Are your asbestos management plans, policies and procedures up-to-date?
Duty holders of all non-domestic properties which contain potential and/or confirmed asbestos-containing materials (ACMs) are required by law to develop a site-specific, up-to-date asbestos management plan. This will incorporate a range of policies and procedures designed to ensure the safe and compliant management of asbestos on those premises.
Asbestos management plans should be easy to access and update, and it is generally recommended that they are reviewed every 12 months, or when updated legislation/guidance or an asbestos related incident, gives reason to suspect the plan may not be suitable. The purpose of the review is to ensure full compliance with relevant legislation and guidance (predominantly, the Control of Asbestos Regulations 2012). However, many duty holders have admitted to not reviewing and updating their management plans as frequently as required, increasing the risk of compromising the health and safety of those who occupy the premises.
What is an asbestos management plan?
An asbestos management plan is a document outlining how asbestos will be managed within a property, detailing the activities required to protect occupants against exposure to asbestos fibres. It usually contains a site plan, which outlines the areas on the premises which may contain/have been identified as containing asbestos. In addition an asbestos register provides further detail of the locations of these potential and confirmed asbestos-containing materials, such as the amount, condition, accessibility and type of each identified material.
Before duty holders arrange for any work to be carried out on their premises, it is important that they consult their plan and refer to the policies and procedures that have been outlined, determining the necessary course of action/s required to minimise the potential of damaging or disturbing ACMs. The plan will outline the corresponding actions required to manage the risk of asbestos and how these can be achieved will be detailed (for instance, how often the condition of suspected and confirmed ACMs need to be monitored), as well as the timescales in which these actions need to be completed by and by whom.
Finally, the way/s in which responsible persons intend to disseminate their asbestos management policies, procedures and responsibilities to all employees, contractors and third parties should be outlined. This includes informing staff and contractors about the locations of potential/confirmed ACMs on the premises, notifying them when training is required/needs to be updated and ensuring that relevant contacts know who to get in touch with in the event of ACMs being disturbed or discovered.
Why is it important to frequently update asbestos management plans?
Asbestos management plans must be updated periodically, particularly if there have been any significant alterations to the property or its usage, or if there is a reason to suspect that the management plan is no longer valid (such as in the event of accidental asbestos release or a change in legislation and/or recommended guidance). The plans must also be updated whenever work has been carried out on the premises that may affect ACMs, while also checking their condition regularly to make sure they haven’t deteriorated during this time and pose a higher level of risk to those occupying the premises. It is also essential that those responsible for the identification and management of ACMs are noted as the relevant points of contact on the asbestos register. Additional details, such as when these individuals last received asbestos training and when their training requires updating, should also be included where possible.
What does a compliance/gap analysis audit involve?
While duty holders must strive to ensure that they constantly have an up-to-date asbestos management plan in place, they must also determine whether the policies and procedures that form part of this plan are adequate. An independent compliance/gap analysis audit can assist in identifying whether each element of a duty holder’s asbestos management is effective and fully compliant with the Control of Asbestos Regulations 2012 (CAR 2012) and other relevant health and safety legislation/guidance. Any gaps in compliance status are identified, with goals, actions, responsible parties and the timescales as to how long these will take to accomplish outlined.
A compliance/gap analysis audit requires the collation of information and documentation to assess the adequacy of asbestos management policies and procedures. There are a number of key areas of legislation within CAR 2012 that a duty holder will need to comply with in order for their policies and procedures to be deemed suitable and sufficient, including (but not limited to):
- Regulation 4 (duty to manage asbestos in non-domestic premises) – developing and maintaining an asbestos risk register and management plan for non-domestic premises, ensuring that these remain up-to-date and valid at all times and that the conclusion/review is consistently recorded. Implementing policies and procedures that ensure that the risks posed by asbestos are safely and legally managed
- Regulation 5 (identification of the presence of asbestos) – implementing policies and procedures which suitably and sufficiently assess the risks of asbestos prior to any works being undertaken which expose/are liable to expose employees (such as surveys, audits, reinspections, management of removal works)
- Regulation 10 (information, instruction and training) – providing adequate and regularly updated information, instruction and training via a competent individual to any employee who is liable/potentially liable to disturb asbestos as part of their normal working activities, and those who manage such individuals
- Regulation 15 (arrangements to deal with accidents, incidents and emergencies) – ensuring that arrangements are in place to deal with accidents, incidents and emergencies relating to the unplanned release of asbestos, all of which are outlined within policies and defined procedures
- Regulation 16 duty to prevent the spread of asbestos – preventing or, where this is not reasonably practicable, reducing to the lowest level reasonably practicable, the spread of asbestos when works are being undertaken.
What factors are analysed when assessing the effectiveness of asbestos policies and procedures?
When determining the adequacy of asbestos management procedures and policies, a number of areas will need to be assessed and reviewed accordingly. Examples of questions that will be asked as part of a compliance audit include:
- Who is responsible for the management of asbestos on the premises?
- How frequent are asbestos management policies and procedures reviewed? Is there a schedule for regular reinspection surveys in place?
- What methods are in place to disseminate information regarding the location and condition of asbestos to all involved parties?
- Are all persons potentially liable to disturb ACMs adequately trained (including regular refresher training)? How competent and experienced is the individual providing the training?
- Is there an accident and emergency procedure for asbestos-related incidents in place? How is this communicated? How and when is this reviewed? (Click here to access the HSE’s infographic on how duty holders can ensure they have an effective accident and emergency procedure in place.)
To access SOCOTEC’s checklist for actions that duty holders must take to ensure their management plans, policies and procedures are up-to-date, click here.
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