Posted By Dave Wilson
Brief overview of the Control of Asbestos Regulation 2006 (CAR 06)
These amalgamate into one set of Regulations and have replaced the following
1 The Control of Asbestos at Work Regulations 2002 (CAWR 02)
2 The Asbestos (Licensing) Regulations 1983 (ASLIC 83)
3 The Asbestos (Prohibitions) Regulations 1992
The new CAR 06 has gone away from specific naming of Licensable products and is now 'risk based'
There is a new control limit of 0.1f/ml for 4 hours which must never be exceeded (Max Exposure Limit (MEL)) for all fibre types blue, brown and white this has been reduced from 0.2 for blue & brown and 0.3 for white.
A Short Term Exposure Limit (STEL) of 0.6 f/ml for 10 minutes for all fibre types.
The 'Minor Works rule has been strengthened and is replaced by "Short duration maintenance work which is of sporadic and low intensity" this means because it is a 'risk based strategy' if the work on ANY asbestos is likely to exceed the 0.6f/ml STEL then that work automatically becomes work which has to be undertaken by an Asbestos Licensed Contractor. The 1 hour and 2 hour is still there but you now have to include the STEL as well.
So this means
1 Any work on 'DAMAGED' Asbestos Sprayed Coating (Limpet) & Asbestos Lagging is licensable work as the STEL will be exceeded.
So no work at all for unlicensed contractors on these products.
2 AIB
Removal of 'screwed' in AIB >1sqm - Licensable
Repair of AIB if more than Minor Damage - Licensable
Removal of any size of AIB if it is 'nailed' in - Licensable
Removal of more than 1 Ceiling tile or if it is painted and can damage the surrounding tiles when removing - Licensable
Drilling Holes in AIB up to 5 Holes greater than 20mm in dia in AIB less than 6mm thick - anything more licensable
Drilling Holes in AIB up to 20 Holes less than 20mm in dia in AIB less than 6mm thick - anything more licensable
There now is a specific requirement for a Risk Assessment and 18 Point Method Statement to be produced for any work with ACMs ,even for unlicensed work (i.e..Cement products & and vinyl floor tiles for instance). The production of this documentation has to be undertaken by a competent person.
To decide whether or not the control limit is likely to be exceeded, it is first necessary to know what concentration of asbestos fibres are likely to be present in the air.
It will be necessary to confirm the estimated exposures by measurement, using an appropriate method unless there is already sufficient, relevant and reliable data available.
A summary of this data and the source from which it was derived should be included in the assessment. Guidance on methods approved by HSC may be found in the HSE publication entitled "Asbestos: The analysts' guide for sampling, analysis and clearance procedures".
Competence to write Method Statements & Risk Assessments
Employers must ensure that whoever carries out the assessment and provides advice on the prevention and control of exposure is competent to do so in
accordance with regulation 10.
Whoever carries out the assessment should:
a) Have adequate knowledge, training and expertise in understanding the risks from asbestos and be able to make informed and appropriate decisions about the risks and precautions that are needed;
b) Know how the work activity may disturb asbestos;
c) Be familiar with and understand the requirements of the Asbestos Regulations and this ACoP;
d) Have the ability and the authority to collate all the necessary, relevant information; and
e) Be able to assess other non-asbestos risks on site.
To be suitable and sufficient, the risk assessment should include:
a) For non-licensed work, a statement of the reasons why the work with asbestos will fulfil the conditions for regulation 3(2) to apply and will not therefore be work which requires a licence;
b) A description of the work (e.g. repair, removal, encapsulation of ACM, maintenance and testing of plant and equipment contaminated with ACMs), and the expected scale and duration;
c) A description of the type(s) of asbestos present and the results of any analysis or a statement that the asbestos is not chrysotile alone;
d) A description of the quantity, extent and condition of any ACMs present;
e) Details of expected exposures, noting:
i. Whether they are liable to exceed the control limit and the number of people likely to be affected;
ii. The level of the expected exposure, so that suitable respiratory protective equipment (RPE) can be assessed and selected;
iii. Whether anyone other than employees may be exposed, and their expected exposures;
iv. Whether intermittent higher exposures may arise and their expected frequency and duration; and
v. Results already available from air monitoring in similar circumstances;
f) The steps to be taken to control exposure to the lowest level reasonably practicable, for example for licensable work, the type of controlled wetting and method of application, the use of local exhaust ventilation (LEV) (e.g. shadow vacuuming), glovebag and wrap and cut and for non-licensable work the use of low dust methods, shadow vacuuming, wetting etc
g) The steps taken to control the release of asbestos into the environment; for example enclosures with negative pressure and entry and exit procedures. Where it is not considered practicable to use an enclosure, a full justification is required, and what action should be taken if an accidental release was to occur;
h) Details of the decontamination procedures including the use of hygiene units where appropriate;
i) Procedures for the selection, provision, use and decontamination of personal protective equipment (PPE) which includes Respiratory Protective Equipment (RPE);
j) Procedures for the removal of waste and contaminated tools and equipment from the work area and the site;
k) Procedures for dealing with emergencies, including, for example, those associated with working in confined spaces;
l) Any other information relevant to safe working practices such as other significant non-asbestos hazards like working at heights or in confined spaces; and
m) Management arrangements ensuring that risks are adequately controlled during the work.
Training
Now a legal requirement to have your employees trained
Class 1 training for persons in the asbestos licensed industry
Class 2 Training for employees who work on un-licensed products
Class 3 training for any other employee whose work involves disturbing the building fabric or services
This has to be undertaken on an annual basis.
Fibre counting method has changed from ERM to the WHO method which means approx 10% more fibres can be counted as part of the process when reading the slides. So cleaning of an asbestos enclosure will have to be better to reach the clearance level of 0.01f/ml.