Rank: New forum user
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Question How much non licenced work does an employee need to do before a medical is required:
HSE answer from website: HSE would expect employers to take a commonsense approach, so if the work was genuinely a one-off, or a very rare occurrence, then it would be disproportionate to require a medical. However, the worker would still need to take all the appropriate precautions[27] and the employer should also be able to provide some evidence that it was a one-off.
In my Company our Engineers have to change Heating Elements in ovens that are Asbestos Lined I have carried out Risk Assessments and Introduced Health and Safety Work Instructions in line with the HSE Guideline Documents.All Operators have recieved Asbestos Risk Training have been Face Fit Tested The Heating Elements probably need changeing once every 5 years
The question to my colleagues is what is very rare occurrence ?
Please let me have your feedback on this question
Regards
John
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Rank: Super forum user
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Is your risk assessment validated by typical on-task fibre counts? Is the ACM disturbed during the task? Medical Surveillance is only relevant to licensed work and the new notifiable non-licensed category. Non-licensed work is.........just that. To apply medical intervention after a one-off would be of no benefit at all.
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Rank: New forum user
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Ron Many thanks for replying In response the risk assessment was validated by air monitoring by assessing fibre counts which were under the specified limit which confirmed no disturbance of the ACM when the ovens are opened When the elements are changed there is a very slight risk that fibres could become airborne
It is possible that the task could be more frequent if element failures increased. this could not then be categorised as one off or a very rare occurrence. What are your thoughts on this
Regards
John
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Rank: Super forum user
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Non Licensed work is just that and is ultimately determined via the type of material and the low intensity and sporadic definition. If your work falls into this then there is no need for ANY medical supervision of any type. At least you are not doing what many contractors and others are doing which is to train a small group of people and send them to undertake ACM work on a fairly regular basis. Exposure to any individual is a factor of level of fibre and the length of exposure. It is the cumulative length of exposure over a period of time that concerns me. The data for low level exposure is extremely limited hence the need to ensure that such work is restricted to small numbers of employees.
As an aside I would suggest that the risk of ibre release is greater to the oven lining when they are in service. Production needs can reduce care taken.
Bob
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Rank: Super forum user
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Sorry I should have said that the need is to limit the Exposure when using small groups of individuals - In your case this small group does not have what I would consider as regular exposure to low levels of fibre
Bob
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Rank: New forum user
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Bob , many thanks for your response
The work will be limited to a small Team of Electricians , during the production the ovens are totally encased and Operators are not allowed to access the inside of the oven . What I forgot to mention as a further control I have introduced background air monitoring in the area as part of my our Operational Control Plan. The time duration for changeing an element is less than 1 hour
Regards
John
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Rank: Super forum user
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Do bear in mind that "sporadic and low intensity" relates to exposure to asbestos fibres, and not to the frequency of the task.
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Rank: New forum user
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Ron
Many thanks
I think that this is a critical point you make and it is important that you have data to back up that exposure to asbestos is "sporadic and low intensity"
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Rank: Super forum user
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Ron
Thereby hangs the real problem in managing non licensed work. It is a bad term with a poor definition in my view as exposure is a combination of level of fibre and length of time exposed. It is thus easy to subvert the intention of the parent directive. The original intention was that workers cold ndertake some ACM work when they encountered it as part of their normal work activity, provided that the fibre level was sufficiently low and it was not something that was being done on a frequent basis. The HSE definition however has permitted a situation wherebysmall groups of employees are trained in ACM work and deliberately sent from place to place to undertake such work. They thus have become full time, or near full time, engaged on non licenced ACM work alone.
This is not the case for the OP but one needs to remeber some caveats to such work.
Bob
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Rank: Super forum user
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In the context of the Regulations Bob, I don't see a problem with some non-licensed work being more or less continuous. We've closely monitored all the minor (task manual) non-AIB tasks we undertake (and we repeat that monitoring at regular intervals) and the results come back as below detectable limits - no where near the 10 minute reference 0.6f/ml or 4 hour 0.1 f/ml. Paragraphs 32-34 of L143 ACoP refer. Not to be confused with the more friable materials discussed at para 40 'short non-continuous maintenance activities'. We have had people (who I think should no better) tell us the non-licensed work should be time-limited based on AIB task confusion. As you say above Bob, the OP needs to know the material. If AIB, then para 41 of the ACoP (time constraints) will apply. I don't think the info on the website is clear enough. Then again, the ACoP isn't always an easy read either. Earlier ACoPs were even more vague on this.
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