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Repair & Refurb Asbestos Management by Bryan Goodayle, Senior Asbestos Consultant, Cromwell Associates
It amazes me that people who manage big projects, high budgets and large work forces want to shy away from asbestos in fear or uncertainty. In my experience working with large corporate businesses or even one man companies it is not normally the former but more likely the uncertainty that makes them nervous. When a company produces a good product they are seen to be experts in their field. When they want to deliver their product rather than do it themselves they go to a packaging company who are experts in providing the packaging material that they need and they use a transport company who are experienced in the logistics of moving products around the country. Why then, if they are uncertain as to the regulations and dangers of asbestos do they try to ‘do it themselves’ rather than go to an asbestos expert? Asbestos related diseases kill over 4000 people each year and the regulations we have in place are there to help reduce this number.
Talking of regulations, from 22nd April 2012 the new Control of Asbestos Regulations (CAR 2012) were issued. These regulations include three main areas: 1. A new class of asbestos - Notifiable Non Licensed Work (NNLW) 2. The need to provide medicals for all personnel who work with asbestos 3. Maintain a register of work (Health records) for all personnel who work with asbestos. The regulations also reinforce the need to ensure that not only do you have to have an Asbestos Register in place but to ensure your asbestos is managed on a regular basis.
Whether the asbestos is NNLW or not will depend on certain factors including what work you are going to carry out, what type of asbestos it is and how friable it is (this means how firmly the asbestos is bonded into a matrix like cement, paint or plastic). Also, is the material in good or poor condition and is further deterioration likely during the removal process? With this information you are now in a position to produce a risk assessment which will be needed prior to any work commencing. From this risk assessment you will make a decision as to whether in ‘your opinion’ the asbestos is NNLW or not. The danger here, however, is will ‘your opinion’ be the same as the HSE inspector’s when he comes to inspect your work. The essence of the regulation is to identify if the work you are going to do, on the non licensed asbestos, will degrade the asbestos to the extent that fibre loss will occur. You will see from the diagrams that the HSE provide that there is not a clear dividing line between NNLW and non-licensed. This is why a risk assessment is vital in formulating your opinion. Whatever you decide, remember, all work with asbestos needs to be carried out with the appropriate controls in place and work with licensed asbestos can only be carried out by a licensed asbestos contractor.
The second part of the new regulations concerns your personnel and the need to provide medicals. Whilst this does not come into force until 30th April 2015 you need to start looking into how you will achieve this. A medical must be carried out every 3 years by a licensed medical practitioner and a certificate must be supplied which will be at your cost. The third area to conform to is the Health Records. You must keep an estimated record of the exposure time for each employee, the nature of the work and the duration. This information is to be completed every time an employee works with asbestos. These records must be kept for 40 years and offered to the HSE or the individual should the business cease trading.
Finally, if all that is not daunting enough, you have the challenge of managing the asbestos you have. As stated at the beginning it is not sufficient to have a register of asbestos and then to ignore it. You must formulate a Management Plan that sets out how you are going to manage your asbestos and follow it through with inspections, recommendations and notes in chronological order for each date an inspection takes place. The time between inspections is your choice but should not exceed 12 months.
With all this in mind, and knowing how busy people are these days, it must be more sensible to employ experts in this field. A word of caution, however, before you all go rushing off to find that company - test the market! Some companies use the word asbestos as a license to print money. Thankfully, however, they are few and far between but it is best to get comparative quotes and to see what they offer. For example we offer a fully interactive web based software that enables us to manage your asbestos. We also provide a full consultancy service within our price.
So, next time before you vacillate when the word asbestos is used, pick up a telephone and let the experts handle it.
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www.cromwell-associates.co.uk 01462 707600 15
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