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#1 Posted : 30 June 2009 11:57:00(UTC)
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Posted By Derrick Robinson We have a problem over the transport of some fibre cement asbestos sheets and if there are any experts on waste transport I would much appreciate some advice. We are a construction company and we have a division which supplies agricultural buildings. We have a building erected some 20+ years ago when fibre cement sheets containing asbestos were still available and the roof is constructed of these. The building is now leaking, it is suspected that the sheets are faulty and they were covered originally by a 30 year guarantee. The manufacturer is still in business (though obviously not using asbestos these days) so we have a potential claim. The proposal is to remove a small number of sheets from the building and replace them with a none a/c alternative, the removed sheets would then be brought back to our works for examination by the manufacturer. We hold a waste carrier registration but we are not authorised to hold or process hazardous waste at our premises. The sheets will eventually be removed from us by a licensed contractor to a registered site and if we do eventually have to strip the whole roof we will have a contractor remove the waste direct from site. My questions are: - Are these sheets waste at this stage or will they become waste after they have been examined? (they will not go back on to the roof regardless of the results of the examination). If they are waste am I allowed to transport them from site to our works under my existing carrier licence and am I allowed to store them here for a few weeks whist investigations take place? I think they are waste and we cant move them, but there is a substantial financial cost involved here and I need to be sure of my ground. Any help would be appreciated.
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#2 Posted : 30 June 2009 12:02:00(UTC)
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Posted By Haggis JM I would also check your insurance as I suspect your own vehicles won't be covered for asbestos...
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#3 Posted : 30 June 2009 13:02:00(UTC)
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Posted By gerry d Once removed from its existing position it is deemed to be waste (hazardous). Therefore, it will be waste if you deal with it in the manner you have outlined. You cannot transport it either because you are not licensed to carry hazardous waste. Thirdly, although this is superfluous, you can`t keep it at your premises as you are not an approved waste transfer station. Hope this clarifies things for you.
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#4 Posted : 30 June 2009 13:03:00(UTC)
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Posted By Les Welling My advice is to contact the EA soonest! Les
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#5 Posted : 30 June 2009 13:53:00(UTC)
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Posted By Fred Pratley Can you leave them on the site in a secure place double bagged and properly labelled) and have the manufacturer come and inspect them? If not, I do not believe that the EA would have any issues with you moving them and holding onto them at your site pending inspection, provided you have a fixed date for it and it is a "one off". It is almost certain the EA will have been asked about this or something similar and it is worth talking to them.
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#6 Posted : 30 June 2009 14:05:00(UTC)
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Posted By Glyn Atkinson Polite question - can they be removed in complete sheets without fear of fibres ecaping during any movement of the sheets from height to floor and hence inspection area? If not, then surely there is the need for a licensed bonded contract firm removing the sheets and glue sealing any suspect areas prior to lowering to ground level?
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#7 Posted : 30 June 2009 14:15:00(UTC)
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Posted By Colin Reeves A simple question, why transport them to your site for examination? If they are asbestos, any examination would be better done by the manufacturer in situ. Then you can decide if they are to stay or be removed - in which case a licensed contractor to do the removal. Seems that your proposed double handling is creating a potential hazard that can be avoided by an on site visit. Colin
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#8 Posted : 30 June 2009 15:34:00(UTC)
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Posted By gerry d As soon as you detach even a small number of sheets, they are waste and should be handled and transported accordingly. Be careful of any advice to the contrary. Contacting the EA is also a good idea. You might also think about getting advice from the HSE on this one. Keeping them on site is a good idea. Why can`t the manufacturer see them in-situ (and in context!)
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#9 Posted : 30 June 2009 16:03:00(UTC)
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Posted By Derrick Robinson Thanks to you all for the advice. Plan has now been changed to keep the sheets on site pending direct removal by a licensed waste contractor. Thanks and Regards. derrick
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#10 Posted : 30 June 2009 16:12:00(UTC)
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Posted By Peter Zunda You need to take a good, long look through the free material available on the HSE Asbestos Essentials website here; http://www.hse.gov.uk/asbestos/essentials/ There's copious information and guides available which would cover removal of the asbestos sheets.
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#11 Posted : 30 June 2009 18:46:00(UTC)
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Posted By andymak Working as I often do on the keep it seriously simple (KISS) principle why can't the sheets you remove be quarantined on site and the manufacturer check them over there. They then don't have to be moved around. If they do however have to leave site then I would say they are not waste until the research on them has been completed.
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#12 Posted : 01 July 2009 09:50:00(UTC)
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Posted By Dave Wilson AS soon as they are removed they are 'Waste' they have to be double wrapped / bagged in polythene and transported to a Waste Landfill site which accepts 'Bonded' asbestos waste, info EA website for current list. The waste technically is still in transit but should be deposited ASAP as if you don't you are operating a 'Waste Transfer Station' and you need a licence from the EA to do this! They have to be stored / transported in a sealed skip / van / lorry and transported as Hazardous Waste under the Hazardous Waste consignment procedures , These can be downloaded from the EA website for free. Bonded Asbestos waste is NOT 'dangerous goods' under ADR and CDG (Special Provision 168 exempts) so do not have to comply with ADR & CDG regs. hope that helps
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