HSE going back to school with asbestos management

Greg Davies 2022

Greg Davies
Director of Market Development, Assurity Consulting
8th September 2022

This is because HSE will be starting a programme of inspections of primary and secondary schools in England, Scotland and Wales, covering the management of asbestos.

The link to the bulletin is - Education: health and safety in schools, further and higher education (hse.gov.uk)

The aims of the inspection programme are to assess “how schools are managing the risks from asbestos within the school estate and meeting the ‘duty to manage’ (DTM) requirements under Regulation 4 of the Control of Asbestos Regulations 2012” (CAR). During the inspections, they “will need to speak to someone with knowledge of how asbestos is managed by the school and may also ask to see certain documentation.”

Regulation 4 of the CAR contains the duty to manage asbestos in non-domestic premises, which includes schools). The requirement/expectations of the regulation include dutyholder requirements to:

  • Identify the location and condition of any asbestos containing materials (ACM) or presumed asbestos containing materials (PACM) in non-domestic premises: and
  • Manage these ACM and PACM accordingly, so the risks of harm to anyone who works on the building or to building occupants is prevented.

For schools, the dutyholder will depend on the organisation, for example:

  • In independent, foundation or voluntary aided schools it is the governing body;
  • For academies, the dutyholder is the academy trust; and
  • In state funded, community and voluntary controlled schools it is the local authority.

What will the inspectors be expecting?

Firstly, dutyholders will need to have undertaken a suitable and sufficient assessment as to whether asbestos is present or liable to be present in their premises and documented it.

Where this assessment indicates asbestos is or is liable to be present the dutyholder must make sure that:

  • A determination of the risk from that asbestos is made;
  • A written plan identifying those parts of the premises concerned is prepared; and the measures that are to be taken for managing the risk are specified in the written plan, including:
    • Monitoring the condition of any ACM or PACM;
    • Making sure that any ACM or PACM is properly maintained or where necessary are safely removed;
    • Making sure that information about the location and condition of any ACM/PACM is provided to every person liable to disturb it;
  • A plan that is reviewed and revised at regular intervals, and without delay (if, for example, there is reason to suspect it is no longer valid or there has been significant change in the premises for which the plan has been developed);
  • Measures specified in the plan are implemented; and
  • Measures taken to implement the plan are recorded.

What does your current management look like?

Some questions you should be asking:

  • Have any ACM/PACM been affected by any works you’ve had done in recent times/over the Summer, and how have these been reflected, as appropriate in your management?
  • Were there any areas excluded for your assessment and what have you done about these since?
  • What does your current asbestos management documentation look like, and does it provide an accurate and up-to-date record?
  • Have all relevant staff had asbestos awareness or asbestos management training, and can you demonstrate this?
  • When was the last time you had condition assessments completed for your ACM/PACM?

The HSE has a wealth of information about asbestos on its website, including:

HSE: Asbestos - health and safety in the workplace

Assurity Consulting has decades of experience in proactively supporting schools and organisations to identify and manage their asbestos effectively. Please feel free to contact us should you have any questions or need some advice.