Rank: Forum user
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If you feel that you meet all the requirements for exemption against regs 9, 18 and 22 in the Asbestos Regs, how can you ensure exposure control limits will not be exceeded with carrying out air monitoring each and every time you perform the job? But in doing so you would only know you are exempt after the air monitoring results are returned and after the job has been done?
I guess through meeting all the requirements under the exemption rules, the risk of fibre release in the air is removed and therefore judged to be below the exposure limits without having to do the tests??
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Rank: Super forum user
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Although familiar with the regs, ACOP and guidance I would not make that decision as I do not deem myself competent to do so.
In my experience this is a judgement founded on quality training, experience and specialist knowledge, and where it is clear it is non-licenced work. Where there is no or very low risk of fibre release from a material like cement sheeting that already encapsulates the fibres. Any damage, cutting or breaking out changes everything, as I believe so does the type of asbestos.
If you had a survey done then the report should point you in the right direction.
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Rank: Super forum user
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There are any number of small tasks (see the HSE task manual) falling outwith the stricter regimes of CAR. If these are repetitive and routine tasks then it makes sense to conduct representative monitoring to confirm the risk assessment and SSoW.
You seem a bit hung-up on air monitoring. There are any number of controls to be applied to ensure the SSoW for those minor jobs (training, PPE shadow vac. maintaining that vac. protecting others, cleaning up debris, incident response, etc.
Better to focus your effort there. And don't be guessing.
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Rank: Forum user
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The job involves collecting small quantities of domestic waste that has been bagged but contains suspected ACMs. Other control measures suggested below have been adopted in the SSoW, but I will perform some representative sampling.
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Rank: Super forum user
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I suggest sometimes you need to adopt the principle of what is 'reasonably practicable'. In other words, where you do not anticipate any exposure above the proscribed guidance there is no need to concern oneself with air monitoring. For example, the removal of asbestos floor tiles would not normally require air monitoring. However, if those same tiles were badly damaged and in sufficiently large quantities then it might be prudent to carry air monitoring post removal. It's about managing the risk and proportionate measures.
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Rank: Super forum user
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AM1 wrote:The job involves collecting small quantities of domestic waste that has been bagged but contains suspected ACMs. Other control measures suggested below have been adopted in the SSoW, but I will perform some representative sampling.
That small bagged quantity should be itself double-bagged or double-wrapped in 1000 gauge polythene (and labelled) by suited and booted personnel on-site before you move it any further.
Presumably it then goes to an analyst for proper identification before disposal via appropriate waste stream. Few if any Local Authorities will accept asbestos waste, other than asbestos cement.
Air monitoring /air sampling outdoors is going to be a bit of a wasted effort?
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Rank: Super forum user
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Just a question, why would you be exempt from the regs?, don't you mean you meet the requirements of the regs?
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Rank: Super forum user
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Why would you not offer medical surveillance to operatives who you may be exposing to carcinogenic substances.
Are you conducting air monitoring every time?
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