IOSH forums home
»
Our public forums
»
OSH discussion forum
»
R&D survey in occupied residential property - can it be done?
Rank: Forum user
|
Hi All,
I’m working for a housing association that are planning some Kitchen and bathroom refurbishments on a number of occupied residential properties.
They and their asbestos company have said it is almost impossible to undertake R&D surveys within occupied residential property as the surveys cannot be coordinated with the refurbishment programme to ensure tenants won’t be left without vital services between the time of the R&D survey and the start of the refurbishment project.
And there will be numerous areas that cannot be viewed such as void areas with wall tiles and bath panels that cannot be removed without breaking.
Therefore only asbestos management surveys are going to be undertaken and we will rely on the principal contractor highlighting any specious materials.
I have already gone through management surveys are for normal occupation / routine & simple maintenance only discussion.
I would be grateful for any comments or experiences you may have with this situation.
Thanks
Steve
|
|
|
|
Rank: Super forum user
|
Steve
I cannot agree with this line of thinking. If work is being undertaken which will disturb the fabric of the building then the law requires a R&D survey must be commissioned. There should not be a big problem programming the surveys in advance of the actual refurbishment work. Residents in situ should not present a problem either. I think the company are making a lot of this in order to justify their position.
The asbestos surveys should be as intrusive as is reasonably practicable. In some cases this may require samples being taken from areas where the work is likely to disturb the fabric. Voids in walls are a particular problem. However unless you intend to remove walls then there is no need to sample behind tiled walls. That said, any damage can be rectified during the refurbishment works.
Management surveys are only good for assessing the potential for ACMs for an asbestos register. They are not considered intrusive enough for refurb work.
|
|
|
|
Rank: Super forum user
|
I would say a R&D survey is required unless you are going to assume the presence. However assuming is not the easy option that people think it is.
The R&D survey does not have to be of the whole building just the work area. I am struggling to see why a R&D survey cannot be carried out without disrupting vital services for this project. Are the buildings non standard construction?
|
|
|
|
Rank: Forum user
|
Thanks for your responses, the properties are of traditional construction.
I presume R&D surveys can be carried out within a resident’s bathroom and or kitchen and still leave it fully functional but this is not the view of the housing association.
If anyone has any experiences of this any comments would be greatly appreciated.
|
|
|
|
Rank: Super forum user
|
I thought I covered this in my original post...bathrooms and kitchens can be left fully functional following a R&D survey. In some circumstances there could be some minor damage from sampling, but this should only be cosmetic and given the property is to be refurbished there should not be a problem. Residents should be asked to make themselves scarce where the surveyor needs access, but as it is not the livingroom there should not be a problem.
As Alfasev comments, the intrusive sampling will only need to take place where the work is occurring, a management survey is normally adopted for other parts of the building giving a hybrid of the two types.
|
|
|
|
Rank: Super forum user
|
Practicalities have to be considered, and I've every sympathy with the association and asbestos company.
Consider this scenario in an occupied house: The analyst removes the base of a pipe box or other panel and disturbs 'historic' AIB debris. What happens next?
Coupled with that, experience suggests you'll only discover AIB in some odd places as you start to strip out cupboards, larders etc. anyway
|
|
|
|
Rank: Forum user
|
Ron Hunter wrote:Practicalities have to be considered, and I've every sympathy with the association and asbestos company.
Consider this scenario in an occupied house: The analyst removes the base of a pipe box or other panel and disturbs 'historic' AIB debris. What happens next?
Coupled with that, experience suggests you'll only discover AIB in some odd places as you start to strip out cupboards, larders etc. anyway
Ron, it doesn't matter, practicalities hold no weight for absolute duties. Now without looking Reg 4 of the CAWR doesn't apply to domestic premises, but the rest of the Regs and HSAW etc (where reasonably practicalities will be judged) do. I seem to remember a client using the HSAW (reasonably practicable reasoning) to get out of R&D surveys in a similar scenario as to what is being discussed. I also seem to remember they had a change of reasoning for some reason that was never brought to light!
|
|
|
|
Rank: Forum user
|
From HSG 264 that may help
12 These requirements mean that organisations such as local authorities, housing
associations, social housing management companies and others who own, or are
responsible for, domestic properties, have legal duties to ensure the health and
safety of their staff (and others) in domestic premises used as a place of work.
As employers, the organisations also have duties under the general requirements
of CAR 2012 to identify asbestos, carry out a risk assessment of work liable to
expose employees to asbestos and prepare a suitable written plan of work.
Construction work
13 CDM requires arrangements to be in place to deal with asbestos during
construction work, including refurbishment and demolition. Where construction
or building work is to be carried out, the CDM client must provide designers
and contractors who are bidding for the work (or who they intend to engage)
with project-specific information about the presence of asbestos, so that the
risks associated with design and construction work, including demolition, can be
addressed. It is not acceptable to make general reference to hazards that may
exist. Therefore, site-specific asbestos surveys should be carried out in advance
of construction work to make sure that the information is available to those who
need it.
|
|
|
|
Rank: Super forum user
|
Bank to the OP:
"They and their asbestos company have said it is almost impossible to undertake R&D surveys within occupied residential property."
The statement is correct. There will be obvious limitations on what can be determined without dismantling everything first. The survey will be incomplete.
|
|
|
|
Rank: Super forum user
|
Ron
Almost impossible still means it is possible - no reason why it cannot be done and non surveyed areas noted. I would not want to be the PC gere
|
|
|
|
Rank: Super forum user
|
I'm sorry but it's absolute nonsense to suggest that asbestos sampling cannot be completed with the resident in situ in a domestic dwelling. I have commissioned hundreds of R&D surveys and never once has there been a problem to my knowledge.
Take a bathroom for example, the majority of potential ACMs will be - floor tiles, artex ceiling, bath panel, toilet cistern and seat, possibly water tank and AIB in cupboards. These will cover about 99% of ACMs which can be expected to be found and all can be easily sampled. The only problem is the removing the bath panel without some destruction, it is possible for an ACM to be found behind the bath panel but very rare in my experience. Assuming walls are not being removed there is no problem and event if walls are to be removed it's very rare to find voids with ACMs in domestic dwellings.
|
|
|
|
Rank: Super forum user
|
Sorry, but my own experience shows it's a fairly regular occurrence. ACM Debris in pipe-boxes, behind panels, packing pieces above and behind cupboards, under window surrounds, etc. And most of it tends to be AIB.
|
|
|
|
Rank: Super forum user
|
Ron Hunter wrote:Sorry, but my own experience shows it's a fairly regular occurrence. ACM Debris in pipe-boxes, behind panels, packing pieces above and behind cupboards, under window surrounds, etc. And most of it tends to be AIB.
Tops of airing cupboards finished with brown asbestos....
Cold water tank in the roofspace....asbestos cement, replaced with plastic and the old tank broken-up and hidden under the insulation....the list goes on, and on...
|
|
|
|
Rank: Super forum user
|
...the list is a long one indeed if you include the whole property, but my point was really that they can all be sampled without too much disruption to the resident.
|
|
|
|
Rank: Super forum user
|
Well; without too much disruption.
Of course, things like an interior ceiling being originally AIB, then covered over with plasterboard, make life difficult.
It always helps to not inform the people dwelling in the house....poor dears get so worried.
And if you do find that several rooms are artexed with asbestos-containing material, and the flooring also, you then have a few difficult decisions to take.
|
|
|
|
Rank: Super forum user
|
I have also had involvement in this type of work and tend to agree with RapRapp. It is important not to overstress the risk of encountering asbestos containing materials in refitting bathrooms and kitchens in domestic properties.
There is already some good advice posted but dates are also important in determining the risks. Establish when the building was built and last refurbished. Asbestos was totally band in 1999 but different types were progressively bands by successive legislation.
There always remains a risk and for example we encountered asbestos wall plugs not so long ago. It was impossible to have identified these during a R&D survey but there was spotted by the contractor because their operatives had asbestos awareness training.
|
|
|
|
Rank: Super forum user
|
The only difficult decisions are whether to remove the offending ACMs or encapsulate them if they impinge on the refurb work. In the case of artex ceilings they are normally painted over and in effect are encapsulated unless they are badly damaged. Floor tiles are generally no problem to remove and only contain a very small amount of ACMs anyway.
Explaining things to tenants can be a bit hit and miss, but most residents don't make a fuss. I always adopt the principle of a little bit of knowledge can be dangerous...but then you can't leave them ignorant either.
|
|
|
|
Rank: Super forum user
|
|
|
|
|
Rank: Forum user
|
Thanks for all the comments, I'm glad to say that after a little arm twisting localised R&D surveys are now being conducted.
|
|
|
|
IOSH forums home
»
Our public forums
»
OSH discussion forum
»
R&D survey in occupied residential property - can it be done?
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.