Rank: Forum user 
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Could someone please clarify a few things for me, I have even spoken to the Environment Agency and ultimately they didn't appear to know the answer.
We have trained some of our guys to carry out non licenced asbestos removal to remove artex ceilings and thermoplastic floor tiles from domestic premises (Insurance work). Can we locate a secure enclosed skip at our site or other nominated site (this would be put in place by a licenced waste disposal company) for our removal guys to place the double bagged asbestos waste in until such time the skip is full and ready for removal to a licenced asbestos tip? If so do we need to do more than register as a mobile services operator and register any premises producing more thean 500kg?
We hold an upper tier waste carriers licence, we will do asbestos risk assessments, clearance certificates, consignment notes etc.
I am now under pressure to get this sorted and am getting nowhere so any informed advice will be totally appreciated.
Thanks
DNW
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Rank: Super forum user
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This is an old chestnut
My advise is to ensure that U have recorded all your conversations with the EA for possible future use -this is where emails are useful as against telephone calls and thereafter work as you propose
Technically [I am slightly out of date] but I would err to caution and register as a mobile services operator and make plans to register any individual premises producing more than 500kg which should not be applicable via one domestic premise
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Rank: Super forum user 
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Had similar issues up here, SEPA apparently unable to interpret or provide definitive interpretation of their own SWAN guidance.
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Rank: Super forum user
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DNW
Had a similar situation whilst working for a social housing provider.
We were told you need a license to have an asbestos skip in your yard - quite expensive if I recall
We went down the route of getting asbestos picked up from each property as it was produced.
Also to transport asbestos you need to ensure your vehicles are suitable - sealed bulkhead between driver and back of vehicle
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Rank: Forum user
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I may be able to help, if the work you are doing is a large project then a dedicated fully enclosed skip may be located in the site compound and waste from each property transfered to the skip as it is produced, I have been advised by the EA that this was completely ok and the site compound was registered as the producer of the waste ( yes >500kg), this was part of a better homes project so lots of properties within the area
If you undertaking insurance work on a ad-hoc reactive basis then you will need a central skip somewhere and this cannot be on the road
So if you put a skip in your own yard to collect the asbestos waste from various properties then you will be effectively acting as a transfer station and need the licence for this activity, been there and done that too !
If as noted by DNW you are going to transport waste then you will need a dedicated area of the vehicle, usually the rear, sealed from the forward areas and washable
Waste carriers licence and all waste should transferred ASAP to a transfer station or landfil licenced to accept asbestos waste, then we have the issues of weight which effect the training required by the driver to handle asbestos waste (ADR - CDG Road )
999kg for bonded and 333kg for fibrous ( this is subject to interpretation due to the textured coating being destroyed during removal)
All good fun so far, the NLW training should include details of waste management and transport of the same, then you have the regular air tests for the vehicles both front and back to ensure cleanliness and no contamination
Makes the removal of a water damaged ceiling quite a task doesn't it !!!
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Rank: Super forum user
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I am fully in agreement with Ginga John. The issue of the central, in your own yard, skip does mean you are now a transfer station and need to handle ALL incoming materials in the same way as any other point of disposal - ie signing off all incoming deliveries to the skip as the recipient of the waste. As this is hazardous waste if the total asbestos content is >0.1% of the total weight of each delivery then it is possible you will need to look at your paperwork systems to satisfy the subsequent needs of a consignment note.
Remember that you are fully responsible at all times for the security of the material in the skip wherever it is located.
Licenced removal contractor does not look so expensive when you start to look at this - they have the advantage of being able to spread standing costs against a large number of jobs which you cannot do.
Please remember also that you may actually be breaching the general requirements for non notifiable work if these people do more than 1 hour a week, to my immediate recall, of such work.
Bob
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Rank: Forum user
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Thanks for all your replies.
It has certyainly made it clear that I'm not losing the plot as others have had the same issues. I will inform the man upstairs that Environmental Legislation cannot be interpreted by the Environment Agency so the best solution is likely to be the costliest.
Thanks again.
DNW
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Rank: Super forum user
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additionally have a good sales and marketing plan in place so the public can be satisfied quickly should any questions be asked as the public are much more knowledgeable and aware these days than they were -this may not sound relevant but I assure U that it is. Additionally make sure that your site is secure
I looked at a site like this recently e.g. working with asbestos in a public place e.g. removing gutters, facia etc. where unknown people had removed some ACM's from the asbestos skip where the materials were being collected before removal & thrown them on the grass around the said skip then took photos of the 'poor management of asbestos' and the rest is history
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Rank: Forum user
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boblewis wrote:I am fully in agreement with Ginga John. The issue of the central, in your own yard, skip does mean you are now a transfer station and need to handle ALL incoming materials in the same way as any other point of disposal - ie signing off all incoming deliveries to the skip as the recipient of the waste. As this is hazardous waste if the total asbestos content is >0.1% of the total weight of each delivery then it is possible you will need to look at your paperwork systems to satisfy the subsequent needs of a consignment note.
Remember that you are fully responsible at all times for the security of the material in the skip wherever it is located.
Licenced removal contractor does not look so expensive when you start to look at this - they have the advantage of being able to spread standing costs against a large number of jobs which you cannot do.
Please remember also that you may actually be breaching the general requirements for non notifiable work if these people do more than 1 hour a week, to my immediate recall, of such work.
Bob You are right for non notifiable work Bob but this type of work will always be notifiable as it does not remove the ACM in its entirety and without damage, this is now Notifiable Non Licenseable Work under Car 12, requires all of the same compliance as Licenseable work except the license
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Rank: Super forum user
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Ginga John
Not quite so as the determination of Notifiable Non Licenced work is made after determining whether it is licensed or non notifiable. I always remove in entirety artex ACM ceilings and plaster as this makes the release of fibres much less of a problem. In both artex and thermoplastic the HSE see the Asbestos fibres as very tightly bound as to need heavy abrasion to cause release. This is a complex decision area to achieve the best solution though.
Bob
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Rank: Forum user
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We will have to disagree on that one Bob, or you will have to advise me how to remove Artex in its entirety without any damage to the ACM itself.
The whole reason for CAR 12 was the removal of textured coatings
The damage and degradation caused to the textured during removal, even if on plasterboard, makes it notifiable non licensed work
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Rank: Super forum user
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Ginga John
The HSE itself have placed the decisions in the order I give - not that I personally totally agree with it. The HSE are also still stating that Asbestos based artex, which I presume is the concern here, takes significant and vigorous abrasion, eg sanding, to release fibres. This is what I am talking about - not non asbestos artex on an ACM base. This latter makes a different ball game.
I can remove/"hack off" plaster in small areas with an insignificant release of fibre, not to say PPE is not used though as I am a belt and braces man. Sodden plasterboard with artex attached is also easily removable without dust production and owing to the relative mass ratios involved between asbestos in the artex and the remaining total material I will come below the levels defined by the EA as hazardous for disposal.
As always we learn that we do not always make ourselves clear even if we think we do - Hale and Hale model springs to mind here. One gives instructions and the recipient processes it we know not how.
Bob
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