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March 23, 2015

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Emergency procedures for asbestos removal

By Paul Clarke-Scholes

Asbestos removal is not an exact science and while the process has been continuously refined in the last 30 years since licensing was introduced things can still go wrong. For example:

  • Asbestos survey data can be missed by the surveyor
  • More asbestos can be found than previously indicated in the asbestos management plan
  • ACMs can be disturbed accidentally by refurbishment operatives
  • ACMs can be accidentally dispersed during the removal process
  • Visual Inspections and/or Air tests can fail requiring further remedial work, delaying hand-over of an area.

It is necessary therefore for procedures to be agreed and in place before maintenance or building work commences that can be implemented in the event of any of these eventualities. In fact it is a legal requirement detailed in Regulation 15 of the Control of Asbestos Regulations.

All Licenced Asbestos Removal Contractors (LARCs) have such procedures which cover all the typical scenarios which could cause serious/imminent danger such as:

  • Fire inside and outside the asbestos enclosure
  • Accident/injury
  • Uncontrolled release of fibre
  • Respirator failure
  • Loss of power to enclosure
  • Loss of water supply to the Decontamination Unit
  • Spillage
  • Water pollution

The procedures should address the asbestos risks and allow for returning the situation to a safe condition.

Recently, HSE have been focusing on the Analysts role. UKAS report that during their assessments of Analysts, approximately 80% of Stage 1 and Stage 2 examinations fail. Anecdotally, LARCs report that about 1% of their jobs fail. As the UKAS visits are supposed to be representative, there is a worrying disconnect between what should happen and what does. As a result of the additional attention from the HSE, analytical standards are rising, failures are getting more common with greater potential for disrupting refurbishment programmes. It is this disruption that is rarely addressed by the existing emergency procedures.

For example, here is a not uncommon scenario:

Asbestos Insulating Board (AIB) has been identified in the airing cupboard and bathroom of a 3-bedroom flat occupied by elderly tenants. The removal contractor estimates that a 2-person team will need no more than 6 hours to remove it. The Resident Liaison Officer (RLO) organises for the tenants to be decanted to a community facility for the day – and is present at 9am when the handover takes place and arranges to organise reoccupation at 5pm.

The removal works take longer than expected and at 4:30pm the Stage-2 air test fails – requiring a second environmental clean. This needs to be scheduled for the next day, perhaps because the analyst has commitment elsewhere, or the operatives do. Alternatively, by the time site is cleared there is no access to the bathroom or the master bedroom before 8pm when the occupant needs to takes their medication and go to bed. The RLO therefore needs to find alternative overnight accommodation for the tenants at short notice which is expensive, time-consuming and causes no little distress.

We therefore recommend that the RLO should be involved in the drafting of the contract’s emergency plan at the lead-in phase. This will allow them to have alternative accommodation in place and, perhaps more importantly, give them the opportunity to manage the tenants’ expectations. Perhaps a cut-off point of 4pm should be defined as the trigger point for organising alternative arrangements.

The emergency plan should also cover the asbestos survey phase – there are instances where intrusive works to sample materials have led to asbestos containing material being exposed that cannot easily or quickly be re-instated. The plan for the survey phase should include provision of a LARC and an analytical consultant to be on-call to attend within 2 hours. The RLO also needs to be involved as decanting and alternative accommodation for tenants may also need to be sought. The same arrangements can then remain in place in case of an accidental disturbance of materials during the refurbishment works.

Paul Clarke-Scholes is HSQE advisor for Clifford Devlin Ltd

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In this episode  of the Safety & Health Podcast, ‘Burnout, stress and being human’, Heather Beach is joined by Stacy Thomson to discuss burnout, perfectionism and how to deal with burnout as an individual, as management and as an organisation.

We provide an insight on how to tackle burnout and why mental health is such a taboo subject, particularly in the workplace.


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