If it was a good survey then, it should still be fit for purpose. Otherwise there's nothing much between an MDHS100 Type 2 then and an HSG wotsit Management Survey now.
There were some real quality issues some years back when Reg4 was new and an over-stretched market tried to meet client demand. Most common problem we had was with areas of "silence" or "access not available" (when in most cases access was readily available).
Common fault in years past was the external Surveyor not being accompanied by someone who knew the premises.

Ray

I agree with the comments of the other posters. I think it all boils down to how thorough your Type 2 survey was in the first place and how competent the asbestos surveyors were who carried out the work. The new survey guide, which details the requirements for the Management and Refurbishment/Demolition surveys appears to have been issued to address shortcomings in the standards of many Type 2 surveys and the quality of information that was being presented to clients under the old MDHS 100 guidance. If the information derived from Type 2 surveys is accurate, contains a minimum of exclusion clauses and can be relied on with some degree of confidence then I cannot see the need to 'upgrade'.

Danny

I don’t disagree as such with most of what has been said, however; that a type 2 survey would be ‘..totally inadequate..’ for the purposes of demolition or ‘major’ refurbishment, goes without saying. This was never the intention of the type 2 survey. Under MDHS100, both type 1 (presumptive) or type 2 (sampling) surveys were management surveys and neither was intended to be full access or fully intrusive surveys; that would have been a type 3 survey.

The adequacy of ‘old’ type 2 surveys and for that matter surveys conducted under 264 is dependent on a number of factors, some of which are in the gift of the client rather than the surveyor. The results of a type 2 survey may still be adequate for the purposes of refurbishment, if the survey actually had access to the area that is being refurbished.

I think it would be incorrect/unfair to suggest that a type 2 survey is inherently ‘unreliable’ or necessarily any less reliable than a management survey under 264.

While I note the HSE’s ‘take’ on caveats in 264 on caveats, of course some caveats are perfectly reasonable and understandable. Whether we like it or not, they are an almost inevitable feature of our work.

There is a re-occurring issue with asbestos surveys, many of which are not sufficient and suitable in the first place. In my experience very few duty holders actually bother to re-inspect at all, never mind 3/6/12 month intervals, which of course does question the validity of the surveys if they are several years old. Despite the requirement pursuant to CDM regs for pre-construction information and Reg 4 of CAR, many clients are not fulfilling their duty which then escalates down the contractor chain.

I believe the problem stems from the fact that CDM Regs and to a lesser extent CAR, are not properly enforced, making a nonsense out of the whole process. Of course, PCs often allow clients to get away with this because industry is client driven. I find it bizarre, if that is the right word, how we practitioners discuss nebulous issues on these forums to the ength degree; yet the reality is basic h&s requirements are often ignored by duty holders - perhaps we are far too dedicated?

The simple fact of the regulations are that you either have the Management survey (type2) in place or if the project involves refurbishment or demolition then you must have the Demo/Refurb survey carried out as it is an invasive survey. Do not accept the survey if it contains caveats at all. HSE inspectors do not appreciate any survey which contains caveats. It also means that a further survey of the inaccessible areas is required prior to works commencing.

Gerry D

I wouldn't necessarily agree with your sweeping assertion that ‘survey reports shouldn't get to being a few years old’. If you have had a thorough survey carried out, providing there has been no significant changes in terms of occupancy or building usage, ACM condition has been routinely monitored and remains unchanged, etc., then surely the information derived from that survey remains valid? Why pay for another survey to tell you what you already know? If anything, surely it will be the asbestos register rather than the survey report that gets ‘tweaked’ by regular updates?

Additionally, although the new guidance goes some way towards improving the standards of surveys and of the information presented to clients, there is still no guarantee that a management survey carried out under HSG264 will not contain omissions and mistakes. The quality of information will largely depend on the competence and experience of the surveyors and the stringency of quality control standards applied by the organisation involved.

Danny

Ron

Accepted. However, having been recently approached by a UKAS accredited inspection body with the suggestion that I convince my client that surveys should ideally be re-done to bring them up to the standards advocated in the Survey Guide, I suspect that some may look on the new Survey Guide as another opportunity to make a killing. I know there were a lot of bad surveys carried out under the MDHS 100 guise, but I'm certainly not about to ask my client for another pot load of money to redo 300-odd Type 2 surveys which, with some exceptions, have proved to be perfectly satisfactory and fit for purpose in the first place.

Gerry

If there has been any misunderstanding on my part then I apologise. Nothing personal intended.

Danny

Well now, in the first instance the HSE need to be more proactive, perhaps actively encouraging the reporting of non-compliance with regulations via a confidential reporting service. Hopefully this would lead to investigating and enforcement - without which there is no incentive for duty holders to comply. There should no be excuse for large organisations with the resources to manage projects not to comply with legislation.

I am happy to concede that I may be missing the point, but…

Both type 1 and 2 surveys under MDHS 100 and a Management survey under 264 are essentially the same thing. That a type 2 survey may be a few years old doesn’t necessarily make that survey ‘invalid’ or necessarily any less useful than when it was first completed. That is dependant on the circumstances. If that survey concluded that an ACM was present, this should form part of the register and the subsequent management plan, a further formal survey under 264 may not be necessary, or at least, not for many years to come. You should review the management plan periodically but that doesn’t necessarily mean that you need to carry out another survey. I am therefore not entirely convinced that an old survey is necessarily an indicator that the management of ACMs has fallen below the standards of 264.

Interestingly I took and still take a slightly different stance to the recommendation of the HSE to ‘leave and manage’ ACMs. While this might in many cases be the most practical and/or cost effective way to manage an ACM, in some cases it might well not be in the longer term. It is easy to fall into the trap of assuming that the ongoing management of all ‘in situ’ ACMs is necessarily easy and/or cost effective and that it will remain effective or robust over an extended period of time.

Following our management survey we took the decision to remove some of our ACMs rather than spend the next ‘x’ years managing it. In the grand scheme we concluded that this was likely to be more cost effective than the ongoing management.

I also take Danny's point. Although as far as I am aware, we haven't been approached to 'redo' our Type 2 survey because it NEEDS to be a new 264 survey, I would guess that this kind of approach might happen. Many of us have 'been there' with the glazing, BSEN3, first aid kits etc etc.