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Posted By Paul Woodard
A farmer wants to dismantle some steel framed sheds with asbestos cement roofs (confirmed chrysotile) and re-erect on another part of his land. My initial thoughts were he cannot because of Regulations. But having looked at Part 3 of the Control of Asbestos Regulations, Reg 25(1)(b) it clearly states "putting asbestos or any product to which asbestos has intentionally been added which has been in use before to a new use". My thoughts would be that the asbestos product is not to be put to a new use as it will perform exactly the same function as before albeit in a different location. Would this be a correct interpretation?
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Posted By Alan Nicholls
Paul
By dismantling, moving and rebuilding, you are putting the sheeting to another use. My thoughts are that it was intended to prevent materials being sold and re used by someone else, not being aware of the regs.
I may well be wrong, this is my view only.
I hate the stuff, with good reason.
regards Alan
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Posted By Raymond Rapp
Paul
Purely on the information supplied I would say the intention of the imposition was to prevent any re-use of ACMs exactly as you have described. It is a matter of semantics which is 'new' and which is the 'same' but in the spirit of the regulation I think it applies as re-use.
Interested to learn what others think.
Ray
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Posted By mark pearson
Hi as a site that when i arrived had spare ACM roof panels in the old factory storage area the idea of removal and erection elsewhere is frightening carefull sutible disposal is the only option.
The regs are long and cumbersome but the aproch is quite simple (imho) identify exactly what it is with a type 1 or 2 survey, if it can be removed do so if it would cost to much and its intacked encapsulate it! but certinly taking down moving reataching this will create exposure however it is completed. The time takern even with cement sheet will require licenced contractors to undertake the removal task.........
the other question that i would ask is why consider reuse as we have i belive beter materials avalible now that will be much quicker to use and provied a beter water tight solution.
I feel the HSE would have a feild day with you ;-)
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Posted By Phil Rose
Paul
No I don't think that would be a correct interpretation. I think the object is to prevent the re-use of the ACM. However, we are talking about a farmer here so .................
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Posted By Ron Hunter
I suggest Regulation 29 of CAR 2006 refers. As I interpret that, "re-use" would be prohibited?
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Posted By Nick Patience
HSE advice at http://www.hse.gov.uk/ag...ture/topics/building.htm
See the comment on "New Buildings" - and "ACMs may not be reused on new buildings"
Also see:
http://www.hse.gov.uk/fo...od/oc/200-299/265_47.pdf in the Annex containing FAQs
"6 What about products already in use?
If a product containing asbestos is already in use, it can stay in use until the end of its service life and need not be replaced. However, products which are merely in stock, and which are being held in warehouses, etc, are not deemed to be already in use and must be disposed of as asbestos waste. The second-hand sale of products containing asbestos (such as cars and trains) is permitted, but the second-hand use of asbestos cement products, which involves dismantling and re-erection is prohibited, eg a builder could not remove asbestos cement sheets from one building and then install them in another building."
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Posted By Seamus O Sullivan
No, he can not reuse asbestos.
On a practical level I suspect much of the sheeting will be damaged when it is dismantled, and could not be reused.
In case the farmer asks, I believe it is also illegal to attempt to sell used asbestos sheeting
seamus
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Posted By Derrick Robinson
We do lots of this type of work. We would strip the sheets and arrange their removal, we would re erect the steel frames but under no circumstances would we re fit A/C sheeting. If the client wants to retain the benefits and appearance of the original sheets there is a perfectly good product on the market which contains no asbestos. Beware though, there are some unscrupulous companies in the agricultural building business and I am sure there are people who would happily quote the client to do exactly what he wants them to do.
Derrick
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Posted By Dave Wilson
When ANY Asbestos product is 'Removed' it automatically become waste, and as such cannot be re used. it has to go to a Waste landfill site under the Hazardous Waste Regs waste transfer note system, if it is fibrous asbestos waste then the CDG / ADR may also apply!.
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Posted By James Denman
I may soon have a similar problem, but the difference being that we need to remove an asbestos roof to lift out some machinery and then put the roof back on. I have said that we will have to replace the roof as we can't put the asbestos containing one back on, as that is my understanding, but I'm not sure if pushed, I can totally back that up.
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Posted By Bob Youel
If you strip a building e.g. a garage to a powwer station; any hazardous materials contained in the origional structure should not be put back into it in its new location! That includeds removal of a section of a roof
Note that its not just the asbestos regs that you have to adhere to; so all applicable regs should be appraised as to their requirements and its got to be easier to put in new non haz material than it is to re claim the old. This is especially so when it comes to asbestos
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Posted By James Denman
But the point being that it isn't going in a new location, it would go back in exactly the same place. But I think I have convinced them that a new roof is what they need to do.
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Posted By Paul Woodard
The point of the original post was to generate discussion on Reg25(1)(b) of CAR. More specifically others opinions on the term 'new use'. As a H&S practitioner I know that the re-use of any ACM's is prohibited, certainly in the past with defnitive regulations. But the above term may be interpretted in more than one way. eg. new use of roofing sheets as fencing material OR new use of roofing sheet on Building A to roofing sheet on Building B.
Prehaps the para. should just say the 'the re-use of ACM's is prohibited' because this debate could go on to include the products where asbestos has been Un-intentionally added eg. imported hardcore.
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Posted By Dave Wilson
If you look in Asbestos: The Licensed contractors guide HSG 247 particularly para 7.87 on page 87
What is asbestos waste?
7. 87 CAWR defines asbestos waste as being any amphibole or chrysotile product that has been removed from its original place of use. Therefore any asbestos product or material that has been removed from its original location should be treated as asbestos waste. This includes debris, dust and associated rubble and other mixtures where asbestos products are present.
The HSE are in the process of producing Asbestos:The unlicensed contractors guide and this will be with us soon I am told. This will also be reproduced int document.
Hope that clarifies things.
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Posted By gerry d
The asbestos cement can be removed by an unlicensed organisation provided appropriate control measures are employed. Staff must have suitable training in asbestos awareness.
Once detached from its original location it is deemed to be waste and cannnot be re-used.
AC is fragile and may break or give off fibres during removal anyway, so should not under any circumstances be considered for re-use.
I have experinced AC containing grunerite (amosite) as well so no one should be under that false assumption that it only contains chrysotile.
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Posted By Dave Wilson
I also have a sample of AC with Crocidolite and it is more common than you think.
Do not believe the hype that Blue / Brown was never put in AC
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