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GUIDELINES FOR MANAGING ASBESTOS IN NON-DOMESTIC PROPERTIES

Asad Khan

GUIDELINES FOR MANAGING ASBESTOS IN NON-DOMESTIC PROPERTIES

The National Organization of Asbestos Consultants (NORAC) and the Asbestos Testing and Consultancy (ATAC) recently published joint research that concluded a far greater threat from legacy asbestos than previously anticipated. Read details about it if you missed our previous newsletter here.

In light of these findings, we’ve put together a summary of the guidelines for managing asbestos on your non-domestic property.

  1. Carry out an initial GAP analysis:

This identifies what is currently missing from your data and confirms what asbestos is identified onsite and what controls are currently in place. To comply with Regulation 4 of Control of Asbestos Regulation (CAR) 2012, the duty holder of a non-domestic property should ensure that the property has had at a minimum an asbestos management survey. This is required to identify the presence, location, and condition of Asbestos-Containing Materials (ACM) in the building allowing for the material to be managed properly. Following on from the management survey report and its recommendations is the requirement for an Asbestos Management Plan (AMP). Unlike the management survey report this is a “Legal Duty” and must be undertaken by Law. However without the management survey in advance it is very difficult to properly assess the asbestos on site. The AMP will be in place to guide you around anything asbestos related on site.


2. Assess the riskS:

Once the survey has been completed the first part of managing asbestos on site is to assess the risks. The risk of exposure to asbestos fibres needs to be assessed and the ACM given a “Material Risk Factor” based on the level of risk. High-risk materials, such as asbestos insulation or asbestos lagging, should be given priority and where risks cannot be safely managed the material should be removed or sealed in situ.

For management and re-inspection alongside the material risk assessment, a priority risk assessment is also undertaken to give a full picture of the material and risk. Once this has been confirmed an Asbestos plan can be completed.


3. Develop an asbestos management plan:

The AMP is provided to the client by the appointed asbestos contractor who will initially conduct the asbestos management survey. The appointed contractor will include all findings of ACMs within the building along with details of ACM present on site, develop an asbestos policy for the site, procedures to prevent or reduce exposure, emergency procedures, provisions of information, instructions, training, recommendations and required reinspection dates. The AMP will also include the details of the appointed site contact and the duty holder for the building.  The AMP should be available to all staff, visitors and contractors on site at all times.

The details of an AMP are tailor-made for each site depending on the type, extent, and condition of asbestos containing material (ACM) present along with the level of risk associated.

4. Re-inspection:

A re-inspection survey is required to comply with the AMP. If ACM’s have been identified within the building and are to remain in-situ, then a re-inspection survey must be commissioned by the duty holder. The re-inspection survey will periodically assess the continuous level of damage to each individual ACM over a timescale of once every 12 months. This inspection time frame may be increased or decreased depending on the overall risk of the ACM and the likelihood of disturbance and the expected degradation of the material.


5. Managed ACM’s:

As previously stated, ACM’s that are to remain in situ and be managed will be accompanied by recommendations. These recommendations can be determined by a number of factors such as the type of material and the location. At a minimum, low-risk ACM’s will be recommended to remain in situ and reinspected every 12 months.

Further recommendations are likely to include removal, encapsulation or enclosing. To further assist in providing an accurate recommendation a priority risk assessment can be carried out to determine which materials may be of greater concern. This can again be carried out by the appointed asbestos consultancy. The decision of how to manage any ACMs present in a non-domestic property is at the discretion of the duty holder, the appointed asbestos consultancy should be used to provide accurate information to assist the duty holder in this process.


6. Implement control measures:

Measures that can be put in place to assist with the management of ACMs in a property:  

  • Labeling of identified ACMs throughout the property.

  • Issuing a permit to work system.

  • Upskilling and training provided to staff as to the location of identified ACMs.

  • Developing an emergency action plan should an ACM be damaged.

  • Issuing exclusion zones.

  • There are many other control measures that may be put in place, this should again be discussed with the appointed asbestos consultancy to determine the best course of action for the property.


    CONCLUSION

By following these guidelines, you can ensure that you are complying with the legal requirements set out in CAR 2012 and that you are taking appropriate steps to manage and re-inspect asbestos in your non-domestic property. Keeping in mind this is a non-exhaustive list of details as per the CAR 2012 and provides brief details on how to manage asbestos on a property. To better understand how to manage asbestos on your property please get in contact and an experienced Asbestos Audit consultant would accurately guide you on how to manage your asbestos.


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