Amendments to the working with asbestos
regulations with particular reference to farm buildings.
By A H Hutchinson FIoR director, Asbestos
These revisions came into force on the 13th November 2006.
The main changes relate to;
- 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
- 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
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
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
- 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 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
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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