Hi Guys/Gals


Can anyone direct me as to where I get a copy of the draft regulations for Asbestos, that look to be coming into force April next year?

Can someone who is conversant with Asbestos regs put in a few simple sentences what the changes are.
I "think" I know but have not been following this closely

GerryD

I agree with you as firms consistently, in my view, distorted the aims of the low level and sporadic exposure to undertake quite significant amounts of acm removal through the use of "routine", ie non medically supervised, workers. This was also to the client benefit as costs were reduced.

It will be up to the HSE to make sure that the changes and the associated acop do bite properly to reduce the risks to the construction and many other induistries as a whole. Look at the mortality and ill health figures. Yes I know all the arguments about historic exposure BUT it is now 11 years on since the final ban and the curve is still rising. Perhaps it is also time that any non licensed work that is not notified is subject to a formal requirement for a detailed assessment to demonstrate that the work will not involve any risk of excursion in airborne fibre above the 0.01f/ml and that it is indeed sparodic with respect to the operatives, which I personally believe the EU intended from the start.

Bob

Sorry about the typo, It should have read 'Notifiable Non Licensed Work'.

Birchall31628 - please be aware that asbestos cement (AC) will not suddenly become notifiable. It will only be notifiable if it has degraded and the risk/ priority assessment informs accordingly.
AC in any state is not a licensed product. It is, however, prudent to involve a licence holder for many different instances when the AC has degraded as they will know the correct control measures, etc. That said it is not necessary to hold a licence to carry out work with AC.

The frequency for medical surveillance for asbestos workers is two years, why the HSE are suggesting a three year frequency for NNLW is out of kilter. Why not make them both two years?

Your last sentence is wrong. The need for NNLW related notifications will have a much much greater impact on organisations that previously did not need to know anything about notifications. So there will be scope for misinterpretation, won't there. And flouting. And ignorance.

I work for a licence holder. We will be the 'easy target' for the enforcing agencies. But we (should) know what to do. It's the organisations that don't know how to interpret and work safey that the HSE/ EHOs should target, isn't it? But, sadly, they won't.

One of the things that cd237 mentions is that a notification should take on average, 5 minutes. Wow, 5 minutes! 5 minutes to do a plan of work, site drawing(s), risk assessment, notification (ASB5), etc, etc. Who are they kidding? Not me for one. I still can't believe they put this in print.

You'll find a definitive summary at the link already given.

As part of the proposed changes, HSE are attempting to pull a fast one and define AIB as non-friable.
I and others have responded accordingly and with concern as part of the recent consultation process.

The HSE have an ideal opportunity to clarify. Sadly, they seem hell-bent on further muddying the waters.

Chris

I prefer to think that now we can really hope to see the extent of the exposure that is occurring rather than it being hidden as something innocuous under the guise of simple firmly bound material that just happens to be 1/2 acre of roofing. At the end of the day the drafters made a dogs breakfast of the 2006 regs and we are finally, I hope going to get it right.


Bob

Thats what occupational exposure monitoring is for Bob ;-)

We have only monitored a few non-licensable tasks (going to be a lot more soon as a check) but they did come out well below (100x) the exposure level.

Do many companies / traders do this? I doubt it.
Is there room for exposures to occur under the guise of firmly held in a matrix? Certainly
Will the changes for notifiable non licensable work change this, unlikely IMO

Des

Des

The real issue is I think "can anyone be certain of not damaging an ACM during removal?" My view is that I doubt it very much. The material has been installed for at least a decade and more and at the very least has become more brittle. The whole issue is a minefield and perhaps there is a need for a small dose of the precautionary principle.

Chris

I well understand what you are saying. At the end of the day we recognise that much work is being undertaken by persons who really ought not be doing so and who are under no form of mandatory health check. and I do tend to agree that only licensed contractors should be doing the work. After all we have ring fenced many trades such as gas fitting and the deaths arising from this activity are minimal compared to asbestos. HMMMM ASB-Safe registration rather than Gas Safe - Idea is mine if HSE ever take it up.

Bob

Completely agree Bob, and any damaged likely to be caused to Asbestos even in held in a matrix then moves this to the proposed notifiable non licensable section.

In fact as part of the consultation process I registered my concerns over this very issue. I queried whether the removal of a CAF joint as currently covered by asbestos essentials (A25) would then become a notifiable operation every time you break containment, sometimes these seals can even split down the middle leaving residues on both sides (damage/degradation to the matrix and possible fibre release). You may not know if this is going to happen before hand.

In the proposed new regs this would make every CAF removal job a possible 14 day notification?

Not wanting to downplay the risk of asbestos or fibre release in such a situation, but if such a rule was to come into force I imagine it may cause considerable work load not only on industry but also the HSE.

Des