The consultation aims to seek stakeholders’ views on three proposals:
- To ensure the independence and impartiality of roles in the four-stage clearance process to further minimise the risk of exposure from asbestos to workers and building users after the removal of asbestos
- To drive up the standard of asbestos surveys to ensure duty holders have the information they need to safely manage asbestos risks
- To clarify the type of work that constitutes work with asbestos known as Notifiable Non-Licensed Work (NNLW)
The importance of transparency following asbestos removal has always been paramount and it makes sure that the four-stage clearance process (preliminary check of site conditions, a through visual inspection of the enclosure, clearance air monitoring, final assessment following enclosure dismantle) is strictly adhered to has been a challenge for many years.
Adding the relevant information from the asbestos surveys to the asbestos management plan has always had its challenges. Further enhancing asbestos surveys by giving clear guidance on caveats, areas covered or indeed not covered and limitations, so it is clear what has been covered should further lead to a more comprehensive approach.
One potential improvement could be to add a walls, floors and ceilings register of each room. This would inform the building occupier or any workers what areas have been covered, what types of materials are used in these areas – critical for future challenges on building materials used and demonstrate that the surveyor has visited each area.
There has always been some debate around Notifiable Non-Licensed Work (NNLW), primarily around the classification of the amount and type of asbestos being delt with including the following:
- Large scale removal of textured decorative coatings using steam or gel methods, minor short duration works involving removal of asbestos insulation board;
- Minor repairs to asbestos insulation;
- The removal of cement products where the material has been significantly damaged or ‘dropped’ from height; and
- Asbestos paper and cardboard products.
The transparency of removal, addition of more information to surveys and further clarification around Notifiable Non – Licenced Work can only help to protect all those involved in the management of asbestos in buildings throughout the UK and all those who work in, visit, or use facilities within these buildings.
If you would like to submit your ideas on the Control of Asbestos Regulations to the HSE you can do so here: Legislative and guidance proposals for the Control of Asbestos Regulations 2012 - Introduction - Health and Safety Executive - Citizen Space