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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?
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Rank: Super forum user
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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
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Rank: Guest
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I can see no exemption under CDM if the project is continuous ?
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Rank: Forum user
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Rank: Super forum user
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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.
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Rank: Super forum user
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I should perhaps add that there is always a natural break at the end of removal for clearance monitoring which MUST precede re-installation.
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Rank: Super forum user
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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.
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Rank: Super forum user
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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
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Rank: Super forum user
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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
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Rank: Super forum user
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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!
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Rank: Super forum user
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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.
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Rank: Super forum user
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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?
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Rank: Super forum user
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Rank: Super forum user
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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.
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Rank: Super forum user
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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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