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Asbestos in soils: Ground InvestigationsMarian Markham BSc(Hons) MSc CGeol FGS PIEMA
13th November 2019 – EPUK
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November 19, 2019
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Agenda
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• Asbestos in the UK
• Control of Asbestos Regulations 2012
• Desk study information
• Forthcoming AGS Guidance 2019
Marian Markham EPUK seminar 13th November 2019
Mavis Nye https://www.mesothelioma.uk.com/patientstories/mavis-nye/
Marian Markham EPUK seminar 13th November 2019
Mavis and Ray met in 1957. Ray worked at Chatham dockyard in the late 1950s.
Asbestos insulation around the pipes, cables, boilers and engines was removed and
replaced during re-fits. Walking in dust, dust on clothes and in hair was normal. Ray
took his overalls home for Mavis to wash. In 2009, nearly 50 years after significant
exposure to asbestos, Mavis was diagnosed with mesothelioma.
The first medical article on the hazards of asbestos dust appeared in the British Medical Journal in 1924.
Most cases of mesothelioma develop >35 years after first asbestos exposure, so almost all recent UK cases are due to exposure before 1980 when asbestos was still widely used.
Britain’s mesothelioma rate is the highest worldwide and is still rising above age 70.
On this day 20 years ago………
Marian Markham EPUK seminar 13th November 2019
24th November 1999 – UK banned new import and use of all asbestos
UK Imports v deaths
6 Rest of Europe: https://www.who.int/bulletin/volumes/92/11/BLT-13-132118-table-T1.html
~5 to 6 million tonnes
Lawyers view
• https://www.asbestoslawpartnership.co.uk/– asbestos lagger / asbestos sprayer or worked with large
amounts of asbestos then 1 year of constant exposure to asbestos dust may be enough to cause asbestosis.
– If you were exposed to asbestos dust on and off for example as a shipbuilder or construction worker then 5 to 10 years of this exposure to asbestos dust may be enough to cause asbestosis.
– Low amounts of exposure to asbestos dust does not cause asbestosis.
– typical UK post-mortem of mesothelioma deaths 100 million fibres in lungs; there are some fibres in all our lungs.
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Marian Markham EPUK seminar 13th November 2019
Control of Asbestos Regulations 2012
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• From HSE website (http://www.hse.gov.uk/asbestos/regulations.htm): came into
force on 6 April 2012, updating previous asbestos regulations to take account of
the European Commission's view that the UK had not fully implemented the EU
Directive on exposure to asbestos (Directive 2009/148/EC).
• In practice the changes were fairly limited. They mean that some types of non-
licensed work with asbestos now have additional requirements, ie notification of
work, medical surveillance and record keeping. All other requirements remain
unchanged.
• Type, condition of ACM
• Work categories NLW, NNLW, LW
• Medical surveillance
• Record keeping
• SALI and Control Limit
CAR-SOIL industry guidance – July 2016
•
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“for use by competent persons”This authoritative document has been prepared with the support of the
Health and Safety Executive and presents the definitive explanation of how
the legal requirements of the Control of Asbestos Regulations 2012 (CAR
2012 or the Regulations) have been interpreted to apply to work with asbestos
contaminated soil and construction & demolition materials.
The guidance is underpinned by the fundamental requirements expressed in
the Regulations, in relation to the protection of employees from risks related to
exposure to asbestos, but is set within a carefully considered framework
designed specifically for soil and C&D materials contaminated with asbestos.
In order to be more directly applicable to the risks associated from work on
soil and C&D materials contaminated with asbestos, the Regulations have
been interpreted in order to allow practical guidance to be produced that is fit
for purpose whilst allowing compliance to be demonstrated with the
overarching requirements set out in the Regulations.
Desk Study
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Site Walkover
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AGS – Site Investigation Asbestos Risk Assessment In
preparation, publication expected 2019
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Contaminated Land
Working Group
Safety
Working
Group
Laboratories
Working
Group
Loss
Prevention
Working
Group
AGS – Site Investigation Asbestos Risk Assessment 2019
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• There remains the potential for asbestos-
containing materials or asbestos fibres to be
present within any Made Ground.
• Ground investigation – trained, competent staff
with right experience and equipment for sampling
as asbestos is Non-Licensable Work provided
SALI and unlikely to exceed Control Limit.
AGS – Site Investigation Asbestos Risk Assessment 2019
• Pre-construction Information
• Desk study
• Historical maps
• Local knowledge
• Buried service ducts?
• Infilled land / old ponds / raised ground?
• Greenfield / Brownfield / MOD
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Planned activities – potential to disturb asbestos?
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• Site walkover
• Ground Penetrating Radar survey
• Surveying fly-tipped waste
• Hand-dug inspection pits
• Trial pits
• Cable Percussion boreholes
• Rotary boreholes
Reg 6
Expected level of
exposure, SALI,
>Control Limit?
Asbestos Work Categories
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• Control of Asbestos Regulations 2012 categories of work:
• CAR not applicable
• NLW = Non Licensed Work
• NNLW = Notifiable Non Licensed Work
• LW = Licensed Work
• CL:AIRE Decision Support Tool
AGS – Site Investigation Asbestos Risk Assessment 2019
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Asbestos-containing material – “original form”
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Materials that may have been coating, or insulation
material:
• where they are degraded, heavily wetted and
mixed with soil, they no longer may easily be
described as being original form asbestos
coating or asbestos insulation.
• In such situations, as more accurate description
for the material would be “Made Ground
contaminated with loose fibrous asbestos debris”
• ACM may be encountered in a clearly identifiable
“original form” such as when chicken wire is
present .
Excavation work
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Risk Assessment: CIRIA C733
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Training
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AGS – Site Investigation Asbestos Risk Assessment 2019
• ACM product, condition, mixed into soil?
• Friability, ease to disintegrate, type soil-matrix
• Distribution, % w/w, depth
• Likely / actual respirable fibres in air?
• Separate sampling of suspected asbestos debris
• Sampling of Made Ground for asbestos analysis
• Accurate description on exploratory log
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AGS – Site Investigation Asbestos Risk Assessment 2019• There remains the potential for asbestos-containing materials or asbestos fibres to be present
within any Made Ground.
• Work to be undertaken by trained & competent persons who can recognise suspected ACMs
• Pre-construction Information – desk study, ground investigation, local knowledge
• CAR-SOIL best available guidance for ground investigation and soils remediation sectors
• AGS SIARA guidance 2019 – practical advice to its membership and GI industry
• Ground Investigation with sampling for asbestos is NLW unless exposure not SALI or >
Control Limit
• Asbestos work category: Notifiable? Licensable?
• Site-Specific RAMS = Risk Assessment (CAR Reg 6) and Plan of Work (CAR Reg. 7)
• Dynamic risk assessments – what is actually being encountered during investigation?
• Sampling and laboratory analysis is the only way to confirm something is asbestos
• Insurance to work with asbestos?
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