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March 2, 2015

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Interpreting asbestos survey exclusions

CIMG3957By Paul Phillips

While asbestos surveyors are trained in, and provided with, basic tools to carry out minor reinstatement they are not building operatives and, as such, there will be instances when they will not be able to access certain areas that are obscured by permanent or semi-permanent interior features of a property such as:

  • MMMF pipework insulation – surveyors will make representative examinations but there remains a risk of later discovery during demolition/refurbishment.
  • Concealed voids – there may be materials hidden within structural elements which will only come to light during the actual demolition process.
  • Access for the survey may be restricted e.g. height, inconvenience to others, immovable obstacles (appliances, tiling, units etc) or confined spaces.

The guidance for how we report these locations is very explicit. HSG264 Paragraphs 53 and 54 deal with this. The key statements emphasise that the surveys are intended to locate all the asbestos in the building “as far as reasonably practicable” and that “the ‘surveyed’ area must be shown to be fit for reoccupation before people move back in”.

If the surveyor is unable to access a location without causing significant damage that would leave the premises unfit for occupation/re-occupation then we are duty bound to identify these locations as inaccessible and exclude them from our report.

This has caused us issues in the past with the building contractor who is, perhaps understandably, reluctant to allow his building operatives to work on areas that are excluded by the report and potentially expose them to ACMs.

There are 2 possible solutions to this issue:

  1. The contractor provides a fitter who accompanies the asbestos surveyor and provides opening-up works and any reinstatement required
  2. The licenced removal contractor provides trained operatives who accompany the strip-out teams and access the excluded areas under semi-controlled conditions

Neither of these methods are necessarily feasible, not least because they can be prohibitively expensive.

The answer lies in using approach one in conjunction with the pilot surveys discussed in Thinking ahead: planning for asbestos. During the pilots the survey team should be able to identify any recurring inaccessible areas which can be accessed by the fitter and assessed. A representative sample of these areas could be made during the lead-in phase and this information extrapolated across the other surveys.

Any excluded areas should be explicitly stated in the report.

For irregular inaccessible areas i.e. not part of the building’s structural make-up and therefore specific to a particular property, we would suggest that these areas are marked as exclusions and re-surveyed at a later date with the fitter in attendance and scheduled in batches to reduce cost and delays.

The key to overcoming this challenge is communication between the building contractor and surveyor at the outset to plan the additional resources in a structured way that will not disrupt the programme.

There are also some technical reasons why we cannot guarantee that all asbestos containing materials have been identified within the survey. Using standard polarised light microscopy (PLM) as detailed in the Analyst Guide (HSG 248), it may not be possible to identify very fine asbestos fibres such as those present in some textured coatings. Also, samples of textured coatings and vinyl floor coverings may contain only trace quantities of Chrysotile asbestos.

Due to this low asbestos content, applications of this product may be non-homogenous and may elicit both positive and negative samples. Where both positive and negative samples are obtained on visually similar products it should be presumed that the products contain Chrysotile throughout even though a “No Asbestos Detected” result has been obtained. This may apply across different properties constructed at the same time.

Finally, given these inherent limitations to R&D surveys in occupied properties building contractors should take adequate precautions to protect the H&S of their staff and occupants including adequate asbestos training of tradespeople, arrangements to ensure that asbestos registers or records are checked before work commences and emergency procedures in place to deal with any suspect/suspicious/unknown materials.

Next week Paul Clarke-Scholes of Clifford Devlin will discuss the ways cost and programme of asbestos removal can be reduced by preparing an asbestos specification.

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