner and if this was not the safest way then they could be in trouble.
If you want to discuss this then drop em an email mate
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Posted By Robert B.
You do need a 'supervisory license' if you are in control of an asbestos contractor on site. However, you are able to stop work or ammend work methods if you believe they are using any unsafe working practices. Depending on how much 'residue' is left on the cement sheets, it would be preferable to wrap it before man-handling down the scaffold. I would say that this consitutes a major change to the work method. I am presuming that the underlying spray coating was removed under fully controlled conditions and that you have a clearance cert for it? If the underside was then encapsulated in some way prior to the sheets being removed then this would be OK, but it sounds to me like they're just cutting corners.
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Posted By Dave Wilson
Agree with rob here
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Posted By Robert K Lewis
Also agree with Rob except to say that YOU personally cannot amend either the method as notified to the HSE or the one proposed - The PC or client can however stop its use until the contractor can demonstrate there is no increased risk.
I rather think the HSE would want detailed explanation as to why wrapping is not done at the work face. Other additional precautions would normally be expected if there is to be a change.
Bob
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Posted By Neil Prince
Could thank everyone for their comments and time given.
I have had a response back from the HSE which effectively goes along the lines of the responses, but gives clarity and direction as to carry on as I have done with the use of the client directing my concerns.
A point from the regulations was para 103 and the effective changes to a construction phase plan can be discussed with the PC "which although not in a strong term" (HSE inspector words) can still used effectively to ensure safety on any given project.
Regards
Neil Prince
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Posted By steven bentham
Neil
I read your question carefully but there are some points missing to enable the correct response to be given.
SPRAYED asbestos is a dangerous product and if removed dry will lead to significant exposure, even for workers with the correct p.p.e. I am assuming that the sprayed asbestos goes over joins, fixing and beams in the cement sheets? If this is correct then how are they preventing the spread of asbestos material?
If they are removing sprayed asbestos you should focus on their methods of injection for wetting and controlling fibre levels. This suggests injection and removing and wrapping is situ.
I am assuming you are not in the enclosure but the contractor has an analyst inside. Get him to take personal air monitoring or digital photographs of debris.
Any dry removal of sprayed asbestos is at the top end of enforcement.
If the contractor remains unhelpful in resolving this it probably needs a call to the Asbestos Licensing Unit in Edinburgh.
[Check its sprayed asbestos on cement sheets first!]
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