Rank: New forum user 
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Hi Im looking for some guidance on best approach to managing bitumen floor adhesive identified as containing asbestos (Chrysotile). To give some context we carry out refurb works for various local authoritys. Type of work is predominantly fitting and refurbishment of kitchens and adaption of bathrooms into wetrooms - level access showers. Wherever Asbetsos is identified in floor tiles we will arrange removal of tiles and adhesive through a licenced contractor.
However in some situations asbestos is identified in bitumen adhesive only but not in floor covering. In these situations should removal also be completed?
Our clients view is that removal of non asbestos flooring is unlikely to release any fibres from adhesive and therefore risk is negligable so we are safe to proceed and dispose of floor coverings as non hazardous waste. Im not entirely comfortable with this as regardless of how minimal the risk may be it is still a risk and fibres could be released if flooring doesnt come away easily. On the Asbestos surveys completed for the properties where bitumen only has been identified it always states the reccomendation "Removal before refurbishment or demolition" so to my mind this is what we should be doing. I suspect the reason behind the current approach and guidance from our client is the increased financial impact of implementing removal on every case of bitumen adhesive identified. This is an area of H&S thats fairly new to me so any guidance or feedback would be greatly appreciated.
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Rank: Super forum user 
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For absolute clarity I suggest you speak directly to the HSE. As observation your cautious approach is correct - unless the adhesive lifts cleanly as a single mass then you cannot guarantee no fibre or fragment of asbestos could be released. Any argument of it being "fixed in a matrix" should be challenged with how do you prove that? If you consider the major hazard in most construction RCS (Respirable Crystalline Silica) is created by mechanical damage to sand and quartz in brick, cement, concrete etc. nearly all suppliers of such building materials flag this hazard in their literature and recommend control measures. This issue with removal costs is the primary driver as to why there was not a wholesale strip out of Asbestos when the material was banned from further use in construction - too big and costly a job to do all at once so the legislation looks to phased removal during demolition and refurbishment over time.
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Rank: Super forum user
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For absolute clarity I suggest you speak directly to the HSE. As observation your cautious approach is correct - unless the adhesive lifts cleanly as a single mass then you cannot guarantee no fibre or fragment of asbestos could be released. Any argument of it being "fixed in a matrix" should be challenged with how do you prove that? If you consider the major hazard in most construction RCS (Respirable Crystalline Silica) is created by mechanical damage to sand and quartz in brick, cement, concrete etc. nearly all suppliers of such building materials flag this hazard in their literature and recommend control measures. This issue with removal costs is the primary driver as to why there was not a wholesale strip out of Asbestos when the material was banned from further use in construction - too big and costly a job to do all at once so the legislation looks to phased removal during demolition and refurbishment over time.
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Rank: Super forum user
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Hi Simon Suggest your starting points in terms of guidance are a23.pdf (hse.gov.uk)
and, perhaps, particularly, em9.pdf (hse.gov.uk) ....as it might well be that the Client's position is about whether what is removed should be classified as "hazardous waste". Suppose you lift tiles which have been sampled and do NOT contain ACMs, then perhaps mixing in a tiny amount of ACM containing adhesive ("black asbestos") from beneath would be such as to NOT make the asbestos content of the waste exceed 0.1% which is the threshold in Great Britain. What is beneath the adhesive needs to be considered. Let's assume as example that the tiles have been glued down to concrete. It's quite unlikely that you will manage to remove every trace of ACM adhesive from the surface below, and if so then the materials below still need to be highlighted as potentially containing ACMs. There is a balance to be drawn. If you try very hard to remove all the adhesive, you could end up potentially generating more asbestos fibres than a less interventionist approach that accepts that you leave some in situ, but then encapsulate those (at least partly) with the next layer of adhesive. However I think this is one where you need specialist input to come to the optimal solution. Good luck, Peter
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Rank: Super forum user
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Rank: Super forum user
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