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How can I help you comply with the Control of Asbestos at Work Regulations?
As we have already seen from earlier pages, the Control of Asbestos at Work Regulations 2002 lay down a legal duty for the duty holder of each commercial property to have an asbestos register compiled and maintained, and for any resulting asbestos found (or presumed) to be properly managed via a written plan of action. A comprehensive risk analysis will also need to be carried out to understand and control the possible release of asbestos fibres from the material identified on the register. However for a couple of hundred pounds (or less) I can do this for you.
Asbestos Register: this is basically a physical record of every piece of 'Asbestos Containing Material' (ACM for short) in your building(s). You are required to record its location, condition, extent, and surface treatment. You should also have a floor plan or building blueprint on which the ACM location is recorded. This is a legal requirement for such eventualities as the fire brigade attending the premises as they will ask to see it.
It is impossible to construct a register unless you can identify ACM properly and comprehensively. Can you do that? Properly trained asbestos surveyors work within a legal code for surveying called the MDHS100. A surveyor will carry out a survey to establish the ACM in the building and produce your register. There are three types of survey depending on what the client requires, and the reasons for conducting the survey (source - MDHS100):
Type 1: Location and assessment survey (presumptive survey) -
The purpose of the survey is to locate, as far as reasonably practicable, the presence and extent of any suspect ACM in the building and assess their condition. This survey essentially defers the need to sample and analyse for asbestos (or the absence thereof) until a later time. The duty holder (therefore) bears potential additional costs of management for some non-ACM.
Any material which can reasonably be expected to contain asbestos must be presumed to contain asbestos, and where it appears highly likely to contain asbestos, there should be a strong presumption that it does.
Type 2: Standard sampling, identification and assessment survey (sampling survey) -
The purpose and procedures used in this survey are the same as for Type 1, except that representative samples are collected and analysed for the presence of asbestos. Samples from each type of suspect ACM found are collected and analysed to confirm or refute the surveyor's judgement. Sampling may take place simultaneously with the survey, or as in the case of some larger surveys, can be carried out as a separate exercise, after the Type 1 survey is complete.
Type 3: Full access sampling and identification survey (pre-demolition/ major refurbishment surveys)
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The survey is designed to be used as a basis for tendering the removal of ACM from the building prior to demolition or major refurbishment. As a Type 3 requires destructive entry into all sealed or inaccessible areas, and therefore requires a high degree of specialist construction equipment to avoid wall collapses etc, I do not carry out Type 3 surveys.
Fibre Release Risk Analysis:
This is a legal requirement for the Duty Holder of the non-domestic premises to have since 21 May 2004. It should be produced as part of the survey, and is by PJ Facilities.
It is based on an algorithm laid down in the Control of Asbestos at Work Regulations 2002. PJ Facilities provide this risk analysis as part of all Type 1 Inspections, or Type 2 Surveys, and in an electronic format enabling the client to maintain it accurately thereafter should he wish to do so himself. The electronic version provided by PJ Facilities also changes the 'alert' colour automatically from green, to amber, through to red depending on the risk levels found thereby allowing 'at a glance' analysis of high risk areas for anyone not trained in the MDHS100 techniques.
On Type 1 inspections as no samples are taken, material type/composition is 'presumed' based on surveyor knowledge and in accordance with legal framework document MDHS100 which all certificated surveyors must abide by.
Management Plan: Every duty holder must prepare a written plan to manage any ACM in his building. It follows that a Type 1 survey will identify 'potential' ACM which has to be managed, which will be considerably more than the actual ACM found by analysis in a Type 2 survey. However a Type 2 survey will initially cost more due to the cost of laboratory analysis of samples taken.
The management plan must be available for inspection by the enforcing authorities (HSE, Local Environmental Health, etc), and must be used to train staff to avoid increasing the risks of the ACM found. PJ Facilities will assist with the production of this plan if required, and can provide a basic template to be used as a guide for production of your own plan. Please note the plan is your legal responsibility, and cannot be passed out to a third party entirely.
If I can be of assistance with your asbestos inspections or surveys, please call me on 0870 4422 037, or email to asbestos@pjfacilities.co.uk.
Related asbestos issues:
What is asbestos?
Am I a Duty Holder?
What are the risks?
What products contain asbestos?