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Asbestos in the 21st Century
GOSH and ACS
Refurbishment & Demolition Works
• Prof R J Willey• BSc (Hons), PhD, FInstP, FIOSH, OSHcr, FRSA
• www.acs-env.com
• © Roger Willey 2012
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The Programme
� Asbestos Diseases & the Duty to Manage
� Asbestos Information: how to get it
� What to do with the information.
� What happened in April 2012 ?
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Section 1
Asbestos Diseases and the
Duty to Manage
What is Asbestos ?
A FAMILY NAME GIVEN TO THE FIBOUS FORMS OF A GROUP OF
NATURALLY OCCURING MINERAL SILICATE FIBRES.
Why was it used ?
� Good insulator against:
Heat, electricity, noise, vibration.
� Impervious to attack by:
Acid, weather, vermin
� Cheap to produce and import
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COMMON LOCATIONS IN PUBLIC
SECTOR HOUSING
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Who is most affected ?
� Not often a problem in privately built
houses/buildings
� A significant problem in publicly funded
housing stock/buildings.
� Therefore, a significant problem for L.A., H.A., NHS,
Edn. Est., MOD, etc - especially when built in 1950’s,
60’s, 70’s and early 80’s.
Public Sector Housing
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Prof Seaton (Aberdeen Univ)
� We are surrounded by asbestos products.
� Post mortem studies show that more than 60% of people in the UK have asbestos fibres in their lungs at point of death
(100% in our urban environments)
� It was nothing to do with cause of death.
What are the risks ?
INHALATIONOF ASBESTOS FIBRES CAN LEAD TO:
� ASBESTOSIS MASSIVE OVER
EXPOSURE
� LUNG CANCER
� MESOTHELIOMA “LOW LEVEL”
LATENT PERIOD BETWEEN 10 - 40 YRS,
typically 25/35
Asbestos: how dangerous?
HSE PROJECTIONS FOR ENGLAND & WALES
TYPES OF DEATH NUMBERS
� HEART DISEASE 165 000
� CANCER 140 000
� RESPIRATORY DISEASE 56 000
� HOME ACCIDENTS 4 500
� SUICIDES 4 000
� ROAD ACCIDENTS 3 000
� WORK ACCIDENTS 174
� ASBESTOS DEATHS 2 000
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Perceived v Real Risk
� There are 60 000 000 people in the UK
� At least 60% have asbestos fibres in their
lungs (Prof Seaton)
� There are at least 36 000 000 people in
the UK with asbestos fibre in their lungs
� If ONE fibre kills then ALL of these would
die of asbestos related disease
Perceived v Real Risk
� If ONE fibre kills then 36 000 000 die
� On average 30 years between exposure
and death
� Therefore 1 200 000 asbestos related
deaths per annum
Perceived v Real Risk
� Theory 1 200 000 Experiment 2 000
� The Scientific Age……compare
� One of them is wrong
� The experimental results come from post mortem studies: must be correct
� Prediction must be wrong i.e. theory is wrong
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Perceived v Real risk
ONE fibre kills ?
I think not!!!!!!
The 21st Century Problem
Asbestos related deaths
� Deaths were relatively constant at about 2000 per annum for many years.
� Death rate has more than doubled in the
past few years.
� Up from 2000 to just over 4100 last year
(2010)
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The PETO prediction
THE NUMBER OF ASBESTOS DEATHS WILL RAPIDLY INCREASE
OVER THE NEXT DECADE.
PEAK COULD BE AS HIGH AS 7500 P.A. (UP FROM 2000 P.A.)
0
1000
2000
3000
4000
5000
6000
7000
8000
2002 2016
Year
Death
s
Who are these people ?
� The additional deaths occur NOT in the
conventional group e.g. heavy industry.
� Deaths occur primarily in tradesman
e.g. electricians, plumbers, carpenters.
� Largest single group is “tradesmen working for
L.A.’s”
� We need new asbestos regulations to protect these
people.
HSE Asbestos Campaign 2008 on
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HSE Asbestos Campaign 2008 on
HSE Asbestos Campaign 2008 on
Roger’s Mesothelioma Cycle
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Roger’s Mesothelioma Cycle
break here
The Asbestos Regulations Nov 2002(no difference CAR 2006 or CAR 2012)
� Exactly same as old Regulations (1987), except
for Regulation 4 - effective May 2004 (note the time gap)
� Reg. 4 : duty to manage asbestos in premises.
� Duty is for non-domestic premises only except common
areas (do not forget Duty of Care of the HASAWA)
The Duty ?
� This is a Duty to Manage, not just a Duty to Survey.
� Carry out the survey (capture the
information)
� Give the information to the tradesman
before the asbestos is disturbed.
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What needs to be done ?
� management plan to give the information to
tradesmen before they start work.
� management plan to prevent work without
the information
Domestic Premises ?
� There is no Regulation 4 i.e. Duty to Manage
� However, there is a Duty of Care under
the HASAWA 1974
� Example of the “heating cupboard”
Who is the Duty Holder?
� Very crudely: the “person” who commissions the work
� Example 1
ACS at Clutha House
� Example 2
ACS at the Claremont Centre
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The Duty Holder?
� Stop and think
� Who is the Duty Holder in your
organisation?
� Are they defined?
� Do they have defined responsibilities?
� Are they trained properly?
Section 2
Asbestos Information: how to get it
The Asbestos Survey
� The asbestos survey and the asbestos register are critical in providing
information:
(a) for the safe management of the building and its occupants,
(b) for the safe management of tradesmen and construction workers
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The Asbestos Survey
� Now critical that everyone is singing from the same hymn sheet
i.e. a standard procedure.
� Hence the introduction of MDHS 100:
Surveying, sampling and assessment
of asbestos containing materials (2001)
Types of Survey (MDHS 100)
� Type 1 visual inspection only
� Type 2 sample suspect materials
� Type 3 intrusive sampling
Virtually all people have Type2 surveys
What Happened ?
� Lots of asbestos survey organisations, some very dubious.
� Suspect surveyors, suspect systems.
� Very poor quality surveys carried out.
� Asbestos materials missed.
� Wrongly identified
� Wrongly classified
� Poor advice to clients
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The Asbestos Survey
• What happened next?HSE Investigation.
65% of surveys not fit for
purpose.
What happened after that?
Replacement of MDHS 100
with HSG 264 Asbestos: Thesurvey guide (2010)
HSG 264
� Some changes for survey organisations.
� Significant changes for clients/Duty
Holders.
� Document really aimed at the Duty Holder
The Asbestos Survey
Some new names:
� Type 1 has disappeared.
� Management survey
� Refurbishment or Demolition survey.
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The Management Survey
� A Management Survey is the standard survey.
� Locate as far as is reasonably practicable
the presence and extent of any suspect ACMs which could be damaged/disturbed
during normal occupancy, maintenance,
and installation.
� Assess their condition
The Refurbishment or
Demolition Survey
� This is needed before any refurbishment or demolition work is carried out.
� Fully intrusive and involves destructive
inspection, as necessary, including areas
difficult to reach.
The Refurbishment or
Demolition Survey
� Disruptive and fully intrusive. (Section 53)
� Should only be conducted in unoccupied areas
(ideally building not in service).
� Under no circumstances should staff remain in
rooms when intrusive sampling is being
undertaken.
� Area must be shown to be fit for re-occupation –
visual inspection - if appropriate: air testing.
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Do we need a Survey?
Section 37-
areas not accessed or not inspected
must be presumed to contain asbestos,
unless there is evidence that it does not.
Do we need a Survey?
• Section 38
� non-asbestos substitute materials
specified by architect/Q.S. (plans)
� Unlikely to contain asbestos:
� wallpaper, plaster board, etc
� >1985 for AIB
� >1990 for decorative coatings
� >1999 building construction
Who does the Survey?
� Can be in-house personnel or 3rd party
� Surveyor MUST be competent.
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Who does the Survey?
Section 17
� HSE strongly recommends the use of
accredited or certified surveyors.
� The Duty Holder should not appoint or
instruct an independent surveyor to carry
out a survey unless the surveyor is
competent.
Who does the Survey?
Either
� UKAS accredited to ISO 17020
(note ISO 9001 is NOT sufficient)
Or
� Personal certification (sole traders/very small companies)
ABICS scheme (Asbestos Building Inspection
Personal Certification Scheme)
Who does the Survey?
� The ABICS scheme has collapsed.
� The only route now to demonstrate
competence is via UKAS accreditation.
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What do we Survey?
� In the non-domestic sector HSE expect every building to be surveyed on an
individual basis.
� In the domestic sector L.A.’s and H.A.s
have very large numbers of properties.
What is reasonable and practicable?
Do Remember
Section 38
� non-asbestos substitute materials
specified by architect/Q.S. (plans)
� Unlikely to contain asbestos: wallpaper,
plaster board, etc
� >1985 for AIB
� >1990 for decorative coatings
� >1999 construction
Surveys in the Domestic Sector
� A proportion of properties in each archetype should be surveyed.
� Exact sampling ratios can not be specified.
(HSE suggest starting at 5% of each group)
� Keep surveying each group until results
demonstrate consistency.
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A little bit of legislation
Asbestos Categories
� Asbestos insulation
� Asbestos insulating board
� Asbestos cement
� Asbestos vinyl tiles
� Textured coatings (artex)
� Asbestos rope
� Asbestos gaskets
Classification of Materials
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The Risk
Risk depends on the amount of fibres you can breath in i.e. the
airborne fibre concentration in f/cc.
The Clearance Indicator is“less than 0.010 f/cc”
The Risk
� Limpet 400 – 1000 f/cc HIGH
� AI 20 – 400 f/cc HIGH
� AIB 2 – 20 f/cc MED
� AC usually less than 0.5 f/cc LOW
� AVT usually less than 0.1 f/cc LOW
Working Procedures
� Asbestos Insulationmust use a licensed contractor
� must notify regulator at least 14
days in advance (and supply a method statement).
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Working procedures
Asbestos insulating board
major works: licensed contractor plus notification (as above)
minor works: 1 hour in 7 days, non licensed contractor,
no notification, trained, safe working procedures
Working Procedures
Asbestos cement
Non licensed contractor, no notification, no time limits, trained, safe working systems
Summary
AI lic. contr, notification
AIB >1hr lic. contr., notification
------------------------------------------------------------------
AIB <1hr non lic. contr., NO notification
------------------------------------------------------------------
AC non lic. contr., NO notification,
AVT no time limits
Rope
Gaskets
Artex some times, not always
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Who does the job, when?
Who does the job, when?
Who does the job, when?
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Who does the job, when?
Who does the job, when?
Who does the job, when?
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Classification of Asbestos Materials
� Who does the job (lic. or non-lic.)
� When the job starts
� How much it costs
� All depend on classification
� Does not depend on asbestos type or
concentration
A poor example of a survey
Loc.No.
SampleNo.
Location AreaSurveyed
Position AsbestosType
Quantity
1 1 G Floor Gym Ceiling Tiles Amosite 50 SQ M
2 As 1 G Floor Hall Ceiling Tiles Amosite 100 SQ M
3 2 G Floor Kitchen Red Floor Tiles Amosite 100 SQ M
A good Survey and
An Asbestos Management System
Loc No
SampleNo
Location AreaSurveyed
Position Product AsbestosType
Quantity Surface Vuln. Damage MatsRA
Priority
1 1 G Floor Gym CeilingTiles
AIB Amosite 50 M² Unseal High Good 6 1
2 As 1 G floor Hall CeilingTiles
AIB Amosite 100 M² Unseal Low Good 6 3
3 2 G Floor Kitchen RedFloorTiles
AVT Chryso 100 M² Good Med Good 1 2
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Section 3
What to do with the information
When would you access
the data base/Register ?
Will the work interfere with the fabric of
the building ?
No……… get on with it.
Yes……… interrogate the register
Types of Work
� Planned, pro-active work
� Requested, re-active work
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PRO-ACTIVE WORKS
� At an early planning stage consult the asbestos register.
� Decide whether work is major or minor asbestos works.
� Decide on type of contractor, pass on information.
� EASY ????
� But ONLY if the asbestos register is consulted FIRST.
RE-ACTIVE WORKS
No asbestos
• Request Help dB Asb (minor)
Desk
Asb (major)
Small nos. …………. hard copy
Large nos. …………. computer system
Information & Management
CRITICAL that information is given to tradesmen PRIORto start of works.
Give as part of purchase order or works requisition order or, in larger jobs, as part of the tender documentation.
If you have no information and you are suspicious…..
STOP
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Section 4
What has recently happened?
What has recently happened?
� Control of Asbestos Regulations 2012
� Made 27 February 2012
� Laid before Parliament 5 March 2012
� Came into force 6 April 2012
The DETAIL
� CAR 2012 is available now to download.
� As always, rather woolly and very difficult
to read.
� The detail (in understandable format) will
come in the Approved Code of Practise
� Promised “any time, soon”
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What has recently happened?
Major Change
� Change to classification system
Currently:
� Major works: notifiable, licensed contractor
� Minor works: not notifiable, non- licensed
contractor, trained, SWP.
The UK System (1983, 2002, 2006)
Basically this is a two tier system:
� Notifiable high risk work
� Non notifiable low risk work
The UK System (1983,2002,2006)
Notifiable works
� Licensed contractor
� Notify 14 days in advance
� Method Statement
� Medicals for staff (EMAS, every 2 yrs)
� Keep records for 40 years
� Trained staff (UKATA or equivalent)
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The UK System (1983,2002,2006)
Non notifiable works
� Non licensed contractor
� Start immediately
� Method Statement ????
� Trained staff (recently UKATA or equiv)
� No medicals, no record keeping
The UK System (1983,2002,2006)
� Low risk materials were exempt from the general requirement to use licensed
contractors
� i.e. exempt from the Licensing Regime
Why change?
The EU delivered a "reasoned opinion“
(in Feb 2011) that CAR 2006 did not
satisfactorily implement some
measures of Directive 2009/148/EC.
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Risk
� Limpet 400 – 1000 f/cc HIGH
� AI 20 – 400 f/cc HIGH
� AIB 2 – 20 f/cc MED
� AC usually less than 0.5 f/cc LOW
� AVT usually less than 0.1 f/cc LOW
This is actually a THREE tier system
CAR 2012
� High Risk: NO CHANGE
notifiable, licensed contractor, 14 days
� Medium Risk:
notifiable (< job starts), non- licensed
contractor, trained, SWP. CHANGE
� Low Risk:
not notifiable, non-licensed contractor,
trained, SWP. NO CHANGE
CAR 2012
New Category of work:
Notifiable, Non Licensed Work
NNLW
Work can be carried out by a non licensed contractor (as before), but
notification must take place
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NNLW - notification
� Completion of an online form
� New form is “ASB NNLW1”
� Form is available from “forms” section of HSE website
� No other route of notification will be accepted
� Notification must be before the start of work
NNLW – the contractor
Medical examinations:� Must include an examination of the chest and be carried out
by a registered medical practitioner (not EMAS)
� Carried out every three years
� Three-year implementation period (April 2015)
Registers of work (health records):� Must contain:
• Details of the individual worker
• The nature and duration of work with asbestos and exposure
• Dates of the worker’s medical examinations
� More detailed medical records will be kept by the doctor
� Registers of work (health records) must be kept for 40 years
This is a major change
Normal Work
� Exposure is SALI; and
� Exposure less than Control Limit; and
� The work involves:(i) short, non-continuous maintenance activities in which
only non-friable materials are handled;
(ii) removal without deterioration of non-degradedmaterials in which the asbestos fibres are firmly linkedin a matrix;
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Key Points
maintenance & firmly linked
Firmly Linked
AC, Artex, bitumen, plastic, resin, rubber, roofing felt, paper linings, cardboard, textiles, gaskets, washers and ropes
Note: firmly linked materials also regarded as non-friable
How will this affect me?
� Licensed work NO CHANGE
� Carry on exactly as you have been doing
How will it affect me?
� What was non licensed work now has to be carefully considered.
� Is it low risk work – do as you did before.
� Is it NNLW – carefully check your
contractor
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NNLW – the contractor
Check:
� Trained staff - UKATA or equivalent
� Medical Tests of staff
� Work Records
� Don’t forget the insurance problem
Who will be most affected?
� Organisations carrying out AC roof removal or demolition
� Organisations which deal with “non-licensed” rubble
eg AC
� Companies who carry out “larger-scale” removal of textured coatings
eg insurance related work
� Companies who do short-duration work on asbestos insulation
� Companies who do short-duration removal of AIB
eg demolition
Summary
� No changes to Duty to Manage, surveys or survey organisations
� No changes to asbestos major works
� Considerable changes to asbestos minor
works
� New category: Notifiable Non Licensed
Work (NNLW)
� New requirements for your NNLW
contractors
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I know it has been
a long, hard morning.
But, if you can save
just one of these then
it has been worth it!
Questions ?
� Roger @acs-env.com
� www.acs-env.com
