Asbestos in Soil: Practicalities Presented by Steve Edgar

11 February 2019

HSE

What Challenges us about asbestos?

Health and safety

Emotion

The Law!

Risk Communication

Long Term Human Health

Understanding

What I’ve been asked to talk about

DEFINING •Defining soils with low level, ‘trace’, “negligible” and sporadic asbestos contamination BEST PRACTICE •Best practice for applying CARSOIL guidance to a site with minor asbestos contamination issues MANAGING •Effectively managing material with minor asbestos contamination:

• segregation of materials and avoiding cross contamination • techniques for processing and remediating low levels of asbestos fibres

in soil • waste classification and reduction and assessing the costs of disposal • giving confidence to landfill and waste site operators in managing this

material

Everyone thinks they understand asbestos and asbestos risk assessment!

Knowledge

I know everything

Actually this is more complicated than I thought

I’m never going to understand this

This is starting to make sense

Trust me its complicated

Ermm

Knowledge

Confidence

Defining: Trace – Negligible - Sporadic

Straw Poll- Trace levels

Which of these might suggest trace levels of Asbestos in soils?

A: 0.1% B: 0.1f/cm3 C: 0.01mg/kg C: 0.001% D: <0.010f/ml

Trace v’s Negligible Asbestos

• Trace (watch Point 2) Car soil

• Negligible only

relates to a risk determination which is independent of Trace levels.

• Sporadic

When should I think about Asbestos in soils? ■ Should we expect to find ACM on site? ■ In short yes for pretty much all brownfield sites. This means that CAR2012

principles will be in play from this presumption. It is also worth noting that accepted demolition methods may leave behind some debris in C&D materials where this ACM has low or trace levels of asbestos. This can give problems for use and sale of crush. See REG 25. Because its accepted doesn’t mean you can ignore it! Is it really trace?

How should it be described? ■ Accurately. It may not be recognisable as AIB, or chrysotile or insulation.

Those logging samples should be competent and experienced in describing and describe accurately to assist in particular with licensing and preparing POW’s. Examples could be

■ Soil contaminated with asbestos sheeting/board. ■ Soil containing loose fibrous asbestos debris ■ PLEASE DISPENSE WITH EURO CODE! ■ THIS COULD MAKE THE DIFFERENCE IN TERMS OF LICENSED WORK OR NOT! ■ Test, identify, quantify, assess INTERPRET and understand your quantification

Defining Asbestos on Site.

Best Practice: Starting off on the right foot!

Best Practice: Managing Works Properly

Best Practice: Licensed or Not

Best Practice: Onward Contractors, Other trades

Best Practice: Good Control On Site

Best Practice: Protecting the future

Best Practice Appropriate PPE

Best Practice: Segregation

Best Practice: Reducing Exposure Preventing Spread

Best Practice: Accumulating Waste

Best Practice: Storing Waste

Best Practice: Controlling Works

Best Practice: Managing Change!

Best Practice: Recovering fragments

■ Under the Regs: On completion you need to be able to prove that – You have proof that the spread of asbestos has been controlled – You’ve met/complied with the Remediation strategy – You have no asbestos left at the surface! (Inc. after SI) – You have some form of clearance or validation report/certificate

– You know what measure need to be taken by onward constructers. e.g does

your piling mat have asbestos in it? ■ Best practice would be to provide a proper comprehensible

Validation/Clearance/work record to onward Contractors

Best Practice: Finishing the Works

Validation/Clearance/work records

Managing

• segregation of materials and avoiding cross contamination

• techniques for processing and remediating low levels of asbestos fibres in soil

• waste classification and reduction and assessing the costs of disposal

• giving confidence to landfill and waste site operators in managing this material

Employers must prevent employees being exposed to asbestos, or if not possible, to put in place measures and controls to reduce exposure to as low as reasonably practicable ■ Work to disturb or that is liable to disturb should not be avoidable! ■ RPE is the last resort

■ Complex section of the regulations which is best discussed

■ A balance needs to be struck with gathering sufficient information to

justify your decisions……. Discuss! ■ Your choice of technique should not increase the risk of exposure over

another technique.

■ Should be applied based on the risks identified for task at hand and based on sufficient information.

■ How do we review ALAPR?

Regulation 11: Prevention or reduction of exposure to Asbestos

Excavate and dry Screen with hand picking

Wet Processing

Excavate and dispose

Cover system

Reduced ?

Exposure?

IS THIS THE KEY REGULATION? Requires the employer to prevent or reduce the spread of asbestos anywhere work is being carried out under their control. ■ Select work methods that will reduce disturbance ■ Select work methods that will reduce release of fibres. ■ Use low intensity methods wherever possible ■ Manage waste appropriately ■ Where enclosures are not used use physical barriers and notice are

necessary ■ RA should demonstrate that risks can be managed without enclosures ■ If enclosures are to be used outside consider other risks

■ Monitoring is required to demonstrate spread prevention

Regulation 16: DUTY TO PREVENT THE SPREAD

REMEMBER PREVENT THE SPREAD

& EVERYTHING ELSE PRACTICALLY

FALLS INTO PLACE

Which Remediation Techniques are Appropriate

Anything that complies with the regulations:

■ Likely to be – Mass disposal – Segregation techniques – Cover systems – Fully wet processing techniques such as size separation and or washing

■ Possibly/Possibly Not Depending on Detailed Assessment – Dry screening – Hand picking – Stabilisation/solidification?

■ Probably not – Dry or conventional crushing and screening – Deliberate disturbance and recovery – Heat based techniques

Don’t Forget Non Asbestos Risks When Selecting

Techniques!

Thank You! Steve Edgar 07973 981 780 sedgar@vertasefli.co.uk