Since the introduction of the Control of Asbestos Regulations 2012 in April 2012, this activity now falls into the category of being “Notifiable Non-Licensed Work”. An electronic submission, using the form ASBNNLW1 must be made to the “relevant enforcing authority”. (This could be either the HSE, Local Authority or the Office of Rail Regulation). This submission must be made prior to the commencement of the activity. A copy of the completed Notification should be on site within the Site Documentation. All other requirements remain unchanged.

With the introduction of the Control of Asbestos Regulations 2006, (now CAR 2012), Asbestos Textured Decorative Coatings (ARTEX) were, controversially removed from the materials requiring to be undertaken by companies that held an asbestos license granted by the HSE. The HSE stressed however that low risk did not equate to no risk.

Textured Decorative Coatings (TDC’s) are materials that have been used historically on ceilings and walls to give a decorative finish. Chrysotile (white) asbestos was used in a plaster mix approximately 2-5% by weight. When set, the material gave a hard finish that was flexible enough not to crack. These properties meant that while wet, the material could be shaped into a variety of different patterns.

Until 2006, TDC’s had been subject to the licensing regulations. However, the HSE conducted research that concluded that asbestos fibre release from such coatings was not sufficient to warrant the strict controls of the licensing regulations. As a result, when the Control of Asbestos Regulations 2006 came into force in November 2006, work on, or removal of TDC’s was no longer a licensed activity.

NOTE.

While working with TC’s has been de-licensed, it has not been de-regulated.

Would suggest that you need to contact a licensed contractor to ensure that it is done correctly


Rodger Ker

You will of course make your own mind up on what to do.

However, may I suggest that you look at the information on the HSE website regarding Notifiable Non-Licensed Work (NNLW) before undertaking this work.

Pay particular attention to the pretty little chart that illustrates what is and not "notifiable"

It states:

"Textured Decorative Coating-using gels/steam to for large-scale removal". "Notifiable Non-Licensed Works"

"Textured Decorative Coatings-only when carefully cutting around backing sheets to achieve removal intact". "Non-Licensed Work".

Rodger Ker

John.

Your original post states "complete removal of TDC ceiling--"

Then you talk about guidance in Asbestos Essentials A-28.

A-28 is entitled "Removing TDC from small area eg 1 square metre"

Can't understand how the two can be related.

Rodger Ker

The HSE are really very optomistic to say bucket of water and damp rags are wet removal. You actually need a steamer and scraper to wet remove and this really is then a specialist task. Why not remove the ceiling complete and then re board with plasterboard. Lot of dust but not asbestos release. You may also find that the total weight of asbestos in the whole mass of ceiling takes you below the point where an asbestos licensed tip is not required. Artex removal WILL produce the need for a licenced tip and the associated costs.

Be careful - assuming that this is a work situation then

1) The EA WM2 changed last Oct and it is highly unlikely that you could consider textured coating as anything other than asbestos waste.

2) It is normally pure fantasy to hope that you can take the ceiling down whole.

3) The work is likely to be NNLW

4) You will need an enclosure - 2 stage etc

5) You will need appropriate training and face fit for the RPE. I think it would quite difficult to get an acceptable level of cleanliness without the use of a type H

6) The reason that the task sheet refers to doing a risk assessment is that the requirement under CAR is more detailed than the info on the task sheet

7) once done you will need a self declared clearance

Have fun.....

Bob, How does this work?
"you may also find that the total weight of asbestos in the whole mass of ceiling takes you below the point where an asbestos licensed tip is not required"

Bruce - Not as fantastic or unbelievable than the HSE method is a wet removal. It can be done and have done it many times. It is far quicker and much easier to control potential exposures.

Redken

It is all down to the EA definitions of when a material that is hazardous is in low enough proportion of the whole the and is well bound for it to be classified as normal demolition waste. The figure is 0.01%w/w from memory. Thus you can estimate the weight of asbestos from the weight of artex in total and also the total mass of the ceiling thence the %ge of asbestos in the whole. Remember you that 25kg of artex went a long long way ( around 50-70m2) and this contains less than 1 kg of asbestos. Plasterboard is between 6 and 8 kg/m2.

Thanks Bob.


JohnW

JohnW

You state that "you are well out of this project" and I can fully understand the reasoning behind your comment and actions.

However, are we not possibly heading for the position that this work will be undertaken with little or no health and safe input?

While I stated earlier that the HSE consider Artex removal as "low risk", they certainly don't consider it to be "NO RISK".

There is now a distinct possibility that this will be "a crash bang wallop job" with the artex just dumped into a general waste skip. (It does happen, I have seen it).

Rodger Ker

John,

I mentioned in an earlier post that there was a full survey published, samples had been analysed last year, some positive 3-5% and some negative. With over 100 sq. mtrs. and including a rather awkward large sloping ceiling the job needs the necessary precautions

Rodger,

They still have 2-3 weeks to make the arrangements before work should start.
The site is on a large highly 'visible' 1000 acre industrial/business estate near Kenilworth where the district council and HSE have a frequent presence so I would not expect the project to proceed without the care that is necessary. The client is also resident on the estate, they own the whole estate and are spending £50M revitalising it.

I had hoped to work on this small project and get some follow-on business but I don't have much spare time to take on difficult projects, and, as I concluded, although I'm familiar with Asbestos Essentials I'm really not qualified/competent to advise on significant asbestos removal work. I expect every building on the estate will have this problem, most having been built before 1980.

JohnW