Independant asbestos Information

Asbestos Surveys and the Asbestos Management Plan

Asbestos surveying and the asbestos management plan

All non-domestic buildings and their surroundings must be surveyed to find any asbestos containing materials (ACM) and where they are found a management plan put in place.

This regulation, in simple terms, says that, by May of 2004:

  • The Duty Holder must survey all non-domestic buildings
  • To find all the reasonably accessible asbestos containing materials (ACMs)
  • Record their condition
  • Write a management plan based on the risk associated with the ACMs
  • Advise all involved of the management plan.

 

The Duty Holder organising the survey is the entity responsible for the building. Sometimes with multiple tenancies and vague contracts it can be difficult to agree who this is. So the regulations say that where the Duty Holder is not clear all parties must work together to ensure that the building is surveyed and a management plan written.

There will also be situations where domestic properties need to be surveyed to assess the risk from any ACMs. Such as before any construction work on the fabric of the building is carried out as a contractor has a responsibility to carry out a risk assessment before he starts work and asbestos release is one of the risks he must assess. So he must assure himself that ACMs are not present but if they are he needs to assess if he is competent to work safely with them. If he is not he must call in a contractor who is competent.

The term non-domestic building needs some explanation. Obviously a domestic house is not covered by this regulation but some parts of a block of flats are non-domestic and so are covered. Such as common areas, typically, foyers, corridors, lifts and lift shafts, staircases, boiler houses, vertical risers, roofs, gardens, yards and outhouses, and so need to be surveyed. Common areas are not shared rooms such as kitchens or communal dining rooms and lounges in shared housing or sheltered accommodation and so they are not covered by the regulations.

The survey must include fixed plant and machinery, but not those such as trucks that only come onto the premises from time to time. It should be noted that many old machines can contain asbestos in gaskets, brakes, clutches, under spray, etc. This will need to be checked.

It is important that a competent surveyor is used, to ensure that all accessible ACMs are found and that the surveyor has adequate knowledge of the health risks of the different ACMs to be able to write a management plan.

The HSE has provided a Code of Practice for the selection of a surveyor and on how the surveyor should carry out their survey and write their report. This is a good starting point but it is over bureaucratic with the criteria for how a surveyor can prove their competence relying too much on formal qualifications and checklists. If this code of practice is followed fully it will force out of business many very competent small surveying companies that have built up their expertise over many years. The senior managers within the HSE understand that regulations should not be written that are a barrier to small companies but so often the detailed regulation does just that. There are I believe a number of reasons; it is so much easier to set out the qualifications required for any given job but far harder to set out how a competent person without qualifications can be recognised and another is the consultation process. Large firms find it easier to allow one of their staff the time to become involved in the development of regulations, but very few small firms cannot afford the time.

Finding a Competent Asbestos Surveyor

  • A good place to start is by asking a local building surveyor practice if they have a competent asbestos surveyor in their practice and if not do they know one they can recommend.
  • Ask local companies who carried out the survey on their buildings and how good they were.
  • Ask for references and take them up
  • I do not recommend the use of a contractor to carry out a survey, unless the contractor is checking for asbestos before he starts work.
  • If the price for the survey work looks too cheap – it probably is
  • If the surveyor is UKAS accredited they will be competent but non accreditation does not mean that they are not competent.

 

Types of asbestos Surveys

  • There are three types of asbestos survey:
    • Type 1 asbestos survey, where the building is surveyed without sampling or checking in inaccessible places. Where materials are seen which might contain asbestos they are noted and have to be treated as if they do contain asbestos until analysis has proved otherwise. Inaccessible places must also be treated as if they contain asbestos, until inspection and analysis proves otherwise. The HSE no longer recommends that this type is carried out.
    • Type 2 asbestos survey, where the building is surveyed and possible asbestos containing materials analysed by a UKAS accredited laboratory1 and where possible inaccessible places inspected and if necessary sampled.
    • Type 3 asbestos survey, this is a full survey, normally carried out prior to a building’s demolition and is similar to type 2 but all areas must be inspected if there is a risk of asbestos content, this could mean inspection in cavity walls or below floors or above ceilings if the surveyor believes that there is a risk of asbestos being present.

 

Management plan

  • The Asbestos surveyor will provide a management plan, which will provide the details of how the ACMs should be managed.
    • If any ACMs are found that are releasing fibres or likely to do so in the near future, the plan will advise whether the ACM should be repaired or replaced and in both cases whether the work can be carried out by a competent contractor or whether a licensed asbestos contractor is required.
    • In many cases if the ACM is in good condition and is not being abraded or likely to be abraded or disturbed in the near future, the plan will say that it should be left in situ but its condition checked on a regular basis, how regular will depend on the product, its age, position, how easy it is for the building’s users to access, etc.
    • In other cases the plan will recommend encapsulation, either by painting with a proprietary sealer or by boarding in and again state how regularly the encapsulation should be checked.
  • The Asbestos Management plan must be available to anyone who needs to know. This could include residents, workers, contractors, tenants, etc.
    • The management plan must be kept up to date as changes are made to the building and its surrounds.
    • If any building work is carried out on the premises after the management plan has been written, then the plan must be reviewed and any changes required made.

 

Note 1 There will be situations where from the age of the suspect material and a visual inspection the surveyor can be confident that it does contain asbestos and so there will be no requirement for analysis.

 


         

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