Do you measure up when it comes to Asbestos Management Plans?
The Great British Asbestos Survey, published earlier this year, highlighted an alarming lack of awareness of asbestos management responsibilities amongst duty holders. An asbestos management plan is a legal requirement for all workplaces liable to contain asbestos yet according to the results not only did a disturbing 37% of duty holders not have a plan in place but 74% of those with an asbestos management plan, reviewed the plan outside the 6 month guidelines detailed in the ACoP. Worryingly this means a startling 84% of duty holders completing the survey were not compliant with the current regulations and the guidance in respect of asbestos management plans.
Why is an asbestos management plan required?
An asbestos management plan is a legal requirement under (Regulation 4 of the Control of Asbestos Regulations 2012) for all workplaces liable to contain asbestos. It is a written plan that sets out in detail how you are going to manage any asbestos risks identified by a survey. It sets out what is going to be done, over what timescales and the methods to be used to manage any asbestos containing materials (ACMs). It also sets out clear lines of responsibility for the management of asbestos. The plan is needed to make sure that:
- Any materials known or presumed to contain asbestos are kept in a good state of repair
- If any materials are damaged, or their location presents a particular risk then the materials are repaired or removed as appropriate
- There are clear lines of communication and everyone knows what their roles and responsibilities are for the management of asbestos
- Information on the location and condition of the material is given to anyone potentially at risk
- Processes are put in place to control and manage any maintenance or building works that may disturb asbestos. This includes making sure everyone is sufficiently trained.
What does an asbestos management plan contain?
Information contained within the survey report provides the basis from which to develop your asbestos management plan. The plan should contain the following information:
1. Asbestos register
An asbestos register will need to be compiled recording details of the location and condition of any asbestos materials recorded. This should include details of:
- Type of asbestos materials
- Location (including accessibility)
- Quantity of materials
- Material assessment
The information can be provided in a number of ways including hard copy, electronic format or alternatively via access to an electronic risk management system. It is up to you to determine which method suits your business the best. In deciding which system to use it is important to consider the ease with which the system can be updated and how easily accessible the information is to all those that may need it
2. Priority assessments and prioritised actions
Information contained in the asbestos register should be used as the basis for conducting a risk assessment of each of the ACMs or presumed ACMs identified. This will help you decide the most appropriate course of action for dealing with the ACMs and decide the order of priority in which they should be tackled.
The risk assessment should include both a material and a priority assessment.
The material assessment looks at the type and condition of the ACM and the ease with which it will release fibres if it is disturbed. This is usually included in the survey report.
The priority assessment considers the likelihood of someone disturbing the ACM. Factors such as cleaning and maintenance and the nature of the activities undertaken by employees/occupants and visitors should all be taken into consideration.
3. Decisions about management options
Appropriate management actions will need to be decided for each of the individual asbestos materials listed in the asbestos register. Dependent on the results of the risk assessment you may choose to:
- Label the material
- Colour code the material
- Protect/enclose the material
- Seal/encapsulate the material
- Repair the material
- Remove the material.
4. Timescales for management actions
The plan should contain target timescales for the completion of management actions. These will be set based on the priority and material risk assessments.
5. Monitoring arrangements
To reduce the risk of exposure you must make sure any building materials liable to contain asbestos are kept in reasonable condition. The plan must contain monitoring arrangements for the regular inspection of any ACMs. Asbestos re-inspections may be conducted by an outside survey company. These should usually be conducted annually or more frequently if there is reason to suspect that materials may have deteriorated or have become damaged.
6. Training arrangements for employees and contractors
You will need to make sure anyone who may come into contact with or disturb asbestos during the normal course of their work has the correct level of asbestos knowledge and training required.
Asbestos awareness training should be sufficient for most staff. This will provide an understanding of the types, uses and likely occurrence of asbestos materials in a building, show how the risks from asbestos can be avoided and the actions that should be taken in an emergency.
More specialised training may be needed for managers and dutyholders who have specific responsibilities under the plan and for anyone required to carry out low risk non-licensed activities.
7. Communicating information about the location and condition of asbestos materials to those who need it
Employees and contractors liable to come into contact with or disturb the asbestos must be provided with information concerning the location and condition of any asbestos materials. Set processes for the communication of this information need to be laid out in the plan.
8. Plans for implementation of new procedures
Systems and procedures need to be put in place to control any work on site and ensure that maintenance workers and contractors are not unknowingly exposed to airborne asbestos fibres. This is particularly important in larger organisations where it is difficult for one person to manage and communicate with all the contractors on site. A formal, written system of work incorporating permit- to-work may be required. This would allow you to control access to the premises and ensure that you know exactly which areas contractors are working in. Supplying this information well before the work starts allows contractors to take the relevant precautions.
9. Details of who will oversee the management plan
The plan must include details of the person(s) responsible for overseeing the management plan
The management plan should be reviewed regularly, to monitor the effectiveness of any set processes and procedures and measure progress against any set timescales. You may need to consider how effective the plan has been in terms of:
- Preventing exposure
- Highlighting the management actions required to deal with any ACMs
- Managing and controlling maintenance workers and contractors
- Raising awareness
You will also need to critically assess any situations where procedures have failed to be implemented correctly or where exposure to asbestos fibres has occurred.
The ACoP recommends reviewing the plan thoroughly every six months. The plan may also need to be reviewed following changes to the organisational structure / staffing, resources, company procedures, refurbishment or changes in the use or occupancy of the building.
Our consultants would be happy to provide you with advice regarding the management of asbestos in your buildings. To find out more about our asbestos services call 01270 765121
Our specialist asbestos division Strategic Risk Management (Asbestos) Limited is a UKAS accredited inspection body for asbestos surveying and a UKAS accredited testing laboratory for asbestos bulk sampling, asbestos air sampling and fibre counting and asbestos analysis.