FAQ’s on asbestos surveys
As an asbestos consultancy Enquin frequently get asked questions which usually have more than one answer. Here we feature some FAQ’s on asbestos surveys and give some possible answers to each one.
Question 1: Why was asbestos not identified on my survey?
Answer a: What was the survey date and standard?
Prior to 2010, the standard for surveying was MDHS 100 and was superceded by HSG 264 The Survey Guide, which significantly increased the standard of best practice for surveys. Many MDHS 100 Type 1, 2 and 3 surveys which pre-date 2010 / HSG 264 are often shown to be insufficient once re-surveyed. A key point to check is the restrictions and limitations on the original survey document.
Answer b: Was the appropriate type of survey undertaken?
There are now two different types of surveys;
- Management surveys identify Asbestos Containing Materials (ACM’s) easily accessible in the building and are non-intrusive
- Refurbishment/Demolition surveys are undertaken prior to works and are intended to be fully intrusive
Answer c: What does a ‘No Access’ mean?
A material is guilty until proven innocent so if an area has not been inspected then asbestos must be presumed to be present. These should be detailed in the report. HSG264 states that if any ‘No Access’ areas are stated on your Management Survey then upon Re-Inspection – all ‘No Access’ areas on previous surveys (if available) must be accessed with suitable access equipment and procedures.
The Health and Safety Executive (HSE) states that restrictions and caveats can undermine the management of asbestos within the building, and that they should only be included where absolutely necessary and need to be fully justified. Most can be avoided by proper planning and discussion.
Answer d: What was the scope of the survey?
The scope of the survey is a key element to check in a survey report. The exact scope of work is critical in both Management and Refurbishment and Demolition surveys. Check the survey includes the building or areas of the building concerned, and with a Refurbishment, does the intrusive strategy reflect the scope of refurbishment works being undertaken.
Answer e: Was the surveyor competent?
It is not a legal requirement to be UKAS* accredited for surveying, however it is highly recommended. The surveyor must be competent and the survey and report should be in accordance with HSG264 in order to be compliant.
Link to HSG 264
*The United Kingdom Accreditation Service (UKAS) is the sole national accreditation body recognised by the Government to assess, against internationally agreed standards, organisations that provide certification, testing, inspection and calibration services.
Using a UKAS accredited organisation to inspect and test for asbestos assures clients that the organisation has met the stringent requirements of international standards ISO 17020 and ISO 17025, showing competence, impartiality and performance capability. By selecting Enquin as a UKAS accredited laboratory and inspection body, our client can make an informed choice about a proven, competent organistion.
Question 2: Why did an Asbestos Containing Material (ACM) get disturbed?
Answer a: Was the person(s) who disturbed it asbestos awareness trained?
It is a requirement under Regulation 10 that employees liable to disturb asbestos are trained in asbestos awareness to ensure they understand the risks and how to protect themselves and others.
Answer b: Was the person(s) who disturbed it aware of the Asbestos Register?
Under Regulation 4 of the Control of Asbestos Regulations 2012, the Dutyholder must provide information on the location and condition of materials to anyone who is liable to work on or disturb them.
Answer c: Do you have adequate contractor controls in place to ensure they know where asbestos is in the building?
Awareness of contractors should be checked and a rigorous system to control works in the buildings should be in place, such as a permit to work.
Answer d: Do you have an Asbestos Management Plan in place?
If you have asbestos in your building you must prepare a Management Plan that sets out in detail how you are going to manage the risk. This includes taking the steps needed to put your plan into action and reviewing and monitoring your plan and the arrangements.
Link to INDG 223
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