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philb  
#1 Posted : 18 January 2013 12:32:06(UTC)
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philb

I'd be interested in opinion of those regularly involved in dealing with ACMs. We need to cut an aperture in a ceiling which has previously been covered in a textured coating which we suspect may contain asbestos. We will test to verify this. Assuming it does we will develop a plan to prevent/reduce exosure, deal with any emergency and prevent spread of the material using appropriate equipment and will carefully cut around the perimeter of the hole and ideally remove the redundant piece whole or in large pieces - for appropriate disposal. We will not remove the textured coating from the plasterboard backing. The question is: Is this work notifiable non licenced
Bruce Sutherland  
#2 Posted : 18 January 2013 12:47:59(UTC)
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Bruce Sutherland

No - intention is to take down whole
Ron Hunter  
#3 Posted : 18 January 2013 12:49:49(UTC)
Rank: Super forum user
Ron Hunter

We only have the flowchart at page 5 of http://www.hse.gov.uk/pubns/guidance/a0.pdf to guide us, and that's quite often as clear as mud. My opinion? Stick to hand-tools, shadow vac and do all the things you mention. Follow the task manual. Non-notifiable.
philb  
#4 Posted : 18 January 2013 14:26:52(UTC)
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philb

Thanks for the replys - like Ron I found the flowchart to be a bit difficult to understand
Ron Hunter  
#5 Posted : 18 January 2013 14:42:32(UTC)
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Ron Hunter

Just to be crystal clear ("hand tools") I mean no power tools!!!
bod212  
#6 Posted : 18 January 2013 21:53:23(UTC)
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bod212

My opinion is that it falls within NNLW (if its found to be asbestos, of course). After all, the ACM will be disturbed to a degree. It will become as a result of the process 'friable and degraded'. The difference between the two classes is as Ron says rather 'blurred' but I would always err on the side of caution anyway. The NNLW process is easy peasy and doesn't take long to do online. Use asbestos essentials as well for more info...
boblewis  
#7 Posted : 19 January 2013 10:48:55(UTC)
Rank: Super forum user
boblewis

When oh when will the HSE get somebody with competence to draw flowcharts. The initial loop is to decide if the work is notifiable and thus licensed work. The ceiling falls into the third category as it is at worst textured coating. The second loop decides if it is now notifiable non licenced the first box here is totally incorrect and one should start on the second row of boxes. I do note the time requirement is dropped out in this section but as I read the 2012 regs it is still relevant but this is a moot point. Finally I do wish that the HSE would learn to use the correct box styles for logic/algorythm drawings. As this is textured coating all HSE evidence is that the asbestos is firmly bound unless vigorously abraded which I think is unlikely in your scenario. Bob
Ron Hunter  
#8 Posted : 20 January 2013 23:44:21(UTC)
Rank: Super forum user
Ron Hunter

gerry d wrote:
I would always err on the side of caution anyway. The NNLW process is easy peasy and doesn't take long to do online. Use asbestos essentials as well for more info...
If we do err on that side, do we not then also require to provide medical surveillance for those involved? (I'm working from memory here). Shame about this mix up with ACM categories. I still think the Directive wording could have been amended to resolve this issue. Iit should have been challenged by the HSE at draft stage, instead they chose to ignore the bit they didn't like - now we end up with the mess that is CAR2012.
boblewis  
#9 Posted : 21 January 2013 11:50:39(UTC)
Rank: Super forum user
boblewis

Ron You are right - assuming NNLW does mean only medically supervised workers being used. The other way to look at it is - If only the people at HSE were adequately competent then the mess up would not have occurred. I cannot but feel that the competence level of the HSE is falling. We can all remember the older HSE inspectors whose views and thoughts could be respected and relied on. Not so much now I fear. The best seem to become consultants by the age of 40 following disillusionment with the system. Bob
DNW  
#10 Posted : 21 January 2013 12:43:48(UTC)
Rank: Forum user
DNW

It is non-licenced work, notification isn't necessary. Bear in mind however if you are not using a specialist contractor then the personnel you use must be trained to undertake non-licensed asbestos removal, asbestos awareness is not sufficient. Recording of notifiable non licenced work and health surveillance will not be enforced until 2015. Thanks DNW
philb  
#11 Posted : 21 January 2013 21:02:26(UTC)
Rank: Forum user
philb

Many thanks for the replies - they were very helpful. Also reassuring that it was not only me who found that blessed flow chart confusing
Ron Hunter  
#12 Posted : 22 January 2013 10:40:06(UTC)
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Ron Hunter

DNW wrote:
Recording of notifiable non licenced work and health surveillance will not be enforced until 2015.
And echoing Bob at #9 above, this is surely a clear example of regulatory ineptitude? The most important factor in any health surveillance or health monitoring regime is the establishment of an early baseline. Yet here we have a statute that essentially encourages employers to bash on regardless for 3 years!
boblewis  
#13 Posted : 22 January 2013 11:21:55(UTC)
Rank: Super forum user
boblewis

Ron A case of the blind leading those willing to ignore. Ineptitude seems such a weak word for what is now happening to a once respected regulator. Bob
Lisa Boulton  
#14 Posted : 22 January 2013 12:03:03(UTC)
Rank: Forum user
Lisa Boulton

Just to add to all the good replies the HSE have produced worksheets for working with textured coatings, A26, A27, A28 and A29. (sorry can't do the links) I'm with DNW #10 that though this is non licensed work you still need all the precautions, training, H type vac, 500 gauge polythene, duct tape, warning notices, exclusions, diposable PPE etc for working as per licensed. All the waste produced becomes asbestos waste and so you need the appropriate waste carriers licence etc. We had this for changing two screws in a light fitting recently in a textured coated ceiling. To be honest nothing has really changed with introducing the non lic/licensed distinction. Like other guidance from the HSE it is a bit Emperors New clothes, or all smoke and mirrors.
rodgerker  
#15 Posted : 22 January 2013 13:04:36(UTC)
Rank: Forum user
rodgerker

While looking at the "Asbestos Essentials Task Sheets", as suggested by others, may be of some assistance, it doesn't answer the question of whether the work being considered is in fact "Notifiable Non-Licensed Work" (NNLW) or not. To find out log onto the HSE website and enter "asbestos nnlw" and that will provide all the information required on the whole topic. Rodger Ker
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