Asbestos and Site Investigations...Compared with asbestos removal in buildings – the risks are...

Asbestos and Site Investigations Control of Asbestos Regulations 2012:

are we doing enough to comply?

Brownfield Briefing ConferenceEffective Site Investigation and Data Management

De Vere Colmore Gate, Birmingham B3 2QDWednesday 24th May 2017

© Remedia Group Limited, 2017 1

Steve Forster B.Sc., M.Sc., CEnv, FGS, MIEnvScDirector, Remedia Group Ltd/Chair, JIWG

Summary

• CAR-SOIL industry guidance: an overview

• Key drivers for safety on site

• Understanding risk from asbestos in the ground• Understanding risk from asbestos in the ground

• Planning to prevent and/or minimise the risk of exposure to asbestos

• Addressing the capability gap: training and competence


“A little learning is a dangerous thing”An Essay on Criticism, Alexander Pope, Poet, (1688–1744)

Quotes to Summarise …

An Essay on Criticism, Alexander Pope, Poet, (1688–1744)

or

“Risk comes from not knowing what you’re doing”Warren Buffett, US Investment Entrepreneur, 1930–


“If we are technically not setting out to look for asbestos, then CAR 2012 don’t apply, no?”

Anon, 2017

Recently overheard …

Anon, 2017

and

“We consultants are all suited and booted, RPE and all, doing the right thing, but the drillers …”

Anon, 2017


My Own Initial thoughts …

• Are we able to identify the hazards?


• Are we able to identify the hazards?• Do we fully understand the real potential risks?• Can we predict the future, 15-55 year latency?• Do we understand the implications of low level

exposure on mortality for our industry?• What is a ‘safe’ level in air?• 0.1 – 0.01 – 0.0001 f/ml (100K - 10K – 100 f/m3)

Sobering thoughts …


Sobering thoughts …


Asbestos on Brownfield Landwhat to expect?

• We know what we know!• 9 in 10 sites …?• Most derelict, abandoned sites where ACMs used• Unregulated waste deposition on-site; fly-tipping


• Unregulated waste deposition on-site; fly-tipping• ALG 02/08 (CAR2012 Reg. 7(3)) – retention of

bonded ACMs prior to demolition; reuse of crush as hardcore

• Continued importation of contaminated materials• Visible vs. invisible; ACMs vs. free dispersed fibres?

Overviewbackground to CAR-SOIL:

• Consider asbestos-soil matrix effects• Risks the same as equivalent materials in buildings?• How to comply?


Overviewbackground to CAR-SOIL:

• Best available, definitiveguidance

• Eliminates uncertainty; levels the playing field


levels the playing field• Tools to reduce risk; health

and commercial• Increases confidence• Applies in E, W, & S (HSE)• Well-received by industry• www.claire.co.uk/asbestos

~9000 Downloads

http://www.claire.co.uk/asbestos

Statusindustry guidance, not ACoP …

• CAR-SOIL only ‘industry guidance’, but:

• “The HSE provided support to the JIWG in producing this guidance, which is aimed at improvements within the brownfield and contaminated land industry.”


brownfield and contaminated land industry.” • adopted by HSE Construction Division (Asbestos

Inspectors, Licensing) • minimum required to comply with H&S law …• … in conjunction with parts of ACoP L143• also touches on environmental compliance, so likely to be

required by other regulators

Target Audiencewho needs to understand and use this industry guidance?

• Geoenvironmental consultants• Ground investigation workers• Demolition and construction workers• Waste processing and recycling plant operators• Waste processing and recycling plant operators• General groundworkers• Construction plant operators• Land remediation contractors

• Managers, supervisors of the above• Clients, regulators, key stakeholders© Remedia Group Limited, 2017 12

Application of the Regulations…requirement to comply with CAR 2012

• All work with asbestos in or on land contaminated with asbestos, even NLW, must be carried out under all of the requirements of CAR 2012, except stated NLW exemptions when they apply, including:


NLW exemptions when they apply, including:• Ground investigations and land surveys• Soil testing/sampling• Land remediation, including ground improvement• Excavations and earthworks• Land-related ‘maintenance’

operations

Activities by Risk and Exposureground investigations: are asbestos hazards present?

• ACM fragments/free dispersed fibres?• How can we tell? Site Assessment? • Air Monitoring?• All of these activities may raise dust and generate


• All of these activities may raise dust and generate subsequent airborne fibre levels – if asbestos hazards are present• Preliminary site survey; walkovers• Trial pitting and trenching• Core sampling using powered equipment• Drilling; cable percussive, rotary, air flushing• Sample collection, coning and quartering• In situ testing and laboratory analysis

Work with Asbestos in Soil/C&D Materials the need to address several fundamental issues…

• What is an asbestos-contaminated ground material?

• When do CAR2012 apply?


• When CAR2012 do apply, can the licensing regime be relaxed to account for the fact that …

• ‘Soil and C&D materials contaminated with asbestos insulation and coatings are unlikely to present the same degree of risk as the equivalent materials in buildings, especially when naturally wetted.’

Asbestos in Soiloccupational risk during groundworks

Compared with asbestos removal in buildings –the risks are significantly lower

• Airborne levels rarely exceed 0.01 f/cm3

• Work is not directly breaking up and removing ACM


• Work is not directly breaking up and removing ACM - mostly investigation, involving low intensity disturbance ACM in bulk/host material which is wetted

• The frequency and duration of asbestos in soil SI work is generally lower than working in buildings where ACMs are present

Identification of the Presence of Asbestos…before work liable to disturb asbestos in the ground begins

• Regulation 5 requires a preliminary assessment of relevant information

• Must consider whether asbestos could potentially


• Must consider whether asbestos could potentiallybe present on or in the ground …

• … as might a relevant planning condition!

Identification of the Presence of Asbestos…before work liable to disturb asbestos in the ground begins

• SI and soil testing/sampling = NLW; compliance with Reg. 10 IIT

• Qualifications, skills and experience required = competence ...


• BS 10175 and CLR 11• … National Quality Mark Scheme! • … National Brownfield Skills Framework!

• Insurances!• Other person’s duties under CDM 2015?

Assessment of Work…which exposes employees to asbestos

• Regulation 6 requires employers to carry out a risk assessment to identify the risks of exposure to asbestos; and

• Record any significant findings and put in place steps to


• Record any significant findings and put in place steps to prevent, or reduce, exposure to employees

• Links with Reg. 11(1) primary duty to entirely preventthe exposure of employees to asbestos, SFARP

• If not possible, .e.g. due to job description, exposure must be reduced to lowest level reasonably practicable

Assessment of Work…which exposes employees to asbestos

• Must identify how employer will achieve this; so, it is not just a matrix, written by competent person

• Also covering any other, i.e. non-asbestos-related risks under Reg. 3 of the MAHASAW Regulations 1999


under Reg. 3 of the MAHASAW Regulations 1999

• Before work starts, suitable and sufficient assessment of exposure risks and steps to be taken to comply

• Assessment must be ‘dynamic’; i.e. be ‘responsive and adapted in the light of changing circumstances’

Plans of Work…written plan of work = method statement!

• Regulation 7 applies to all work, e.g. surveys, investigations, sampling

• Should set out what to do in event of unacceptable risks to health and/or safety are discovered while work is in progress …


work is in progress …• … e.g. disturbing hidden, missed or incorrectly identified

asbestos; unexpected or ‘materially different’ conditions.

• Employer should stop any work affecting the asbestos, except:• to put suitable controls in place and prevent further

spread; emergency procedures.

Plans of Work…what is in a written plan of work?

• POW must include the following information: • nature and probable duration of the work;• number of people involved in the work;• address and location where the work is to be carried out;• methods to be used to prevent or reduce exposure to


• methods to be used to prevent or reduce exposure to asbestos, e.g. prevention and control measures and arrangements for the handling and disposal of asbestos waste;

• type of equipment, including PPE and RPE, used for:• protecting and decontaminating those carrying out

the work; • protecting other people present at or near the

worksite.

Work with Asbestos…assessing the hazard and; work categorisation

• Watch Point 8:

• JIWG Work Category Spreadsheet – DST• Qualitative hazard and risk ranking phrases


• Qualitative hazard and risk ranking phrases• Structured, comparative, based on HSG264 and

HSG227 • Simon Cole, AECOM/Garry Burdett, HSL• Risk assessment and licensing status for POW• Real and assumed data; model scenarios = ‘what if?’• Plan for the reasonably foreseeable and unexpected

Work with AsbestosJIWG Work Category Spreadsheet – DST






Asbestos in Soil and C&D MaterialsJIWG Work Category (Asbestos Licensing) DST …

• For use by ‘competent persons’ to undertake qualitative risk assessments for asbestos POWs

• Matches risk, licensing status, to controls• RPE – to reduce exposure to SFARP


• RPE – to reduce exposure to SFARP• Dust Suppression – to prevent spread/reduce exposure• Personal Decontamination – to prevent spread

• Indicative – a starting point• May increase if local circumstances indicate stricter

controls advisable• Precautionary principle

Asbestos in Soil and C&D Materialsrisk factors to be considered – JIWG Work Category DST …

• ACM type or ‘free dispersed fibres’ mixed-in• Weathered, intact, degraded, disaggregated• Friability - ability to escape to air (or bonded?)• Distribution across site surface (and at depth) -


• Distribution across site surface (and at depth) -occasional, sporadic or gross/major?

• Amount (quantity)• Type of work activity is expected and the duration?• Exposure levels (air concentrations)• Matrix/host material type• Respirable fibre index for ACM (RIVM)

Working on Soil and C&D Materialshow do we avoid exposure to asbestos in the ground?

‘Lines of Evidence’:

• Pre-demolition asbestos surveys• Asbestos removal verification• Previous Phase 1 and 2 reports


• Previous Phase 1 and 2 reports• Remediation Strategy• ‘High risk’ site?• Site walkover; required to inform POW• Is asbestos likely to be present?• If so, types, form, amount?• Assessment of hazard and risk, as well as licensing status:

JIWG CAR Work Category and Receptor Risk DSTs?

Prevention/Reduction of ExposureCAR 2012 Reg. 11

‘Requires employers to prevent exposure to asbestos. If not possible then reduce exposure to as low as reasonably practical’.


• Methods used to achieve this end must be documented in the Plan of Work (Method Statement) (Reg. 7)

• Must assume potential for asbestos to be uncovered and plan effective contingencies

Prevention or Reduction of Exposureexample of use of PPE/RPE on site

• Note PPE and RPE:• Cat 3/Type 5• Orinasal• Glasses


• Glasses• Gloves• Boots• Helmet• Monitoring• Barriers

Photo courtesy of VertaseFLI

Competenceasbestos in soil and C&D materials …

• Need clearly-defined skill sets for addressing asbestos in, on or under the land

• Geoenvironmental and Asbestos sectors must skill up to meet expectations and demands … PII/claims!


up to meet expectations and demands … PII/claims!• Much asbestos training may be required, TNA• Appropriate and adequate IIT by competent trainers• Asbestos Awareness and NLW for any employee

whose work may disturb asbestos in the ground• Management training essential to avoid pitfalls

(technical and commercial)

CAR 2012 Reg. 10: IITrecognised asbestos training courses

• Asbestos awareness (for groundworkers)• NLW, including NNLW (for groundworkers)• BOHS Proficiency Modules• ARCA/ATaC• All courses examined/require pass


• All courses examined/require pass• CL:AIRE listed on HSE website as recognised training

provider for asbestos in the ground• CAR-SOIL, AA and NLW for land contaminated by

asbestos available from CL:AIRE• www.claire.co.uk/projects-and-initiatives/asbestos-

training• Other courses, etc. to broaden knowledge

http://www.claire.co.uk/projects-and-initiatives/asbestos

ASBESTOS AWARENESSONLY:

FOR WORK WHERE


CAR-SOIL DEFINITIONOF ‘TRACE’ APPLIES!

Thank you for listening …

… contact details

Stephen Forster, Remedia: [email protected]

@RemediaGroup

Join the discussion on JIWG Asbestos in Soil and Construction & Demolition Materials


mailto:[email protected]

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