9. Examples of how asbestos risks can be managed
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The following examples describe typical situations where asbestos could be present. They show who is responsible at each stage for acting to effectively manage asbestos risks.
The HSE publication A comprehensive guide to managing asbestos in premises has more detailed examples of individual risk assessments.
A National Health Service Trust
An NHS Trust has more than 70 buildings, most of which it owns, but 15 are leased and some are rented for clinics. The Trust employs 35 maintenance workers and uses a number of building maintenance contract companies, and a preferred list of contractors.
During planned refurbishment of plant rooms, asbestos debris and overspray was discovered at the start of the site work. This was believed to have been left at the time of the original asbestos removal in the 1980s, but was not recorded on the asbestos register.
At another leased premises, a route for new network cabling was identified which avoided the asbestos-containing materials (ACMs). However, the cablers decided to use an alternative route through sprayed asbestos, resulting in several rooms becoming contaminated.
What the Trust did
To minimise the potential for any asbestos exposure in the future, the Trust recognised it needed to urgently review its asbestos management arrangements.
They also recognised the benefit of in-house asbestos expertise and set up a dedicated asbestos team and recruited a competent asbestos professional.
The team drew up an action plan which included a commitment to:
- review all existing surveys to identify any gaps in information and update the asbestos registers throughout the Trust premises
- undertake a risk profiling exercise of all plant rooms where ACMs were known or presumed present
- maintain ACMs in the short-term but set priorities for their removal in line with future works
- introduce a dedicated contact for contractors within the asbestos team
A risk-based colour coding system was also developed for plant rooms based on the type and condition of ACMs present. This informed the control arrangements for safe working of all maintenance workers.
These improvements to communicate accurate information on ACMs will help the Trust avoid repeats of the previous incidents.
Local authority – improving record keeping and information sharing
A local authority (LA) has approximately 35,000 properties under its control. Around 32,000 of these are domestic and the responsibility of the LA’s housing services.
Types of properties include:
- public buildings, such as leisure centres and libraries
- education buildings, such as schools and nurseries
- social services buildings, including day care centres and residential homes
- operational buildings, such as depots and workshops
Reports and records from previous asbestos surveys were kept and entered onto a corporate asbestos database.
Due to the database being used ineffectively, some properties had been surveyed more than once over the years, while others were not surveyed at all.
What the local authority did
The local authority worked with a software provider to develop a new system as their main asbestos management database which includes the asbestos register for the entire estate.
The database was designed to be compatible with the system used by the LA’s architectural and surveying service. This ensured that floor plans identifying the location of ACMs can be downloaded for maintenance workers when they are carrying out work on housing properties.
Some of the other key elements include:
- live asbestos information being updated to the register following re-inspection for example any repairs needed
- end user access to the system, such as site staff and contractors
- tracking of how a user has accessed the system including who the user is, when and what information they have accessed
- clear visuals such as plans and photographs designed to make identifying an ACM, or element of a building, easier
- users being able to select elements of a site, for example a block or room and download a mini report relevant to those locations
- the local authority being able to see historic data changes which is useful from a legal perspective
- links with the estate’s database so that the site or building changes are mirrored in both systems
The updates to the LA’s system meant specific asbestos information could be easily requested prior to commissioning works. This request is recorded on an audit trail system which ensures no request is closed down until all the required information is received. This also ensures that the system is kept up to date.
Facility management company – managing contractors undertaking unplanned or short-notice work
A facility management company has around 500 properties in its nationwide portfolio. The premises range from large offices to small individual buildings, many containing ACMs.
On any day, a building may require planned or unplanned maintenance work. Although there will be many refurbishment projects, there will be far more unplanned activities, such as the replacement of light fittings, a sudden failure of an air conditioning system, or a leaking radiator.
Any one of these activities could involve the disturbance of an ACM, leading to building workers and resident staff being exposed.
What the facilities management company did
The company developed a workable and effective system to control their maintenance contractors across their premises. This involved:
- any fault being nominated to a ‘responsible person’ for each premises who contacts the company help desk who then notifies the relevant contractor
- the contractor confirming whether ACMs are present in the work area by checking the asbestos register before arriving on site
- all contractors receiving asbestos awareness training and being told to stop work and contact the help desk if they suspect asbestos is present unexpectedly
An asbestos risk assessment will then be done to decide whether:
- the ACM must be removed by an HSE licensed asbestos contractor
- the work is undertaken by contractors trained in non-licensed work and uses HSE’s asbestos essentials task sheets
By sharing and updating existing information about ACMs, and ensuring all workers are trained correctly, the facilities management company can be sure that ACMs in their portfolio are effectively managed.
Independent school – HSE asbestos management inspection
The school has 18 separate buildings, some of which were built or refurbished using asbestos in the 1960s and 1970s.
They had been using the same surveying company to annually assess the condition of identified ACMs since 2010. Each time, the school was issued with a re-inspection report and kept these reports in the bursar’s office.
One year, the usual company was unable to attend so a different surveying company was contracted. They reported ACMs that had not been previously identified.
The school was visited by HSE inspectors as part of an asbestos management inspection programme who identified a number of issues, which resulted in an Improvement Notice being served.
The issues included the following:
- the new survey identified asbestos in the ceiling voids - which had never been inspected yet were not presumed to contain asbestos
- the asbestos management plan was incomplete and did not specify deputies to cover staff absences
- the asbestos register had not been updated following the issue of the re-inspection reports, instead 13 separate re-inspection reports were held
- no competency checks had been made of the longstanding survey company
- a lack of clear roles and responsibilities and effective training for key staff. For example:
- the bursar had been identified as the person with responsibility for holding and sharing information on the presence or location of ACMs but did not know where they were
- the head of maintenance had received no asbestos awareness training despite their work involving potential disturbance of ACMs
- there was no means for communicating information about the presence and location of ACMs to emergency services
What the school did
To comply with the Improvement Notice, the school immediately:
- presumed ACMs were present in all areas not previously inspected, until proven otherwise, and updated their asbestos register to show this clearly
- put together an ‘emergency grab bag’ containing an up-to-date hard copy of the asbestos register
They reviewed their existing asbestos management plan against HSE guidance to identify gaps in procedures and arrangements and the following:
- identifying who the dutyholder was, in this case the board of governors
- carrying out a training needs analysis to identify appropriate training for those who could disturb asbestos or have responsibilities for managing it
- ensuring suitable competency checks were completed before contracting a new survey company including whether accredited by UKAS for management surveys and re-inspections
- after any reinspection by the new survey company, the head of maintenance updating the asbestos register with photographs and material assessment scores. They also capture any new actions resulting from the reinspection
- carrying out an emergency response exercise to test their procedures in the event of accidental disturbance of ACMs once staff had been trained and provided with relevant site-specific information
The Improvement Notice was complied with and the school were more confident that they were effectively managing risk from their ACMs.