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Posted By Brenda H
Ok, at risk of being mobbed, I am still confused!
I have spent most of this afternoon trawling through previous threads and asbestos related documents and still require further clarification!
I know the duty is generally to identify ACM's in non-domestic property. HOwever, it is accepted that in the case of the HA maintenance staff will have to go into the property to do maintenance and therefore could be exposed.
So, the question is: -
1) Does asbestos have to be identified? I feel yes, although from previous posts people still say no, as not non-domestic.
2) I know managing asbestos and not just surveying is the way foward. But, in order to know what type of asbestos there is and where it is, how is this information best attained? Is it still through a survey and if so, which type?
3) If you don't have the survey, which from previous posts i've seen a lot of people rubbish, then how will you know what the asbestos is?
Sorry for the repetition, but i've got myself confused!
PS, even though domestic premises, you would still need to assess deterioration because of the workers wouldn't you?
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Posted By Dave Wilson
Brenda,
Reg 4 talks about the DTM in Non Domestic premises, so no onus on domestic householder to provide info to contractors. (This does not apply to common areas and full DTM applies in these areas)
Reg 5 basically says that 'no employer shall allow his employees to work on ANY premises unless he has ascertained if asbestos is present OR assumes asbestos is there and acts accordingly."
SO CAR 06 reg 5 applies as this is their place of workSo you will have to sample areas where the fabric of the building is going to be disturbed or get a survey done.
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Posted By Robert K Lewis
It has to be identified if you are to send someone in to do work who could foreseeably encounter asbestos. The means of doing this are as numerous as removal contractors and specialist surveyors.
I have been training surveyors for one organisation whereby these surveyors will undertake only type 1 presumptive during routine works and also following desktop studies of their stock. Decisions for type 2 and type 3 are made following these inspections. At this stage external specialist surveyors are used.
All major voids are type 3'd in the areas dfor refurbishment.
You will need to ensure all operatives, employed or contracted, have their training under regulation 10.
Bob
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Posted By Adrian Watson
Dear Brenda,
The over-riding duty is to prevent exposure to asbestos as without exposure there is no risk. Unfortunately there is a mistaken belief that asbestos surveys can do this; they cannot!
The only way to do this is to train the man in the van, i.e. the worker on site, to be asbestos aware so that if they come across something that may contain asbestos they treat it as though it does contain asbestos and then take the appropriate precautions.
Regards Adrian Watson
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Posted By Brenda H
Ok, fairly happy with all that, and given that the workers could be exposed, am happy that asbestos must be identified.
Does the type have to be identified? As the only way of truley doing that is a type 3 survey isn't it?
Is it satisfactory to say yes there's asbestos in the shape of XXX but we don't know what type?
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Posted By Robert K Lewis
Brenda
A type 2 with sampling will suffice but do train your employees and ensure any contractors have been suitably trained. Type 3 surveys do cause damage and can create problems if attempted universally. Your management plan needs to pick up all these areas.
Bob
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Posted By Adrian Watson
Brenda,
The type of asbestos (Fibrous Riabeckerite, Fibrous grunerite or Chrysotile) does not need to be identified. However, the type of asbestos containing material, its condition and location does.
A type 3 (destructive) survey only needs to be done for demolitions and refurbishment work, where you will be opening up the structure. A type 2 (intrusive, non destructive with sampling) is sufficient for most works.
Regards Adrian Watson
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Posted By Robert K Lewis
Adrian
Try Riebeckite!
Bob
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Posted By Brenda H
Ok that's great, thanks for all your help.
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Posted By AHS
It definitely has to be checked and with domestic premises the onus is on the principle contractor(and client if they are a landlord).
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Posted By ddraigice
Going off the subject slightly, that some get confused about. Although there is no duty under CAR 06 for the management of asbestos in shared areas etc. there is still a duty under HSW to ensure the ACM's are managed.
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Posted By Robert K Lewis
Time for a hobby horse off the point i am afraid
There is no such thing as a Principle Contractor.
The Principal Contractor does exist
Bob
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Posted By Dave Wilson
Adrian I would slightly disagree with the fibre ID as this will have to be done to satisfy
a. The requirments of a 'Material assessment' for surveying &
b. The requirements in Reg 6 regarding suitable asbestos Risk assessments
as these are part an parcel of these.
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Posted By Adrian Watson
Dave,
Some comments:
1. The regulations require that you do not assume that the asbestos is chrysotile alone ( I think this is throwback to the previous regulations where there were different standards for amphiboles and chrysotile).
2. Whilst the risk is determined by the asbestos type, intensity, duration and frequency of exposure this boils down in practice to material type, location, condition and vulnerability to damage.
3. The type of material is a useful surrogate for type of asbestos. Spray contains loosely bonded blue/brown asbestos fibres in very high percentages (80%+) that is extremely friable; Cloth, paper and millboard contains loosely bonded white asbestos fibres in very high percentages (80%+) that is very friable; Asbestos insulation contains bonded brown asbestos fibres in moderate to high percentages (40-60%) and is very friable if damaged; Asbestos insulation board contains bonded blue/brown asbestos fibres in moderate percentages (40%) that is moderately friable if damaged; Low density asbestos cement contains bonded white asbestos fibres in low percentages (20%) that is not very friable if damaged; High density asbestos cement contains bonded white asbestos fibres in low percentages (10%+) that is not friable even if damaged; Composites artex and artex that contains bonded white asbestos fibres in low percentages (5+) that is not friable even if damaged.
4. The epidemiological studies were based on mixtures not pure asbestos, therefore the risk estimates are for mixtures.
5. Control is based upon material type, condition etc and not type of fibre.
Regards Adrian
Bob, will check spelling in future!
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Posted By Adrian Watson
Dave,
Some comments:
1. The regulations require that you do not assume that the asbestos is chrysotile alone ( I think this is throwback to the previous regulations where there were different standards for amphiboles and chrysotile).
2. Whilst the risk is determined by the asbestos type, intensity, duration and frequency of exposure this boils down in practice to material type, location, condition and vulnerability to damage.
3. The type of material is a useful surrogate for type of asbestos. Spray contains loosely bonded blue/brown asbestos fibres in very high percentages (80%+) that is extremely friable; Cloth, paper and millboard contains loosely bonded white asbestos fibres in very high percentages (80%+) that is very friable; Asbestos insulation contains bonded brown asbestos fibres in moderate to high percentages (40-60%) and is very friable if damaged; Asbestos insulation board contains bonded blue/brown asbestos fibres in moderate percentages (40%) that is moderately friable if damaged; Low density asbestos cement contains bonded white asbestos fibres in low percentages (20%) that is not very friable if damaged; High density asbestos cement contains bonded white asbestos fibres in low percentages (10%) that is not friable even if damaged; Composites artex and artex that contains bonded white asbestos fibres in low percentages (5%) that is not friable even if damaged.
4. The epidemiological studies were based on mixtures not pure asbestos, therefore the risk estimates are for mixtures.
5. Control is based upon material type, condition etc and not type of fibre.
Regards Adrian
Bob, will check spellings in future!
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Posted By Adrian Watson
Dave,
Some comments:
1. The regulations require that you do not assume that the asbestos is chrysotile alone ( I think this is throwback to the previous regulations where there were different standards for amphiboles and chrysotile).
2. Whilst the risk is determined by the asbestos type, intensity, duration and frequency of exposure this boils down in practice to material type, location, condition and vulnerability to damage.
3. The type of material is a useful surrogate for type of asbestos. Spray contains loosely bonded blue/brown asbestos fibres in very high percentages (80%+) that is extremely friable; Cloth, paper and millboard contains loosely bonded white asbestos fibres in very high percentages (80%+) that is very friable; Asbestos insulation contains bonded brown asbestos fibres in moderate to high percentages (40-60%) and is very friable if damaged; Asbestos insulation board contains bonded blue/brown asbestos fibres in moderate percentages (40%) that is moderately friable if damaged; Low density asbestos cement contains bonded white asbestos fibres in low percentages (20%) that is not very friable if damaged; High density asbestos cement contains bonded white asbestos fibres in low percentages (10%) that is not friable even if damaged; Composites artex and artex that contains bonded white asbestos fibres in low percentages (5%) that is not friable even if damaged. (Dave I know you know this, but others may not).
4. The epidemiological studies were based on mixtures not pure asbestos, therefore the risk estimates are for mixtures.
5. Control is based upon material type, condition etc and not type of fibre.
Regards Adrian
Bob, will check spellings in future!
Post a new response
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Posted By Adrian Watson
Dave,
Some comments:
1. The regulations require that you do not assume that the asbestos is chrysotile alone ( I think this is throwback to the previous regulations where there were different standards for amphiboles and chrysotile).
2. Whilst the risk is determined by the asbestos type, intensity, duration and frequency of exposure this boils down in practice to material type, location, condition and vulnerability to damage.
3. The type of material is a useful surrogate for type of asbestos. Spray contains loosely bonded blue/brown asbestos fibres in very high percentages (80%+) that is extremely friable; Cloth, paper and millboard contains loosely bonded white asbestos fibres in very high percentages (80%+) that is very friable; Asbestos insulation contains bonded brown asbestos fibres in moderate to high percentages (40-60%) and is very friable if damaged; Asbestos insulation board contains bonded blue/brown asbestos fibres in moderate percentages (40%) that is moderately friable if damaged; Low density asbestos cement contains bonded white asbestos fibres in low percentages (20%) that is not very friable if damaged; High density asbestos cement contains bonded white asbestos fibres in low percentages (10%) that is not friable even if damaged; Composites artex and artex that contains bonded white asbestos fibres in low percentages (5%) that is not friable even if damaged. (Dave I know you know this, but others may not).
4. The epidemiological studies were based on mixtures not pure asbestos, therefore the risk estimates are for mixtures.
5. Control is based upon material type, condition etc and not type of fibre.
Regards Adrian
Bob, will check spellings in future!
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Posted By Dave Wilson
Adrian I agree however the Regs are quite specific that the fibre type must be identified as part of the asbestos Risk Assessment.
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Posted By Adrian Watson
Dave
Reg 6 (2)states "Without prejudice to the generality of paragraph (1), the risk assessment shall— (a)subject to regulation 5, identify the type of asbestos to which employees are liable to be exposed;"
Reg 5 "if there is doubt as to whether asbestos is present in those premises he—
(i)assumes that asbestos is present, and that it is not chrysotile alone, ..."
Therefore the duty holder just has to assume that the asbestos is not chrysotile alone.
Regards Adrian Watson
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Posted By Bruce Sutherland
Just felt like doing a bit a MC style speak
introducing the connnnnnnsultant in the left corner wearing whiiiiiiittttte trunks and ...... in the right corner wearing the long baggy red trunks the .... connnnnnnn tractor!!!!......
Not met you Adrian so I am sure how your body style is - Dave and I both sadly need long baggy trunks
Happy Christmas guys
Bruce
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Posted By Brenda H
blimey, that was really good, you were almost in my office for a moment then;)
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