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Posted By Colin Harrisskitt
I’m currently writing a procedure on Asbestos Management and would welcome clarification/feedback to the following.
1) It is not a mandatory requirement to engage a licensed contractor for work with asbestos cement, asbestos rope type insulation on electrical cables, asbestos gaskets (CAF joints).
or
2) AIB (including ceiling tiles), asbestos coating and asbestos insulation subject to the following;
That the work is less than 1 person hour in seven days
or
If the work is to be of longer duration than this and carried out on our own premises by our own staff (not contractors) and we have notified HSE of our intention to begin work at least 14 days before the start date.
I have also addressed the issue that it is not acceptable to split large work into small groups in order to avoid the need for licensing
I have identified that a level 2 type survey is to be undertaken to determine the presence and type of ACM prior to any work commencing.
Following the sampling and as an example one ceiling tiles contain chrysotile which in good condition the other single ceiling tile contains amosite in the same condition. Both must be removed Would a licence be required to work on them taking into account the above?
Regards
Colin
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Posted By Charles New
Remember that the total hours worked by all persons involved must not exceed 2 hours, and that ACOP L27 and CAW Regs 2002 still apply.
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Posted By Adrian Watson
Dear Colin,
If your own staff is carrying out the work on your own premises then the two-hour rule, doesn't apply. Asbestos Licensing Regulations 1983. Reg 3.
You have to do the work in accordance with the Control of Asbestos at Work Regulations 2002 and the appropriate ACOP. The work doesn't need to be notified to the enforcement authority unless the action level is exceeded. Control of Asbestos at Work Regulations 2002 Reg 8.
Regards Adrian Watson
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Posted By Hilary Charlton
I will be the first to admit that I am definitely a chicken ... but, we have a chrysotile asbestos sheeting roof and we do not permit any work to be carried out by any persons other than Licensed Asbestos persons. It might sound a little namby-pamby, I'm sure it does, but given the way legislation has gone on the general issue of asbestos and the end game that has ended up being very different from what was envisaged, when the claims come in at the end of the day I can prove that all my work was carried out under License by specialist contractors and out of hours.
I know it costs a bit more to do it this way, but the Management Team and myself at our place feel it is safer just to pay the extra and have the peace of mind that this brings.
I know this doesn't answer your specific question at all but I just wanted to put a different perspective on this situation.
Hilary
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Posted By Charles New
Hilary,
Not withstanding what I said before I do tend to agree with your view. By the time someone has complied with the Regs, (particularly reg 10 and reg 15), and ACOP, they might as well have got a licensed contractor to do the work. At least they have all the decon facilities and 'H'type vacs etc on hand, and you can demonstrate that the work was done by a competent person.
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Posted By Michael Miller
Strange but true! Many of the licensed contractors who remove asbestos have spent thirty years or more installing it. Ironic to say the least. (just another thought for the day)
Mike
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