This explains the waste and recycling inspection initiative for 2015 – 16 which targets waste transfer stations (WTS) and associated skip-hire activities where asbestos containing material (ACM) may be present in the waste. The primary focus is ACM handling but there will be a range of other activities (see Other Inspection Activities) that can also be covered during inspections.
WTS receive a wide range of waste and recyclates from municipal (household), commercial or construction/industrial streams, some of which may include ACM. These sites may be run by local authorities or major contractors, but are usually associated with SME operations.
The function of a WTS is to facilitate the transfer of small amounts of appropriately packaged ACM from delivery vehicles (such as small skips or properly modified small vans) directly into a lockable sealed skip (‘bulking up’) for onward transfer to other facilities.
Most sites receiving asbestos ACM waste do so under conditions permitted by the Environment Agency (EA), Natural Resources Wales (NRW) or the Scottish Environmental Protection Agency (SEPA).
Some WTS (permitted or not) may receive loads containing ACM when they should be asbestos-free, such as when ACM waste has been deliberately or mistakenly placed in the mix.
During 2014 - 15 inspections by HSE inspectors (some done jointly with the EA and NRW), identified evidence of poor ACM management and handling at WTS. High levels of enforcement ensued, for both asbestos-related issues and general health and safety topics (such as transportation, application of LOLER and machinery guarding).
EA & NRW in particular continue to be concerned that some WTS may be receiving ACM without permits and that many permitted sites may be operating with poor standards. These circumstances would give rise to health and safety as well as environmental concerns.
As was the case in 2014 – 15, EA & NRW officers will target WTS as a priority. Where practicable, HSE inspectors should visit jointly with EA and NRW officers. Local discussions should take place with SEPA to encourage similar involvement, or at the very least to inform them of our intention to visit these WTS.
The Waste and Recycling Sector Team at the start of the 2015-16 work year will supply FOD’s geographical division Heads of Operations with:
Asbestos is the single greatest cause of work-related deaths in the UK, responsible for around 4,500 deaths a year.
It was used extensively in the UK as a building material, especially for fireproofing and insulation, from the 1950s through to the mid-1980s. Any buildings (houses, factories, offices, schools, hospitals, etc) constructed before 2000 could contain ACM, so refurbishing or demolishing them can result in ACM ending up in the waste stream.
For licensed materials (lagging, insulation board, etc.) an HSE-licensed asbestos removal contractor must be used and in most instances this material will go direct to landfill. Occasionally, small amounts of licensed ACM may be received at a WTS and bulked up (placed in a lockable skip until it is full), before onward transportation to landfill.
Non-licensable materials (e.g. asbestos cements), may also go direct to landfill (most likely for large loads from a demolition site), but smaller loads do commonly end up at WTS. This material (which should be double wrapped or bagged) should also be bulked up before transportation to landfill.
The main legal requirements applicable to the asbestos work are the Control of Asbestos Regulations 2012 (CAR) which applies to work with licensed and non-licensable ACM. The specific areas of asbestos-related concern for WTS operations are likely to be:
A minimum of 225 sites should be visited nationwide. This equates to about 75 per FOD geographical region. Divisions may negotiate with each other to split the work to take account of staff ratios and other priorities.
The primary target is WTS sites permitted by the appropriate environmental regulator to accept asbestos waste.
Where sites do receive ACMs they should have suitable systems in place to reflect the risks of handling that material.
Some WTS (permitted or not) may receive loads containing ACM when they should be asbestos-free, such as when ACM waste has been deliberately hidden or mistakenly placed in a skip. The dutyholder should have suitable systems in place to identify and deal with such eventualities.
Information sources include the lists of permitted sites from Agencies (supplied by the Waste and Recycling Sector Team), local knowledge and any relevant COIN information.
WTS and skip hire process/activity will normally fall under SIC codes:
However, some sites may be incorrectly coded and found under other SIC codes:
Give priority to:
Within those categories the focus should be on:
Further indicators to help identify PLIs include:
The primary purpose of the assessment visits is to assess how the dutyholder deals with asbestos related issues. Previous experience, however, has indicated that there will be a number of other health and safety issues are likely to require attention at WTS. Typically, these include:
The initiative should be carried out during the 2015 – 2016 work year. Visits may be undertaken at any time spread across the full year or as part of phased initiatives to fit with local priorities and workloads.
Only staff who have received appropriate asbestos awareness training should take part in site visits.
It is expected that FOD B3 inspectors will carry out these inspections; however, B4 inspectors with the appropriate experience may also be considered for the work.
As appropriate, specialist inspector support may be required, particularly where follow up action in support of Enforcement Notices or Prosecutions is required.
Visits should take no more than 0.5 Band 3 regulatory contact time per intervention, ie, a total resource of 112.5 days Band 3 contact time. This does not take into account DIO activity, follow-up (eg enforcement) time, reactive work, or any input that may be required from Specialist Inspectors.
Normal COIN inputting arrangements apply.
Where ACMs are not encountered during the visit the COIN record should highlight this. In all cases an indication of the extent (e.g. frequently/infrequently/not at all) of reception of ACMs at the WTS should be recorded.
All waste transfer station (WTS) sites should be recorded under the appropriate SIC 2007 Code – 38.1, 38.11 or 38.12.
Inspectors should advise the Waste and Recycling Sector Team directly, preferably with copies of relevant photographs, letters, notices, etc, if they find:
The Waste and Recycling Sector Team will produce a summary report in the first quarter of 2016 -17.
Your health and safety comes first! If in any doubt leave the premises and make appropriate arrangements to return at a later date.
Please note the relevant Health and Safety Supplements available on the Internet under ‘Your Health and Safety’and in the Asbestos safety supplemen
English may well be a second language at many sites
Other Asbestos guidance:
HSE’s waste and recycling website, especially:
Inspection Topic Packs. The following may prove useful:
Environment Agency (EA) guidance – ‘Quick guide 215-2: Storage and transfer of asbestos wastes’. This document is not published on the EA website but copies are available on request from the Environment Agency. It will be made available to all DIOs and it may also be obtained on request from the Waste and Recycling Sector Team.
Agriculture, Waste and Recycling Sector, Waste Management and Recycling Team, HSE, Cardiff office.