Posted By NickW No im not being deliberatly contentious. L143 (the new-ish ACOP to the Control of Asbestos Regs 2006) states that 'where removal of ACM's is time consuming and resource intensive and only involves a lower risk material such as textured coatings containing asbestos, then removal prior to demolition or major refurbishment may not be reasonably practicable' (!!!). I am very dubious about the merits of this. We are a testing lab and have seen plenty of brand-spanking new building materials testing positive for asbestos, not because it was deliberately added, but because they contain building-hardcore which has been contaminated due to failure to seperate waste streams. I spoke to a demolition contractor some months ago and though he said his firm would not entertain doing this, it was a hot topic at the demolition contractors federation and that clarification was being sought from HSE. So does anyone know if there have been any more developments with this issue and if its been clarified? cheers Nick

Posted By Ron Hunter These new products made from recycled are presumably highly bonded and you are detecting fibres via destructive testing? There surely has to be some sensible limit (reasonable practicability) to demolition activity. Discussion would extend to floor tiles, adhesives, fillers etc, some if which is essentially undetectable in existing structures anyway. No-one could guarantee that all ACMs were 100% soft-stripped prior to bringing down an old building. In environmental terms, is the "background level" going to be changed appreciably from that caused by decades of previous release, including friction linings on old motor vehicles?

Posted By Peter MacDonald Hi Asbestos material in fire damaged buildings or structurally unsound buildings is fairly common but only after consulation with LA, HSE, and the production of a risk profile. Typically this only applies to bonded materials such as sink pads, window mastic, stair nosings, CAF gasgets, cement panels etc and even then measures should be taken to recover these items post demolition or run off all arrisings as waste. Latter option very expensive. In my experience most end users have crushed hardcore screened for grading, chemical ananlysis and asbestos against a tender specification for re-use and if it fails the grading it's the demolition contractors responsibilty. That usually focuses the emphasis on proper ACM removal. Peter

Posted By Colin Reeves Nick You say "However, it IS usually possible to detect asbestos in liners and fillers etc prior to demolition by carrying out a thorough Type 3 survey, as legally required by CAR and CDM 2007 (the new ACOP of CDM mentions carrying out such surveys)." The original question was "'where removal of ACM's is time consuming and resource intensive and only involves a lower risk material such as textured coatings containing asbestos, then removal prior to demolition or major refurbishment may not be reasonably practicable' (!!!). In other words, the asbestos is known about, it is not a failure of the survey, but an apparent let-out from removal prior to demolition. This thread seems to have moved away from the original question a bit! Colin

Posted By NickW "With great respect you are wrong in stating that anything greater than 0.1% w/w asbestos is classed as hazardous if you are quoting the waste regulations. In this case it is whether the waste exhibits hazardous properties and contains more than 0.1% W/W of asbestos" Adrian can you clarify the definition of hazardous waste (due to asbestos contamination) please. If the 0.1% ww criteria is not the critical factor what is?

Posted By Adrian Watson Nick, The special waste regulations was based on a single criteria of whether the waste contained more than 0.1% W/W of asbestos. The Hazardous Waste (England and Wales) Regulations 2005 REQUIRES that the waste contains more than 0.1% W/W of asbestos AND that the waste ... not the asbestos ... exhibits the hazardous properties of asbestos. Thus as an extreme example if you have a glass block in which there is more than 0.1% W/W asbestos, then it is not hazardous waste because it does not exhibit the hazardous properties whilst waste containing more than 0.1% W/W of asbestos flock would be hazardous waste because it would exhibit the hazardous properties of asbestos. Regards Adrian

Posted By Dave Wilson The basic concept is that if the Tex Coating can be easily removed then it should be, under controlled conditions Reg 11 ACOP para 167 -177. for instance on plaster board etc. However if the TC is attached to the substrate where it is difficult to do so then as much as possible should be removed, in accordance with the above' and the residue can be knocked down with the rest of the building. This can be done by an unlicensed contractor if he follows the above methodology AND his Risk Assessment deems it to Sporadic and Low intensity.(SALI) Remember ALL the following criteria MUST BE MET for the SALI Reg 3(2)to apply. 1. the expopsure of emplyees is SALI -0K 2. It is clear from the Risk assessment that exposure of any employee to asbestos will not exceed the control limit - Will it? AND the work involves a.Short non continuous maintenance activities b.removal of materials in which the asbestos fibres are firmly linked in a matrix c.encapsulation / sealing of ACM in GOOD condition d.Air monitoring / sampling etc See para 34-40 in the ACoP for more detail

Posted By NickW Dave that makes sense and I would advocate your intepretation of it, however para78 of the ACoP doesnt stipulate that it only applies to asbestos residues remaining after asbestos residue. It would be nice if we could get a definitive response from HSE about this.

Posted By Dave Wilson Forget the last posting - found it. We have arranged a number of seminars on this and the question has been asked and the HSE response is - "If your Risk Assessment deems it to be SALI" and the only way you will know is if we visit and it is not" Not very helpful I know but this is how they would interpret this. The HSE task cards are quite specific when it comes to AIB as to when a licensed contractor should be used a1 - a9 but the rest of them it is up to the biuilder as part of his RA as to when the work will not be SALI and when to use a licensed contractor. For instance any work on damaged Limpet / lagging is now licensed work as you will instantly go above the Control Limit so Reg 3(2) does not apply