Rank: Super forum user 
|
|
|
|
|
|
|
Rank: Super forum user
|
I think this link should be sent to the HSE help desk. I phoned up this morning to enquire where the information was on their web site to no avail - I asked if I was to carry out any work work on unlicensed materials after the 6 April would I be breaking the new regulations - again I drew a blank
|
|
|
|
|
|
Rank: Super forum user 
|
Anyone got a link to detail of "particulars approved by the Executive" for a health record requirements?
There are a great number of new employers captured by NNLW category and many additional employees now captured by Reg 22. Will it be necessary to maintain records of involvement (presumably quantified in terms of time) of individual employees for each & every instance of notified works?
On the subject of NNLW, will it be permissible to notify a "blanket" of proposed works over a 12 month period?
|
|
|
|
|
|
Rank: Forum user
|
The HSE have been about as helpful regarding the changes as a sore toe! From what i can gather the new catagory; Notifiable Non Licenced Work (NNLW) will require any operative undertaking such work to recieve a medical check every 3 years. These checks have a 3 year gracing period on these being carried out, these must be kept on record for 40 years. Employers to notify HSE of any works due to be undertaken falling under NNLW. Finally records to be made of any such work and including the names of those carrying out the works. I found this analysis quite concise and helpful;
http://www.keltbray.com/...20Regulations%202012.pdf
|
|
|
|
|
|
Rank: Super forum user
|
Looks to me like somebody has broken the publication embargo judging from the web address. It will make life very difficult for this organisation to be a close consultee in future.
Bob
|
|
|
|
|
|
Rank: Super forum user
|
I think 3.2(c)i is interesting as it refers clearly to maintenance work of short duration and non-continuous also. Given the ordering and the intervenng "ors" there could be scope for this to be regarded as a hurdle that all work must at least. The removal of roofs and gttering etc seem to be clearly outside the exemption. Looks like the death knell of the contractor teams called in to do non licensed work.
|
|
|
|
|
|
Rank: Forum user
|
A blanket notification would not be permitted. I can't give any links for health record requirements but, to answer your other question Ron, it will be necessary to maintain health records for each individual employee with reference to every instance of notified works. This is what we do currently in terms of the existing categories (Non licensed and Licensed).
The lack of guidance from the enforcing authority is disappointing but no surprise. The reliance for info has been left with other organisations (as the link proves). So, the already tough task (probable understatement) of interpretation and compliance is just going to be magnified. The good guys will get it. The bad guys won't care anyway and just keep on doing what they are doing (or not, if you know what I mean).
|
|
|
|
|
|
Rank: Super forum user
|
Ok, so what's this about. Am I the only one who didn't know CAWR was changing? Thought we were supposed to be given advanced warning of new or updated Regs? There's no mention of this on the HSE website at all.
Does anyone know what the main differences are and when the ACOP will be published?
Thanks
|
|
|
|
|
|
Rank: Forum user
|
I attended a very useful update seminar on the changes recently. I have the slides on pdf, so am happy to share if you send me your address.
Basically there is another tier of work with ACM's Previously we had 'non licensed' and 'licensed work'. In between that we now have 'notifable non licensable work' (essentially boils down to filling in a form on the hse website before work at the moment). I understand the HSE is to update all the asbestos essential taks sheets in due couse.
|
|
|
|
|
|
Rank: Forum user
|
Clairel,
Try subscribing to the HSE e-Bulletin service. The plan to update the Regs has been known for a while as well as a CD being in circulation (CD 237). For your reference I have cut & pasted the latest e-Bulletin:
The Control of Asbestos Regulations 2012 [1] will come into force on 6 April 2012, updating previous asbestos regulations to take account of the European Commission’s view that the UK had not fully implemented the EU Directive on exposure to asbestos (Directive 2009/148/EC). In practice, the changes are fairly limited and mean that some types of non-licensed work with asbestos now have additional requirements, i.e. notification of work, medical surveillance and record keeping. All other requirements remain unchanged, e.g. relating to licensed work with asbestos, duty to manage, risk assessment, the asbestos control limit, control measures and training requirements. Further information will be available from 6 April on HSE’s Asbestos website - http://www.hse.gov.uk/asbestos/index.htm Hope that's been useful. John
|
|
|
|
|
|
Rank: Super forum user
|
Thanks for the info guys.
|
|
|
|
|
|
Rank: Super forum user
|
'In practice, the changes are fairly limited'.
Not sure I agree with that statement one bit
|
|
|
|
|
|
Rank: Super forum user
|
chris121 wrote:I attended a very useful update seminar on the changes recently. I have the slides on pdf,
Part of my worry here Chris (et al) is (as happened with CDM) various organisations presenting THEIR interpretation. The CD and consultation process about detail was clear as mud. These (no doubt well-meaning) messages gain a foothold whilst the HSE maintain the usual silence. Some authorative guidance please HSE!!!!
|
|
|
|
|
|
Rank: New forum user
|
Hi Chris would love a copy of the PDF if possible
|
|
|
|
|
|
Rank: Super forum user 
|
|
|
|
|
|
|
Rank: Super forum user
|
Clairel wrote:Ok, so what's this about. Am I the only one who didn't know CAWR was changing? Thought we were supposed to be given advanced warning of new or updated Regs?
I hope it doesn't seem pedantic but the CAWR merged into the CAR in 2006 when it became an amalgamation of previous regs.
|
|
|
|
|
|
Rank: Super forum user
|
Well, yes you are being pedantic frank - I think we all know the Regs I was referring to. But then I expect nothing less than to be picked up on such a thing. Think I'll always think of it as CAWR so I'm sure it won't be the last time I'm picked up on it either. Needless to say with clients my referencing is right.
|
|
|
|
|
|
Rank: Super forum user
|
Claire,
the latest HSE eBulletin (today) stated that further information on the new Regulations would be available from the HSE asbestos website from 6th April. However, as that is a public holiday I doubt if there will be anything to see. Even if there is, if it is anything like the Consultation Document or the new Regulations it will be incomprehensible.
|
|
|
|
|
|
Rank: Super forum user
|
Clairel,
I think you had then opportunity to be a bit more professional in your postings here but instead you've come across as ungrateful, unapologetic, even petulant. You should try harder to make a good example on this forum, populated as it is by non-professional people.
|
|
|
|
|
|
Rank: Super forum user
|
Clairel wrote:Well, yes you are being pedantic frank - I think we all know the Regs I was referring to. But then I expect nothing less than to be picked up on such a thing. Think I'll always think of it as CAWR so I'm sure it won't be the last time I'm picked up on it either. Needless to say with clients my referencing is right.
Apologies for upsetting you, Claire but at the end of the day, it is the CAR (2006) and not the CAWR. Two or three years ago, i wouldn't have known the first thing about ANY Asbestos Regs and i wasn't certain of your knowledge by your original post. There was a consultation period last year about the new regs and a lot of info on the HSE website at that time. Personally, i believe it would be an advantage to all if we use the current term for the regs to avoid any confusion.
Like i said, apologies if offended.
|
|
|
|
|
|
Rank: Super forum user
|
Redken
It is a new week and Month today so they have just gone up on legislation.gov.uk site
|
|
|
|
|
|
Rank: Super forum user
|
frankc wrote:Clairel wrote:Well, yes you are being pedantic frank - I think we all know the Regs I was referring to. But then I expect nothing less than to be picked up on such a thing. Think I'll always think of it as CAWR so I'm sure it won't be the last time I'm picked up on it either. Needless to say with clients my referencing is right.
Apologies for upsetting you, Claire but at the end of the day, it is the CAR (2006) and not the CAWR. Two or three years ago, i wouldn't have known the first thing about ANY Asbestos Regs and i wasn't certain of your knowledge by your original post. There was a consultation period last year about the new regs and a lot of info on the HSE website at that time. Personally, i believe it would be an advantage to all if we use the current term for the regs to avoid any confusion.
Like i said, apologies if offended.
Didn't say I was offended - and I wasn't - I just agreed that you were being pedantic but also that I expected nothing less than people to pick me up on using the outdated term.
Mind you, if I picked up everyone on every error they made on this website I'd never stop posting. Sometimes It's easier to read between the lines and just know what someone means. We all have out little lapses and quirks etc. Me.....I'm human!! ;-)
|
|
|
|
|
|
Rank: Super forum user
|
Claire
A lady admitting to Senior moments:-)
Yes we all have them but as an arch pedant I seem unable to forgive others as easily as I forgive myself:-)
I just people would recognise that there are regulations as that would be a start especially with such a serious situation concerning asbestos related deaths and disease. As for the at work bit it is a good place to start after all.
Bob
|
|
|
|
|
|
Rank: Forum user
|
We attended our group SHEQ meeting yesterday. We are being told that there is nothing the HSE interweb...yet. There is no publication of guidance...yet. Don't hold your breath, mind. The changes are not, in my opinion, limited. The new category will encapsulate (see what I did there) many organisations with no previous concept of notification, surveillance medicals, health records, etc. I see breaches. I see prosecutions. Yes, I am cynical...but realistic. The HSE have had to rush this through to comply with European Directive. Hence the lack of guidance. Tread carefully people.
|
|
|
|
|
|
Rank: Super forum user
|
In reality this will be a big burden on industry. We remove CAF joints quite regularly (very old chemical plants) and the requirement to notify on each occasion a joint is damaged is quite onerous. In practice we will send notification for all pipework to prevent any delay once the job has started. As for health surveillance I'm expecting that we cover this in our current monitoring but it will be a massive burden for those who don't. Have the regulations added anything positive, it doesn't appear so. As the HSE are quoted as expecting 30% compliance I don't think they do either. This is completely driven by those with most to gain - asbestos specialists - and expect the scary literature to start dropping on your doorstep from the same.
|
|
|
|
|
|
Rank: Forum user
|
Whilst I don't disagree with John Js comments I would say that our Company (LARC) have never and would never wish to be seen to drive this one. We are busy enough with Licensed work thanks. However, I have no doubt there are organisations out there jumping on the bandwagon as we speak...You only have to see the opinions expressed above relating the differing interpretations of the changes to understand that it is clear as mud. Shysters will no doubt attempt to capitalise on this with the scare tactics.
|
|
|
|
|
|
Rank: Super forum user
|
Gerry, there are plenty of reputable asbestos companies out there that will continue pretty much unchanged. The problem will be those that currently behave questionably I.e charging those with limited knowledge of the asbestos regs a fortune to remove asbestos bearing corrugated cement sheeting.
|
|
|
|
|
|
Rank: Super forum user
|
Johnj
I think the HSE might regard your approach as flawed. They want to be notified of intended works and not possible work. For me the changes come late and are necessary. I am actually concerned that the real harm caused by asbestos has been somewhat diminished in the view of many contractors and clients. I have long felt uncomfortable at the range of work that was exempted from real control by the sparodic and low intensity definition as it has developed.
I speak, as some will know, from the perspective of a student exposed to crocidolite during my 1st year at university. I am only now just about moving to the right hand side of the bell distribution curve. BUT I am not now, or potentially never will be, certain that nothing will develop. I see many contractor employees working with ACMs most days of their life with no health monitoring and records. All this because the HSE chose to define exempt work in such a broad manner.
Bob
|
|
|
|
|
|
Rank: Super forum user
|
It may be over cautious but for many jobs we will not know whether the joint contains asbestos or if it will come off in one piece.
Are we seriously expected to stop, take off all the protective gear, notify the HSE, wait to ensure the notification is accepted, get fresh gear and continue the job to completion?
Our procedures are robust enough that I am comfortable with the regulations as they stand.
Notifying the HSE will not reduce exposure and in this case I feel the HSE had sensible guidance that has been changed for the worse through no fault of their own.
|
|
|
|
|
|
Rank: Super forum user
|
Johnj
The problem is that you have stated that the gaskets may well not come off in one piece and thus you have moved from non licensed to licensed work by virtue of your own work assessment. You need to get some formal agreements in place with your local inspectorate on this matter. To say however that these changes are unnecessarily onerous is soemthing I would reject. Rather I would say, as did the European Court, that the HSE were unnecessarily LENIENT in their interpretations and people have been quick to use this laxity.
I have to ask however - If you change these gaskets so frequently then they should all be non asbestos by now - the ban on installation of ACMs is after all 12 years on. Given this regular changing then you will know precisely which gaskets are non ACM. Where then is the problem?
Bob
|
|
|
|
|
|
Rank: Super forum user
|
Non Licensed work as per the current definition, will only be considered as such if the material is “ non friable” and the work is “ without deteriation of ” materials (material intact no damage other than weathering) examples being a CAF joint / gasket that can be removed whole and intact, an asbestos sheet that can be removed whole and intact.
I work on a site with several chemical plants and miles of steam pipework. Some of the plants are in excess of 40 years old. We are also stripping out a lot of older pipework (pipework that would not normally be disturbed) so these regs will have a significant effect on us.
The guidance on non-licenced work and its controls were already there in HSE guidance. The change has added nothing but a layer of red tape and will not change the behaviours of those who already choose to ignore the guidance.
|
|
|
|
|
|
Rank: Super forum user
|
|
|
|
|
|
|
Rank: New forum user
|
I agree with Ron Hunter (above), guidance please.
It is fine to release a new regulation on all of us, but what about the guidance from the HSE? This regulation needs to be backed up with guidance (same with any new regulation introduced).
|
|
|
|
|
|
Rank: Super forum user
|
Is it just cynical me or have the HSE just opened the door to regarding all asbestos cement sheeting being seen as non licensable. See this chart identified by PH2
http://www.hse.gov.uk/as...stos-work-categories.pdf
Asbestos cement is simply listed without any descriptor such as firmly bound or non friable. I can now see this as a license to remove all without worry about condition and meeting the sporadic and low intensity criteria.
I also have problems with the difference between string and rope with regards to fibre release, why does string release fewer fibres even if it is in the same condition as rope? Charts like this can become a license to kill if we are not careful.
Bob
|
|
|
|
|
|
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.