Asbestos in system buildings - duty holder checklist

Certain school buildings are called "system buildings" and have their structural columns fire-proofed with asbestos materials, which in turn are enclosed by metal casings or cladding. In 2006, HSE identified that asbestos fibres could escape from these metal casings if:

• there was damaged asbestos beneath the casing; and
• the column casing was vibrated in some way, e.g. by an adjacent door being slammed; and
• there were gaps or other openings in the casings.

When these gaps and openings are sealed - asbestos fibres cannot escape into classrooms.

If you have responsibility for the maintenance and/or repair of non-domestic premises such as schools, then you have duties as a ‘dutyholder’ under the Control of Asbestos Regulations 2006.

This means that you should know whether your premises, including system buildings, contain asbestos, where it is, what condition it’s in and then ensure that you manage it properly which includes telling those people who may disturb it that its there. Even if you are not the building owner but have some responsibility for the premises or its inhabitants you should be able to answer the questions in the checklist below.

In system buildings you should assume that asbestos materials are present around structural columns and beneath casings and claddings unless you know for certain that no asbestos materials are present. You should also be aware that steel-clad columns with asbestos insulation may have been incorporated into traditionally-built schools of the time.

Answering these questions will help you determine whether you are taking the necessary action or need to do more to manage the risks from asbestos in system buildings such as CLASP, SCOLA etc, as detailed in the CLASP guidance [153KB].

System Buildings

• Are you aware of the types of system building where asbestos-containing materials may be present within metal-encased columns and related areas?
• Do you know how many of these buildings you have and where they are (including traditional buildings of the time with the ‘system-type’ columns and cladding)?
• Have you visually inspected the buildings and identified where there are gaps in the column casing?
• Where windows have been replaced have you checked for any cuts that may have been made into adjacent column casings?
• Have you taken action to seal all gaps in the column casing, including as above and where items such as fire extinguishers have been fixed?
• Is further action still needed and, if so, when will it be completed?
• Have you replaced all broken or missing ceiling tiles in these buildings?
• Have you informed* all relevant staff where asbestos is likely to be present including potential contamination of ceiling voids, and have you provided them with instructions not to disturb such materials, lift ceiling tiles or access voids without appropriate protective measures?
• Have you recorded all action taken?
• Do you have arrangements for ongoing inspection, maintenance and repair of the seals and ceiling tiles as necessary?
• Have you advised school and other relevant staff of action to take if they find or suspect damage to column seals or ceiling tiles?
• Do you have arrangements in place to ensure an effective response to rectify any damage notified?
• How do you ensure that all persons, including visiting workers, who might disturb asbestos-containing materials e.g. wiring contractors, caretakers, etc are advised* of its presence?

General asbestos management arrangements

• Do you have an asbestos register for all premises containing asbestos-containing materials?
• Do you know the condition of asbestos-containing materials in all your buildings?
• Do you have a plan for managing the risks from asbestos and is this reviewed periodically?

*As part of your information sharing it may be appropriate to consider labelling areas where asbestos-containing materials are known or suspected to be present at your premises.