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Posted By clare coles
Hi
Please can someone help?
We have a large office/warehouse and an Asbestos Survey has found a very small amount of Asbestos (Chrysoltile).
The Local Authority has turned up at this site (as it is only 6 months old) and as asked for an Asbestos Management Plan.
Does anyone have a blank word document that I could use as a template.
She has only given me two weeks to supply this and I really want to crack on with it.
Many thanks
Clare
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Posted By Robert K Lewis
Clare
Are you saying that the warehouse itself is less than 6 months old? If you are I think you would be best to contact me directly such that we can talk about this properly. No structure erected post Jan 200 should have any asbestos present - This is the HSE stated position. If a survey has positively identified ACM in such a new building then a regulatory breach has occurred and you need to be looking towards the contractor who built it.
If however this is an older building I will also be pleased to assist with the plan and any LA discussions.
Bob
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Posted By clare coles
Hi Robert
Thank you. Sorry, I will clarify, building is approx 25 years old, our Company has had the site for approx 6 months.
Regards
Clare
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Posted By Robert K Lewis
Clare many thanks for the clarification. Unfortunately then the LA is absolutely correct in the need to establish a plan. Sharon's links are a good start point, however a management plan takes a lot longer than 14 days to produce if you are not familiar with such plans. You need to agree with your managers the following heads and other matters
Responsibilities for the plan
Location and condition of known/suspected ACMS
Inspection regime
Control of work procedures
Emergency procedures
etc etc
Not an easy task if you are unfamiliar with the Management Plan requirements. I would still advise that you get specialist help if you want to meet your 14 day target.
Bob
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Posted By Phil Rose
Clare
Don't take this the wrong way, but saying that 'asbestos' has been found isn't helpful. It sounds pedantic I know but more accurately some asbestos containing material has been found, and the asbestos within this has been identified as Chrysotile. The type of ACM is relevant in assessing the risk and thereafter the management intervention.
From what you have said the management plan should be simple enough, and you can use the Material Assessment Algorithm in MDHS 100 to help you to accurately assess the level of risk and this will in turn help you with your management plan based on such things as location, extent of ACM, the use and occupancy of the area, the likelihood of the ACM being disturbed etc etc.
Hope this helps
Phil
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Posted By Alan Hoskins
Could you not ask whoever undertook your survey produce a management plan perhaps? They should at least know the where and what already...
Alan
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Posted By Robert K Lewis
As a PS
I know this is closing the stable door but your solicitors have apparently let you down when you acquired this building as the asbestos management plan should have been requested at due diligence stage and it is apparent that this was not so. I have lost count of the number of building occupiers who have ended up in this position. Regulation 4 is absolutely clear - If you control the premises by lease, rental, ownership, contract or any other mechanisms the management plan is your responsibility from Day 1 of the control.
Bob
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Posted By Robert K Lewis
Alan
Not necessarily true, the surveyor knows only what he has identified. Other ACM may remain and most surveying organisations will not touch these areas in any plan they produce.
Bob
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Posted By Alan Hoskins
Bob,
But any management plan must take account of the survey report, so in effect they would be starting from the same base.
Or am I being thick?
Alan
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Posted By Robert K Lewis
Alan
Totally agree, it is just that the surveyors are probably the least inclined to prepare the full management plan as their PI often excludes such activity. I find that most competent H&S practitioners still need training before they set out on the preparation especially if the deadline is tight as in this case.
I provide both 1/2 and 1 day courses dependent on previous experience and find that it can be a struggle for many.
Bob
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Posted By Dave Wilson
Be aware that the HSE / LA EHO are rigourously enforcing the Duty to manage as past of the FIT 3 and DRP Pogramme
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Posted By Dave Wilson
And another thing, asbestos surveyors can help with management plans however this involves close liaison and communication with the client as the DTM will be site specific and depending on what the client wishes to do with any ACM found and the level of risk involved may involve major capitol spend, but it's the clients decision.
Its not just about the report but how the client is going to manage it lok in HSE OC 265/50 and the HSE DTM inspection pack.
If you know what they are going to enforce then you can put things in place and head them off at the pass
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Posted By Ron Hunter
Claire: do you know the type, location , extent and condition of the asbestos containing material?
Your "Management Plan" (IF the ACMs are all in good condition and not likely to be disturbed) COULD be as simple as stating that you will let everyone who needs to know what and where it is (you might want to label it too);record every twelve months that that condition hasn't changed; and if it does change , or the area has to be worked on, that you'll bring in a competent contractor to deal with it.
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Posted By Bob Youel
all the advice herein is good advice so take notice
However if you only have 14 days you are best getting in a specialist as you may get a notice which could affect many things; and yes a plan can be very simple or very complicated noting that on either account a plans adequacy is only defined via a courts decision
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Posted By clare coles
Everyone
Thank you for your help and advice.
Ron - just to say I have suggested to the HSE Inspector that I would type up some sort of report stating where the Asbestos is ( it is very minimal) carry out visual checks and record this, notify Contractors who come on site of the Asbestos (show report if necessary). All asbestos areas are labelled - however, she said this was not good enough. She is really going to town on this one!
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Posted By Ron Hunter
Rant:
I find it totally unacceptable for any representative of any gov. agency to tell you what you're doing isn't good enough, threaten you with further action and then to walk away without offering you at least some advice on how best to achieve compliance or clearly express what it is they DO want from you; particularly where the employer is an SME.I find this style of enforcement quite offensive.
Rant over.
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Posted By clare coles
Ron
Yes I quite agree, I have met quite a few Inspectors in my 7-8 years in H&S and must say they have always been helpful, however this one is entirely different.
She has quoted legislation to me, and in very broad terms told me what needs to be done but when I asked for a more concise view of what she wanted as I told her I was unsure, she just repeated the legislation etc etc.
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Posted By Ron Hunter If the Inspector had been in any way helpful they should have at least pointed you at: http://www.hse.gov.uk/pubns/indg223.pdfLooking at that guidance (the short form version of the ACoP L123) I suggest from what you are telling us that you are actually doing all that is required - or very, very close to it.
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Posted By TT
Is the asbestos in an area that is likely to be disturbed? Fork lift trucks ready to strike it and cause damage etc.? Is so then you would likely need to do more to satisfy the EHO that the risk was being controlled.
However, if the ACMs you've identified are in a location that is unlikely to be disturbed, PLUS you label it and demonstrate a system for ongoing management, then there is nothing more that you need to do.
Going further than this leads on to encapsulation, removal etc. and this all entails cost which may be frankly unreasonable and not in line with sensible risk management.
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Posted By Robert K Lewis
At the root of the inspectors attitude is the issue of what other asbestos may be present hidden in the structure/equipment. It is not simply a question of the asbestos you have identified. Thus it is serves no purpose to talk and plan purely in terms of the identified materials. The management plan must look at the whole approach to any works that may be intended and how it is to be controlled. Like all good plans it will have roles, procedures, information records, monitoring and review processes etc.
Bob
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Posted By Dave Wilson
Before we get hung up on the inspectors attitude, as an EX EHO they enforce legislation and nothing more, if you ask for any specific advice you will get a verbal but never written as, if it all goes pete tong, then you can stand up in court and say "well the LA EHO / HSE told me to do it that way".
It is the employers responsibility to comply with the law and there is no defence to say "I didn't know!" it is your responsibility to know. (legitimat non excusat, I think or something like that)
As far as the DTM goes if you read the HSE Enforcement of DTM guide on HSE website, this has been produced under FOI and this is quite explicit in what the HSE are telling their people what to look for when doing DTM inspections, it also tells you at what stage they would be looking to serve Notice/ prosecute under their Enforcement Management model (EMM). There are also prewritten IN/ON which are there as well, so have a shifty!
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Posted By Ron Hunter
Dave, I've read that internalops doc you refer to.
It isn't explicit at all w.r.t. Asbestos Management Plans.
In any event is it reasonable to expect any employer to be aware of this document? They can be expected to have access to general guidance, particularly the free stuff on the HSE site (as I referenced above) which actually contains more detail about what should be done to comply with Reg 4.
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Posted By Dave Wilson
Ron,
I know mate but if you know what the HSE are looking for then at least you have a chance of getting it right.
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Posted By Karl B First off, there should be an asbestos register. When the law changed, all buildings were required by law to have them. This should have all the details of the asbestos throughout the building. This would have been done on a type one or type two survey. Type one being presumptive, type two consisting of taking samples. The type 3 is normally pre demolition. This link is a free document to start putting together your register. http://www.asbestosregis...k/asbestos_register.aspx There are very few HSE or EHO bods out there that actually know anything about asbestos. We used to call them routes and boots. They know one or two of the basics but there the knowledge(common sense) stops. Chrysotile is normally found in a matrix, usually cement which is reasonably safe to work with providing you take the correct precautions. My advice, hand it over to an analytical firm, somebody UKAS accredited. Without an asbestos register (and you have been there six months, so no excuse) you could find yourself liable if there has been work carried out there without the staff or contractors being informed of the risks. I would certainly check back to the time when you took over the building to find out what happened to the asbestos register.
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Posted By Ron Hunter
Karl, the issue is about Asbestos Management Plans, not Asbestos Risk Registers. Although related, this is not the same.
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Posted By Robert K Lewis
Ron
I know precisely how you feel. Unfortunately many organisations see a register as a complete plan and we end up with endless work problems
Bob
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Posted By Karl B
didn't want to cause confusion but the register is the key document. You could produce a thousand page asbestos management plan but if you don't know where it is and in what quantities and condition, you could be potentialy wasting your time and resources. As a former contractor, I didn't care if a company had a management plan, I wanted to know if I was going to disturb anything nasty in the fabric of the building. Nearly all HSE prosecutions in relation to asbestos fall into 2 catagories. 1. Staff not being trained or made "asbestos aware" and 2. Duty holders not informing contractors if there is a risk of asbestos. Once a register is produced then you can look at the management, or do both at the same time. My advice, get the cheque book out and get a survey/register done.
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Posted By Dave Wilson
Karl
I understand what you say mate but in essence the 'survey' is only the start of the production of an asbestos management plan and an implementaion programme should be produced to get this in place at all premises built before 2000. (Pre 2000 the plan is easy, only one page of A4)
Remember it is a 'Duty to Manage' not a duty to survey or remove etc however these should be considered as a part of the overall plan.
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Posted By Robert K Lewis
Karl
Just to reinforce what Dave has said.
There is far too much concentration on the register as the A*** document to manage asbestos. It causes far too much emphasis on the identified materials and can divert attention from the materials that may be hidden. A good management plan will certainly need a record process for known ACM and its monitoring but it will also hold the balance to ensure that work does not start without proper checking for possible presence etc etc.
Bob
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Posted By Ron Hunter
Dave meant to say post-2000.
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