Control Of Asbestos Regulations 2006

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Control Of Asbestos Regulations 2006 Powered By Docstoc
					Bruce Sutherland & Andy Ellis

Control Of Asbestos
Regulations 2006
Program

  What is the problem
  CAR 2006
  What does it mean in practice
           Asbestos
How big is the problem

All Work Death inc Rail
Road Death
Cervical Cancer Death

Asbestos Related Death
Asbestos Diseases

 Pleural Plaque, Asbestosis, Lung Cancer, Mesothelioma

              1600

              1200
      Cases




               800

               400

                 0



                           Death Certificates



 2-3% of all male lung cancer ?
Other law
 HSW s 2,3,4
 Man Regs 1992
 Workplace Regs 1992 – “occupiers to maintain
 workplace buildings to protect occupants and
 workers
 CDM 2004 and 2007 – nb “higher” duty under CDM
 2007 on information
 Defective Premises Act 1972 – landlords to take
 reasonable care re tenants & others safe from PI /
 disease caused by defect in state of premises
 EPA 1990 – s 79 statutory nuisance
More Books……

 ASLIC / CAW /            Control of Asbestos
Prohibition Regulations     Regulations 2006
  L27, L28 ASLIC Guide    L 143 ACOP
  L127 ACOP on Reg 4      New L127 ACOP on Reg 4
  MDHS77 MDHS39/4         HSG248 lab guide
  HSG189/1 etc etc        HSG 247 licensed contractors
  HSG210                  HSG210
  HSG 189/2               HSG 189/2
  MDHS 100                MDHS 100
  HSG227                  HSG 227
                          MDHS 87
Control of Asbestos Regs
   Replaces ASLIC / CAWR
/ Prohibition
   13 November 2006
    New ACOP
   “Non Licensable” work
   “Licensable” work
    Analytical Changes
CAR Reg 2 Interpretation
  Control Limit – 0.1f/ml 4 hour TWA
Exposure Levels
 “the control limit” means a concentration of
asbestos in the atmosphere of 0.1 fibres per ml of air
averaged over a continuous period of 4 hours

   Peak airborne levels should be reduced to below 0.6
fibres per ml on a 10 minute average

No difference between the fibre types – i.e. blue and
white have the same value
CAR Reg 2 Interpretation
  Control Limit – 0.1f/ml 4 hour TWA
  ISO 17020 / 17025 surveys and labs
  Debris - guidance
  Asbestos Cement new test - guidance
  Textured Decorative Coatings (TC (artex))
  unlicensed – guidance
  AIB / Insulation / Coating – ACOP
CAR Reg 2 ( cont)
   Work with Asbestos - ACOP
   Competence - ACOP
“ adequate information instruction training for
   task being undertaken, and can
   demonstrate adequate and up to date
   understanding of the work, required control
   measures and law AND sufficient practical
   experience to apply this effectively”
CAR Reg 3
  Licensable / Non Licensable
  Sporadic and Low intensity - guidance
  Short non continuous maintenance – ACOP
Reference to HSG 210
  Insulation / AIB – ACOP
  Employer’s duties – consider other people /
  two employers to cooperate - ACOP
“Licensable Work”
 Insulation / AIB / Coating
 HSE License full ancillary supervisory
  Notify (14 days)
  Medical & health record
  Asbestos emergency procedures
  Identify “asbestos area”
Non Licensable Work
 No HSE License
 Not notify
 No medical & health record
 No asbestos emergency procedures
 No “asbestos area”

HSG 210 provides a good guide
Sporadic and Low Intensity
   Assessment - less than Control Limit and less than
MEL
   short, non-continuous maintenance activities,
   removal of materials in which the asbestos fibres are
firmly linked in a matrix,
   encapsulation or sealing of asbestos-containing
materials,
   air monitoring and control, and the collection of
samples to ascertain whether a specific material
contains asbestos.”
Short non- continuous
maintenance activities
   Assessment - less than Control Limit and less than
MEL
   Examples of short non-continuous maintenance
activities include the following type of tasks when working
with asbestos insulating board for which there is greater
detail in HSG210 e.g.
   Drilling between 1 to 20 holes, up to 20mm in diameter
in asbestos insulation board up to 6mm thick when using a
plastic enclosure over the drill, which is connected to a
Type H vacuum cleaner.
   Drilling between 1 to 5 holes, up to 20mm in diameter in
asbestos insulation board up to 6mm thick when drilling
through paste.
Non Licensable Work
Where it is clear from the risk assessment that the control limit
will not be exceeded no license is required:
  asbestos cement,
  textured decorative coating which contains asbestos,
  any article of bitumen, plastic, resin or rubber which contains
asbestos where its thermal or acoustic properties are incidental
to its main purpose (e.g. vinyl floor tiles, electric cables, roofing
felt),
  asbestos materials such as paper linings, cardboards, felt ,
textiles, gaskets, washers, and rope where the products have no
insulative values
CAR Reg 4 Duty to Manage
 Limited change
 Reissue of ACOP L127
 NB competence definition
 Surveyors – ISO 17020 – UKAS / NIACS
     Reasonable Steps to find ACM / condition
     Presume acm unless otherwise proved
     Written record / up to date
     Assess risk of exposure
     Plan to Manage Risk / follow it
  ACM kept in good condition / repair / remove
  Provide information to anyone at risk
CAR Reg 5 Identification of
presence of Asbestos
An employer shall not undertake work in demolition,
     maintenance or any other work which exposes or
     is liable to expose employees to asbestos in
     respect of any premises unless either
a) Suitable and sufficient assessment as to what type
     of asbestos in what material and what condition
or
b) If there is a doubt that asbestos is present assume
     it is and it is not Chrysotile alone and

Reg 4 / CDM / sample or assume licensed
CAR Reg 6 & 7 Assessment
/ Plans of Work
 Prevent exposure in first place
 Job Specific – but can use generic as a base
 In writing
 If licensable – on site
 Communicated in a comprehensible manner
 Must know what fibre concentration in air is –
 estimated exposures confirmed by measurement –
 summary of data and source in assessment
 If Non licensed – summary of why
 18 points to be included in RA! E.g.. if no
 enclosure why and what action should be taken if
 an accidental release happened
 Carried out by a competent person
Competence for Assessment
 “whoever carries out the assessment should:
   have adequate knowledge, training and expertise in
 understanding the risks from asbestos and be able to
 make informed decisions about the risks and
 precautions that are needed;
   know how the work activity may disturb asbestos;
   be familiar with the Asbestos Regulations and
 understand the requirements of the ACOP;
   have the ability and the authority to collate all the
 necessary, relevant information
   be able to assess other non-asbestos risks on site”.
CAR Reg 9 Notification

  14 days
  Only licensable
  Enforcing Authority Regs – LA / HSE
  Only correctly notified if to correct
  authority
CAR Reg 10 Training
   Asbestos awareness training is required to be given to
 employees whose work could foreseeable expose them
 to asbestos – demolition, refurbishment, maintenance
 and allied trades know how the work activity may
 disturb asbestos;

   Training for non licensable asbestos work

   Training for licensable asbestos work familiar with the
 Asbestos Regulations and understand the requirements
 of the ACOP;
CAR Reg 10 Training (cont)
   Competence of Training providers - ACOP

 “Adequate personal practical experience and a
 theoretical knowledge of all relevant aspects of work”

 HSE’s Asbestos Licensing Unit has a list of trainers who
 have signed up to their guidance and standards for
 training on www.hse.gov.uk
CAR Reg 14 Provision and
Cleaning of Protective
Clothing

  Coveralls – ISO 13892-1 – type 5
  Surveyors – decide if kit
  contaminated
CAR Reg 15 Arrangements
to deal with accidents,
incidents and emergencies

  Safety drills – tested……
  Information for emergency
  services - ACOP
  Uncontrolled release - ACOP
CAR Reg 17 Cleanliness of
premises and plant


  Thorough cleaning – Licensable –
  4SC - ACOP
  Dry manual brushing / sweeping /
  compressed air – banned – ACOP
  4 Stage Clearance
CAR Reg 18 Designated
Areas


 Licensable – demarcated / signed
 All areas – RPE – SFARP
 Competent to enter
CAR Reg 19 Air Monitoring

 Air monitoring all work unless
 Previous monitoring - < 0.1 / 0.6
 f/ml
 Non licensable and known levels
 PPE so good that no better could
 be needed
CAR Regs 25 - 37

 25 – 31 – prohibitions
 32 – 34 – exemptions
 35 – existing licences
 36 - revocations
 37 Defence – all reasonable precautions and
 exercised due diligence
Demolition
  In the case of demolition or refurbishment, the plan of
work must specify that asbestos is removed before any
other major work begins where this is reasonably
practicable and does not cause a greater risk to employees
than if the asbestos had been left in place.
   Where removal of ACMs is time consuming and
resource intensive and involves a low hazard material such
as asbestos-containing textured decorative coatings, then
removal prior to demolition or major refurbishment is
unlikely to be reasonably practicable.
   Noble currently leading the discussion with ALU on this
subject
Sample One
Sample Two
Sample Three
Sample Four
Sample Five
THIS WALL

 •Duty holder
 •Prove not asbestos- Survey
 •Training, Asbestos awareness
AIB ON FIRE DOOR
AIB ON FIRE DOOR

Assume asbestos unless prove otherwise,
 assume not white
Assume Licensed,
Must know anticipated fibre level, Specific
 Risk Assessment , Plan of Work, H type
Training, Practical
Insurance
TEXTURED COATING
Textured Coating
  Anything portable and likely to be contaminated remove
  Enclose / sheet
  2 stage air lock
  P3 masks
  Decontaminate in air lock using type h and cleaning
footwear in 1st stage and removing in second stage
  Thorough clean
  No air test
  Visual inspection by contractor – self issue certification
Fibre Counting
•0.01f/ml (20 fibres in 480 lts of air)

ERM:                                      WHO:
1 Fibre                                   2 fibres
Fibre Counting
- dusty slides
 ERM                WHO
 31                 36
 84                 90
 13.5               15.5
 27                 28
 37                 38

        WHO counts approx 10% higher
           AIB may be 50% higher