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Asbestos Cement Roofing Sheet - NNLW or not?
Rank: Forum user
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I am looking for expert advice from those with experience of working with asbestos cement roofing sheets.
The scenario is - we have an AC roof onsite which is being over-sheeted with a metal roof followiing damage late last year. The AC roof is fully intact with no damage, it was the previous metal sheet which was blown off by the wind.
Problem - the metal sheets are to be fixed to metal brackets which are in turn fixed to the purlins on the roof structure. In order to do this the roofers must drill through the AC sheeting in order to attached their metal brackets to the roof purlins. They have the experience of working on similar roofs for other local (well known) companies, so dont doubt their experienced.
The HSE website provides some advice on working with AC, defining it as non-licensed work (which is not notifiable) but based on "short, non-continuous maintenance work on asbestos cement (AC)". However, I am struggling with this meaning in relation to the work mentioned above.
The roofers believe this is non-licensed given that although they will have to drill many holes, the drilling is very short duration (3-5seconds per hole) and is interspersed with other preparation work before fixing sheets in place, so they regard it as non-continuous.
To further complicate matters - the provide more advice by means of a flow chart:
http://www.hse.gov.uk/pubns/guidance/a0.pdf
The roofers will be using the approved HSE AE9 document i.e. using paste to capture fibres. We will also be carrying out static air monitoring for the first 2-3 days in the warehouse just to prove to ourselves there are no issues.
Can anyone shed some light on this?
Thanks
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Rank: Super forum user
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The issue here is the drilling element, PM me if you wish to discuss.
Regards
FS.
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Rank: Forum user
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I meant to add - the building is an empty warehouse with no (immediate) risks to persons below.
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Rank: Super forum user
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Typicall poor HSE decision chart. First key question is the material is the roof non friable if it is then it is likely not to be notifiable NLAW. However the decision chart also seems to forget the sporadic element which is also key and causes problems as here. It might be 2 min per hole at 1000+ across the whole roof. Also the definitions include removing intact so drilling would seem to deny non breaking as fibres may be released. Note that whether or not other people may be at risk is irrelevant as I read the regulations. The material itself and the duration are the required parameters. As you have also said these operatives are regularly undertaking this task. So what is the problem of notifying the work??
Bob
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Rank: Forum user
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Is it possible that they do not want to notify as they do not want to have medicals etc that go along with carrying out NNLW ?
I agree with the last post, it appears that these operatives are fully aware of what is required so why not notify
Regards
PaulR
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Rank: Super forum user
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Very much depends on the method to be employed to prevent fibre release during this significant amount of drilling. If the contractor isn't proposing special measures then, although he may have experience, his competence is questionable. Regs 6 & 7 0f CAR 2012 refer.
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Rank: Forum user
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I May be missing the point here, but if the roofing sheets are in 1 piece as you described, why are you over sheeting?
Simply bond the fibres with paste as you described, remove the anchors to the steel and fit the new roof direct to the existing purlings, thereby removing the issue of drilling and dust as well as preventing yourself further trouble in later years when the roof may need repairs.
Maybe they are really trying to reduce the final waste disposal costs, these costs i cannot imagine will ever reduce in time.
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Rank: Forum user
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up north wrote:I May be missing the point here, but if the roofing sheets are in 1 piece as you described, why are you over sheeting?
Simply bond the fibres with paste as you described, remove the anchors to the steel and fit the new roof direct to the existing purlings, thereby removing the issue of drilling and dust as well as preventing yourself further trouble in later years when the roof may need repairs.
Maybe they are really trying to reduce the final waste disposal costs, these costs i cannot imagine will ever reduce in time.
The roof is in excess of 8000 square metres, with the damaged section amounting to approx. 1/3rd of this. The MD does not want to stump up the extra cash to dispose of this waste, which would run into a considerable sum of money given the number of sheets.
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Rank: Forum user
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ron hunter wrote:Very much depends on the method to be employed to prevent fibre release during this significant amount of drilling. If the contractor isn't proposing special measures then, although he may have experience, his competence is questionable. Regs 6 & 7 0f CAR 2012 refer.
Ron, as I mentioned, the contractor is employing the methods indicated in HSE Asbestos Essentials 9 - which is to use glue or paste to capture fibres.
Or, are their other control measures which I should be looking at?
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Rank: Super forum user
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B.Bruce- my apologies, I didn't read your post through properly before rattling off my response.
I would suggest, with reference to:
http://www.hse.gov.uk/as...le-non-licensed-work.htm
that the work is not notifiable under CAR2012. Your intention to conduct real-time monitoring of the warehouse volume is a useful added control - provided you have effective on-site analysis. My own experience of monitoring results from this type of work is fibre counts routinely below detectable limits.
I think my focus (beyond obvious WAH and fragile surface issues) would be on the records of face-fit testing of the operatives and on-task compliance with PPE and RPE requirements. Paste capture and clean-up isn't rocket science by any manner of means. Your contractor should be able to evidence specific training in accordance with Reg10 ACoP requirements.
Sorry for unnecessary confusion.
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Rank: Forum user
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Hi Ron,
Thanks for the message. No problem at all - appreciate your comments.
I spoke to contractor this morning and they have confirmed they have face-fit testing certs and that all Operators on the project have Asbestos Awareness trianing.
They have indicated this morning that they may well notify the HSE given the number of holes having to be drilled. I see no harm in it.
Initially I posted to get other peoples opinions on CAR2012 - and the responses have been most helpful.
Thanks again to all who have responded.
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Rank: Super forum user
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Your use of the phrase asbestos AWARENESS Training worries me -this is the basic level and is not intended for those actually doing work on the ACM.
Bob
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Rank: Super forum user
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Good spot Bob - the contractor in this instance should have Category 2 training.
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Rank: Forum user
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Hi Bob, yes good spot indeed.
I meant Cat 2 training, my mistake - was rushing out to a meeting and quickly typed my reply before I left. Obviously didnt engage brain at the point..........
Thanks
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Asbestos Cement Roofing Sheet - NNLW or not?
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