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Posted By Dave Wilson
Decorative Textured Coatings are to become an unlicensed Asbestos Product come the new Regualtions!
Ok fine, been reading the draft ACoP and I quote "In general reg 3(2) will apply to work with Decorative Textured Coatings and asbestos cement. However the risk assessment may identify factors that lead to the conclusion that the control limit (0.6 f/ml over a 10 min period)could be exceeded or the exposure would not be sporadic and low intensity and in this case the exemptions would NOT APPLY." Hse say removing a whole asbestos sheet will release 0.5 fibres remove 2 inside 10 minutes and you need a licensed contractor - crazy!
If you do not have experience of working with asbestos how could you tell if you are going above the Control Limit, as if you do you need a licensed contractor!
So its not notifiable, so HSE / LA do not know you are doing it so this will expose more people to asbestos dust!
I am all for removal of TC cant see how this is going to work!
Daft or what!
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Posted By Bruce Sutherland
Do we need to declare commercial interest here Dave?
The main problem that we see is that other than asb strippers no one else appeasr to know or understand how clean asbetsos clean should be. And sometimes the strippers only reach that standard after effort by the third party auditors - UKAS lab - the HSL document appears to suggest that the level of risk created by debris from TC is very low. How acceptable that will be to people reoccupying is another matter.
There will be some interesting challenges to decide whether some work will require a licensed contractor or not in the short term - the words sproadic and short duration are fine in relation to rmeoving AC sheets off an outside toilet roof once a year, but what about someone who works for a demoltion contractor and spends 12 weeks stripping AC sheets from roofs on an old MOD site?
Perhaps of equal concern is that the level of 0.6f/ml whihc is being set almost as an old fashioned MEL is going to offer serious problems to licensed contractors working when the new regs come in. There are a number of tasks that I can see that will be difficult to do in line with the law unless people move to airfed BA
For the record I run a UKAS lab and hold an HSE Project Management Licience and sit on the UKAS asb technical advisory committee
Bruce
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Posted By MarkJAWatkins
That's another fine mess you got me into..., sound familiar.
I personally believe that all asbestos products should only be worked on by licensed contractors and that clients should appoint the analysts to conduct four stage clearance testing....(the only way to be safe)
Maybe one day this will happen....and maybe someday I will wake up with all memebers of girls aloud (except the ginger one)!
Regards,
Mark
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Posted By Dave Wilson
I agree,
TC is a lower risk, however when the first PN is served on a general builder for not having a suitable risk assessment and site specific method statement detailing why the Control limit will not be breached before he removes TC, why he does not have type H Vacs and why he has not set up an enclosure with and airlock then the fun and games commence.
This is not about Licensed contractors keeping something in house, this is about general builders who do not have a scooby on how to do this work safely and people will be put at risk!
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Posted By Gerry Marchant
'This is not about Licensed contractors keeping something in house, this is about general builders who do not have a scooby on how to do this work safely and people will be put at risk'
Hope were not tarring all general builders with the same brush here.....there are some out in this wide world who do take their duty of care responsibly and consider all risks when looking at work...including asbestos...no matter what content it is!!
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Posted By Descarte
There definately seems a lot of bias, heavy opinion and discrimination here...
... whats wrong with the ginger one?
Well I guess beggers cant be choosers
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Posted By The toecap
I need some advice. Do i need a license to work as per asbestos essentials i.e removing artex for less than 1 hour? Do the guys need health checks? I know they need training. Sorry for hijacking this thread
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Posted By Dave Wilson
Case in point.
the 1 hour rule in any seven days and 2 man hours etc refers to whether an unlicensed contractor can work on licensable products, if its above the time period its licensable work. and you cannot do another 1 hour job within the 7 seven days so its not 1 job today and another tomorrow.
You are also required to produce a Risk Assessment and site specific method stetement as well, detils in l27/L28
However all work must be carried out in accordance with L27 / 28 and the licensed Contractors Guide / HSG 210 if unlicensed work
If you go above the action levels and control limits this when RPE / face fits / medicals etc kick in. This will be reucede to 0.1f/ml in the new regs and in some extreme cases may even require SCBA / Airlines.
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