Posted By Daniel Stonehouse
Ladies and Gentlemen:

I have recently carried out a Risk Assessment on the site Asbestos Containing Materials skip. It is used to store routinely found/removed small items that contain ACM's such as gaskets, fire doors, lagging etc.

This skip is emptied approximately annually by a licensed waste contractor.

All items placed in this skip are double bagged and labelled and the skip is kept padlocked, with the Site Emergency control room issuing the key.

One issue that came up was the fact that this skip is a large 'walk in' variety with an access door at one end (padlocked). At the moment although all items are double bagged, the way in which the skip is emptied at the landfill site raises concerns that these bags may be damaged during emptying.

This would then raise the slight possibility of ACM fibres being present inside the skip on return.
The skip is rented to us and is the only one that we have on site - any work that will result in the uncovering of large amounts of ACM is carried out by our on site licensed Asbestos contractor and the waste taken off site via another route, however from time to time smaller amounts of ACM's are found. It is these small amounts of mixed types of ACM's that are placed in the skip.

The skip is not cleaned before being returned to us. This could subsequently result in there being fibres present in the skip when returned, thus the issue with persons actually walking into the skip. Because of its size (financial considerations here), there is a real chance that people will want to 'pop inside' whilst loading this skip up.
There is presently no control who places materials in this skip, all materials are logged so we know what is in there, but it is mainly contractors using this facility.

We have very rigorous policies as regards Asbestos on our site, however the risks from the ACM skip itself is one area that we are less sure of.

I have looked through the CAW Regs 2002 and also the proposed Regs, ACOP etc. but there is nothing i can find that stipulates whether these skips need to be cleaned / certified clear of ACM's before return, or the precautions to be taken when in / around these types of skip.
As an interim measure we have banned entry into the skip, though as it is almost full now this will not be an issue - it is when it returns empty that people will feel the need to enter it in order to ensure maximum loading. In addition we will shortly be carrying out an audit of the removal / emptying / return of this skip.

Any information or experiences of this issue would be most welcome.

Posted By Daniel Stonehouse
Thank you for that information. One of the issues we will raise during the audit will be wash out facilities / damage potential to the bags.