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Notifiable Non-Licensed Work (NNLW)

September 2015 - Essential maintenance is required

Essential maintenance work is required to HSE services and is scheduled to take place on 8, 10, 15, 17 and 22 September 2015. To minimise disruption this work will be undertaken between 6pm and 10pm. During this time the asbestos report forms will be unavailable. HSE apologise for any inconvenience.

All non-licensed work needs to be carried out with the appropriate controls in place. However, for some types of work , employers must meet additional requirements.  This is known as notifiable non-licensed work or NNLW, and requires employers to:

Is my work NNLW?

You will need to decide if the work you plan to do is licensed, NNLW or non-licensed in each case. This will depend on the type of work you are going to do, the type of material you are going to work on and its condition. Identifying the type of asbestos-containing material (ACM) to be worked on and assessing its condition are important parts of your risk assessment, which needs to be completed before you start work.

First, decide if the work is licensable or not.

If the work is not licensable, you then need to decide if it is NNLW.  To do this you must consider:

The type of work you are planning to do

The asbestos type

The material's condition

Examples of notifiable non-licensed work (NNLW) with asbestos

Minor, short duration work:

Removal of:

Examples of non-licensed work with asbestos

Removal:

  • of asbestos cement products, (eg roof sheeting and rainwater goods) provided the material is carefully handled/removed without breaking up; this includes work with asbestos cement which is weathered but not otherwise substantially damaged
  • of small areas of textured decorative coatings using suitable dust-reducing methods, to support other activities such as installation/replacement of smoke alarms and light fittings
  • without deterioration, of textured decorative coatings (eg if the backing board is carefully cut around to achieve virtually intact removal)
  • and re-attachment of loosely fixed (eg screwed) asbestos insulating board (AIB) panels in order to gain access to areas for other maintenance activities (eg under a bath to carry out pipework maintenance, or for access to a ceiling void for repair of lighting)
  • of an AIB door with asbestos fire proofing

Maintenance work:

  • involving asbestos cement products (eg on roof sheeting, tiles and rainwater goods)
  • involving asbestos in ropes, yarns and woven cloth
  • on asbestos gaskets or asbestos rope cords (including removal as part of repair and upkeep of equipment) if this can be done without substantial breakage
  • involving asbestos-containing thermoplastic and vinyl floor tiles, bitumen roof felt, shingles, damp-proofing coatings, and mastics
  • of asbestos-containing felt and paper
  • involving plastic paint coatings, PVC floors, panels and sealing compounds
  • on asbestos-containing conveyor belts/drive belts, bonded rubber, electric cables
  • of resin-based ACMs such as friction products (eg brake linings)

Short duration work:

  • to repair minor damage to AIB
  • involving drilling holes in AIB (eg when installing shelving)

Other work:

  • drilling of textured decorative coatings for installation of fixtures/fittings
  • encapsulation and sealing-in work on asbestos-containing materials (ACMs) that are in good condition
  • painting/repainting AIB that is in good condition
  • cleaning up small quantities of loose/ fine debris containing ACM dust (where the work is sporadic and of low intensity, the control limit will not be exceeded and it is short duration work)
  • on other materials containing asbestos (such as paints, bitumen, resins, rubber, etc) where the fibres are bound in a matrix which prevents most of them being released (this includes, typically, aged/weathered AC)
  • associated with collecting and analysing samples to identify the presence of asbestos

Further examples of non-licensed work are available in Asbestos Essentials.

Examples of licensable work

Work on:

  • removing sprayed coatings (limpet asbestos)
  • removal or other work which may disturb pipe lagging
  • loose fill insulation
  • asbestos millboard
  • cleaning up significant quantities of loose/fine debris containing ACM dust (where the work is not sporadic and of low intensity, the control limit will be exceeded or it is not short duration work)
  • on AIB, where the risk assessment indicates that it will not be of short duration

All non-licensed and notifiable non-licensed work with asbestos needs to be carried out with the appropriate controls in place, and those carrying out the work must have had the correct level of  information, instruction and training, to protect themselves (and others in the area) from the risks to health that exposure to asbestos causes.

If you determine that the work you are about to do is notifiable non-licensed work (NNLW), the section below on notification explains how you comply with the additional requirements.

Notification

Employers need to notify the relevant enforcing authority of any NNLW with asbestos:

Which enforcing authority to notify based on the type of premises/activity
Type of premises/activity Enforcing Authority
Shops, offices, separate catering services, launderettes, sport, entertainment and recreational activities, exhibitions, church or religious meetings, hotels, camping and caravan sites, wholesale and retail storage LA (Local Authority)
Factories and factory offices, civil engineering, construction and demolition sites, hospitals, research and development establishments, local government services and educational establishments, fairgrounds, radio, television and film broadcasting, sea going ships, docks, transport undertakings, domestic premises, quarries, farms (and associated activities), horticultural premises and forestries,  mines /quarries and offshore installations, licensed nuclear sites HSE (Health & Safety Executive)
Railways, railway lines, signal boxes ORR (Office of Rail and Road)

Designating areas

All areas where there is NNLW taking place must be designated and marked with a suitable warning notice.  These areas must be restricted to those carrying out the work. 

Food and drink must never be consumed in designated areas.

Medical surveillance

By 30 April 2015, all workers carrying out NNLW will need to have had a medical examination. Examinations will then need to be repeated at least every 3 years, as long as the worker continues to do NNLW. After April 2015, workers carrying out NNLW for the first time will have to have an examination before they can start such work:

Guidance for doctors conducting these medical examinations is available online.

Record keeping

Employers need to keep a register (health record) of NNLW with asbestos for each employee exposed to asbestos:

This must include:

Record keeping may be as simple as writing down the names of workers on the job on your copy of the notification or keeping copies of the notification form for each person carrying out NNLW work, as the notification copy will document the nature of the job and type of asbestos from which likely exposure can be estimated.

More detailed medical records will be kept by the doctor.

Registers of work (health records) must be kept for 40 years (and offered to HSE or the individual concerned should the business cease trading).

The need to record exposure does not mean that every non licensed task must have air sampling. There will often be published exposure figures or knowledge within the industry about exposures found at similar lower risk work done in the past. If a task is unusual, then sampling may be required.

Updated: 2015-09-08