The initial onus is on the Client to provide information about the presence, condition, etc., or absence of ACM's and if present to have an Asbestos Management Plan.
If you proceed with the pipe inspections ensure that you have selected the most appropriate RPE and protective clothing - not all RPE will afford a suitable degree of protection against the inhalation of asbestos. There are a number of safety related issues here and you would be well advised to refer to the HSE website page on asbestos management.

It sounds like someone has had a survey done...and that's all. The duty to manage is a legal requirement under reg 4 of CAR 2012. One assumes the Client has this duty therefore you should not proceed until you have in your possession a valid and accurate asbestos management plan (e.g. asbestos register) provided by whoever has the duty of care. You are right to be worried for your personnel in areas that have been deemed to be asbestos free given that there seems to be a problem anyway in the sharing of information from the Client end. I assume you obtained the 'low and medium risks' bit from the original survey? Why would you be given the original survey? That will not guide anyone safely on its' own, there needs to be a bona fide asbestos management plan that is developed from the survey. The 'low and medium risk' bit may be irrelevant because this will only relate to the material assessment carried out by the surveyor. There needs to be a priority assessment carried out that is combined with the material assessment using algorithmic scores to establish an overall risk to people. Priority assessment should always be done by someone with an intimate knowledge of the building/ area/ location where the ACMs have been detected in the original survey. Stop and ask. Thats' my advice.

Many thanks all, for your very helpful replies.

Unfortunately, the Client is not very communicative at the planning stage of this project, and for some reason our PM is very keen to start asap.

My advice to him was to wait for a Client response (or from his agent) with an Asbestos Management Plan (AMP) before we even consider sending someone in any of those tunnels. The company has tight procedures for confined spaces, emergency plans etc but the final versions will have to consider the info contained in the AMP.

Must admit that all the criticism on H&S not being pragmatic enough is making this job a little confusing..

Raz

Apart from CAR there is also an issue with the CDM Regs. Pre-construction information should be provided by the Client identifying the hazards associated with the project. This information should be provided at the tender stage. Information from previous assessments and surveys should include - for example, those carried out pursuant to Regulation 4 of the Control of Asbestos Regulations 2006. Asbestos surveys should provide information on the location of ACMs, the condition and the risks they pose during maintenance or refurbishment work. As per CDM ACoP below:

‘However, where there are gaps in this information, the Client should ensure these are filled by commissioning surveys or by making reasonable enquiries. It is not acceptable for clients to make general reference to hazards which might exist - for example that ‘…. there may be asbestos present in the building’. Clients should carry out the necessary surveys in advance and provide the necessary information to those who need it’.

In short, I recommend that you do not proceed with the work until the ACMs have been identified or you are satisfied no ACMs are present. The responsibility lies with the Client, perhaps they need to be reminded of their statutory duty?

Raz

You need to find out more about the Asbestos - low and medium risk are still fairly irrelevant terms -

there are quite a few products that could be involved and the risks that each of them create in this type of environment are different - eg long ducts may have fire compartments and have AIB fire check - the AIB may well be classified as medium risk but unless people have been drilling it and left debris it is unlikely to cause an issue to your work.

Conversely there could be pipe lagging in poor condition whereby your guys may knock it when working or tread on bits or just breathe in lots of fibres....

Contractually the client not only has to provide the information as other people have pointed out, but you are also in a good position to rattle their cage as they also don't have a leg to stand on with a claim back against you if you walk - bearing in mind that neither side normally wants the hassle you can normally manage to achieve a satisfactory compromise whereby they provide what you want as long as you are robust!!

have fun

kind regards

Bruce Sutherland

Regs 4(8) - 4(10) of CAR 2012 refer, frankc. Although not referred to as a "register" as such, the inference and meaning is I think the same. The Regulation refers to a "written" plan. I think it safe to say that an electronic version would be equally acceptable, as is this practice is accepted by HSE for general R/A in the same context.

please stop waffling - if you want to talk legislation then at least get it correct - the duty under CAR is to have a management plan not a register what is the point of quoting regs if you get them wrong?

I have advised the PM not to start any work until the Client is showing us a site clearance certificate.

The asbestos plan the Client has in place resumes to an asbestos survey and an invoice meant to prove that all the asbestos FOUND has been removed.

Until we see a site clearance certificate based on an air test we're not sending people into those tunnels.

Again, thank you all for your replies.

Ray-R: re your comment "Bob, am I correct in thinking a 'management plan' can be a method statement for low risk work" I personally would say no as a plan is not necessarily a method statement but I am sure that you or I could create one plan that could cover all


NB: I passed details to the party concerned re our communications

Reg 4 CAR gives the absolute duty to manage starting with identification eg; a survey appropriate to the use of the building, either a management survey or a refurb / Demo survey, the requirement is for a plan of proactive management of any and all ACM's discovered during the survey process and any decent survey will list all discovered ACM's as a site register
It's the Asbestos management plan that is required, the asbestos register is just a summary of the survey findings that is used to structure the AMP

It seems from the replies that the original poster has got a handle on the issue but the history of the area should play a big part of the current RA's, asbestos removal removal has a shady past and if all that is available is an invoice for previous works then the area should be presumed to remain contaminated to some degree
All the other issues aside face fits and suitable RPE, PPE. and possibly training for decontamination procedures could be required as well as a hygiene unit if the areas to be inspected are still deemed to be contaminated

Clients are still shamefully unaware of their duties within both CAR and CDM and in the current financial climate it's an up hill struggle trying to get areas either made or proven as safe work places for those required to enter or occupy them