29 November 2019
As ACS celebrates its 40th anniversary in risk management and enters its 30th year of accredited asbestos services, reflection on how far the understanding of asbestos risk has come is encouraging.
For example, in the UK we have now:
- Considerable research data upon which to base risk assessments and historical exposure calculations (e.g. it is known that to contract mesothelioma over 100 million asbestos fibres are likely to be in the lung);
- Licensing and registration schemes for remediation work and waste disposal (note that we now have 3 different classifications of asbestos work) plus accreditation schemes for surveying and inspection bodies;
- A host of asbestos-specific legislation, codes of practice and guidance notes, even including the HSE's 'Task Essentials' detailing how the lower risk non-licensed work should be carried out by 'non-asbestos' trades.
- A continued use of non UKAS accreditied asbestos surveying firms, despite accreditation being 'strongly recommended' by the HSE and non-accredited surveyors having great difficulty in demonstrating compliance with the requirements of HSE Guidance Note HSG264 (The survey guide).
- A lack of understanding as to what constitutes 'common areas' within domestic housing (e.g. attics), which fall under the Duty Holder's/Landlord's responsibility (e.g. requiring Management Surveys).
- A dilution of governance control through construction supply chain, e.g. where Clients pass on the asbestos responsibility to a Principal Contractor which may then use sub-standard. consultants/contractors or simply ignore 'good practice'. In such cases not only can the PC be held liable for failures but also the Client under their duties to properly monitor contractors.
- Contractors being given inadequate or inappropriate asbestos data at the tendering or pre-start stage of a contract but not challenging this to ensure the correct data is obtained before disturbing building fabric.
- Uncertainty over waste classifications which can lead to unsafe handling of materials and/or hugely inflated waste disposal fees (particularly on complex scenarios relating to land contamination).
- A general misunderstanding of what the 'duty to manage' actually means, i.e. asbestos policy, procedures and competency frameworks as well as arrangements for planned and reactive 'works' on buildings.
Expert help is at hand if required.
Martin Mitchell BEng(Hons)
FRSA; MIIRSM; MREHIS; MFAAM; MInstLM AIEMA
[Martin is a qualified Chemical Engineer and Safety Practitioner specialising in asbestos risk management. He is a member of the Faculty of Asbestos Assessment and Management and has been a Director of ACS for over 20 years.]