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					                     HEALTH DEPARTMENT OF WESTERN AUSTRALIA

                                         CIRCULAR

Applicable to: GENERAL MEDICAL UNITS
                   PSYCHIATRIC SERVICE UNITS
                   PUBLIC HEALTH UNITS
                   COMMUNITY HEALTH UNITS
                   DENTAL HEALTH SERVICES UNITS

Enquiries to:      Environmental & Occupational Medicine Unit     Number:       A 7251
                   (09) 222 4972                                  Date:         27 September 1989
File No:           86-01321


Subject:       ASBESTOS IN HEALTH SERVICE UNITS



      The Health Department of WA’s Asbestos Management and Custodial Control Programme
      has undergone significant revision. A copy of the new document is appended for your
      information.

      This update has occurred in response to the Occupational Health, Safety and Welfare Act
      1984. The Programme reflects a tripartite approach and incorporates the recommendations
      of the National Occupational Health and Safety Commission's (Worksafe Australia) Code of
      Practice and Guidance Notes on Asbestos.

      The Health Department of WA’s goal - to ultimately remove all asbestos from the workplace
      - has not changed. This new programme provides specific guidelines for the identification,
      evaluation and control of asbestos-containing materials. Sources of asbestos in a good
      condition will continue to be monitored but will necessarily receive a lower removal priority
      than other potentially more hazardous sources.

      The responsibility for the implementation of this programme lies with management, but all
      employees through their health and safety representatives should be involved in ensuring a
      healthy and safe working environment.


           The Head of each Hospital and Service Unit is required to confirm the adoption
           of this programme in writing before 1 November 1989. Thereafter an annual
           report is required from each individual Hospital and Service Unit which details
           the assessed condition of all asbestos-containing products which remain on the
           premises. Such correspondence should be addressed to the Environmental and
           Occupational Medicine Unit, 11th Floor, Mineral House, 11 Plain Street, Perth,
           Attention: Ms S Griffiths.


      You are urged to read this document carefully. An ongoing asbestos management
      programme should be implemented in each Health Department Service Unit as a priority.




      Bruce K Armstrong
      COMMISSIONER OF HEALTH
                         HEALTH DEPARTMENT OF WA

  ASBESTOS REMOVAL/MANAGEMENT AND CUSTODIAL CONTROL PROGRAMME


                                CONTENTS

1.0    INTRODUCTION
2.0    WHAT IS ASBESTOS?
3.0    HEALTH ASPECTS
4.0    LEGISLATIVE REQUIREMENTS
5.0    CONSULTATION
6.0    ASBESTOS DETECTION
7.0    MATERIAL SAMPLING
8.0    RECORDS
9.0    RISK EVALUATION
10.0   AIR MONITORING
11.0   EXPOSURE STANDARDS
12.0   SELECTION OF APPROPRIATE CONTROL METHODS FOR ASBESTOS
12.1   MANAGEMENT AND CUSTODIAL CONTROL
12.2   REMOVAL
                                           - 2 -


1.0      INTRODUCTION

The purpose of this document is to provide asbestos guidelines for Health Department
establishments which have asbestos in some form within their workplaces, and require an
asbestos management policy suited to their needs.

Experience in asbestos management, in conjunction with current legislation, has shown the
need for each worksite to develop and implement a written policy on asbestos
management.

It is hoped that this document can be used as a starting point to enable identification,
evaluation and control of the asbestos materials within Health Department buildings and
workplaces.

Although the ultimate goal is to completely remove asbestos from the workplace much of
the asbestos found in structures today is not in need of immediate removal. Resources
should be concentrated on asbestos which is a health risk or is in vulnerable or exposed
locations. This programme therefore, provides for two options, namely management and
custodial control or removal. Management and custodial control defers asbestos removal
through implementing procedures to minimise exposure and regularly reassessing the
condition of the asbestos products until removal is warranted.


2.0      WHAT IS ASBESTOS?

Asbestos is a broad term for a group of fibrous silicate minerals. The most commonly used
in Australia were:

               Chrysotile     (white asbestos)
               Crocidolite    (blue asbestos)
         and   Amosite        (brown asbestos)

These long thin rock fibres can easily be separated and this, together with their qualities of
tensile strength, durability, flexibility and resistance to heat, wear and corrosion gave
asbestos products a wide range of uses.


3.0      HEALTH CONCERNS

Asbestos becomes a health risk once fibres are released from asbestos material, inhaled
and subsequently deposited in the lungs. The resulting asbestos-related diseases follow a
dose-response relationship, often encompassing a long latency period. The greater and
longer the exposure to asbestos fibres the greater the likelihood of disease.

The main asbestos-related diseases are:

•     Asbestosis

A progressive scarring of lung tissue (fibrosis) which can leave the patient chronically short
of breath.

•     Lung Cancer
                                          - 3 -


Lung cancer caused by exposure to asbestos is clinically identical to other lung cancers.
People exposed to asbestos and who smoke greatly enhance their risk of developing lung
cancer.

•     Mesothelioma

A rare cancer affecting the lining of the chest cavity (the pleura) or, less commonly, the
lining of the abdominal cavity (the peritoneum).


4.0     LEGISLATIVE RESPONSIBILITIES

The Occupational Health, Safety and Welfare Act 1984 imposes responsibilities on
employers, contractors, subcontractors and employees. Regulations made under this Act,
the Occupational Health, Safety and Welfare Regulations 1988, (Part 8, Division 1,
Regulations 801 to 825 inclusive), relate specifically to working safely with or near
asbestos. The Health (Disposal of Asbestos Waste) Regulations 1984, provide for the safe
collection, transportation and disposal of asbestos waste throughout Western Australia.


5.0     CONSULTATION

All parties involved with asbestos including governments, employers, property owners,
employees, health and safety representatives and trade unions, have a positive role in
establishing and maintaining safe and healthy places of work and work practices.

Where asbestos products are present (or thought to be present) in a building or other
structure, full consultation, involvement and information sharing should occur between
employers and employees through established consultative processes, at each step of the
inspection, identification, evaluation and control processes.

Establishment of direct provisions for consultation, communication and co-operation at all
levels is essential and may include the appointment of health and safety representatives,
formation of joint health and safety committees and ready access to inspectorial and expert
advisory services.


6.0     ASBESTOS DETECTION

Asbestos has reportedly been used in more than 3,000 products and may be found mixed
with a variety of substances including diatomaceous earths, talc, clay, chalk, sand, cement,
paper, rubber and a wide range of resins. The use of trade names may further impede its
detection.

Asbestos-containing sprayed insulation materials may be encountered throughout buildings
and other structures, especially those built in the 1950s to early 1970s.

Many other asbestos-containing products and materials may still be found. These include
asbestos-backed vinyl tiles, laboratory table tops, asbestos cement products, roofing felts
and suspended ceiling tiles. However, these types of materials do not present a health risk
unless the binding material has deteriorated and/or they are tooled, but, sanded or
otherwise abraded or machined (particularly at high speeds) so as to generate airborne
asbestos dust. Asbestos-cement products including building and fencing sheeting may
                                             - 4 -


present a health risk if they have weathered to an extent sufficient to generate significant
quantities of airborne asbestos fibres.

The types of asbestos-containing materials which may be encountered in a building or
other structure which are of most concern from a health standpoint include:

•     sprayed-on fireproofing/soundproofing/thermal insulation. These vary from hard,
      impervious and well-sealed materials to friable materials applied by spraying or
      trowelling. The colour will normally vary from white to brown/grey to blue, although in
      some instances products may have been painted or dyed.

      These materials are found on structural steel members and decks (as fireproofing),
      ceilings, fire-plugging, fire doors and occasionally on walls (as fireproofing and/or
      soundproofing). They may be exposed or may be concealed by suspended ceilings or
      other decorative structures. It should be noted that, where the material has been used
      exclusively for fireproofing, it will probably be found to have been used for the same
      purpose throughout the building or other structure.

•     acoustic plaster soundproofing. This is a firm, open-pored, plaster-like material
      applied by a trowel. The soundproofing material is usually exposed and not usually
      painted.

•     insulation. Asbestos-containing material used in the insulation of air conditioning ducts,
      hot and cold water pipes, steam pipes, hot-water reservoirs, pressure tanks, and boilers
      is generally covered with a fabric or metal jacket. Fire doors often contain laminates of
      asbestos materials covered by wood or metal.

It should be noted that not all spray-on fireproofing/soundproofing, acoustic plaster and
insulation contains asbestos. Only laboratory analysis of samples of the particular material
can conclusively identify the presence, type and proportion of asbestos.


7.0      MATERIAL SAMPLING

Sampling and analysis of suspect material is the only way to verify the presence of
asbestos (air monitoring to determine the presence of asbestos is not acceptable by itself).
It is important to sample all suspect material and have it analysed. Suspect material should
be handled with care.

Samples should be taken of all suspect or friable material. Whatever method is used it is
important that a representative sample be taken by a person experienced in dealing with
asbestos. Any variations in the appearance, texture or colour of the material will
necessitate additional samples being taken.

Samples taken should be adequately labelled to enable follow-up action. For example the
name and location of the building, the exact location of the sampled material, date of
sampling, a batch identification number and the number of the person sampling should all
be recorded.

It is important that the analysis is performed by a competent laboratory to ensure accurate
results. False results could lead to expensive abatement actions or allow an existing risk to
remain.
                                            - 5 -



8.0      RECORDS/BUILDING REGISTER

The Health Department of WA, Building Services Division and the Building Management
Authority have already undertaken thorough inspections of all hospitals. Detailed records of
asbestos-containing materials within such buildings should already exist including
information relating to the location, type and condition of any asbestos products found.
Such records should be updated at least annually following a routine inspection in
accordance with the Asbestos Management and Custodial Control Programme (refer to
Part 12 of this document).


9.0      RISK EVALUATION

If analysis of material samples confirms the presence of asbestos, the potential exposure of
persons entering the building or other structure should be evaluated. Many factors
associated with the condition and composition of the material need to be assessed in this
process.

The general condition of all asbestos products contained in the workplace, including those
used in the building or other structure for thermal or sound control, shall be visually
assessed by a person who is competent to evaluate the associated risk (that is the
potential of such asbestos products to release airborne dust). Such assessments should be
undertaken in association with the Health and Safety Representative for each respective
workplace.

The period between each visual assessment will be determined by the condition and
location of the asbestos. In some cases a visual assessment will be required on at least an
annual basis. Where the asbestos is in good condition and unlikely to be disturbed visual
assessment at three-yearly intervals may be adequate.

There is a need to look at the usage of the asbestos-containing area and of people's
access to such areas.

The factors noted in visual inspection of buildings for asbestos insulation are:

•     Condition of Material:

If material is deteriorating, coming loose or if pieces are falling off, the possibility of fibre
release is increased.

•     Water Damage:

If water/steam is leaking onto the material it can cause rapid deterioration leading to fibre
release.

•     Exposed Surface Area:

The greater the exposed surface area of the material the greater the likelihood that any
released fibres will reach people working nearby.
                                           - 6 -


While a suspended ceiling may cause material to be classified as non-exposed, it should
be appreciated that maintenance workers above the suspended ceiling are not protected
by the enclosure.

•   Accessibility:

If the material can be reached by workers or occupants, it is potentially subject to accidental
or intentional damage which may release fibres.

•   Activity and Movement:

Air movement or building vibration can cause fibre release, while the movement of people
or vehicles on the floor can stir up fibres that have settled. Cleaning by dry methods, eg.
broom sweeping or the use of compressed air, is prohibited because particularly high
airborne fibre levels are generated.

•   Friability:

Material which is easily crumbled or reduced to powder (friable) has a greater potential for
asbestos fibre release.

•   Air Plenum or Direct Air Stream:

If friable material is enclosed within an air plenum, any fibre release which may occur is
likely to be distributed throughout the building.

•   Asbestos Content:

The higher the asbestos content in the material the greater the number of asbestos fibres
released under any given conditions.


10.0    AIR MONITORING

Air sampling is not an alternative to visual assessment in estimating asbestos
contamination and exposure. The Member Filter Method is the only recognised
measurement technique for the determination of airborne asbestos fibre. Results obtained
by air sampling are almost invariably below the detection limit of the Membrane Filter
Method, especially when samples are taken at times when the asbestos is not being
disturbed.

Air monitoring is required in certain circumstances. For example, when asbestos removal is
in progress, the Membrane Filter Method shall be used.

Air monitoring must only be undertaken by persons adequately trained and using approved
monitoring techniques.

Determination of airborne asbestos fibre samples shall be performed only by NATA
(National Association of Testing Authorities) registered or government accredited
personnel, when such accreditation is available.


11.0    EXPOSURE STANDARDS
                                           - 7 -



Exposure to airborne asbestos should be kept as low as achievable and in any case below
the specified exposure standards.

The exposure standards listed below are those currently specified by the National
Occupational Health and Safety Commission for OCCUPATIONAL EXPOSURES; that is,
for those workers engaged in processes related to the use of asbestos, or in the removal of
asbestos products.

The exposure standard sets out the time-weighted average (TWA) fibre concentration of
the air breathed by the worker throughout a working shift, as calculated from one or more
measurements taken over a sampling period of not less than four hours using the
Membrane Filter Method. The TWA airborne concentrations shall be kept as low as
achievable and in any case shall not exceed:

       •    chrysotile                                    -   1.0 fibres per millilitre
       •    crocidolite                                   -   0.1 fibres per millilitre
       •    amosite                                       -   0.1 fibres per millilitre
       •    other forms of asbestos                       -   0.1 fibres per millilitre
       •    any mixture of these, or where the            -   0.1 fibres per millilitre
            composition is unknown

These values may be reviewed from time to time, therefore the most recent publication of
the NOHSC Exposure Standards document should be consulted for any variations.

During asbestos removal works the air monitoring results should be displayed in a
conspicuous area accessible to all employees working within the building concerned.
Results displayed should be accompanied by a statement clearly referencing such results
against the occupational exposure standards given above.

The exposure standards given are for occupational exposures. No public health exposure
standards exist however the potential for members of the public to be exposed to
measurable levels of asbestos in or around hospitals for a prolonged period of time is
negligible. The aim should be to ensure that members of the public have no measurable
exposure to airborne asbestos fibres.


12.0   SELECTION OF APPROPRIATE CONTROL METHODS FOR ASBESTOS

Where the evaluation process has revealed a likelihood of exposure to asbestos fibres, all
practicable steps should be taken to ensure that employees are not unnecessarily exposed.
A thorough examination of work practices is an essential preliminary action. Procedures
should then be adopted to ensure, as far as possible, that employees are not exposed to
asbestos.

Based upon the assessment of the condition of the asbestos, the possibility of further
damage or deterioration, and the potential for employee exposure to airborne asbestos, an
appropriate method should be selected, either:

       Management and Custodial Control

       or
                                   - 8 -


Removal.

12.1   Management and Custodial Control

Notwithstanding the ultimate goal of an asbestos free workplace priorities should be
set for control in the short term. Asbestos products, if stable and inaccessible,
should be left in situ until demolition, partial demolition or major renovation.

Asbestos management and custodial control defers removal and allows asbestos
containing material to remain in the building through establishing procedures to
eliminate or minimise exposure. Through this option resources can be concentrated
on those sources of asbestos that represent an immediate risk to health.

Appropriate control procedures as identified below must be adopted and followed
whilst asbestos containing materials remain in the building.

       12.1.1 Appointment of a Designated Officer:

       A person must be nominated to be in charge of the programme. This person
       should be someone who preferably works on site and is readily accessible.
       He/she must be a competent person to the satisfaction of the Administrator
       and the Health and Safety Committee.

       The Designated Officer will:

       •   be familiar with all the areas where asbestos is known to exist

       •   maintain written records in the form of a Building Register. These records
           must include details of the location, type and condition of asbestos-
           containing materials and the date of each inspection.

       •   be informed at the earliest opportunity of all matters relating to the
           presence of asbestos within the building

       •   be advised of all proposed maintenance works intended to be
           undertaken within asbestos-containing areas or in any location likely to
           disturb asbestos-containing materials.

       •   ensure supervision of all persons intending to enter asbestos-containing
           areas whether maintenance staff or contractors.

       •   implement and periodically inspect labelling, warning sign and security
           procedures to ensure that access to the areas containing asbestos is
           limited to people who need to be there.

       12.1.2 Precautions for workers entering asbestos containing areas:

       Access to the areas containing asbestos must be limited to people who need
       to be there.

       Workers, including contractors, entering an asbestos area should be
       informed of the presence of asbestos. All workers in the area must use safe
       work practices and all such work must be supervised. Personal protective
                             - 9 -


clothing and equipment should be worn. Training of maintenance workers in
safe work practices should be undertaken early. (The Occupational Health
Unit of the Health Department will be prepared to help and advise whenever
requested).

Contract staff needing to enter asbestos areas must be issued with, and
requested to sign, a statement detailing safe working practices which must
be followed before entering such areas (see Appendix 1).

12.1.3 Labelling and Warning Signs:

Cautionary labels and warning signs must be used where practicable to
ensure that persons entering the area will know of the presence of asbestos,
to ensure that no one works on asbestos without an appropriate licence and
to ensure that, in the event of damage, the occurrence is reported
immediately so that corrective action can be taken.

All identified asbestos in a building or other structure should be labelled so
that it is clearly visible to persons using the area until it is finally removed.
This requirement applies equally to asbestos which is in a good condition
and to treated asbestos. Labels used for this purpose must identify the
material as containing asbestos and should comply with Australian Standard
1216. All warning signs should comply with Australian Standard 1319.

Non-asbestos insulating products should also be labelled (including details
of the trade name and composition) when such products are installed.

In areas where the locating of adequate warning signs may prove difficult eg.
in ceiling spaces, warning signs should still be positioned where practicable
at likely points of entry but a system of work dockets should also be
introduced. For work in such spaces work dockets stamped with the words
"Asbestos Work - Caution" should be issued by the designated officer.

The work should be authorised and supervised by that officer who should
ensure that all protective clothing and equipment required is issued and
used.

The international symbol should be used for labelling asbestos-containing
products.

INTERNATIONAL ASBESTOS LABEL
                           - 10 -




12.1.4 Protective Clothing and Equipment:

Arrangements must be made to ensure that all persons entering areas
containing asbestos are provided with protective clothing and equipment. For
maintenance work which is likely to disturb the asbestos, Class L or M
disposable dust respirators, overalls and head covers should be worn.

An asbestos-approved vacuum cleaner must be available to vacuum clean
work clothes prior to leaving the area(s). Under no circumstances must
anyone leave the 'dirty' area with disposable overalls on.

12.1.5 Smoking, Drinking and Eating:

No smoking, drinking or eating is to be allowed in the asbestos designated
area(s).

12.1.6 Disposal of Asbestos Containing Waste Materials:

Any waste material generated which could contain asbestos should be
collected and disposed of appropriately. In the case of asbestos dust this
involves collection using an approved vacuum cleaner, transport in labelled
heavy duty polyethylene bags and burial at a site as specified in the Health
(Disposal of Asbestos Waste) Regulations 1984 or otherwise approved in
writing by the Commissioner of Health.

12.1.7 Periodic Inspections of Asbestos Containing Materials:

All asbestos containing areas must be periodically inspected to ensure that
the asbestos is still in a satisfactory condition not requiring removal or other
treatment. Inspections should be undertaken by the designated officer or
other experienced person to the satisfaction of the Health and Safety
Committee. These inspections should be undertaken at least annually
however the frequency will depend upon the condition of the asbestos
present and should be determined by the Health and Safety Committee after
seeking advice from persons experienced and qualified to give such
guidance.

The person undertaking such inspections shall provide a written report of
his/her findings; copies of which must be sent to the Administrator or
                                 - 11 -


       Hospital Secretary, the Occupational Health and Safety Committee of the
       Service Unit and the Health Department of W.A. (Building Services and
       Occupational Health Unit).

       If it is noticed that the asbestos has deteriorated advice should be sought
       immediately from the Health Department of W.A., Occupational Health Unit,
       as to whether any further action needs to be taken.

12.2   Asbestos Removal:

       12.2.1 By Whom?

       Contractors or other agencies to be engaged in asbestos removal and
       maintenance work, whether incorporated, unincorporated or self-employed,
       shall be licensed as asbestos removalists under the Occupational Health,
       Safety and Welfare Regulations 1988.

       No person should be allowed to remove asbestos, or engage in maintenance
       work upon asbestos products, unless they or their employer are so
       registered.

       12.2.2 When?

       Asbestos which is not in a stable condition, or is determined to constitute an
       unacceptable health risk, shall be removed by a registered removalist.

       Major asbestos removal programmes are often complex, expensive and
       cause substantial disruption to the occupancy of the building. Even then, the
       removal process poses an increased risk to the personnel engaged in the
       removal and can result in increased fibre counts in other areas if the removal
       programme is not strictly controlled. In general, asbestos insulation should
       be removed:

       •   when it is breaking away from the substrate base; or

       •   when the insulation is likely to be abraded or otherwise damaged; and

       •   when the surface is friable and other control techniques are not deemed
           to be satisfactory.

       As there is a possibility that non-asbestos insulation may become
       contaminated from adjacent sprayed asbestos, consideration may need to
       be given to the treatment of this adjoining non-asbestos insulation.

       12.2.3 General Conditions of Removal:

       Before the commencement of asbestos removal or maintenance work a
       permit for the particular work is required from the Commissioner of
       Occupational Health, Safety and Welfare.

       Supervisors of asbestos removal projects and demolition and structural
       alteration projects involving asbestos must:
                                          - 12 -


              •   be suitably trained and experienced

              •   report directly to the designated officer

              •   have authority to stop work if there is a risk to health and safety

              •   have full-time involvement in the asbestos work

              •   work in conjunction with those conducting air monitoring.

              12.2.4 Provision of Information:

              A registered asbestos removalist shall, following consultation, give adequate
              notice to property owners, employers and employees that asbestos removal
              is to be carried out and when it is to be carried out. The notification should
              also include an explanation of the general procedures, the equipment
              involved and the precautions to be taken. Adequate information and
              instruction shall be provided to all employees whose duties are likely to be
              affected by the asbestos removal works.

              12.2.5 Disposal of Asbestos Containing Waste Materials:

              Any waste material generated which could contain asbestos should be
              collected and disposed of appropriately. In the case of asbestos dust this
              involves collection using an approved vacuum cleaner, transport in labelled
              heavy duty polyethylene bags and burial at a site as specified in the Health
              (Disposal of Asbestos Waste) Regulations 1984 or otherwise approved in
              writing by the Commissioner of Health.


REFERENCES

Information contained within this document has been extracted mainly from the following
sources:

•   Asbestos - Code of Practice and Guidance Notes
    Worksafe Australia
    National Occupational Health and Safety Commission
    Aug. 1988, AGPS Canberra 1988.

•   Occupational Health, Safety and Welfare Act 1984

•   Occupational Health, Safety and Welfare Regulations 1988

•   Health (Disposal of Asbestos Waste) Regulations 1984
                                                                              APPENDIX 1



INSTRUCTIONS TO BE ISSUED TO CONTRACT STAFF ENTERING ASBESTOS AREAS

In accordance with relevant legislative requirements, contract staff entering asbestos areas
must read and comply with the following:

1.     For maintenance work which is likely to disturb the asbestos insulation: Class L or M
       disposable dust respirators, overalls and head covers must be worn.

2.     An asbestos-approved vacuum cleaner must be available to vacuum clean work
       clothes prior to leaving the area(s). Under no circumstances must anyone leave the
       'dirty' area with disposable overalls on.

3.     Maintenance work carried out in asbestos areas must be performed in such a
       manner as to avoid unnecessary disturbance of the asbestos materials present.

4.     Should the asbestos materials be damaged or disturbed then the contractor must
       advise (specify designated officer) and must take precautions to minimise further
       contamination, eg. through the use of an approved vacuum cleaner before leaving
       the work area.

5.     No smoking, drinking, or eating is allowed in the asbestos designated area(s). The
       hospital generally is a non-smoking area.

6.     No maintenance work to proceed until (specify designated officer) is consulted.

7.     All protective equipment will be supplied (Asbestos Removalists Exempted from this
       instruction) by (specify protective equipment arrangements).

8.     Any questions may be directed to (specify designated officer) by calling (specify
       contact arrangements).



                Signature                                         Signature



                Signature                                         Signature



     Name of the Contract Company



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