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Posted By simonwm
I am looking for advice with regards to the removal of Asbestos Flock and Cement debris to glass fibre from within a roof void of a public building. The asbestos consultant advises that this can be removed without the need of containment/enclosure and that wetting down will be a suitable and sufficient control, i am looking to see if the consensus of opinion would support this opinion or otherwise?
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Posted By Rodger Alan Ker
"Asbestos Flock", dependant upon its age, could contain Crocidolite (blue asbestos).
The very worst kind of asbestos.
Would need to examine the asbestos survey before coming to a firm opinion.
I think you do need a second opinion.
If you wish, contact me direct.
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Posted By MW
Simon,
I run an asbestos removal company and it doesn't sound right from what I am reading.
Even if the attic space was to form the enclosure by sealing up vents/etc, there would still need to be a 3 stage air lock and negative pressure tried to be achieved. The problem when doing loft environmental cleaning projects is the positioning of the air lock on the landing area. What normally needs to happen (especially with flock) is that the secured access ladder to the loft space needs to form a tunnel covering the ladder area (this is sometimes referred to as a 4th stage) from this you would have a 3 stage air lock and if space permits a bag lock leading from the area as well.
We have recently completed a similar job and we enclosed the attic space as far is as reasonably practicable and then had our air lock (although no room for bag lock) I would also ask if they intend to do personal monitoring whilst removal takes place and I would also suggest back ground monitoring during the works for the building occupiers piece of mind and then finally the 4 stage clearance by the analyst at the end of the works which is mandatory.
Another thing to bear in mind is that if there is large amounts of flock it could have fallen down into the wall cavities and you will need to take this into consideration when you have workman drilling into wall in the future.
Hope this helps.
MW
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Posted By MW
As an aside to the last comment;
Asbestos cement debris could be notifiable to the HSE when remedial works are being conducted if there is a likley hood that the control limit could be exceeded.
But, the general comments are spot on that the nature of the flock means the who job turns notifiable.
Nasty, nasty, horrible stuff!
MW
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Posted By simonwm
to add clarification to my original post, from the survey report the samples taken have identified the materials to be Amosite and Chrysotile. The roof area is separated from the internal areas below (a Swimming Pool) by general ceiling constructions, if this helps any further
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Posted By Chris L
My reply is that 'it all depends'.
It's been reported as debris: a single piece of flock debris lying on fibreglass could indeed be removed without controlled conditions etc. - it could be just 'picked' by suitably protected personnel.
However my experience of any limpet/flock debris is that there's always more to find - you may need a second survey, or solid confirmation from your existing surveyor that the full extent of debris has been identified.
An example: we have an area with limpet debris. Consultant 1 took 5 samples, 3 of which were negative. After observing that you could turn your ankle on the amount of flock debris I could see, I employed a second consultant. They took 134 samples with 134 positive.....
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Posted By Ian-Edwards
Simonwm,
It's probably worth mentioning that your Public Liability insurance is likely to exclude all liability relating to "asbestos"
Interestingly, you'll probably find that the policy won't offer a detailed definition of asbestos either, so all types will be a problem so far as public liability insurance cover is concerned.
Therefore, the use of a licensed contractor(with current adequate insurance, I hasten to add) will be important to ensure your potential liabilities are covered.
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Posted By steven bentham
'asbestos flock' is licensed work and you should contact licensed asbestos removal contractor [its normally at the higher end of risk for removal work and protection of the public]
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Posted By Arran Linton - Smith
Simon,
I would never dream of calling myself an asbestos expert; however I would be extremely cautions of any asbestos consultant who stated the Asbestos Flock could be removed by “simply wetting down”.
The test that I simply apply is ‘would I trust this information I have against a PI claim’! I have in the past walked away from projects where this test has failed.
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Posted By gerryd21
`Flock` is usually a sprayed coating. This is a licensed product which should only be removed or abated by a licensed asbestos contractor. The person operating under the term `consultant` isn`t one if they are saying `just wetting down` is enough. I despair at these people, I really do. Get another (correct) opinion. Good luck.
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Posted By Chris L
Has anyone actually read the original post? It's reported as flock debris that can be removed without an enclosure.
This is perfectly correct IF it is a single, small isolated piece of debris, subject to a specific assessment of risk and likely exposure. My biggest concern is whether they have found all of it, because it is rare (though not impossible) to find a single piece in isolation.
To the OP: Go back to your consultant and ask them to fully explain the situation and their recommendation. If you're not happy, seek a second opinion from another consultancy.
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Posted By Dave Wilson
No such thing as a 'licensed' or 'unlicensed product' anymore. Its all about fibre release when working in, on or in close proximity to ANY ACM.
If you are likely to exceed the Control limit (0.1 f/ml 4 hr TWA or 0.6 f/ml in ANY 10min) then this work is LICENSED, it does not differentiate between type of asbestos
For the work to be unlicensed ALL of the following have to apply.
The work is of Sporadic and Low intensity eg not above the control limit(above)
AND
A Risk Ass says so
AND
The work is of short duration (1 man for 1 hour in any seven days OR total job less than 2 hours from start to finish)and is maintenance (not removal)
AND
The fibres are firmly held in the matrix of the product AC, floor tiles etc.
As this a friable product and the job will be above the STEL and will take more than 2 hours, as all the MMMF will be deemed contaminated THIS IS LICENSED ASBESTOS REMOVAL.
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Posted By Peter MacDonald
David
To clarify one more thing. The question was not about whether notifiable or not but whether a enclosure was required.
I would argue not necessarily depending again on RA and expected fibre release. An entire roof space yes, but a small isolated patch then perhaps no.
Your thoughts
Pete
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Posted By Peter MacDonald
David
Sorry, my post above reads like I'm having a go. Your answer was excellent! Just digging for more info!
Pete
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Posted By gerry d
Dave you are right. I will try to qualify my post by saying that the term licence or licensed refers to the organisation working with, coupled with the level of planned activity on an asbestos containing material and not specifically the product itself.
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Posted By Dave Wilson
The HSE 'expectations' are
See para 257 in the ACoP
If the work is of a licensable nature and it is practicable to build an enclosure - then an enclosure is built. The HSE will take an extremely robust stance (PN and Prosecute)if Licensed contractors are "found to be interpreting CAR to make work unlicensed for financial gain rather than safety" this is a direct quote from the HSE!
They will also be 'closely looking' at the client who has forced this on the Licensed contractor.
The problem at the moment is that people are using HSG 247 the Licensed Contractors guide, as the up to date guidance - which was made under CAWR 2002, CAR 06 is more robust and stringent in its requirements.
A new HSG 247 is in the pipeline.
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Posted By MW
I know of a contractor who done an isolated enviro clean of a boiler house with no enclosure or air testing.
Just vacuumed up a couple of small bits of debris...my point is this, how do they know that the small bit they vacuumed up was all there was!? what about the other bits!
All debris samples taken were positive, none were negative so surly that would mean an environmental clean of the whole area was needed.
There are some cowboys out there!
MW
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Posted By Dave Wilson
If they get caught they will get a severe looking at by the HSE.
Sadly there are a number of companies out there who only accept a lowest quite rather than what is actually required to ensure the area is safe.
For licensed work
MS & ASB5 notify 14 days
brief the team
set the site up
build enclosure etc
pre clean
remove
Clean
4 stage clearance
certificate of occupation
clear site
It's that easy
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Posted By MW
Dave,
Your right and as an asbestos contractor myself, I know of the problems.
It all comes down to the might £. However, on a job we priced recently we came in second and soneone else was 'way' below us. They did ask the questions of the other company but the only response they got was;
'we havent lost money on a job yet...'
MW
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