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Posted By RP
About to take down and dispose of a prefabricated portacabin type building which is around 20 years old and falling apart. A permanent building is to replace it and falls under CDM. a survey for asbestos done 4 years ago reported no asbestos present and no changes have be made since.
Question:
Prior to demolition or dismantling would an asbestos survey be required and if so at which level, i.e. 1, 2 or 3
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Posted By Ron Hunter
Yes, Type 3 - or as the new version of MDHS 100 would have it, a refurbishment & demolition survey.
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Posted By Robert K Lewis
Ron is spot on here. The fact that previous, lower level, surveys have failed to establish the presence of ACMs is not evidence that there is none present.
As an aside there is no need to assert the new structure is subject to CDM - all construction work is so controlled - it is amatter of to what degree.
Bob
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Posted By Southerner
Or you could just get in touch with the manufacturer of the portacabin and ask them about the construction fabric of the unit.
I have not see a cabin of any age that does not have a manufacturer plate riveted on the side.
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Posted By GeoffB4
Could you be certain no asbestos has been installed after manufacture though?
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Posted By RP
Thank you for this valuable information.
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Posted By Adrian Watson
Not necessarily, a survey is required if the building is likely to contain asbestos. A 1980's porta-cabin is not likely to contain asbestos; your type 2 survey has confirmed this fact. You therefore do not have to do a type 3 survey.
Regards
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Posted By Rodger Alan Ker
Mr. Watson, you are wrong, a type 2 survey is not sufficient for a demolition/construction project.
Please read Control of Asbestos Regulations 2006, Regulation 4.
Paragraph 51 of ACOP L143 states:
"The employer should not simply rely on information provided by other dutyholders unless the dutyholder can produce reasonable evidence to confirm the validity of the information such as survey details (eg a type 3 survey is required for major refurbishment and removal work covered by the CDM Regulations."
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Posted By Ron Hunter
Agreed. Such sweeping assumptions are entirely contrary to presumptive approach required by CAR.
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Posted By Haggis JM
"a type 3 survey is required for major refurbishment and removal work"
...but does a single portacabin count as "major refurbishment and removal work"?
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Posted By Rodger Alan Ker
Haggis
The original post stated:
"About to take down and dispose of a prefabricated portacabin type building which is around 20 years old and falling apart. A permanent building is to replace it and falls under CDM. a survey for asbestos done 4 years ago reported no asbestos present and no changes have be made since".
Part of a CDM project, therefore a type 3 survey is required.
I accept that it is appears to represent a small part of the project, but you cannot have met your "Regulation 4 obligations" without one.
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Posted By MW
RP,
The consensus of opinion is correct. A type 3 is required.
A couple of years ago, I went to survey a portacabin of similar description and was told on arrival that there was no asbestos and we were wasting our time...
The portacabin was 20 metres long and 8 metres wide with numerous partitions...
Every wall was asbestos cement and we found AIB behind every wall mounted electric heater!
Hope this helps.
Mark
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Posted By gerryd21
Even though it is only a `port-a-cabin`, the fact that it is being entirely demolished means a type 3 (or refurbishment/ demolition) survey is required regardless of the size of the building. This type of survey should not cost much if it is a convetional small temporary building, e.g. cabin.
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Posted By RP
Thanks again for this information, i have also checked through several documents and a Type 3 survey is now planned.
I note the comment on cement asbestos used behind electrical fittings. Looks like the wall heater has a painted panel behind it and could be of such material.
The survey will be interesting and I will post back the outcome for future reference to all...
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Posted By GeoffB4
Quote:Not necessarily, a survey is required if the building is likely to contain asbestos. A 1980's porta-cabin is not likely to contain asbestos; your type 2 survey has confirmed this fact. You therefore do not have to do a type 3 survey.
A bit of worrying advice?
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Posted By Adrian Watson
An employer shall not undertake work in demolition, maintenance, or any other
work which exposes or is liable to expose his employees to asbestos in respect of
any premises unless either -
Dear All, Reg 5 states:
(a) he has carried out a suitable and sufficient assessment as to whether
asbestos, what type of asbestos, contained in what material and in what condition is present or is liable to be present in those premises; or
(b) if there is doubt as to whether asbestos is present in those premises he -
(i) assumes that asbestos is present, and that it is not chrysotile alone,and
(ii) observes the applicable provisions of these Regulations.
The point in this case is whether the assessment is suitable and sufficient; That depends on the fact. In this case it is a simple construction which has been surveyed. Furthermore Para 51 is not part of the acop it is guidance.
Regards
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Posted By Kenneth Patrick
What was the point in doing the survey four years ago?
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Posted By Dave Wilson
Lets not get to hung up on this.
Point 1 These types of temporary structures have had asbestos in them - Fact. (unless you have the manufactures data)so ACM could be 'embedded in the structure!
Point 2 - would a 4 year old type 2 have found these?
YES - then NFA required
NO - Then a type 3 survey needs to be undertaken.
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