Rank: New forum user
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I have had an incident where a contractor was removing some 100mm pipework that contained suspected asbestos gaskets. We sought the advice of a licensed contractor on how to deal with the gaskets, and were advised to cut either side of the flanges, without disturbing the gaskets, and leave them aside to be collected for removal. Unfortunately, the waste carrier removed them along with all the other waste pipework. I have advised my client of my concerns over the lack of supervision on the site, and will address that in a separate report. I have asked to see the contractors risk assessment (and I am still waiting!). My main concern is over the type of notification required for the disposal of the asbestos gaskets as the waste carrier disposed of the whole load as one, I assume that it was all melted down. Any advice will be appreciated.
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Rank: Forum user
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The waste code is 17 06 05, which is for bonded asbestos waste. The notification should be lodged with EA (in England) or SEPA (in Scotland). I am in Scotland so I am not that conversant with the EA procedures.
But from my limited contact with my English colleagues the waste would be notified in a single consignment. The originating site needs to have a 'permit' for the waste. The waste carrier needs to be licensed to carry asbestos waste too.
Having said all this, the waste is gone and can't come back, can it? The main thing is you have spotted the incident and can take steps to prevent it happening again.
http://www.hse.gov.uk/pubns/guidance/a25.pdf is a useful guide for companies on how gaskets can be dealt with.
You don't need (at present) to have a licence to remove CAF products as long as you implement the correct procedures and control measures. The people on site have not segregated the offending items properly. Even warning labels, in my experience don't deter waste carriers that are allowed to run free in an uncontrolled way. Even waste carriers who are allegedly conversant in asbestos don't always fill me with confidence. The key thing is to remember every stage of the process involving an ACM is followed to the letter.
http://www.environment-a.../topics/waste/32180.aspx tells you how hazardous waste should be dealt with correctly.
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Rank: Super forum user
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Presumably all water under the bridge now. Next time, you'll know to have appropriate bags and proper segregation.
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Rank: Super forum user
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You have stated enough for a prima facie breach in both CAR and Hazardous Waste Regs. It is not enough now I think to simply look at the risk assessement you need to look at the entire system of management. If the value of these works is/was over £250k the Site Waste Management Regs may also be open as a vehicle of prosecution and here even the client may be at risk because of the joint declaration signed within the plan, if one was required.
Your contractor and the management system for contractors needs some close analysis.
Bob
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