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Lee3183  
#1 Posted : 12 June 2024 15:44:40(UTC)
Rank: New forum user
Lee3183

Please could someone help clarify if a type 1 asbestos survey (prior to the introduction of the Asbestos Regulations 2012) is appropriate to demonstrate compliance with the current regulatory requirements? 

My understanding is that the old type 1 and 2 asbestos surveys are not recognised following the implementation of the 2012 regulations, but a type 2 is the same as an Asbestos Management Survey. Therefore, I believe that type 1 surveys are no longer sufficient, but a type 2 survey that has been maintained through annual inspections would remain sufficient and compliant. 

The reason for the question is that a client has a number of sites that have type 1 asbestos surveys in place dating back to 2008. Annual inspections have not been carried out and therefore the condition of the presumed asbestos containing materials is unknown. The organisation I work for has been appointed by the client to carry out inspection, testing and maintenance on their properties. So, I need to understand if a re-inspection to verify the type 1 assessments by a UKAS accredited asbestos surveyor would be sufficient, or would a new asbestos management survey be required? 

Note, that a UKAS accredited asbestos surveyor has carried out a re-inspection at one of the clients sites, but it is based on a type 1 survey (so only a presumptive survey), and therefore I'm concerned that it is not sufficient. The re-inspection report does contain an asbestos register, assessment of risk, and an asbestos management plan. Based on my research, this appears to be compliant with the requirements for an asbestos management survey, however no samples or testing was undertaken and the whole of the premises were not surveyed. Only the areas where presumed to contain asbestos were checked. My understanding is that for an asbestos management survey to be compliant with the 2012 regulations, sampling and testing should be carried out to verify the type of asbestos material. 

peter gotch  
#2 Posted : 13 June 2024 15:02:06(UTC)
Rank: Super forum user
peter gotch

Hi Lee

I doubt that many competent asbestos surveyors would place much trust in any survey dating back to 2008 UNLESS done by their own company and clearly done to high quality standards.

I think that in theory you COULD do an HSG264 standard "management survey" without doing any sampling whatsoever, particularly for a srructure where all the elements date back to the few years before the use of chrysotile ACMs was finally abolished, so perhaps structure from 1995 onwards.

BUT, you would need to make lots of decisions to PRESUME the existence of chrysotile ACMs, EXCEPT where you could make a solid case to PRESUME the absence of ACMs.

....and you could apply a similar strategy to older structures by presuming those materials to incorporate amphibole (generally crocidolite or amosite) ACMs - which would then indicate more stringent precautions going forward than if any ACMs were solely chrysotile, and particularly so if the materials were either in relatively easily damaged locations or not in the best of condition at the time of survey.

....again with an exception - if the material could be dated to after the prohibition on use of amphibole materials then the PRESUMPTION could be the presence of chrysotile.

Ultimately it is for client and surveyor to agree the terms of reference, and in the medium terms it would not suit the client's interests to try and restrict the amount of sampling done to ensure relative confidence on the adequacy of a management asbestos survey.

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