Hi folks. I'm clear that I know the answer to this question, but I'll pose it for others to chip in their tuppence worth... A company I consult for in the NW of England is being asked by a large principal contractor to conduct strip-out works (some pipes, duct-work, electrical services and the like) in a disused factory. So far, so easy. However, the situation is complicated by the fact that the building is *known* to contain asbestos. Quite a bit of it, as it happens. There's an asbestos register present, and drawings which show where *most* of the asbestos is. However, it seems that not all the asbestos has been identified, and the (foreign owned) main contractor is putting pressure on the company to train all its men so that they know what to do should they come into contact with any ACMs. I'm settled on the view that all ACMs need to be identifed and removed before work even happens in the areas which are being worked in. I think it's a legal requirement. Training as a principal control measure? Shome mishtake, shurely? Thanks, J

As the PC is now in control of the premises the Client has now successfully passed the costs over to the PC. You do well to stand your ground and insist on a D&R survey and an agreed management plan before you work. Simple training to level 2 - unlicensed ACM work is unlikely to meet all that is required as there may well be licensable work involved here. There will I think be almost certainly Notifiable Non Licensed work and then Medical Supervision also kicks in. Any management plan for the asbestos should recognise that identifying "on the hoof" so to speak is a recipe for a loss of control to occurr. This could result in building or external environment contamination. Hence some nice large fines from both the HSE and EA. Bob

It's not entirely clear whether the PC has been appointed or if he has actually "mobilised" to the construction phase. A crazy situation surely to be at mobilisation stage of a Project and not be clear as to the extent and impact of enabling asbestos removal works - this tends to put planning and costing right out the window! Anyhoo......irrespective of the extent and the planning of the asbestos enabling work, it is surely at least reasonable (I would suggest mandatory) to expect that every single operative working on demolition contracts (generally) has the requisite CAR Reg10 awareness training?

Thanks all. A few comments and facts: 1. PC has been appointed and is in situ. 2. A demolition survey has been conducted, but there are gaps in it (i.e. bits missing). 3. Following on from point 2, not all asbestos is labelled. 4. There is no systematic management process, and it's all being done 'ad hoc', with no plans to remove some of the asbestos which sits cheek by jowl with the services we're stripping out.

(Location or area) gaps in the survey, test and analysis info. are permissible provided those areas aren't to be worked on or likely to be disturbed. There's no absolute requirement to label ACMs (although it can be helpful) It is conceivable that adjacent ACMs may be left in place whilst services are stripped - but someone has to devise the safe system of work! Is it clear who that someone is? The only "absolute" arising thus far from the discussion is that all personnel must have CAR Reg 10 awareness training. Not a 'primary' control, but an absolute legal requirement.

Hi Looking at the HSE site, the main contractor may have a point, if it is deemed a risk that some ACM may be misses during the survey and removal then there may be a need for training for the employees who come in after the licensed work is carried out. But only at the level of awareness training. E.g. be able to recognise ACM and escalate the issue thru the chain of command.