There is a general belief that asbestos containing materials (ACMs) are always releasing dangerous quantities of fibres, and that therefore as soon as they are discovered they should be removed and disposed of. This is not the case.
If in good condition and left undisturbed, ACMs are highly unlikely to release dangerous quantities of fibres.
As a naturally occurring substance, small amounts of asbestos fibres are naturally released into the atmosphere all the time, but at such low levels, the fibres are of little threat.
However, once disturbed (to be removed), despite how careful the operative is, much larger quantities of fibres will be released than if the material was left alone.
Many ACMs have a long life, and so if left until they reach the end of their economic life, they could be in place for another 50+ years. As their economic life declines, the quantity of fibres in ACMs that could be released will be much smaller than if you take immediate action; as such, if possible, it can be beneficial to allow ACMs to remain undisturbed until a later date.
Of course, this is not possible in a variety of projects such as demolition, reconstruction and the like. If asbestos removal and disposal is absolutely necessary, then please see our advice on how to remove asbestos.
Asbestos in Non-Domestic Buildings
In relation to the management of asbestos containing materials (ACMs) at non-domestic buildings – such as farms – the following information has been sourced from the Control of Asbestos Regulations 2006.
The regulation, in simple terms, says that since 2004, the responsible duty holder must:
- Survey all non-domestic buildings to find all the reasonably accessible ACMs and record their condition.
- Write a management plan based on the risks associated with said ACMs.
- Advise all involved of the management plan.
The following advice will outline what is meant by non-domestic buildings, who has responsibility to manage the ACM’s, how the survey should be carried out (and by whom) and how ACM’s should be managed.
All advice provided on this page is targeted towards dealing with asbestos in a farm building environment. This information should be used only as a brief guide; this is by no means a complete guide to managing asbestos in non-domestic buildings, nor is it a complete guide to health and safety responsibilities when on a farm. Anyone carrying out the survey or managing asbestos containing buildings should read and understand the Approved Code of Practice L127 ‘The Management of asbestos in non-domestic premises’ available from HSE Books.
Before reading the following advice, if you are unsure how to identify asbestos cement products on a farm, then please read our resource on asbestos cement.
What is meant by non-domestic premises?
Where a building such as a barn has been converted or split into flats then the common areas, such as foyers, corridors, lifts and lift shafts, staircases, boiler houses, vertical risers, gardens, yards and outhouses are covered 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.
Who has the responsibility to manage the asbestos?
The duty holder is the entity that has control over the repair and maintenance of the building, so it can be an individual such as a farmer, a company or a tenant or managing agent, and can at times be very complicated. Because of this, everyone involved has the responsibility to advise and assist one another.
A typical area of complication is a large building such as a farm yard that has been split into a number of different units, some of which have been sold, some of which have been rented out, with the tenants having different contracts with the building owner. Undoubtedly this will leave grey areas, such as party walls where it is not clear who has responsibility for the repair and maintenance. It will not be acceptable for some of the structure not to be surveyed – all those who might possible have responsibility must work together to ensure that the survey is carried out or they must treat the non-surveyed areas as containing asbestos unless they have good reason to believe otherwise.
The owner may pass the repair and maintenance to a managing agent, in which case it will be their responsibility to ensure that the survey is carried out and the management plan written.
Where a premises is empty and unoccupied, the duty holder is still the entity in control of the premises.
Who should carry out the survey?
The duty holder must use a competent surveyor to carry out the survey in accordance with MDHS100 ‘Surveying, sampling and assessment of asbestos containing materials’ available from the HSE.
The surveyor must be adequately trained, be able to demonstrate independence, impartiality and integrity, and have an adequate quality management system.
One of the ways of ensuring that the surveyor is competent is to employ one that has personal UKAS certification for asbestos surveying.
On a normal farm, it is likely that the farmer will know their buildings so well that they will feel competent to carry out the survey themselves, and if they are typical farm barns then this should be acceptable.
All non-domestic buildings must be surveyed, including 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 tractors and other old farm machinery are quite likely to contain asbestos in gaskets, brakes, clutches, under spray, etc. and so these will need to be checked.
The survey needs to be carried out on the premises and their surrounds – but quite how far the word surrounds covers is unclear.
In the past, asbestos cement pipes were used as field drains, particularly where they drained into ditches. The view from the HSE is that the surveyor can not be expected to survey for land drains, but where the farmer or surveyor notices asbestos cement pipes used as drains, this should be noted on the plans.
Many farmers have water or sewage pipes running across their land, some of which will be asbestos cement pipes. Since these pipes are under the control of water boards or sewage companies, it is their responsibility to survey and manage them, and not the farmers. There is an argument to say that the water or sewage company should advise the farmer of where any asbestos cement pipes are on his land, although the risk from the asbestos even if the pipes are dug up is probably too small to be measurable unless they are aggressively abraded.
The first task for the surveyor is to obtain or create a drawing of the premises and surrounds being surveyed. The surveyor should then check all drawings or paperwork for:
- indications of ACMs;
- any refurbishment or repairs which may contain ACMs
(checking where possible with designers, builders and relevant employees for ACMs).
Following this desk work, all the buildings, plant and surrounds should be thoroughly inspected, but before work starts a risk assessment should be carried out and method statements written on how to reduce the risks found. Typical risks on a farm are; working at heights, working in confined spaces, working near large animals, breathing in asbestos fibres, contact with hazardous chemicals, etc.
During the survey, the drawings and other papers provided should be checked for accuracy. Where ACMs are found, they should be clearly marked on the drawings plus their condition should be recorded. Since it is likely that these drawings will be used by employees who do not have a good knowledge of the building trade or its terminology, it is important that the recording is done in such ways as to ensure that the non-expert understands not only that asbestos is present, but exactly where it is present.
Where access is not gained to any area (and so is not surveyed), this must be clearly marked on the drawing, and that area must be treated as if there is asbestos present – unless there is good reason to believe otherwise.
Information the survey report should contain
The report must record – in detail – the position, type and condition of ACMs. All areas not surveyed must be presumed to contain asbestos. unless there is good reason to believe otherwise.
The report should provide details of the risk associated with the ACMs found. Asbestos cement in good condition does not easily release fibres unless it is aggressively abraded, Asbestos cement that has been badly attacked by acids or alkalis may easily release fibres.
It is sometimes assumed that asbestos cement cannot release fibres unless it is abraded – this is normally the case, but there has been exceptional situations previously.
For example, the lack of ventilation in a cattle building crowded with cattle and infrequently cleaned out resulted in the forming of such aggressive condensate that the cement had been abraded on the underside of the sheet to such an extent that all that was left was pure asbestos mats hanging down from the roof sheeting.
What should be done with the report?
The report should be kept in a prominent position for the life of the buildings, revised when conditions change and available for anyone using the building to read at any time.
Based on the report, a management plan for the ACMs must also be written and subsequently acted upon.
Working with Asbestos Summary
When asbestos containing materials (ACMs) are found, how they are treated should be based on the following advice:
- ACMs which are sound, undamaged and not releasing fibres should be left undisturbed and have their condition monitored on a regular basis.
- Where possible, damaged ACMs should be repaired and protected as necessary, provided that the repair or sealing will be durable and not likely to be disturbed.
- Removal should only be performed where repair is not possible or the material is likely to be disturbed.
The handling of low-density insulation boards and spray coatings containing asbestos is a skilled job that must be carried out by a contractor licensed by the HSE to handle these products.
Note: the above information was produced using an article from volume 3 Issue 4, Summer 2003 of Countryside Building, The Journal of the Rural & Industrial Design and Building Association as a guide.