Encompassed Ltd

Adam Burns

Control of Asbestos Regulations 2006

What are the key changes?How do they affect you and your business?

Background• Amendments to the European Asbestos Workers

Protection Directive (AWPD) & the need to follow the industry drove the changes

• HSC began a consultation process– Took place between industry members until Jan ‘06

• CAR 2006 introduced on 13th November last year– Replace CAWR 2002, ASLIC 1983 and the Prohibitions

Regulations 1992 • Aim: Better protect maintenance workers and

simplify the regulations

Change 1

Work with Textured Coatings (Artex™)

Work with Textured Decorative Coatings (Artex™)

– Risks much lower than previously thought– Research & air-monitoring support this– In most cases, work is now non-licensable– Subject to RA concluding STEL won’t be

exceeded– Safe removal techniques still important– Need to use Asbestos trained personnel– Waste needs to be disposed of appropriately

What does this mean for me?

– It means the work requires less stringent controls

– Therefore the work takes less time to complete– You should be looking for a reduction in costs

associated with removal of Textured Coatings

– Remember: Textured Coatings are NOT safe!

Textured Coatings & Demolition

• IF it is not reasonably practicable to remove coatings before demolition they can be left in

• If resulting waste contains <1% Asbestos; rubble can be used as in-fill or sent to land-fill

• Could save time and money but………• Moral issue here:– potential for fibres to

be released into environment!

Change 2Training Requirements

Asbestos Awareness Training

• Building Workers now have highest incidence of accidental exposure to Asbestos

• Maintenance workers, Electricians, Plumbers, Roofers, Cable Installers etc

• Education was seen as a good way to reduce this inadvertent exposure, so......

Asbestos Awareness Training

Now a Mandatory Requirement for anyone who may be exposed to Asbestos whilst

working

Asbestos Awareness Training

• HSE defined a syllabus to be covered• Training must be given by a

competent person• Annual refresher training required• Enforceable requirement• Check sub-contractors have received it

– Duty to ensure anyone conducting work on your behalf is trained

What are the realities of this?

• Some 1.8m workers need to be trained!

• The CDM regulations also support this requirement– Planning Supervisor & Principal

Contractor

• Increased awareness amongst workers will save lives– HSE target is to save 5,000 lives

Change 3

Requirement to ‘reduce exposure to as low as is reasonably practicable’

What does this mean?

• A respirator is required for ALL work with Asbestos

• Previously, only required if action level was exceeded

• A ‘face-fit’ test is required along with a record of it taking place

• Employees entitled to copies of these records

What type of respirator?

• Must have a P3 particulate filter• Ideally an Approved Protection Factor

(APF) of 20 or more– i.e. APF 20 = airborne fibre levels reduced by

20x’s

• RPE is not as good as it was believed to be

Sundstrom SR100: APF 20, £30

Change 4

Notification of Work to Local Authority/HSE & Medical Surveillance

Notification of Work & Medical Surveillance

• Will no longer apply where:– Worker exposure is sporadic and of low

intensity– It is clear from the Risk Assessment that the

STEL won’t be exceeded!

• Where notification is required:– Employees entitled to copies of medical

records

• Confused?!

Notification of Work & Medical Surveillance

• If exposure likely to exceed 0.6f/ml over 10mins it is not ‘sporadic and of low intensity’

• ACoP (L143) defines licensable work on same basis and gives examples

• Reflected in HSG 210 ‘Asbestos Essentials’

• For most work, status quo maintained

Change 5

Clearance Certificates

Clearance Certificates

• Refers to licensed removals• After April 6th 2007, UKAS

accreditation is a necessity for 4-Stage Clearance Certs.

• Clients responsibility to check analytical company is accredited to ISO 17020 and ISO 17025

Change 6

New Method for Classification of Asbestos

(Insulating) Board

Asbestos (Insulating) Board

• Previously a density test was used– If density <1000Kg/m3 = AIB

• Now a water absorption method is used– If materials weight increases by >30%

after being submerged in water then it is AIB

Asbestos (Insulating) Board

• How will this affect me?– This means materials which were

previously non-licensable could in fact now be licensable!

• Pay attention to analytical results– Failure to spot a change could be costly

Change 7

Control Limits and Short-Term Exposure Limits

Control Limit and STEL

• Undergone a few changes– Control Limit reduced to 0.1f/ml for all

Asbestos types– Measured as a 4-hour TWA– STEL maintained in ACoP as 0.6f/ml over

10 minutes

Change 8

World Health Organisation (WHO) Fibre Counting Method to

Replace European Reference Method (ERM)

WHO method to replace ERM

• Most analytical companies have transferred over

• Check that yours have• What are the effects of the change?

– Fibre counts ~20% greater– More air-testing failures for re-

occupation– Greater emphasis on pre-cleaning

should help

Change 9

Other changes

Miscellaneous Changes

• Asbestos is defined• Supervisory & Ancillary work is

defined• As manufacture of Asbestos Products

is banned; exemption for employers now removed

• More emphasis on pre-cleaning and planning to consider the clearance process

Control of Asbestos Regulations 2006

Summary

Summary

• Textured coatings: Deregulated

• Awareness Training: Made mandatory

• RPE: Must be worn for all work

• Notification/Medical Exams: Licensed work

• Clearance Certificates: April 6th UKAS accreditation for 4-stage clearance certs.

Summary

• Classification of AIB: New Method

• Control Limits/STEL: Lowered

• Counting Method: WHO replaces ERM

• Miscellaneous changes:– Asbestos Defined– Supervisory/Ancillary work defined– Exemptions removed– Pre-Cleaning emphasised

www.asbestosawareness.co.uk

Questions?

adam@encompassed.co.uk

T:0845 050 8750

M:0772 543 11 33