As we return to new ways and patterns of working, we will see our workplaces as well as our employees having to adapt. Space may see change in use and other areas of the building potentially opened to accommodate for a new future work style.
Precisely because it can be so easily overlooked, the Health and Safety Executive (HSE) titled asbestos as, “The Hidden Killer”. Where changes in space occurs, asbestos management must be part of your conversation and considerations.
Why has asbestos become an issue?
Asbestos is an abundant natural mineral that has many beneficial qualities that make it an incredibly versatile building material. It benefits from high tensile strength, heat, electrical and chemical resistance and can be used in its raw form or blended with other materials to produce a wide variety of building products. As a result, increasingly during the 19th and 20th centuries asbestos was widely used for and in buildings on everything from roof panels and insulation boards, to toilet cisterns and flash guards.
Unfortunately, over this time, it also started to be recognised that the fibres of this mineral pose a significant threat to the health and safety of those involved in the manufacture and use of asbestos related produces. Consequently, a series of bans on the use of asbestos in the UK started in 1980 with all forms of asbestos banned in 1999 for use in buildings.
Asbestos related diseases can, however, take many years to appear and despite the most dangerous forms of asbestos being banned from use for almost 40 years, the UK still sees approximately 5,000 people die every year from asbestos related diseases, making it our greatest cause of occupational deaths.
There are still many thousands of tons of asbestos in buildings across the UK today, which if managed correctly pose no risk to those occupying and maintaining them. How asbestos is to be managed is governed by The Control of Asbestos Regulation 2012 and associate guidance documents.
The HSE have recently launched its second Post Implementation Review of the regulations, to obtain feedback from those involved in the management of asbestos, on the effectiveness of the regulations. The previous Post Implementation Review undertaken in 2017, found that there may be further distinctions required between licensable and non-licensable work, but otherwise the regulations have proved successful at delivering on the objectives it set out. The findings of the latest Post Implementation Review are due out in late 2021.
Do I still need to carry out an asbestos survey?
The Control of Asbestos Regulations 2012 require those responsible for all or part of a building to identify all asbestos containing materials (ACMs), that are present within the building. If you have strong evidence to believe the building is free from asbestos (for example due to the age of the building or a statement from the original builders that no asbestos was used in its construction), there may be no need for a survey to be carried out.
An asbestos management survey is an important tool to help you make sure that you have an accurate asbestos register. A trained surveyor may be able to identify ACMs that you might otherwise have not considered to be asbestos containing.
A good asbestos management survey will detail areas where no asbestos is present. This can provide useful information for future building projects. A lack of evidence that areas being worked within are asbestos free, can cause considerable delay to the planned work. It is important that any surveys you carry out are properly planned, using a pre-survey plan as any areas not accessed must be ‘presumed’ to contain asbestos.
If for any reason you believe your existing survey may no longer be valid, needs updating or it does not cover some of the areas you need to access, you should consider as a minimum, a review of your current asbestos management and/or a further up to date survey.
What do I need to be doing to manage my asbestos?
A robust asbestos management system will help make sure that those working in or visiting your buildings, are kept safe from exposure to asbestos fibres. The starting point is to set out your asbestos policy, stating your intentions for the management of asbestos and how this will be achieved.
Once you have identified all your ACMs, it is important that these are put together onto a register, that can be readily made available to anyone who may come into contact with your ACMs. This could be building maintenance staff, contractors and the emergency services.
Where you employ people who may work in areas where asbestos is present, you should organise training that is specific to their role and on the type of asbestos present in your building. This may be as simple as a toolbox talk or general asbestos awareness training, but it may also require more in-depth management training, such as BOHS P405 for those with asbestos management responsibility.
Your management system should also include a regime of regularly checking the condition of your asbestos, to make sure it has not deteriorated or been damaged. You should also have emergency procedures in place should any of your ACMs become damaged or if new potential ACMs are discovered.
Do I need to remove all my asbestos?
It is a common misconception that all asbestos must be removed from buildings. In some sectors there has been a drive to make all buildings asbestos free, particularly in the education sector.
You should base all your asbestos actions/decisions on your asbestos risk assessment and management plan. These documents will highlight the relative risks associated with each of your ACMs, in terms of the likelihood that it will be disturbed and shed fibres that someone could be exposed to. In some instances, removal may be the best option, but this is not always the case, and it does come with additional risks too.
Removal of asbestos (especially friable materials which can easily shed fibres) is often a complicated process that requires:
- Specialist contractors;
- The use of independent air sampling analysts; and
- The sealing off parts of the building where the work is taking place.
It is therefore it can be a costly and disruptive process. We have supported several customers who have found their asbestos removal projects have not been carried out correctly, leading to additional cost and disruption further on for them. If managed correctly, regularly inspected and well maintained, asbestos containing materials can be left in place and will pose little to no risk to those occupying your buildings.
What do I do if I think I’ve discovered a previously unknown piece of asbestos?
If any works being undertaken in your building cause damage to materials known or presumed to contain asbestos, works should stop immediately. All staff should leave the area, it should be locked/sealed and signage put up to warn others not to enter the area.
You should organise for an independent asbestos specialist to inspect and if necessary, sample the material to determine whether asbestos is present and provide advice on further action to take.
Some minor works to repair ACMs can be undertaken by in-house teams, but most works including removal will require a licenced contractor.
While most reputable surveyors will endeavour to identify all ACMs or presumed ACMs in your building, unfortunately they can, and do get missed. Particular attention should be paid to any areas of your premises where your survey may indicate they were “not assessed” or “excluded” from the work they carried out.
With many of our buildings having undergone change over the last year and with the pressure to repurpose or utilise more of the space in a different way, your asbestos management needs to feature heavily in your considerations to minimise disruption and maintain the health and wellbeing of your staff and others.
Assurity Consulting is the UK’s leading independent consultancy specialising in workplace health, safety and environmental solutions. As your partner in compliance management you will reap the benefit of our more than 30 years’ experience of helping customers across a range of different sectors – manage their compliance responsibilities as effectively as possible. If you need any help with your health, safety or environmental compliance, or if you would like more information on the services Assurity Consulting offer, please get in touch.