Rank: Forum user
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I have been told that following the change in guidance for asbestos surveys to HSG264 that there is a transition period that allows the old type 1,2 & 3 surveys from MDHS100 to be carried out until Dec 2011 due to the fact that it was only a change in guidance and not the regulations. I am not aware of this so was wondering if anyone could shed anymore light regarding this matter
Thanks
PaulR
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Rank: Forum user
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I am unaware of any transition period either Paul. We have used HSG264 since its inception in early 2010. The publication of guidance documents for asbestos (e.g. HSG247, 248 & 264) is out of kilter with the publication of the regulations (L143) anyway so there are some glaring differences. The longest time window even for a re-inspection is one calendar year so the latest a type 1/2/3 survey would still be valid would be one carried out in Dec 2010/ Jan 2011. After that the new types (management or refurb/ demol) would be valid and appropriate.
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Rank: Super forum user
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I am not aware of any transition period, however is it right that an old Type 1,2 or 3 survey becomes invalidated following the new HSE guidance? Does an organisation really have to undertake new style 'Management Surveys' having spent large sums doing Type 1/2/3 surveys? Surely the old style surveys are still relevant for doing ongoing condition checks and for managing the asbestos containing materials in buildings. I would welcome the opinions of others.
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Rank: Super forum user
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In the context of Regulation 4 "Duty to Manage" what matters most is the effectiveness of the Asbestos Risk Register ARR. If that document is Reg4 compliant, it matters not how it was informed, or what 'name' the informing survey had at that time. A valid ARR remains a valid ARR.
If any professional body out there is still trying to 'sell' Type 2 or Type 3 Surveys to prospective clients in the commericial market I think the HSE would be interested in the competency of that body. Any survey company worth their salt would have been aware of the considerable cosultation period which led up to HSG264 and would hopefully have dropped all and any references to Type 2/3 some time ago.
L143 Reg 5 ACoP is not that much out of step. It merely refers to a withdrawn publication (MDHS100). HSG227 (Reg4) however is woefully out-of-date.
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