Rank: Forum user
|
We have a number of mobile service engineers working in both commercial and domestic premises whose work does not involve disturbing the fabric of the building. All have received Asbestos Awareness Training compiled and delivered internally by competent trainers - I don't want to debate trainer competence.
My question is how far should we go to establish the "Asbestos status" of the buildings in which we work - bearing in mind literally 1000's of buildings are involved. At present we feel the training gives them sufficient knowledge to spot what they think might be Asbestos and where necessary stop work and seek advice.
Any views ?
|
|
|
|
Rank: Super forum user
|
Hi Phil
Commercial (non domestic) premises should not be a problem. If you are happy with the training provided and the ability of your emplyees then I do not see any further cause for concern.
|
|
|
|
Rank: Super forum user
|
In the commercial (non-domestic) properties there is an onus on the duty holder to provide Asbestos Register information. This should include known or presumed incidence of ACMs in items of plant and equipment. There will be an onus on your engineers to scrutinise this information, make appropriate judgement and comply with local arrangements and instructions made known to them.
Problems arise of course when the duty holder at commercial premises has not complied with CAR.
Remember that CAR issues extend beyond 'building fabric', and include boilers, switchgear, storage heaters etc. You should be building-up information about the plant you work on through contact with suppliers and manufacturers and passing this on to your engineers. That sort of info would be equally applicable in domestic premises.
There will be an increased likelihood of the on-site ARR at commercial premises recording ACMs as being "presumed". Your people will have to know with greater certainty?
There's a wealth of information out there on this, from ARCA and others.
|
|
|
|
Rank: Forum user
|
Phil
The training that you have given is great; I don't want to devalue it in any way. But (there had to be a but!) I think it's actually the second line of defence. Their first line is to ask the person in control of the premises. The onus, as Ron points out above, is on them to know. Not guess or surmise, but know what is in their premises. Your engineers' training only cuts in after they have received the blank looks, shrugged shoulders etc.
In my view, your engineers have a vital role to play in mithering the laggards to do something.
|
|
|
|
Rank: Super forum user
|
Jim / Ron we should point out to Phil that it is the employers duty to ensure the HS of the Engineers.
ie the Employer of the engineers are responsible for providing safe systems of work.
I accept the company may have suitable policies, procedures and training that permits the engineers to look for evidence of asbestos from the registers
Steve
|
|
|
|
Rank: Forum user
|
Ron/Jim,
It is not the duty of anybody to produce an asbestos register. It is the duty of the person in control of the premises to manage asbestos, including informing persons of the product types and locations of the materials.
It is the duty of the employer to ensure the safety of persons. To that end persons should be trained to identify non-asbestos (note non-asbestos) materials and instruct workers that if it cannot be identified as being a non-asbestos material it must be treated as being asbestos and that appropriate precautions must be followed. They should also be taught always to ask "is there any known asbestos in this building, if so can you show me?" and the procedures to be followed if asbestos is discovered, disturbed or damaged.
Regards
|
|
|
|
Rank: Forum user
|
As others have pointed out the duty holder (whoever that may be) must inform the anyone using that building of the presence of ACMs. That does not devolve any employers duty under CAR or other general safety. If your engineers have a good base knowledge and level of training on the subject, thats' great, but its not their (or your) duty to 'establish the asbestos status' of a given building. Unless you are the duty holder. Ron makes a very good point about looking for ACMs in places other than the building fabric. It lurks in places where you wouldn't expect.
|
|
|
|
Rank: Super forum user
|
Akwatson is of course spot-on from a strict legal perspective (Regs 4 & 5 of CAR as I recall?). I however favour and pomote a more pragmatic and practical approach for all but the simplest and smallest of properties, and that in turn involves the creation and maintenance of an Asbestos Register based on (at least) a Management Survey (which should be updated as other survey, sampling and analysis and removal/remedial works are undertaken).
There are several weaknesses here of course, including the non-compliant duty holder (occupier/employer/landlord etc.) and the often limited approach and baseline knowledge of asbestos surveyors about asbestos materials in fixed plant and equipment.
Thus my suggestion that the employer of the Service Engineers has to do a bit more research and provide his engineers with more info about the ACMs historically used in older boilers, cabinets, heaters etc.
If you're lucky, the Site ARR may state 'presumed'. Often it won't say anything - some Surveys (and therefore Registers) do tend to focus somewhat on building fabric issues.
I admit to being puzzled and more than a little concerned by this concept of being trained to recognise that which is "non-asbestos". In its heyday, manufacturers of ACMs made every effort to "mimic" everday products - even wood. ACMs are also often 'hidden' just below a recent plaster-skim.
I say again - Registers built from sample and analysis data (surveys) ensure compliance and keep people safe. Anything else is guess work.
|
|
|
|
Rank: Forum user
|
ron hunter wrote:Registers built from sample and analysis data (surveys) ensure compliance and keep people safe. Anything else is guess work.
Ron,
Registers unfortunately do not ensure compliance and definately do not keep people safe! By knowing what materials they can work with safely without special precautions and by treating all other materials as "potentially unsafe" and taking appropriate precautions then the worker is defaulting to a safe working practice.
Regards Adrian
|
|
|
|
Rank: Super forum user
|
Yes Adrian, my point being that avoiding all other materials as "potentially unsafe" won't get you very far beyond working on bricks, brieze blocks, ceramics and glass - and that's not an entirely practical approach for the building and maintenance trades.
I would also readily concede that Registers out there often leave a lot to be desired. A key point in training is to recognise these faults, such as confusion of room number/ident systems, missing rooms, areas of silence and 'presumed' ACMs etc.
I fear we are moving beyond the initial poster's query here though.
|
|
|
|
Rank: Super forum user
|
akwatson wrote:Ron/Jim,
It is not the duty of anybody to produce an asbestos register. It is the duty of the person in control of the premises to manage asbestos, including informing persons of the product types and locations of the materials.
It is the duty of the employer to ensure the safety of persons. To that end persons should be trained to identify non-asbestos (note non-asbestos) materials and instruct workers that if it cannot be identified as being a non-asbestos material it must be treated as being asbestos and that appropriate precautions must be followed. They should also be taught always to ask "is there any known asbestos in this building, if so can you show me?" and the procedures to be followed if asbestos is discovered, disturbed or damaged.
Regards
Registers unfortunately do not ensure compliance and definately do not keep people safe! By knowing what materials they can work with safely without special precautions and by treating all other materials as "potentially unsafe" and taking appropriate precautions then the worker is defaulting to a safe working practice.
Mr Watson, what an excellent way with words you have. Asbestos is a subject I shy away from, not being insured to even discuss it really, but I now have a clearer knowledge of some of the requirements thanks to your comments.
If you agree I may use the above in future discussions re the requirement for a Register and asbestos awareness?
|
|
|
|
Rank: Super forum user
|
The problem for Service Engineers is that they are generally called out for emergency repairs rather than true servicing!!!!!!!!!!!!!!!!
The premise occupier certainly has the major role and the asbestos management plan has to be the first port of call together with its general register of known ACMs. Treat the latter with caution though - it can never be totally complete.
From your point of view some tasks could indicate penetration potential through non-surveyed structure and yo may be able to filter these out at the time of order with suitably structured systems.
Bob
|
|
|
|
Rank: Forum user
|
Many thanks to all those who replied - interesting to hear differing views.
The problem of course is that not all customers know if they have any asbestos in their building or not - we often get blank looks. (Yes - its wrong but's thats how it is). In this case and similarly in domestic premises we have no option but rely on training our men to potential spot ACMs'.
At the other end of the scale where a customer does know - they invariably have a register and this can be a very meaty document.
Is the Duty Holder discharging his duty to inform by expecting a Service Engineer to review the register - for example for a large hospital?
Opinions welcome
|
|
|
|
Rank: Forum user
|
philb
To me 'obligation to inform' means that the maintenance engineers must be directly informed by the Duty Holder – owner or occupier. In a hospital the appropriate facilities department should identify the location of any asbestos containing materials and its condition to the engineer. This should relate to the area(s) they will be working in. It should not be for the engineer to wade through documents to get to the information they need.
A quick look at some Local Authority policies confirms that they provide the relevant information to those who need it and do not just give them access to a register.
Cheers.
Nigel
|
|
|
|
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.