Hello David
As this is none notifiable Asbestos work you may use the site washing facility as long as it is barried off and for your use alone the area can be cleaned down at the end of every working day using damp rags and then visually at the end of the job the area does not normally require an air clearance as for the waste water if the waste water is only contaminated with trace amounts of asbestos this may be discharged into the sewage system a very good referance document is HSG 210 asbestos essentials for none licesable work em8 personnel decontamination and em9 disposal of Asbestos waste also cat 2 training for none licesable work would be very good training if you have not recieved this already and as a minimum training legal requirment for this nature of work if you require any training please get in touch as i would be able to point you in the direction of a very good training provider hope this helps you out ......

This one worries me as I do find it hard to see the removal of a roof as low intensity and sporadic plus the other requirements of reg 3 CAR.

I think this one may well be licensable with a recalcitrant client trying to save money.

There are numerous decon units with water storage and you should be using one of these if the work is truly non-licensable - they are available to hire.

Bob

On what basis would the careful removal of AC sheets ever be considered to be licensed work?
David, wearing disposable, hooded coveralls and careful bagging of these along with used tack-rags on every occassion you leave the work are should be adequate. Why do you want to use water (beyond the odd bucket or two)?

forgot to say duration of the roof strip is approx 1 day (50m2)
and thanks all for your advice

David

Bob,
With equal respect, and happy to discuss the point:
The 4 conditions attached to Regulation 3(2)(c) are not collective (there is no "and" between (i), (ii),(iii) or (iv)). L143 p14 refers.
Removal of AC sheets, outside. Exposure can only really be sporadic and low intensity, irrespective of whether I do the task for an hour or for a fortnight. There are enough analytical measurements and commissioned reports to back that up.
I don't believe the letter or the spirit of the Regs is breached here.
Remember too that "sporadic" refers to fibre exposure, not the time taken on-task.
See also: http://www.hse.gov.uk/asbestos/regulations.htm

Hi,

Just a quick question if the Main Contractor / Client is worried about one or two buckets of water contaminated with asbestos fibres from decontaminating, what are they saying about the wet strip/water suppression / mist spray you are applying whilst stripping the ACM roof sheets. Will you be setting out a bund system or have allowed to a shadow vacuum technique as you remove, how will the bag be disposed of as there is no full enclosure to open the vacuum, the questions are endless.
A simple answer to your first question is to bag the water in asbestos waste sacks, put some MMMF or sand into the bag then pour the water on top , the MMMF and sand will filter the water and adsorb, do not over fill the bags as this would become a manual handling issue. Seal the bags with cloth tape and dispose of with the roof sheets.
1. Roll out 1000 gauge polythene under the area to be removed.
2. Polythene the scissor lift
3. Create a small decontamination area containing 1 H Type Vacuum, 2 buckets of water, cloths, baby wipes ,a few asbestos waste bags and a few clean pairs of overalls
4. Wearing FFP3 masks as per your face fits, Type 5/6 Overalls, cleanable footwear, gloves, goggles, hi-viz(dispose of after), hard hats etc etc
5. Spray the underside of the exposed sheets with surfactant then spray the top to dampen any loose fibres.
6. Crop the sheets whole using bolt croppers
7. Lower between two operatives
8. Wrap in 1000 gauge polythene
9. Label with correct tipping information (stick a asbestos waste sack inside the polythene wrap)
10. Transport to skip
11. Repeat until roof sheets removed vacuuming roof joists etc as works progress.
12. Mop excess water up from polythene with rags and bag as contaminated waste
13. Roll polythene and bag as contaminated waste
14. Decontaminate with your Type H Vacuum, then wipe and wash mask, footwear etc etc
15. Dispose of mask and suit at washing station in bag also put cloths and baby wipes in waste bag
16. Change into new overalls
17. Dispose of water as above
18. Change into home clothes
19. Have tea in welfare facilities

Carter33769 has it spot on. A simple, clear and concise way of doing the work. Removal of AC sheets is not a notifiable task. Careful removal from a roof is not a notifiable task. The job might be notified (and require a LARC) if something out of the norm was planned and the control limit was going to breached. It appears this job is not out of the norm.

Dear All,

Regulation 3(2) states:

Subject to paragraph (3), regulations 8 (licensing), 9 (notification of work with asbestos), 15(1)(arrangements to deal with accidents, incidents and emergencies), 18(1)(a)(asbestos areas) and 22 (health records and medical surveillance) shall not apply where—

(a)the exposure of employees to asbestos is sporadic and of low intensity;

(b)it is clear from the risk assessment that the exposure of any employee to asbestos will not exceed the control limit; and

(c)the work involves—

(i)short, non-continuous maintenance activities,
(ii)removal of materials in which the asbestos fibres are firmly linked in a matrix,
(iii)encapsulation or sealing of asbestos-containing materials which are in good condition, or
(iv)air monitoring and control, and the collection and analysis of samples to ascertain whether a specific material contains asbestos.

I agree with Ron, paragraphs 2 (a), (b) and (c) are conjunctive whilst the subparagraphs of paragraph(3) are in the alternative so the exposure to asbestos must be sporadic of low instensity and not exceed any control limit; and the work must be short, non-continuous maintenance activities or removal of bonded ACM or encapsulated of ACM in good condition or air sampling.

Therefore this work is not licensable as the work is not liable to exceed the control limit and exposures to asbestos is liable to be sporadic and low intensity and the work involves removal of materials in which the asbestos fibres are firmly linked in a matrix.

Regards Adrian