Hi Damian

The asbestos regulations give you the chance to take a conservative review and assume that the waste contains asbestos rather than sampling and getting the samples analysed.

So, your starting point is HSG264.

Which leads you to decisions:

1. Materials which you can reasonably assume NOT to contain asbestos.

2. Materials which can assume to be ACMs.

3. Everything else where in this case a Demolition/Refurbishment survey would be appropriate. [Probably very little of what is present]

So, you have corrugated sheets. They might NOT contain asbestos but it is probably easier, quicker and cheaper to assume they do.

So, then it's all about the cradle to grave documentation for the carriage and collection/disposal of dangerous waste that needs a paper trail.

As for the on site handling, I am fairly sure that one of HSE's numerous guidance sheets deals with AC sheets. In simple terms you need to assess the degree of damage and hence how friable the material is. Then take appropriate precautions. In simple terms apart from the edges of broken sheets, the asbestos should be well bonded within the cement. 

P

Hi Damian

Might not be the Client's fault that some flytipping has happened.

Could have been dumped before the Client took ownership. 

After that point in time what you do to protect against unauthorised access should be proportionate to risk, i.e. what is reasonably practicable.

...and fly tippers don't play by rules of reasonable practicability.

I would take the view that you should be expecting ACMs at ANY brownfield site, INCLUDING those which have been buried at some point in the past.

...and any competent Client would be setting aside a sum for dealing with this and other ground contamination when redeveloping a brownfield site.

When the insurance market tightened when it came to the potential for asbestos claims, my former employer (like others) went into risk averse mode and decided not to do anything that might involve "work with asbestos" within the meaning of the regs.

In practice that would mean never touching any project on a brownfield site, unless all the necessary site investigations had already been completed, but if you are in a business where part of your role will be likely to involve specifying the investigations that's not really a viable option.

Strangely the lawyers were entirely relaxed about our staff working on a project where much of the contamination was hexavalent chromium. Just about as deadly but didn't mean the dreaded A word!!!

If you are going to be working on similar projects going forward you might want to look at all the CIRIA guidance and training packages on contaminated land. All good for your CPD!