Health and Safety
Executive / Commission
Education
Note issued to Directors of Education/Children’s Services in England and Wales, Directors of Education, Scotland, and to Governing Bodies of Foundation, Voluntary Aided and Independent schools in England and Wales, and Official Correspondents of Independent Schools in Scotland in October 2006.
1. A potential problem for exposure to asbestos fibres has come to light in certain types of CLASP constructed schools, specifically type 4 and 4B. This is an opportunity for you to take appropriate action to ensure that children, teachers and others are not exposed to asbestos fibres.
2. Hopefully the attached note Potential for Asbestos Fibre Release in CLASP Buildings: Guidance to Duty Holders 
October 2006 that has been agreed between HSE, LGE, and DFES is self-explanatory. Clearly the sooner the issue is dealt with the better. The upcoming half term (as well as out of school hours) should provide you with the opportunity to assess the situation in your schools.
3. You are reminded of your responsibility for the maintenance and/or repair of schools in your control as duty holder under regulation 4 of the Control of Asbestos at Work Regulations (CAW) 2002. This means that you should already know whether your schools contain asbestos, where it is and what condition it’s in. This includes managing it properly and when necessary telling those people who may disturb it that it’s there. Further detailed information for schools is available on HSE’s website together with more general asbestos guidance.
4. SCAPE are happy to liaise with individual Local Authorities to clarify which buildings are class 4 and 4B, and they have issued their own note on the SCAPE website. Also available to download is the SCAPE Asbestos Awareness handbook which contains detailed information about types of CLASP buildings and the types of asbestos products contained in them.
5. Please can you forward this information to the Governing Bodies and School Heads of Foundation Schools so that they are also apprised of the issue.
6. Contacts:
1. A Local Authority (LA) in Wales have discovered potential for exposure to asbestos in some of their 'CLASP' constructed schools. CLASP is the Consortium of Local Authorities Special Programme.
2. Mark 4 and 4b CLASP buildings were identified as a cause for concern regarding asbestos fibre release in foreseeable circumstances. However, this should not exclude other types of CLASP buildings e.g. asbestos material was also used in the construction of Mark 2, 3, 3b, 4, 4b and 5 buildings.
3. The schools are steel framed buildings, the steelwork being clad with asbestos insulation board (AIB), possibly for fire protection. The AIB itself is encapsulated with metal cladding, which in some cases is fixed to the AIB using screws. In some cases the AIB is fixed to the cladding rather than the steel beams. There are gaps in the metal cladding of various dimensions. In some cases the cladding is very loose. The AIB contains amosite.
4. It has been found that if the cladding is struck, asbestos fibre can escape into the room. The degree of escape of fibre varies. In some cases levels in the general atmosphere of the room are very low. But in others levels have been found that exceed the control limit. The striking was three or four sudden blows and is the kind of disturbance that is foreseeable in a school environment. Disturbance is also foreseeable when doors are slammed where the doors are adjacent to damaged AIB / loose cladding or where possible wind loading on replacement windows which have been fixed by screws directly into the steel columns which are clad with AIB. HSE sampling has confirmed sampling results found by independent Council funded sampling.
5. The disturbance was carried out under controlled conditions in a tented environment in which the negative pressure was switched off for the duration of the sampling. Personal samplers were worn during tenting. I understand levels were below clearance levels. So this provides some reassurance that during 'normal' conditions when the cladding has not been struck levels are not significant.
6. The standard of cleanup after construction at the schools visited was poor with off cuts of AIB being left in ceiling voids etc. The condition of cladding has deteriorated over the years and sockets and other fixtures have in some cases been screwed through the metal cladding and probably into the AIB. Window replacement was also carried out to a poor standard with frames screwed into the asbestos. All of these are likely to be ‘risk factors’
7. The mechanism of release is not clear. But in the worst cases it may be associated with the screws moving in the AIB abrading it, the striking of the cladding acting like a 'bellows' to disperse fibre. A number of factors are likely to be relevant to the degree of fibre release including damage to the AIB, overall maintenance of the building, gaps in cladding etc. HSE specialists are currently looking into this issue.
8. During construction it also seems that off cuts of AIB and debris have in some cases been swept into the gap between the wall and plasterboard stud partitioning or wall cladding. Skirting boards then sealed this debris in. When the plasterboard was struck fibre was again released through the skirting board gaps. Not all contractors will have been so cavalier in their approach so this issue may be limited in scope. Examination of another CLASP school of similar design has indicated a much better standard of construction – and a much better standard of window replacement. Release of fibre from struck cladding in this school has not been quantified but is likely to be much lower.
9. There are many thousands of buildings constructed under the ‘CLASP’ scheme. Of these a percentage will be constructed using this type of steel frame with AIB / metal cladding. The link below is to the CLASP/SCAPE website. SCAPE are now responsible for current buildings and have identified CLASP buildings constructed in the way described. A list is attached. The problem will be UK wide (maybe Europe wide). The number of CLASP schools varies hugely with some councils having dozens and others apparently none.
10. The Local Authority in Wales took the step of sealing gaps in the cladding using silicone sealant, expandable foam and other similar sealants. Sampling has confirmed that sealing using this method has been effective in preventing significant release of asbestos fibres.
11. SCAPE/CLASP will also be sending out a briefing note to all CLASP building owners.
Action required
12. As a priority you should identify the Mark 4 and 4b CLASP buildings under your control for attention. As described above, sealing gaps in the cladding using silicone sealant, expandable foam and other similar sealants has been found to be effective in preventing significant escape of fibre to levels below the clearance level. Initially this sealing/encapsulation work should be carried out below ceiling level. The work should be undertaken as a priority to mitigate any potential asbestos fibre release. Following this, monitoring for fibre release should be undertaken as reassurance.
13. Essentially, this is a duty under the Control of Asbestos at Work Regulations 2002, in that duty holders have responsibilities regarding the duty to manage asbestos which not only to requires them to assess whether asbestos is present but also to determine the risk and prepare and implement a plan for managing the risks which must be reviewed at regular intervals. There is more guidance available on HSE's web site.
14. A distinction should be made in terms of who would be competent to undertake this work. Sealing/encapsulation work as described in Appendix 1 attached is unlikely to disturb asbestos in these circumstances. Therefore carrying out this work below ceiling level can be carried out by non-licensed contractors as long as they have been trained and equipped as described in the appendix below. Work above ceiling level, in the ceiling/roof voids should only be carried out by asbestos licensed contractors because there is risk of asbestos contamination in these areas.
15. As mentioned above, asbestos material was also used in the construction of Mark 2, 3, 3b, 4, 4b and 5 CLASP buildings. These buildings should also be inspected and risk assessed as part of routine duty to manage.
16. For further advice/information: contact your local HSE office.
1. Methodology
Short-term solution
All gaps to column cladding, skirtings, and walls to be sealed to enclose the AIB dust and debris. Also UPVC finishing strips can be used as finishing over the top of the gaps using the same sealant. Following remedial works, air monitoring to be carried out to ensure enclosure/encapsulation of asbestos has been successful. Re-assurance air monitoring is then carried out on the basis of a risk assessment. Asbestos re-inspection surveys will also be required as part of the Asbestos Safety Management Programme.
Longer-term Solution
Use expanded foam to fill tops of the columns and cavity walls where they are open to the ceiling void above the suspended ceilings. This work should only be carried out by Licensed Asbestos Removal Contractors. Asbestos monitoring should be carried out on a regular basis in accordeance with regulation 4 of the Control of Asbestos at Work Regulations 2002, as part of an asbestos management programme.
Suitable induction training in relation to asbestos awareness should be provided to those managing this work and to all employees undertaking the work to ensure that they are competent to do the job safely. The training should include how to wear Respiratory protective equipment (RPE), and inform staff what asbestos is (the types) and what the risks and health effects are from exposure to asbestos.
Personal Protective Equipment
All employees involved in supervising or handling asbestos waste should be provided with suitable and appropriate PPE as a precaution only. Suitable PPE would include:
When putting on PPE remember to put the facemask on under the hood of the asbestos suit and not over the hood.