Planning for asbestos

Paul Phillips describes how to go about managing asbestos in schools prior to embarking on a major maintenance or refurbishment project

It is estimated that as many as three quarters of schools and further/higher educational establishments have some asbestos-containing materials (ACMs) in their buildings’ fabric. After all, asbestos was only totally banned as a building product in the UK in 1999 so most buildings’ constructed in the 20th century are likely to contain some ACMs.

Exposure to asbestos can cause fatal diseases – according to the Health & Safety Executive over one hundred school teachers died from the asbestos-related lung cancer between 2002 and 2010. However, asbestos only becomes hazardous to health when its fibres become airborne. If left in good condition and undisturbed it can be relatively safe.

Under the Control of Asbestos Regulations 2012 the duty to manage asbestos in schools ultimately falls upon the “employer”. For community schools, community special schools, voluntary-controlled schools, maintained nursery schools and pupil referral units, the “employer” is the local authority. For academies, free schools, voluntary-aided and foundation schools, it will be the school governors. For independent schools, it may be the proprietor, governors or trustees. In situations where budgets for building management are delegated to a school by the local authority, the duty is shared between the local authority and the school governors, with both parties having responsibilities for the repair and maintenance of the premises.

One of the key responsibilities of the duty holder is to have an asbestos management plan (AMP) in place which records and monitors all ACMs on a continuous basis. A study in 2010 by the Asbestos Testing & Consultancy Association found that only a quarter of schools had a satisfactory AMP, while in 2013/2014 HSE inspections of 153 non-local authority schools resulted in 44 schools (29 percent) being sent written advice on improving their asbestos management. Twenty of the 44 were issued with improvement notices: eight had no management plan; eight had inadequate assessments; two had failed to manage the risks and two had inadequate training and information for employees.

An adequate plan should contain the following: a comprehensive inventory of the locations, quantities and conditions of all ACMs in your organisation’s property portfolio, an emergency plan of action in case of uncontrolled release of asbestos fibres and documented responsibilities for key persons.

The asbestos register will be based on information gathered during an asbestos management survey. This should be conducted by a UKAS-accredited consultancy which will inspect all accessible internal and external areas which may be accessed by staff, pupils, students, visitors and maintenance personnel. This includes accessible service risers, floor ducts and plant rooms. The survey will include a visual inspection of all floors, cladding, partitions, panels, walls and doors, ceilings, fanlights, soffits and pipe runs, as well as windows, sills and sashes, back panels to radiators, stair nosing, toilet cisterns and sinks.

An appropriate number of samples will be taken in areas of interest, in particular where there is a likelihood of repeat materials on other floors. Photographs in the report will identify the sample reference and location.

Based on this information, the consultant will prepare an asbestos register, which is a table of all suspected ACMs and includes their location, estimated quantity, condition and a recommendation for action i.e. how the materials should be managed. The condition of all ACMs should be re-inspected by a consultant on an annual basis at least.

It is, however, a common misconception that the data in the asbestos register can be used to inform and instruct maintenance staff or your refurbishment contractor. While the management survey will involve some sampling, it is not fully intrusive and is likely to include some “exclusions”, i.e. locations that the surveyor was unable to access, such as high areas, external materials, void spaces etc.

To prevent asbestos from becoming a safety issue during the project you should commission a refurbishment and demolition (R&D) asbestos survey. Unlike the management survey, this will involve fully intrusive techniques to access, inspect and sample suspected ACMs in all areas that are likely to be disturbed by the works. Samples will be taken of any suspected ACMs and tested in a laboratory. Indeed, when preparing for intrusive maintenance or refurbishment works, an R&D survey is a legal requirement.

Regulation five of the Control of Asbestos Regulations 2012 requires employers to identify the presence of asbestos and its type and condition before any building, maintenance, demolition or other work liable to disturb asbestos begins. It also sets out the requirement to arrange a survey if existing information on the presence of asbestos in the premises is incomplete or appears unreliable.

For example, in 2012 the HSE prosecuted Sherborne School, a large independent boys school in Dorset and the director of the company responsible for a refurbishment project there, after asbestos insulation boards were removed in an unsafe way, exposing building contractors and a teenage work experience student to asbestos fibres. The HSE investigation found that from the initial design stages right through to undertaking the construction work, there was inadequate planning and a failure to carry out a full R&D asbestos survey which would have identified the presence of asbestos in the boards.

To minimise the cost and disturbance caused by the R&D survey it is important that you brief your asbestos consultant thoroughly. Provide them with detailed plans and a full scope of the project so that they can focus their investigation on the areas that are likely to be disturbed by the works.

Because of the intrusive nature of the R&D survey you will need to give your consultant’s surveyors vacant possession of the buildings in question. The survey should ideally take place out-of-hours, i.e. evenings, weekends or holidays, and a member of the FM team should be available to accompany the surveyor to provide access to locked rooms/cupboards, plant rooms and void areas as required. Carrying out the survey out-of-hours will also prevent any unnecessary alarm that can occur should pupils/students see operatives wearing personal and respiratory protective equipment.

Before the R&D survey commences you should also inspect the consultant’s emergency plan. Uncontrolled asbestos-containing material can be exposed during surveys and the consultant should have a documented plan of action for sealing/isolating the contaminated area in such circumstances and arranging for an emergency environmental clean (carried out by a licensed asbestos removal contractor) as well as attendance by an independent analytical company to carry out reassurance air testing and issue paperwork stating that the area is fit for re-occupation.

If the maintenance/refurbishment work is imminent, it makes sense for any ACMs identified in the R&D survey to be remediated immediately. In which case there is little need for the intrusions caused by the sampling to be reinstated. However, there are occasions when the works may be delayed for some reason and the building will need to be reoccupied in the meantime. In this instance the intrusions will need to be repaired.

Basic reinstatement typically involves covering the cavity or abrasion with polythene fixed with a clear tape which is designed to prevent fibre emission. However, given the additional stresses that educational buildings often experience, especially schools, we would recommend more robust reinstatement – either painted MDF board or wipeable plastic sheets with tapered edges secured with security tape, adhesive and silicone.

Finally, it is vital that any information about the remediation is used to update your asbestos register. At the completion of the remediation phase you should receive a plan of works and consignment notes from the contractor as well as a certificate of reoccupation from the analytical company which will include an inventory of what ACMs were removed. Ensure that you retain this documentation and either use it to update the asbestos register yourself or pass it to your consultant who can revise the asbestos management plan when the next re-inspection is due.

Paul Phillips, Global Safety & Environmental

Asbestos in numbers 
128 teachers died from the asbestos-related lung cancer (2002-2010)
1999 the year asbestos banned as building product in UK
75% UK schools that contain asbestos (estimate)
1983 asbestos removal becomes licenced in UK
2012 latest revision of Control of Asbestos Regulations
25% UK schools with adequate asbestos management plan (2010)
3 main types of asbestos (brown, blue and white)
4,000 Workplace-related fatalities due to asbestos exposure each year 

Where asbestos is typically found
Textured coatings e.g. artex
Floor tiles
Insulating boards
Corrugated roofing
Millboard/paper insulation
Rainwater goods

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