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Amendments to the working with asbestos regulations with particular reference to farm buildings.

• A licensed asbestos contractor is required unless the work involves sporadic and low intensity exposure
• a reduction in the Control Limit,
• the removal of textured coatings from the requirement to always use a licensed asbestos contractor,
• the more detailed statements on the training required for any one who might come across asbestos containing materials (ACM) in their work
• a far more time consuming and expensive way to tell the difference between an asbestos cement product and other more dangerous products, that used to be classed as low density.

In this article I will cover the changes in the regulations and how they effect work with asbestos cement products (AC), particularly on farm buildings. I will not go into any detail on the changes to work with asbestos insulating boards and asbestos coatings as this is specialist work, where only firms licensed by the HSE should be used.
The following article is only a brief guide; it is not a complete guide to Health and Safety responsibilities when working with asbestos containing products nor is it a complete guide to health and safety responsibilities when on a construction site. Anyone working with asbestos cement products should read and understand the ACoP for these revised regulations ‘Work with Materials Containing Asbestos’ L 143 which is obtainable from HSE books. In the past there were two ACoPs one for work on materials where a licensed is required and one for work on materials where a licence is not required, it is a shame that this time they are combined as it makes it harder for the non licensed contractor to understand what he has to do.
Sporadic and low intensity exposure
Basically the revised regulations say that when work on an ACM is required and there is no way of avoiding that work then a licensed asbestos contractor should be used, unless the work is with AC, textured decorative coatings or any article of bitumen, plastic, resin or rubber where their thermal or acoustic properties are incidental to its main purpose and involves sporadic and low intensity exposure.
Sporadic and low intensity exposure is defined as exposure that does not cause the ten minute limit or the 4 hour control limit to be exceeded, if the risk assessment shows that either of the limits set out below are at risk of being exceeded then the work is not sporadic and low intensity and so a licensed asbestos contractor must be used.
Reduction in the Control limit
The new limits are the same for all types of asbestos, so even though the risks associated with the different types are very different, this is ignored in the limits set. There are two limits;
The ten minute limit of 0.6f/cm3 (f/ml)
The 4 hour control limit of 0.1f/cm3 (f/ml)

It is interesting to note that the 0.1f/cm3 comes from the EU directive that this change in regulations is implementing except that the directive asks that it is averaged over 8 hours. Once again the HSE is forcing UK industry to work to limits in excess of those that their EU competitors have to, with very little if any evidence that this restriction will reduce asbestos related illnesses.
It is my belief that if AC products are correctly worked with and the correct precautions taken then the above limits should not be reached, but I would still strongly recommend that those companies that are planning to work with AC roofs employ a UKAS (www.ukas.org) accredited laboratory to carry out air sampling on typical jobs, whilst the work is being carried out to ensure themselves and their clients that their techniques used to keep the release of fibres to the minimum are correct and that the limits are not being breached.
Methods to reduce the release of fibres to the minimum
Before starting work check whether the work is necessary, is it possible to carry out the work without disturbing the ACM? A typical example is re-roofing; a risk assessment will often show that over roofing will provide the least risk. If a building is being demolished the removal of the ACM's is required prior to demolition as far it is possible to do so.
Before work starts the employer must ensure that a competent person carries out a suitable risk assessment and that a method statement is provided on how the work is to be actioned to comply with these regulations. The risk assessment and method statement shall:

• Determine the nature and degree of exposure
• Reduce the exposure to asbestos to the minimum possible. Consider ways of doing the work without disturbing the ACM, only if that is not possible should the ACM be disturbed.
• State whether the employees might be exposed to asbestos fibre levels in excess of the Control Limit or the Action Level, if they are take the steps listed below under ‘Action Levels and Control Limits’ must be followed.
• It is not necessary to provide a risk assessment for every individual job. Where an employer carries out work that involves very similar jobs on a number of sites such as roofing, only one assessment for that work may be needed. When one is considering using a risk assessment written before, it is important that the job is inspected to ensure that the conditions of the ACM and the site are the same as the previous jobs. It is possible in very extreme cases for asbestos cement products to be attacked by acids or alkalis to such an extent that the cement matrix is eaten away to leave the raw asbestos. This can happen in very poorly ventilated animal housing. The fibre counts in the building are likely to be so high and the product so friable that it should be treated as a low-density product and handled by a Licensed Asbestos Contractor.
• The risk assessment should be reviewed if there is any reason to believe that the original is no longer valid, such as a change in the condition of the ACM or the work required.
• The method statement should be written for the job, it is not acceptable to provide a generic method statement. It must be kept on site during the work.
• The method statement must list the place of work, the methods to be used to keep the release of asbestos to the minimum possible and the characteristics of the equipment to be used.
• The employer must ensure that as far as reasonably practicable the work is carried out in accordance with the method statement.
• Where situations occur that are not covered by the method statement such as the discovery of other ACM's or a change in the ACM's condition, work must stop until another method statement to cover the new situation is written.

If the following methods are used to work on asbestos cement products that are not in a very friable condition, the fibre counts are likely to be low and below the Control Limits.

• Keep the material wet when working on it.
• Avoid using power tools and breaking ACM's but carefully remove or cut fixings so that the product can be removed in one piece. Carefully carry to the ground and either double wrap in polythene or place in a covered skip.
• Where it is necessary to cut or drill asbestos cement sheets, ensure the material is wet and if possible scribe and break, if this is not possible use hand tools, preferably in the open air.
• Where power tools have to be used employ dust extraction.
• Keep the site clean and tidy at all times and clean up after work by dampening any dust and carefully placing in a polythene bag for disposal as asbestos waste.
• Unless the risk assessment shows that RPE is required, the operatives should preferably wear a disposable mask that is CE marked to EN 149 with FFP2 particulate filters and disposable overalls, which should be disposed of at the end of the shift as asbestos waste.
• When working at heights follow the advice in HSG 33 Health and safety in roof work.
• Old asbestos cement sheets are very fragile.
• Any plant or equipment contaminated with asbestos must be thoroughly decontaminated before being removed from site.
• When the work is complete if it has been inside a building and is not of a minor nature then Clearance air sampling and a certificate of reoccupation will be required.
• Training Requirements
Employers must ensure that their employees have received adequate training, understand the risk assessment and know and understand the method statement. This training should include:
• All workers who are involved in maintenance should receive adequate asbestos awareness training in case they come across ACM's of which you are unaware.
• The health risks of asbestos.
• The types, uses and likely occurrence of asbestos in buildings and plant.
• The details of how an emergency should be handled.
• How to avoid the risks from asbestos.
• The correct use of protective equipment
• Refresher training should be provided on a regular bases and at least once a year for those regularly involved in working with ACM's.
• There is a responsibility on the employer to ensure that adequate information is provided to non-employees who are on the premises and could be affected by the work.
• The procedures for providing information, instructions and training should be clearly defined and set out in a written document.
• Records should be kept of every individual's training.

Recognising and differentiating between an AC product and other more dangerous products
The Regulation states that an AC product is one that ‘when in a dry state absorbs less than 30% water by weight.
In the previous regulations this was based on a simple test to give the density of the product, because it was so simple any one could do it and was very accurate. This change means that the water absorption of the product is the deciding factor, a difficult test that requires the use of a competent laboratory and is likely to be less accurate than the original criteria based on density.
One of the basic requirements when considering work on an ACM is to try and avoid the work, yet this is ignored in this test, which requires the sample to be handled a number of times, some times when it is not in an enclosed air tight bag. In the old test all one had to do was to drop a piece of any size in water and see if it sank or floated.
There is also the problem that one of the ways to make an asbestos insulating board (AIB) safe is to seal it. Now an AIB in its natural state will absorb more than 30% of its weight in water, but if in the past it has been well sealed it probably will not, so even though the test method says ‘partially painted samples can be used but may need longer to absorb water’ I still believe that there is the risk of AIB being listed as AC.
Practical advise that can be used on a farm site to recognise Asbestos Cement ACM's
It is sometimes difficult to tell the difference between an AC product and a low-density insulation board, but there are a few rules that can be followed.

The ACM will be AC if:

• The product has been used as a roofing or cladding product, open to the weather. Manufacture of all low density products was stopped in the late 70’s and since they were not weather resistant, if they had been fixed outside they would have broken down long before now.
• The product is moulded as low-density products were not moulded, except as half rounds for pipe lagging.
• The product is in sheet form and has been used as animal pens or in wet areas. Low density products were not robust enough to be used as animal housing nor could they withstand wet conditions without breaking down.

When cementitious products like AC were manufactured, they had a cement-rich surface. The asbestos fibres were encapsulated within. Thus, occupants of buildings with AC sheet or slate roofs are unlikely to be at any greater risk than people outside in the fresh air. The small quantities of fibres released during natural weathering are unlikely to be dangerous but significant and possibly dangerous amounts of fibre can be released if the products are subject to any abrasive cleaning or working. It is therefore important to use the correct techniques and working practices when handling ACM's.
Non-asbestos alternatives to AC began to be introduced to the UK market in 1984, but AC products continued to be supplied into the UK market until 1999. So any product that looks like AC that was supplied prior to 1984 will contain asbestos, any product supplied after 1984 until 1999 could be an ACM. Unless one can find an identification mark on the product it is not possible for the layman to look at a sheet and tell whether it contains asbestos or not and in many cases even an expert can not tell without finding the mark or having a sample analysed. The manufacturers’ mark on profiled sheets is indented into the overlap of the side lap roll, it will normally, in code form, give the name of the manufacturer, the date of manufacture, the shift and possible the machine it was made on. If it contains asbestos it will contain the letters AC or AT if it is non-asbestos it will contain the letters NT. With slates the mark was ink jetted on to the back of approximately one in twenty products, with the same letters denoting whether they contain asbestos not.
Finding these marks can be a problem, with slates a quantity will need to be removed before the mark is found and so unless you have good reason to believe that they are non-asbestos they should be treated as an AC. For roofs fixed after 1984, when the slates could be AC or non-asbestos, looking at the original specification may help but a number of specifications were changed by the roofing contractor because AC slates were cheaper than their non-asbestos alternatives, and the client and designer were not necessarily notified of the change. It may therefore be necessary if one has to work on these products to either treat them as AC or arrange for a sample to be removed and analysed by a competent laboratory.
With Profiled sheets identification is not a lot easier, although the sheets should have carried the indent on the overlap roll this did not always happen or the imprint is too vague to be read. There is also the problem that unless the roof is relatively resent it will be dirty and covered in moss and lichens, which will once again make the marks harder to read. It should of course be remembered when accessing the roof to check for the mark that both AC and un-reinforced fibre cement sheets are very fragile and so protection must be provided to the operative to ensure that he cannot fall through the product, a far more immediate and serious risk than the risk of catching an asbestos related disease.
In the mid 1990s some profiled sheet manufacturers started to inkjet the underside of their sheets with the production mark. On a single skin construction this should be seen from ground level and again if there is the letters AC or AT in the mark then it is AC if the letters NT are in the mark then the product does not contain asbestos.
For other moulded products the position of the mark will vary, with some having no mark, where there is a mark the same lettering applies.
Very few flat sheet products will have any marks.
Asbestos waste
Asbestos waste is any waste which contains more than 0.1% w/w asbestos. It is subject to the waste management controls set out in the Hazardous Waste (England & Wales) Regulations 2005 that amended the “Special Waste Regulations. This states that the waste must be consigned as soon as possible by a licensed haulier to a dump licensed to take asbestos.

The exception for farmers is that they are allowed to safely store the Waste on site for a maximum of one year and then they can haul it to the licensed dump themselves as long as they have contacted the dump in advance and completed the necessary consignment notes.
The Environment Agency should have a list of licensed haulier's and waste dumps in your area.
The Hazardous Waste Regulations state that "Where hazardous waste is produced at or removed from, any premises other than exempt premises, the premises must be notified to the Environment Agency". This means that any business producing hazardous waste has a legal duty to register with the Environment agency any premises where hazardous waste is produced. Each premises registered will be given a unique registration number - known as a 'premises code' . Many farms will already be registered but if not they need to register if more than 500 kg of ACM waste is being disposed of.
The above is only a brief guide, it is not a complete guide to Health and Safety responsibilities when dealing with asbestos containing products, for more information obtain and understand
Approved Code of Practice and Guidance L 143 ‘Work with materials containing asbestos’ – HSE Books

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