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Notification

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MEden380  
#1 Posted : 13 May 2013 10:09:01(UTC)
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MEden380

Project involves the removal of asbestos by a licensed contractor and then reinstating new insulation / lagging to pipe work & ducting Work will take over 30 days - 4 weeks to remove asbestos, 2 weeks install new lagging / insulation Project is let out as one continuous program. As far as I am concerned over thirty days the project is notifiable. Client's H&S adviser says it does not require notification as asbestos removal is not notifiable work under CDM Regs as it is notified to the HSE as Licensed removal work. What do you think?
boblewis  
#2 Posted : 13 May 2013 11:08:23(UTC)
Rank: Super forum user
boblewis

The removal notification does not cover the reinstatement if you look at what is required. Thus no notification is required for the removal under CDM but may be for the re-instatement. Treat as one project and do both as there is really no extra work specifically involved iin the actual planning and management etc. If the asbestos was removed under one contract and then replaced under another then the situation is clearer. I think Client is slightly confused. The intention was to ensure large removals of asbestos did not get caught up by two notifications as it is still construction work and subject therefore to CDM whatever the case. The HSE are effectively exempting ACM removal from the CDM notification for licensed work. Bob
BJC  
#3 Posted : 13 May 2013 14:24:55(UTC)
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Guest

I can see no exemption under CDM if the project is continuous ?
TJA  
#4 Posted : 13 May 2013 17:39:59(UTC)
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TJA

Totally agree with Bob
boblewis  
#5 Posted : 13 May 2013 21:49:21(UTC)
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boblewis

BJC The licensed removal is notified under the CAR 2012 and is thus deemed not to require an F10. The reinstatement is not covered by the licensed removal notification.
boblewis  
#6 Posted : 13 May 2013 21:51:12(UTC)
Rank: Super forum user
boblewis

I should perhaps add that there is always a natural break at the end of removal for clearance monitoring which MUST precede re-installation.
MEden380  
#7 Posted : 14 May 2013 08:57:38(UTC)
Rank: Super forum user
MEden380

Thanks for the comments Just one thing Where does it say in CDM ACOP that asbestos removal whether licensed or not, if notified to to HSE, is exempt from F10 notification if the work is over 30 days / 500 person days. If you look at the ASB5 form it mentions notifiable projects on the back in small print.
boblewis  
#8 Posted : 14 May 2013 12:48:41(UTC)
Rank: Super forum user
boblewis

Mark It does not but talk to one of your local construction inspectors and they will tell you that the asbestos notification is all they need for the removal. This applies only to work that is either Licensed or NNL work
SP900308  
#9 Posted : 14 May 2013 13:09:07(UTC)
Rank: Super forum user
SP900308

Bob, with all due respect, Inspector A's opinion could differ from Inspector B's. Secondly, does the CAR 2012 Notification capture ALL of the information set out in under CDM (Schedule 1)? If not, then I'd suggest the requirements of CDM2007 haven't been fully satisfied if reliant on the CAR 2012 Notification? Simon
SP900308  
#10 Posted : 14 May 2013 15:23:36(UTC)
Rank: Super forum user
SP900308

Bob, following my previous post, looking at the asbestos Notification Form (CAR2012), it doesn't appear to contain ALL information required under Schedule 1 of CDM2007. Therefore, I cannot see how using the asbestos Notification form alone would satisfy the requirements of Schedule 1 under CDM2007? The HSE may accept this approach but that doesn't mean it is compliant with CDM2007!
boblewis  
#11 Posted : 14 May 2013 20:10:48(UTC)
Rank: Super forum user
boblewis

SP900308 No it is not the same but talk to your local licensed contractor - Really all HSE want is in the notification of licensed work - for simple removal this is ALL they need as it has 1) Job Location 2) Scope of work 3) Client 4) Contractor 5) Methods of work 6) Who will sample 7) Monitoring 8) Dates of work This applies to EVERY licensed removal regardless of size or duration.
SP900308  
#12 Posted : 15 May 2013 12:29:35(UTC)
Rank: Super forum user
SP900308

Bob, I understand what you are saying and is also sensible! Therefore, if the missing elements of information required under Schedule 1 are added to the CAR Notification then CDM has also been satisfied in this context (as the mechanism for providing the Schedule 1 information can be 'as you wish' - as you know). Correct me if I'm wrong?
boblewis  
#13 Posted : 15 May 2013 13:12:28(UTC)
Rank: Super forum user
boblewis

Read the asbestos notification form carefully including notes at https://www.hse.gov.uk/f...notification/fodasb5.pdf There is a smidgeon of difference but not really relevant to the HSE Bob
SP900308  
#14 Posted : 15 May 2013 13:28:07(UTC)
Rank: Super forum user
SP900308

Bob, again I'm with you on this but I still see gaps in the Notifiable information: 1) Client contact details (the form does give the opportunity to capture the CDM Client details but doesn't stipulate doing so by offering contractor or Employer as options); 2) CDM Co-ordinator details; 3) Principal Contractor details; 4) Authorisation (although does have an authorisation box, doesn't imply the CDM Client / on behalf of). To me it would be signed by the specialist asbestos removal contractor? The smidgen of difference is relevant to the requirements of CDM.
boblewis  
#15 Posted : 15 May 2013 16:18:18(UTC)
Rank: Super forum user
boblewis

Tell the HSE it is their approach. They do believe that the information you raise is not that necessary however. This is why I stated that the replacement would fall under the CDM notificaation where necessary. Me I would simply list the work on the F10 and do the asbestos notification as normal. Bob
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