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Page 1: Estate & Infrastructure Group Asbestos Management Plan (AMP)€¦ · Defence SafetyMan Part 2, WHS Hazards and Risks . Environmental Protection Authority . Western Australia Department

Version: 4.1 Doc Date: 28 Jul 2020

Estate & Infrastructure Group Asbestos Management Plan (AMP)

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Document Review and Approval

Revision History:

Version Author Date Revision

1.0 DSPA 22 December 2017 Initial Release

2.0 DSPA 15 February 2018 Role Clarification

3.0 DWHSPC 18 July 2018 Reviewed and Updated

4.0 DWHS 8 October 2019 Reviewed and Updated

4.1 DWHS 28 July 2020 Limited Review Control Revision and Amendments The E&IG Asbestos Management Plan (referred to as the AMP) is subject to ongoing review and development as further consultation takes place and as relevant regulations, codes of practice and/or advice on asbestos management become available or are amended. The Master copy of this document is held within Objective. This AMP will be revised no later than 5 years from date of approval or earlier when changes to legislation, policy, procedures, information systems or responsibilities / accountabilities reduces the effectiveness or relevancy. Proposals for amendment to this instruction including clarification, corrections or omissions should be forwarded to the Directorate of Work Health and Safety (DWHS) for consideration via E&[email protected]. Consultation The development of this AMP has been undertaken to assure alignment with: Work Health and Safety Act 2011 (Cth) Work Health and Safety Regulations 2011 (Cth) Code of Practice – How to Manage and Control Asbestos in the Workplace Code of Practice – How to Safely Remove Asbestos Australian Institute of Occupational Hygienists E&IG Estate Appraisal Policy Ver. 2.2 dated 1st July 2018 E&IG Estate Handover/Takeover (HOTO) Process Defence SafetyMan Part 2, WHS Hazards and Risks Environmental Protection Authority Western Australia Department of Health, Guidelines for the Assessment, Remediation and Management of Asbestos Contaminated Sites in Western Australia 2009 The following areas have been consulted as part of the development of this AMP: Zone Operation and Coordination (SE Zone, N&C Zone and E&W Zone) Product Directors – Estate Upkeep and Estate Works Program Office Infrastructure Division Chief Information Officer Group DPG WHS Branch Environment and Engineering Branch

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Table of Contents

ACRONYMS AND ABBREVIATIONS ................................................................................ 5

CHAPTER 1 DEFENCE SPECIFIC ..................................................................................... 7

SECTION 1 THE ASBESTOS MANAGEMENT PLAN................................................................... 7 SECTION 2 AIM ................................................................................................................................... 7 SECTION 3 ROLES AND RESPONSIBILITIES .............................................................................. 8 SECTION 4 USERS OF THE ASBESTOS MANAGEMENT PLAN ............................................ 15 SECTION 5 THE DEFENCE ASBESTOS REGISTER .................................................................. 16 SECTION 6 GOVERNANCE ............................................................................................................. 19 SECTION 7 ASBESTOS EDUCATION AND THE PROVISION OF HAZARD INFORMATION .................................................................................................................................. 20 SECTION 8 ASBESTOS TRAINING................................................................................................ 20 SECTION 9 HEALTH MONITORING ............................................................................................ 21 SECTION 10 NOTIFIABLE HEALTH MONITORING REPORTS ............................................ 21 SECTION 11 ADMINISTRATION OF HEALTH MONITORING RECORDS .......................... 22

CHAPTER 2 ASBESTOS INCIDENT MANAGEMENT ................................................. 23

SECTION 1 INCIDENT RESPONSE................................................................................................ 23 SECTION 2 CONFIRMING THE PRESENCE OF ASBESTOS ................................................... 23 SECTION 3 CONFIRMING WORKER EXPOSURE .................................................................... 23 SECTION 4 NOTIFIABLE INCIDENT (EVENT) REPORTING ................................................. 24 SECTION 5 CLEARANCE OF THE SITE FOR RE-OCCUPATION .......................................... 24 SECTION 6 COMMUNICATING LARGE SCALE EXPOSURES .............................................. 24 FIGURE 1 – FLOW OF ASBESTOS INCIDENT REPORTING ................................................... 26

CHAPTER 3 DEFENCE CONTRACTORS ....................................................................... 27

SECTION 1 MANAGEMENT OF ASBESTOS ON THE DEFENCE ESTATE .......................... 27 SECTION 2 CONTRACTOR ROLES AND RESPONSIBILITIES .............................................. 27

CHAPTER 4 THE DEFENCE ESTATE – ASBESTOS WORKS .................................... 30

SECTION 1 ASBESTOS REMOVAL WORKS ............................................................................... 30 SECTION 2 WORKS POTENTIALLY AFFECTING ASBESTOS .............................................. 31 SECTION 3 ASBESTOS WORKS DELIVERED THROUGH ESTATE WORKS PROGRAMS ........................................................................................................................................ 32 SECTION 4 ASBESTOS WORKS THROUGH OTHER PROGRAMS ....................................... 34 SECTION 5 DEMOLITION WORKS .............................................................................................. 35 SECTION 6 WORKS INVOLVING ASBESTOS IN SOILS (ASBINS) .......... Error! Bookmark not defined. SECTION 7 THE ROLE OF THE COH / LAA DURING ASBESTOS WORKS ........................ 36 SECTION 8 AIR MONITORING FOR RESPIRABLE ASBESTOS FIBRES ............................. 37 SECTION 9 REGULATOR NOTIFICATION OF ASBESTOS WORKS .................................... 39 SECTION 10 ASBESTOS REMOVAL CONTROL PLAN ............................................................ 39 FIGURE 2. COMMUNICATION PROCESS FOR ASBESTOS WORKS.................................... 41 SECTION 11 FINAL CLEARANCE AND CLEARANCE CERTIFICATES .............................. 42 SECTION 12 RECORD KEEPING ................................................................................................... 43

CHAPTER 5 ASBESTOS IN SOILS AND SURFACE CONTAMINATION .................. 44

CHAPTER 6 ASBESTOS RE-INSPECTIONS AND ASBESTOS SURVEYS ............... 42

SECTION 1 SERVICES REQUIRED ............................................................................................... 42 SECTION 2 PARTICULARS ............................................................................................................. 43

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SECTION 3 ASBESTOS RE-INSPECTION AND SURVEY PLANNING ................................... 44 SECTION 4 ASBESTOS SURVEYS (PHYSICAL INSPECTIONS) ............................................. 47 SECTION 5 ASBESTOS SAMPLING PARTICULARS ................................................................. 48 SECTION 6 RISK ASSESSMENT .................................................................................................... 50 SECTION 7 DETECTION OF VERY HIGH OR HIGH RISK ASBESTOS ................................ 51 SECTION 8 RISK CONTROL MEASURES ................................................................................... 51 SECTION 9 SIGNAGE AND LABELLING ..................................................................................... 53 FIGURE 3. SAMPLE ASBESTOS HAZARD WARNING LABELLING ..................................... 53 FIGURE 4. SAMPLE ASBESTOS WARNING LABEL SPACING .............................................. 54 SECTION 10 UPDATING THE ASBESTOS REGISTER WITH THE ASBESTOS RE-INSPECTION OR ASBESTOS SURVEY DATA ............................................................................ 55 SECTION 11 RE-INSPECTION / SURVEY REPORT ................................................................... 57

CHAPTER 7 INFORMATION ON ASBESTOS IN THE ESTATE FOR ALL DEFENCE WORKERS ........................................................................................................ 59

SECTION 1 HOW DO I IDENTIFY ASBESTOS? .......................................................................... 59 FIGURE 5. ASBESTOS SAMPLE DESCRIPTOR LABEL (i.e. Sample ID# 62411.108.04) ....... 61 SECTION 2 WHY DOESN’T DEFENCE JUST GET RID OF ALL THE ASBESTOS? ............ 61 SECTION 3 HOW DO I ASK FOR THE ASBESTOS REGISTER? ............................................. 62 SECTION 4 WHAT’S THE HEALTH RISK TO ME? ................................................................... 62 SECTION 5 HOW DOES ASBESTOS ENTER THE BODY? ....................................................... 62 SECTION 6 I BELIEVE I HAVE FOUND ASBESTOS AT MY WORK OR ACCOMMODATION BLOCK. WHAT DO I DO NEXT?............................................................. 63 SECTION 7 WHAT ACTIONS WILL BE TAKEN AFTER I REPORT THE ASBESTOS? ..... 63 SECTION 8 IF THE RESULTS ARE POSITIVE WHAT DO I DO NEXT? ............................... 63

DEFINITIONS ....................................................................................................................... 65

REFERENCES ....................................................................................................................... 73

INTERPRETATION ............................................................................................................. 73

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ACRONYMS AND ABBREVIATIONS1

ACM Asbestos Containing Material ACD Asbestos Contaminated Dust or Debris

AHIR Asbestos Hazard Identification Record2

ASBINS Asbestos in Soils

ASRS Assistant Secretary Regional Services

BM Base Manager

BSC Base Services Contract

BSSC Base Services Support Centre

CA Contract Authority

CFI Capital Facilities &Infrastructure

COH Certified Occupational Hygienist3

CRAT Contamination Risk Assessment Tool

CSAP Contaminated Site Assessment Practitioner

CSR Contaminated Site Register

DAHCES Defence Asbestos and Hazardous Chemical Exposure Scheme

DEIS Defence Estate Information System4

DEPU Directorate of Estate Planning and Upkeep

DERP Directorate of Environmental Remediation Programs

DEWPO Directorate of Estate Works Program Office

DEQMS Defence Estate Quality Management System

DPN Defence Protected Network

DWHS Directorate of Work Health and Safety

EA Estate Appraisal

E&IG Estate & Infrastructure Group

EEB Environment and Engineering Branch

EFR Environmental Factor Record

EMOS Estate Maintenance and Operations Service

EPA Environment Protection Authority

EWP Estate Works Program

1 Hyperlinks are available only to users on the Defence Protected Network 2 This was former DEMS description for a single asbestos instance. Now replaced by Environmental Factor Record 3 Under the WHS Regulation, an independent licenced COH may carry out all the roles relating to Class A and Class B asbestos-related

works, sampling and air monitoring tasks. 4 Previous DEIS included: DEMS and IBIS.

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GEMS Garrison Estate Management System

GDL GEMS Data Load

HRU Head of Resident Unit

ID Infrastructure Division

LAA Licenced Asbestos Assessor5

MIC Management Integration & Coordination

NAD No Asbestos Detected

NPS National Program Service

PCBU Person Conducting a Business or Undertaking

PD Product Director

PDS Project Delivery Service

PPE Personal Protective Equipment

SDD Service Delivery Division

SFARP So far as is reasonably practicable

SME Subject Matter Expert

WHS Work Health and Safety

Zone WHS Zone Work Health and Safety Officer6

5 Under the WHS Regulation, an independent licenced asbestos assessor may only carry out certain functions connected with Class A asbestos removal work. These are:

- Air monitoring - Clearance inspections - Issuing a clearance certificate

6 Previous AMPs included references to Hazardous Chemicals Officers as the Asbestos Leads for their respective Zones. This role is now referred to as Zone WHS Officer.

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CHAPTER 1 DEFENCE SPECIFIC SECTION 1 THE ASBESTOS MANAGEMENT PLAN 1.1 E&IG is the area of Defence responsible for supporting the Australian Defence Force (ADF) and the whole Defence organisation in meeting their capability objectives by managing and sustaining the Defence estate of land, buildings and infrastructure. This Asbestos Management Plan (AMP) covers all bases, training areas, ranges and leased sites where plant, infrastructure, property and/or equipment is owned, stored, maintained or operated by E&IG. 1.2 The management of any ACM that is part of a military platform rather than being part of a building or infrastructure (i.e. any ACM contained in a military platform or spare parts for a military platform) is the responsibility of the controlling Group or Service and therefore is not covered by this AMP. Units with military platform containing asbestos must create their own asbestos management plan, in accordance with Regulation 429 of the WHS Regulations. 1.3 The preparation for the disposal of Group or Service items containing ACM is also the responsibility of the relevant Group or Service. E&IG can facilitate the removal of asbestos from military equipment and inventory by providing technical assistance and aid through assisting with the engagement of an appropriate person to conduct the asbestos removal works and air monitoring. Arranging the disposal of these inventory items is undertaken through the base services contract; however, the Unit or Group responsible for the inventory or equipment is responsible for all remediation and disposal costs. SECTION 2 AIM 1.4 The overarching aim of this AMP is to safeguard the people who occupy, maintain and/or visit the Defence estate against exposure to airborne asbestos fibres. This overarching aim is to be achieved by implementing and maintaining the following eight (8) asbestos management objectives:

1.4.1 Objective 1 - To eliminate all very high and high risk instances of ACM from the estate.

1.4.2 Objective 2 - To develop a safety and environmental incident response plan applicable to typical instances of asbestos found on the estate.

1.4.3 Objective 3 - To deliver an effective asbestos management strategy, including remediation works programs.

1.4.4 Objective 4 - To adopt safe work practices and asbestos management procedures to ensure that no employee, contractor or visitor is exposed to potential sources of airborne asbestos fibres.

1.4.5 Objective 5 – To ensure that the Risk Compliance & Environmental Management Module (known through this document as the asbestos module) is up-to-date and accurate, through a robust survey inspection program and the timely entry of asbestos data onto the asbestos module.

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1.4.6 Objective 6 - Ensure Defence meets all of its statutory WHS obligations relating to asbestos and asbestos management. 1.4.7 Objective 7 - To provide a consistent and effective approach to the management of ACM in buildings, plant, infrastructure and in soils across the Defence estate.

1.4.8 Objective 8 - To develop effective lines of communication with stakeholders to ensure that stakeholders are informed in a timely manner with accurate and relevant information.

1.5 The long term aim for the Defence estate is to eliminate the asbestos risk from the Defence estate via programmed asbestos remediation works, in accordance with Regulation 35 of the WHS Regulations. Where elimination is not possible in the short to medium term, in accordance with WHS Regulations 36 and 37, the intent is to minimise the risk so far as is reasonably practicable (SFARP) by implementing and maintaining control measures in accordance with the hierarchy of risk controls. SECTION 3 ROLES AND RESPONSIBILITIES 1.6 Defence and Officers of Person Conducting a Business or Undertaking (PCBU) – Under the Work Health and Safety Act 2011, Defence has designated the Secretary of the Department of Defence, the Chief of the Defence Force, the Associate Secretary, Vice Chief of the Defence Force and all Group Heads and Service Chiefs, as Officers of the PCBU, and must exercise due diligence to ensure that their workers comply with the Work Health and Safety Act 2011. All workers must support these Officers in performing their duty. Examples of duties owed to workers and others in relation to asbestos management include:

1.6.1 Eliminating or minimizing, SFARP, the risk of exposure to airborne asbestos and ensuring the exposure standard for asbestos is not exceeded.

1.6.2 Providing suitable and specific information, training and instruction to workers, including contractors and sub-contractors.

1.6.3 Programming assurance activities to verify all workers, contractors and sub-contractors are complying with their legislative obligations.

1.7 All Officers of a PCBU must exercise due diligence to ensure that WHS duties are being met. Officer duties pertaining to asbestos include gaining an understanding of the hazards and risks associated with asbestos as well as ensuring appropriate resources and processes are available and used to eliminate or minimise risks to health and safety associated with asbestos. 1.8 Directorate of Work Health and Safety (DWHS) - As the authority for E&IG asbestos policy, DWHS will undertake reviews of this AMP in accordance with the requirements of Regulation 430 of the WHS Regulations (i.e. whenever a triggering event set out under Regulation 430 takes place and, in all circumstances, at least every 5 years).

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1.9 Regional Services – Defence regional and base services are managed under a zone structure by three Assistant Secretary Regional Services. The Assistant Secretary Regional Services are responsible for the oversight of asbestos management and remediation services delivered within their zone. The Assistant Secretary Regional Services will ensure that E&IG (Zone WHS) staff are appointed to support oversight. 1.10 Base Manager (BM) - The BM has the authority and responsibility for common area WHS management and to support the delivery of E&IG products and services at the base level. Other support services outside of the BM responsibilities are to be agreed with the SADFO and HRU. These responsibilities include:

1.10.1 Coordinating and maintaining cooperative consultation and working relationships with the SADFO and all HRU in regards to all asbestos related issues, with support of the Zone WHS Officer.

1.10.2 Ensuring that the most current version of this AMP is widely disseminated to all base stakeholders through the Base Management Forum, the Base WHS Committee and via promulgation on base websites.

1.10.3 Ensuring employee, contractor, consultant and visitor concerns about asbestos are dealt with in a satisfactory and timely manner, with support of the Zone WHS Officer.

1.10.4 Raising and coordinating an asbestos “Hot Issues Brief” when required, with support of the Zone WHS Officer.

1.10.5 Initiating Work Health & Safety Investigations as prescribed in SafetyMan – Work Health and Safety Event Investigation Policy Guidance - Levels of Investigation.

1.11 Capital Facilities and Infrastructure (CFI) – CFI is responsible for ensuring that all projects undertaken by their contractors are conducted in a manner that is cognisant of asbestos hazards present on the Defence estate; that projects comply with WHS legislation, Australian Standards, the Handover/Takeover (HOTO) Process and this AMP when providing services to Defence and that they (CFI) consult, cooperate and coordinate activities with Defence and any other person who holds a relevant WHS duty in the same matter. CFI responsibilities include ensuring that:

1.11.1 CFI-engaged contractors conduct any asbestos related projects to the standard required and that all instances of ACM being removed, disturbed, enclosed or sealed are updated in GEMS.

1.11.2 CFI-engaged contractors are appropriately qualified/licenced and aware of their responsibilities with regards to asbestos management requirements.

1.11.3 This AMP and the Defence asbestos register is reviewed by all CFI-engaged contractors prior to any work commencing on the Defence estate.

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1.11.4 With the exception of the ACT,7 the licenced asbestos removalist shall notify Comcare whenever undertaking asbestos removal works involving all friable asbestos and / or all non-friable asbestos >10m2.

1.11.5 All notifiable incidents are reported to Comcare by CFI using the E&IG Guidance for the Reporting and Managing of Work Health and Safety Events.

1.12 Groups and Services Conducting Works on the Estate – Other Groups and Services including, but not limited to CIOG, CASG and DSTG may undertake projects or works on the Estate outside of E&IG project management arrangements. The Group or Service commissioning such work is responsible for ensuring that all projects undertaken by their contractors are conducted in a manner that is cognisant of asbestos hazards present on the Defence estate, that they comply with WHS legislation, Australian Standards, the Handover/Takeover (HOTO) Process and this AMP when providing services to Defence and that they consult, cooperate and coordinate activities with Defence and any other person who holds a relevant WHS duty. This includes ensuring that:

1.12.1 This AMP and the asbestos register is reviewed prior to the commencement of any work. All contractors are cognisant of the risk that unidentified ACM may be present in inaccessible areas, underground services and in soils. Safe work procedures must include planning for immediate response to contain any unexpected discovery or disturbance until incident management procedures are initiated.

1.12.2 Where asbestos is disturbed or damaged as a direct result of the work, the Group or Service is responsible for funding the remediation of the immediate affected area to the standard required. Incident management and remediation can be initiated by contacting the BSSC to engage E&IG’s EMOS Contractor on a ‘user pays’ basis. Alternatively, the Group or Service conducting the work may engage an asbestos removal contractor to conduct the remediation in accordance with the requirements of this AMP.

1.12.3 When the Group or Service elects to directly engage an asbestos removal contractor, the contractor must be appropriately qualified/licenced and aware of their responsibilities with regards to asbestos management requirements. This AMP is reviewed by all contractors prior to any remediation work on the Defence estate. All documentation pertaining to any instances of ACM being removed, disturbed, enclosed or sealed shall be submitted to the EMOS for updating of the Asbestos Register.

1.12.4 The licenced asbestos removalist notifies Comcare whenever undertaking asbestos removal works involving friable asbestos and / or non-friable asbestos <10m2.8

7 The Australian Capital Territory requires notification for all asbestos works, regardless of type or quantity

8 The Australian Capital Territory requires notification for all asbestos works, regardless of type or quantity

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1.13 All notifiable incidents arising as a result of the work are reported to Comcare by the Group or Service who conducting the work. 1.14 In this AMP the following definitions of contractor apply:

1.14.1 Contractor - the term contractor applies to ALL contractors and sub-contractors operating on the Defence estate, including the EMOS Contractor and any sub-contractors of the EMOS Contractor.

1.14.2 EMOS Contractor - this term refers specifically to the contractor contracted to provide the Estate Maintenance and Operations Services to the Department of Defence (including any sub-contractors of the EMOS Contractor).

1.15 Non-EMOS Contractor - this term refers to all contractors or sub-contractors, except the EMOS Contractor or any sub-contractors of the EMOS Contract work. 1.16 In this AMP the following definitions of contractor apply:

1.16.1 Contractor - the term contractor applies to ALL contractors and sub-contractors operating on the Defence estate, including the EMOS Contractor and any sub-contractors of the EMOS Contractor.

1.16.2 EMOS Contractor - this term refers specifically to the contractor contracted to provide the Estate Maintenance and Operations Services to the Department of Defence (including any sub-contractors of the EMOS Contractor).

1.16.3 Non-EMOS Contractor - this term refers to all contractors or sub-contractors, except the EMOS Contractor or any sub-contractors of the EMOS Contractor.

1.17 Other Contractors – E&IG manages a broad range of contracts and consultants (contractors) to deliver both minor and major capital works; the estate works program, remediation works, maintenance, waste disposal and other services on Defence bases. 1.18 Principal Contractors must ensure that all of their sub-contractors are cognisant of asbestos hazards present on the Defence estate, that they comply with WHS legislation when providing services to Defence and that they must consult, cooperate and coordinate activities with Defence and any other person who holds a WHS duty in the same matter. E&IG-engaged Contractors are responsible for:

1.18.1 Ensuring that their workers and sub-contractors are appropriately qualified/licenced and aware of their responsibilities with regards to asbestos management requirements.

1.18.2 Ensuring their workers and sub-contractors are provided with asbestos awareness training.

1.18.3 Ensuring that this AMP and the Defence asbestos register is reviewed by all contractors and sub-contractors prior to any work commencing on the Defence estate.

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1.18.4 Complying with relevant Commonwealth/State/Territory legislation and Defence procedures, including the Handover/Takeover (HOTO) Process and this AMP.

1.18.5 Ensuring the licenced asbestos removalist notifies Comcare and the State regulatory authorities when required.

1.18.6 Reporting asbestos related notifiable incidents to Comcare, State/Territory Regulators and Defence.

1.19 Directorate of Estate Planning & Upkeep (DEPU) – As the Product Director (PD) for Estate Upkeep, DEPU is responsible for ensuring that the EMOS Contractor (and their sub- contractors) are undertaking all base service contract activities in a manner that is cognisant of asbestos hazards present on the Defence estate and that they comply with WHS legislation, Australian Standards, the Handover/Takeover (HOTO) Process and this AMP. This includes:

1.19.1 Undertaking assurance activities on contractor services supplied under the base services contract (such as ensuring that contractors are supplying all relevant asbestos works specified under the base services contract).

1.19.2 Ensuring that the supplied works are to the standard required.

1.19.3 Ensuring that GEMS is maintained (including quality assurance of the data delivered under the asbestos inspections program).

1.20 DEPU is also responsible for ensuring that any EMOS Contractor related non-compliance is rectified or escalated to the Contract Authority for rectification. 1.21 EMOS Contractor - The EMOS Contractor is to undertake its contractual obligations9 in-line with legislation and the processes set out in relevant Defence policy, including this AMP. 1.22 Directorate of Estate Works Program Office (DEWPO) - As the PD for the Estate Works Program, DEWPO is responsible for ensuring that all projects undertaken by the Project Delivery Services (PDS) contractors through the Estate Works Program (EWP) are conducted in a manner that is cognisant of asbestos hazards present on the Defence estate and that contractors comply with WHS legislation, Australian Standards, the Handover/Takeover (HOTO) Process and this AMP. This includes:

1.22.1 Ensuring that PDS contractors (and sub-contractors) conduct any asbestos related project works to the standard required.

1.22.2 That all instances of ACM being removed, disturbed, enclosed or sealed are updated in GEMS.

1.22.3 Ensuring all notifiable incidents are reported to Comcare by DEWPO using the E&IG Guidance for the Reporting and Managing of Work Health and Safety Events.

9 The EMOS Contractor’s contractual obligations are set out in the Contract for the provision of Estate Maintenance and Operations Services as well as in the suite of EMOS Contractor deliverables annexed to the contract.

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1.23 DEWPO is also responsible for ensuring that any EWP related asbestos non-compliance is rectified or escalated to the Contract Authority for rectification. 1.24 Head of Resident Unit (HRU) - HRUs are accountable for the implementation of the relevant Group/Service Work Health and Safety Management System (WHSMS). HRUs are represented at the Base Management Forum (BMF) and are to contribute to base-wide WHS planning and risk management, including ensuring the availability of the HRU WHS representative to assist the BM with coordination activities. 1.25 If HRUs undertake sponsored works, they are responsible for ensuring that those works are conducted in a manner that is cognisant of asbestos hazards present on the Defence estate; that they comply with WHS legislation, Australian Standards, the Handover/Takeover (HOTO) Process and this AMP when providing services to Defence and that they consult, cooperate and coordinate activities with Defence and any other person who holds a relevant WHS duty. HRU duties also include:

1.25.1 Ensuring that ALL sponsored works are authorised through E&IG in accordance with the Sponsored Works Procedure on DEQMS10 (including providing all asbestos documentation and information related to the sponsored works to the EMOS Contractor for recording on GEMS).

1.25.2 Ensuring that their contractors are appropriately qualified/licenced and aware of their responsibilities with regards to asbestos management on the Defence estate.

1.25.3 Ensuring that this AMP and the Defence asbestos register11 is reviewed by all contractors prior to any work commencing on the Defence estate.

1.25.4 Reporting all asbestos related notifiable incidents to Comcare and creating a Sentinel Event report for all such incidents.

1.25.5 Informing the EMOS Contractor via an AE547 Service Request to the Base Services Support Centre (BSSC), telephone 1300 658 975, if ACM that is not recorded in GEMS has been identified.

1.25.6 Ensuring all persons are inducted into the units building(s) or facility(s) and that the induction includes any relevant information pertaining to asbestos contained in the unit’s area of control.

10 Sponsor funded works through the “Self Help Works” option is for low risk works and shall not include any asbestos work. 11 Refer to paragraph 1.35 for AE547 request process

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1.26 Zone WHS Officer – In the context of this document, the Zone WHS Officer is a person employed or appointed in a Service Delivery Division zone. The Zone WHS Officer is to:

1.26.1 Provide general advice on asbestos to stakeholders.

1.26.2 Contribute to reviews of this AMP, through the provision of Subject Matter advice.

1.26.3 Contribute to reviews, and provide comment on, draft, updated or any other Defence asbestos policy.

1.26.4 Support the PD (DEPU or DEWPO) and the BM through either leading or participating in incident investigations and fact finding activities.

1.26.5 Support the PD (DEPU or DEWPO) and DWHS through assisting with or undertaking assurance activities to ensure the integrity of: the asbestos module; asbestos surveys; asbestos re- inspections; and general asbestos management activities on the estate.

1.27 A list of current Zone WHS Officers can be found in the E&IG WHS SharePoint site. 1.28 Employees, Visitors and Third Parties – Through E&IG Base / HRU inductions, employees, visitors and third parties are to:

1.28.1 Comply with all lawful health and safety instructions.

1.28.2 Follow signage directions (including asbestos warning signage and labelling).

1.28.3 Cooperate with their employers, supervisor and/or relevant Defence members and comply with the policy requirements of both this AMP and any other relevant Defence policies.

1.28.4 Avoid creating or increasing any unnecessary risk of health and safety to themselves or others.

1.28.5 Provide all relevant information and assistance requested to allow any potential asbestos exposure to asbestos to be formally investigated, recorded and documented.

1.28.6 Report damaged ACM or suspected ACM to occupants in the immediate area, their sponsor/escorting officer and/or the BM.

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SECTION 4 USERS OF THE ASBESTOS MANAGEMENT PLAN 1.29 This AMP defines the obligations and actions required by each of the different duty-holders and stakeholders that are involved in the management of asbestos on the Defence estate. The users of this AMP (as either duty-holders or stakeholders) include:

1.29.1 Service Delivery Division:

(a) Base Manager (BM) and team;

(b) Product Directorates (PD) – Estate Upkeep, Estate Works Program Office and Estate Environment and Energy Service Delivery;

(c) Estate Management and Planning (EMP);

1.29.2 Infrastructure Division (ID)

(a) Capital Facilities and Infrastructure (CFI) including:

(1) Project Administration / Contract Administration (PMCA) contractors

(2) Person with Management Control (PWMC) contractors

(b) Environment and Engineering Branch including:

(1) EEB-engaged contractors

1.29.3 Property Management Branch (PMB)

(a) PMB-engaged contractors

1.29.4 EMOS Contractors including:

(a) EMOS-engaged sub-contractors

1.29.5 Directorate Estate Works Program Office (DEWPO including:

(a) Project Administration / Contract Administration (PMCA) contractors;

(b) Person with Management Control (PWMC) contractors

1.29.6 Australian Defence Force (ADF):

(a) Contractors engaged directly by the ADF

1.29.7 Head of Resident Unit (HRU)

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1.29.8 Other Groups and Services including, not limited to, CIOG, CASG and DSTG:

(a) Contractors engaged directly by other Groups and Services

1.29.9 Building occupants

1.29.10 Voluntary staff and workers

1.29.11 Regulatory Authorities

SECTION 5 THE DEFENCE ASBESTOS REGISTER 1.30 The Department of Defence utilises GEMS as the current DEIS for the management of Defence estate assets. Asbestos data can be located in two areas within GEMS:

1.30.1 GEMS asbestos module (for asbestos in the built environment);

1.30.2 GEMS Contaminated Site Register (CSR). 1.31 Both areas will detail all known applicable instances of asbestos for each Defence property. 1.32 The GEMS asbestos module records all asbestos data on the estate collected during:

1.32.1 asbestos re-inspections

1.32.2 asbestos surveys

1.32.3 project works 1.32.4 Asbestos removal works

1.32.5 New asbestos finds

1.32.6 All other Estate activities delivered under the Base Services Contract.

1.33 The GEMS CSR records Asbestos In Soils (ASBINS) on the estate collected during:

1.33.1 project works

1.33.2 asbestos removal works

1.33.3 new asbestos in soils finds. 1.34 Before undertaking any works which may involve the potential disturbance of ACM on the Defence estate, the GEMS asbestos module and, (where sub-surface works are applicable), the GEMS CSR shall also be checked.

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1.35 It is the responsibility of any contractor undertaking works with the potential to disturb asbestos to obtain a copy of a Defence asbestos register (prior to works) and to check the asbestos register as it pertains to their project. It is the responsibility of the project manager for the works to ensure that the Defence asbestos register is made available to all relevant contractors linked to that project. 1.36 Where there is objective evidence to suggest that the asbestos register does not accurately reflect the estate’s asbestos footprint in a certain area, the EMOS Contractor should be engaged prior to material being tested.12 1.37 For works undertaken or arranged by a Group or Service other than E&IG, it is the Group or Service responsibility to ensure that the Defence asbestos register is requested, checked and understood prior to any works commencing. Paragraph 1.35 refers to the options available to request the asbestos register. 1.38 For Defence projects delivering works throughout the estate, or where persons require visibility of the Asbestos Register applicable to the area in which they are working, an extract of the latest Asbestos Register from the Garrison Estate Management System (GEMS) can be obtained by:

1.38.1 Downloading the Asbestos Register from the GEMS Risk, Compliance and Environmental Management module;13 or 1.38.2 Raising a Service Request via the AE547 webform; or

1.38.3 Calling the Base Services Support Centre (BSSC) on 1300 658 975.

1.39 GEMS provides the following information for Defence buildings and/or facilities:

1.39.1 The presence or absence of asbestos (recorded in GEMS as asbestos present, presumed, removed, no asbestos detected, post 2003 or pending lab results).

1.39.2 The location and secondary location of the asbestos.

1.39.3 The type of asbestos material and the quantity. 1.39.4 The condition of the material.

1.39.5 The control measures recommended as a result of a risk assessment.

1.39.6 The status of asbestos labelling at the site.

1.39.7 The risk level of the asbestos.

1.39.8 The date that the asbestos was identified.

1.39.9 The accessibility of the material being tested.

12 More detailed or enhanced reports maybe available from the EMOS to assist all works 13 Personnel who require access to estate data, including asbestos information, from GEMS are required to complete CAMPUS training on how to access and use the relevant GEMS modules.

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1.40 GEMS is linked14 to associated asbestos documentation, such as clearance certificates, air monitoring results, survey reports and photos. GEMS provides access to the most current data associated each EFR (stored in Objective). Historic data is stored in a master folder under the Parent Site in Objective (Estate Management). NOTE: GEMS only permits one Objective link. 1.41 Where there is any ambiguity about the meaning of the information in the Defence asbestos register, the EMOS Contractor should be contacted for clarification. 1.42 GEMS is maintained and updated by the EMOS Contractor.15 The requirement for timely updates to the asbestos module is mandated by WHS legislation,16 which requires that Defence maintain an up-to-date asbestos module at all times. The EMOS Contractor is to ensure that:

1.42.1 GEMS is up to date and accurately reflects the state of buildings, plant, equipment, facilities and in soils across the estate.

1.42.2 All instances of identified asbestos materials are recorded in the GEMS Environmental Factor Recording module – for asbestos within the built environment and GEMS Contaminated Site Register module for ASBINS, as required, regardless of whom identifies the asbestos.

1.42.3 Changes to asbestos status must be updated in GEMS as soon as is practical (but no later than 14 calendar days) after the EMOS Contractor has been notified of the change or becomes aware of the change.

1.42.4 All new and updated asbestos documentation shall be loaded to Objective and linked to the relevant EFR in GEMS by the EMOS Contractor. Documentation may include but not limited to: air quality monitoring, certificates of analysis, asbestos removal control plans, site barrier drawing, safe work method statement, clearance certificates, traceable waste documentation, updated site services drawings and photos.

1.43 DEPU is tasked with, and is responsible for, ensuring that the EMOS Contractor is maintaining GEMS in-line with both Defence’s legislative obligations and contractual requirements.17 If tasked, a Zone WHS Officer may undertake independent quality assurance checks and reviews of the currency and accuracy of the Defence asbestos register for a site, as it relates to the state of asbestos on the Defence estate to assist DEPU.

14 Hyperlinked to the documents which are stored in Objective. 15 See clauses 3.19.1-3 of Section 1.1 Management, Integration and Coordination Section 1.1 Management, Integration and Coordination Description and Deliverables. (CCP 2019-095 Changes to MIC Description and Deliverables, CA Approved 9 Sep 2019) 16 WHS Regulation 425(2). 17 Assurance activities designed to ensure that contractors are up-holding Defence legal requirements are a legal requirement of the WHS legislation (i.e. see Sections 14, 16(3) (b) and 272 of the WHS Act).

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1.44 DWHS will work in conjunction with the Zone WHS Officer to assist DEPU and the Contract Authority to undertake periodic legislative compliance assurance activities over a Defence asbestos register to ensure that the provided asbestos register for a site is legislatively compliant and readily provides all necessary information to users of the asbestos register; however, the responsibility for ensuring that the integrity of GEMS remains with DEPU and the Contract Authority. 1.45 The EMOS Contractor is to undertake regular18 re-inspections of known instances of asbestos and desktop review of the asbestos data in GEMS to ensure that all known asbestos has effective controls in place and all high or very high risk asbestos instances have been remediated. The EMOS Contractor is to raise a service request for any outstanding instances of high or very high risk asbestos.19 DEPU is responsible for ensuring that the regular desktop reviews of the asbestos data in GEMS successfully target all high and very high risk instances of asbestos and that all instances of high and very high risk asbestos are expediently remediated. SECTION 6 GOVERNANCE 1.46 The management of asbestos on the Defence estate is governed by the Commonwealth Work Health and Safety (WHS) Legislation, the WHS Act 2011 and WHS Regulations. 1.47 The Commonwealth WHS legislation is supported by Codes of Practice (including the Code of Practice How to Manage and Control Asbestos in the Workplace, the Code of Practice How to Safely Remove Asbestos) and the Australian Standards (including the Australian Standard AS 4964:2004 Method for the qualitative identification of asbestos in bulk samples and Guidance note on the membrane filter method for estimating airborne asbestos fibres 2nd edition 2005). 1.48 State regulations apply to E&IG contractors and sub-contractors who are not Commonwealth Licensees. 1.49 For further information about the potential health risks of asbestos exposure, please refer to the WHS Branch website. The Defence Asbestos and Hazardous Chemical Exposure Scheme (DAHCES) is open to current and former employees of the Department of Defence and Australian Defence Force members (including Cadets) who suspect that they have been exposed to asbestos or a hazardous chemical as a result of their employment with Defence. Once registered with the DAHCES participants can access medical support for asbestos exposure. Registration with the DAHCES can be undertaken by calling 1800 000 655. For further information about eligibility and access, see the DAHCES website. Current exposure incidents must be entered into Sentinel irrespective of whether the individual registers their details with the DAHCES. 1.50 ADF members should also refer to the Defence Health Manual, Volume 2, Part 14, Chapter 9 - Health Aspects to Managing Asbestos Containing Material in the Australian Defence Force, for actions particular to the ADF.

18 Every five years or as recommended by a competent person (i.e. hygienist report). 19 See Contract Schedule 2 - Statement of Work, Estate Maintenance and Operations Services, Section 1.1 Management, Integration and Coordination - Estate Appraisal - Supplementary Information Annex B, C, D, E and F Attachment 2.

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SECTION 7 ASBESTOS EDUCATION AND THE PROVISION OF HAZARD INFORMATION 1.51 All known instances of asbestos on the Defence estate are recorded in GEMS. This information is to be provided to all persons who may be exposed to asbestos in the course of their employment, by the relevant party controlling the activities associated with the potential for exposure. 1.52 General base induction materials need to ensure employees and visitors have been properly informed about the presence of asbestos on the Defence estate and any relevant exposure risks. 1.53 HRUs need to ensure that their visitors and staff are properly inducted and informed of any asbestos hazards present in the area controlled by the resident unit. An asbestos register can be provided and should be made available upon request. If requested, the Zone WHS Officer will support the BM and the HRU in the provision of asbestos hazard information, interpretation of the asbestos register and, where necessary, supply relevant asbestos information regarding facilities and plant. 1.54 It is the responsibility of the project manager engaging a non-EMOS Contractor to ensure that contractor workers (including sub-contractors) are supplied with relevant information relating to asbestos hazards and Defence policy. SECTION 8 ASBESTOS TRAINING 1.55 The Defence asbestos training program uses a “triggered awareness” model for the delivery of asbestos training to Defence workers and stakeholders to reinforce messages about the health risks posed by asbestos and how these risks are controlled through effective risk management of the in-situ asbestos. Training is targeted towards those personnel who are working in close proximity to asbestos materials or asbestos related remediation activities. The asbestos awareness program is available on Campus. 1.56 ADF, APS and contractors who may come into contact with ACM on the estate must be provided with asbestos awareness via the Base WHS Plan. The Base WHS Plan needs to include the following:

1.56.1 Information on the health risks associated with asbestos.

1.56.2 Availability of asbestos training on CAMPUS which will provide information on the health risks associated with asbestos.

1.56.3 Information on the presence of asbestos in the Defence estate, including the typical locations where asbestos may be encountered on that specific base.

1.56.4 Roles and responsibilities under this AMP.

1.56.5 Information on the Defence asbestos register and how to access the Defence asbestos register.

1.56.6 Direction to this AMP for information on the correct processes and procedures to follow to prevent exposure.

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1.57 Contractors must ensure that all of their employees and sub-contractors undertaking asbestos removals, asbestos works, asbestos-related works or work that could potentially disturb ACM are appropriately trained in safe work procedures for identifying and handling asbestos, as well as the requirements of this AMP for working with asbestos on the Defence estate. 1.58 Contractors must maintain records of any asbestos training and a register of the personnel having undertaken the asbestos training and make these records available to Defence upon request. Asbestos training records are to be kept for as long as the person receiving the training is employed and for another 5 years beyond their employment period.20 SECTION 9 HEALTH MONITORING 1.59 Health monitoring is mandatory for workers engaged to perform licenced asbestos removal work. Health monitoring may also be required for workers performing other ongoing asbestos removal or asbestos-related work where there is a risk of exposure. Asbestos-related work means activities which involve working with or near asbestos whilst performing tasks not necessarily related to asbestos removal. For example, an electrician regularly works in buildings with asbestos containing switchboards. 1.60 All workers are to determine whether there is a need for health monitoring for its workers based on:

1.60.1 The potential for exposure.

1.60.2 The frequency of potential exposure.

1.60.3 The duration of the work being undertaken. SECTION 10 NOTIFIABLE HEALTH MONITORING REPORTS 1.61 Health monitoring reports must be provided to Comcare and Defence if the report contains:

1.61.1 Any test results which indicate the worker may have contracted a disease, injury or illness as a result of asbestos work carried out on behalf of Defence or on the Defence estate.

1.61.2 Any recommended remedial measures, including whether the worker can continue to carry out the work.

1.62 The mechanism for notifying Defence in the above circumstance is via a Sentinel Event, attaching the relevant health monitoring report.

20 WHS Regulation 2011 Regulation 445(3)

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SECTION 11 ADMINISTRATION OF HEALTH MONITORING RECORDS 1.63 Health monitoring records are to be retained for a period of 40 years21 after the record is made. Privacy principles apply to health monitoring records and contents are not to be disclosed to another party without written consent from the individual. The exception is if the record qualifies as a notifiable health monitoring report.

21 The requirement to keep asbestos medical records for 40 years is set out in Regulation 444 of the WHS Regulations.

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CHAPTER 2 ASBESTOS INCIDENT MANAGEMENT

SECTION 1 INCIDENT RESPONSE

2.1 Asbestos incidents are initiated when known asbestos, or material suspected to be asbestos, is disturbed, broken, compromised or uncovered. All asbestos incidents must be treated as high risk until confirmed otherwise. The immediate response is to take all available measures to separate personnel from further exposure to the hazard until the area is declared safe for reoccupation.

2.2 The discovery of suspect material alone does not necessarily pose an exposure hazard. The material must first be confirmed to be asbestos and disturbed to an extent that fibres are released into the breathing zone of personnel at concentrations higher than amounts specified in the National Exposure Standard. The determination that the incident has resulted in an exposure or potential exposure must be assessed by a COH.

2.3 The overarching Defence policy for managing asbestos incidents is described in SafetyMan Asbestos Management Procedure 07 – Asbestos Incident Management. The flowchart at Figure 1 in this Chapter describes the asbestos incident response procedure for situations where material, dust or debris, suspected of containing asbestos, is disturbed on the Defence Estate.

SECTION 2 CONFIRMING THE PRESENCE OF ASBESTOS

2.4 The GEMS Asbestos Register is to be consulted to ascertain whether there is a record relating to the instance of the suspect material. If the record is available and the material has been identified as containing asbestos, further testing is not necessary. If the presence of asbestos cannot be confirmed, the identification of whether or not a suspect material contains asbestos must be carried out by a COH/LAA as soon as possible. Samples of the material must be sent to a NATA accredited laboratory for identification. The COH/LAA also determines whether the material is friable or non-friable. All test results, regardless of whether or not analysis outcome is positive for asbestos, must be followed up with a written report which includes the laboratory results.

SECTION 3 CONFIRMING WORKER EXPOSURE

2.5 Once asbestos has been confirmed as being present in the material, the COH/LAA is to be consulted to assess whether workers were exposed, or potentially exposed, to airborne asbestos fibres. The COH/LAA can be the same practitioner who undertook the sampling and the assessment may take place concurrently with sampling activities. Assessment of worker exposure is to consider the duration the inhalation hazard was present, the locations/areas where personnel were exposed (expressed as rooms or vicinity from), details of any protection from PPE and results of air monitoring.

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2.6 A written summary of the results of the assessment of worker exposure is to be prepared by the COH/LAA and be provided to any workers and stakeholders involved in the incident.

SECTION 4 NOTIFIABLE INCIDENT (EVENT) REPORTING

2.7 An asbestos incident is notifiable to Comcare immediately by telephone once the following conditions are confirmed:

2.7.1 The material is confirmed to contain asbestos, and

2.7.2 Workers were exposed, or potentially exposed, to airborne asbestos fibres above exposure standards in the professional opinion of the COH/LAA.

2.8 Notification to the Commonwealth and/or State/Territory regulator is the responsibility of the party controlling the activity where/when the notifiable incident happens. Contractors are to report notifiable incidents to both the Commonwealth and the State/Territory Regulator via normal reporting channels. Commonwealth employees are only required to notify Comcare of a notifiable event in which they are involved.

2.9 The entry of an Event report into Sentinel is to follow the initial notification to Comcare. Sentinel automatically triggers the written notification to Comcare required within 48 hours of the initial notification. For further detail on Sentinel Event Reporting, refer to:

2.9.1 E&IG Guidance for the Reporting and Managing of Work Health and Safety Events

2.9.2 Base Service Contract Instruction – Reporting Notifiable Work Health and Safety Events in Sentinel.

SECTION 5 CLEARANCE OF THE SITE FOR RE-OCCUPATION

2.10 Following an asbestos incident, the site must be cleared prior to re-occupation. The following documentation confirms the site is safe to occupy:

2.10.1 A clearance certificate provided by a COH/LAA

2.10.2 Test results that prove the material does not contain asbestos.

SECTION 6 COMMUNICATING LARGE SCALE EXPOSURES

2.11 A large scale asbestos exposure is when a COH/LAA confirms that multiple workers have been exposed, or potentially exposed, to inhalation of airborne asbestos fibres. Large scale exposures includes incidents that involve personnel under the command of more than one HRU/Manager, impact on more than one Group or Service, or where a new instance of asbestos has been identified and the COH/LAA deems that hazard has been present over an enduring period of time.

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2.12 The initial reporting of the dangerous incident to Comcare remains the responsibility of the party controlling the activity, as described in Section 4. Under most circumstances, this will be a contractor. Further to Comcare reporting, a communication plan advising all workers involved in the incident that may have been exposed, must be implemented to facilitate reporting. Communications must provide all of the facts such as the location of the exposure, the time period over which the hazard was present, who was exposed and details of the COH/LAA assessment. Details of the Defence Asbestos and Hazardous Chemicals Exposure Scheme (DAHCES) must be incorporated into the communication plan along with instructions on Sentinel reporting.

2.13 The communication plan is to be coordinated as follows:

2.13.1 Incidents involving more than one RU on a Base but exposure not likely beyond the Base population, the BM should coordinate communication through Base networks

2.13.2 Exposures which affect personnel beyond the Base population and will require Defence wide communication are coordinated through DWHS via Group Safety Coordinators.

2.14 Communicating large scale exposures must be undertaken without delay.

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FIGURE 1 –ASBESTOS INCIDENT REPORTING FLOWCHART

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CHAPTER 3 DEFENCE CONTRACTORS

SECTION 1 MANAGEMENT OF ASBESTOS ON THE DEFENCE ESTATE

3.1 The key principles of asbestos management used for making management decisions relating to asbestos on the Defence estate are summarised below:

3.1.1 Asbestos removal is not always necessary for the day to day management of buildings; however, asbestos removal must be completed before a structure, or part of a structure, is demolished.

3.1.2 Asbestos which is incorporated into a stable matrix can be found in many working environments. Provided the matrix remains stable and no airborne dust is produced, it presents a negligible health risk.

3.1.3 Asbestos presents a risk when it is airborne and in people’s breathing zone. The risk to health increases as the number of fibres inhaled increases. Asbestos also poses a health risk when ingested; however, in the context of managing asbestos on the Defence estate, ingestion is not considered to be a realistic route of exposure, given the age demographics of the workforce.

3.1.4 The policy for the management of asbestos in soils is set out throughout this AMP, specifically in Chapter 5.

SECTION 2 CONTRACTOR ROLES AND RESPONSIBILITIES

3.2 E&IG manages a broad range of contracts and consultants / contractors to deliver both minor and major capital works; the estate works program, remediation works, maintenance, waste disposal and other services on Defence bases.

3.3 Principal Contractors must ensure that all of their sub-contractors are cognisant of asbestos hazards present on the Defence estate, that they comply with WHS legislation when providing services to Defence and that they must consult, cooperate and coordinate activities with Defence and any other person who holds a WHS duty in the same matter. E&IG-engaged Contractors are responsible for:

3.3.1 Ensuring that their workers and sub-contractors are appropriately qualified/licenced and aware of their responsibilities with regards to asbestos management requirements.

3.3.2 Ensuring their workers and sub-contractors are provided with asbestos awareness training.

3.3.3 Ensuring that this AMP and the Defence asbestos register is reviewed by all contractors and sub-contractors prior to any work commencing on the Defence estate.

3.3.4 Complying with relevant Commonwealth/State/Territory legislation and Defence procedures, including the Handover/Takeover (HOTO) Process and this AMP.

3.3.5 Ensuring the licenced asbestos removalist notifies Comcare and the State regulatory authorities when required.

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3.3.6 Reporting asbestos related notifiable incidents to Comcare, State/Territory Regulators and Defence.

Estate Maintenance and Operation Services (EMOS) Contractors

3.4 The EMOS Contractor is to undertake its contractual obligations22 in-line with legislation and the processes set out in relevant Defence policy, including this AMP. The EMOS Contractor is engaged to:

3.4.1 For incidents outside of CFI, PDS or Defence-delivered projects, the EMOS shall provide the initial response for asbestos incidents including:

(a) Making safe the affected area (prevent further potential exposure, limit spread of potential asbestos fibre.

(b) Engaging the services of a COH23 or LAA;24

(c) Site remediation;25

(d) Providing the clearance certificate(s) from a COH/LAA prior to re-occupation.

3.4.2 Deliver the program of asbestos re-inspections and asbestos surveys. Surveying all ACM is to be undertaken by the EMOS Contractor in-line with the Estate Appraisal Contract deliverables and Chapter 6 – Asbestos Re-inspections and Asbestos Surveys of this AMP.

3.4.3 To provide the asbestos survey schedule and to deliver the asbestos survey in accordance with the schedule.

3.4.4 Update and maintain asbestos data in GEMS.

3.4.5 Provide an asbestos register to Defence projects and to any worker requesting an asbestos register.

3.4.6 Place and maintain asbestos warning signs and labels.26

3.4.7 Conduct asbestos remediation projects.27

3.4.8 Provide project support to contractors engaged through CFI and DEWPO or Environment and Engineering Branch (EEB).

22 The EMOS Contractor’s contractual obligations are set out in the Contract for the provision of Estate Maintenance and Operations Services as well as in the suite of EMOS Contractor deliverables annexed to the contract. 23 Class A and B 24 Class A only 25 User pay process for accidental damage (non-fair wear and tear) 26 Any warning signage that is permanently secured either externally or internally shall be managed by the EMOS Contractor EU. 27 The EMOS Contractor can manage remediation projects (small and large) from cradle to grave; however, most large scale remediation projects are delivered through the Estate Works Program, to which the EMOS Contractor would provide project support.

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Estate Works Program (DEWPO) Contractors

3.5 National Program Services (NPS) Contractors - The NPS contractor, in consultation with each Zone’s stakeholders (including, but not limited to, the EMOS Contractor,28 relevant BM) is responsible will develop the three year EWP for asbestos. The NPS contractor is to use the Estate Appraisal (EA) information (including information from the asbestos re-inspections and asbestos surveys, the Defence asbestos register and any other third party appraisal information) to create the three year program. The program of works is to be delivered by the Project Delivery Service (PDS) contractors.

3.6 Project Delivery Services (PDS) Contractors – The PDS contractor has responsibility for assuring that the relevant project contractor delivering the EWP is cognisant of asbestos hazards present on the Defence estate and has the required licenses and training to undertake asbestos works on the Defence estate. The PDS contractor is to ensure that all asbestos works undertaken through them comply with WHS legislation, Australian Standards and this AMP. This includes:

3.6.1 Ensuring that contractors (and sub-contractors) conduct any asbestos related project works to the standard required.

3.6.2 Ensuring that all instances of ACM being removed, disturbed, enclosed or sealed are updated in the Defence asbestos register.29

Other Contractors

3.7 It is the responsibility of the Defence project manager engaging a non-EMOS Contractor to ensure that contractor workers (including sub-contractors) are supplied with relevant information relating to asbestos hazards and Defence policy to ensure the requirements of WHS Legislation and the two Codes of Practice relating to asbestos are adhered to.

3.8 HRU and/or non-EMOS Contractors undertaking asbestos works on the Defence estate must supply the EMOS Contractor with all relevant documentation for uploading to GEMS as soon as reasonably possible after obtaining the documents and in all circumstances within 14 days.30

28 The EMOS contractor has an obligation to consult, co-ordinate and manage pursuant to the Estate Upkeep and Estate Appraisal Deliverables and the Estate Maintenance and Operations Services Section 1.7 Management, integration and Coordination Description and Deliverables. 29 This is achieved (prior to Defence re-occupancy) by completing and updating an Asbestos GEMS Data Load (GDL) and providing all supporting documents in accordance with Defence policy to the EMOS for validation and loading into GEMS and Objective. 30 Calendar days (including weekends and public holidays)

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CHAPTER 4 THE DEFENCE ESTATE – ASBESTOS WORKS

SECTION 1 ASBESTOS REMOVAL WORKS

4.1 All asbestos removals on E&IG plant, buildings or infrastructure must be undertaken by a licensed asbestos removalist and supervised by an independent COH, regardless of the friability of the ACM being removed. The type of asbestos removalist required will depend on the friability of the asbestos / ACM to be removed. An A Class asbestos removalist will be required for all friable asbestos removals, while a B Class asbestos removalist can be utilised for the removal of non-friable asbestos in accordance with Regulations 485 and 487 of the WHS Regulations.

4.2 All asbestos assessors working on the Defence estate built environment must also be COH/LAA (see Chapter 4 Section 7 Role of the Occupational Hygienist). A COH/LAA includes the employees of a COH/LAA company/business overseen by a qualified COH/LAA.

4.3 Any Defence contractor undertaking asbestos removal works on the Defence estate either directly or via a sub-contractor is responsible for supervising the works and ensuring that:

4.3.1 The asbestos removalist holds the appropriate licence31 for the State/Territory in which the work is to be conducted.

4.3.2 Comcare and State/Territory regulators are notified of licensed asbestos removal works.32

4.3.3 An appropriate asbestos removal control plan is provided (see Chapter 4 Section 10 Asbestos Removal Control Plan).

4.3.4 A communication plan is developed and relevant information is communicated to all stakeholders.

4.3.5 Air monitoring is undertaken by an independent COH/LAA (see Chapter 4 Section 8 Air monitoring for Airborne Asbestos Fibres”).

4.3.6 That all works are conducted in a safe and competent manner in accordance with the legislative requirements, this AMP and the asbestos removal control plan provided

4.4 That at the completion of all asbestos removal works a clearance inspection is undertaken and a clearance certificate is provided by an independent COH/LAA before the workplace can be reoccupied (see Chapter 4 Section 12 Final Clearance and Clearance Certificates).

31 Regulations 485 to 490 of the WHS Regulations address the requirements of obtaining relevant asbestos removal licenses for undertaking asbestos removal activities within the Commonwealth jurisdiction. For jurisdictions with mirror WHS legislation the Commonwealth WHS Regulations recognise the licenses issued by State/Territory Regulators. Note the term ‘corresponding WHS laws’ in relation to Regulations 488 and 490 are defined by Regulation 6A of the WHS Regulations. 32 WHS Regulation 466.

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4.5 At the end of any remediation/removal works the relevant contractor must ensure that all documentation associated with the remediation/removal works is provided to relevant stakeholders and the EMOS Contractor for uploading onto the asbestos module (see Chapter 4 Section 13 Record Keeping).

4.6 In accordance with Regulation 472 of the WHS Regulations, an asbestos removalist undertaking asbestos removal works or asbestos works on the Defence estate must ensure that ACM and any contaminated PPE, which is not practicable to decontaminate, is correctly disposed of at a site authorised to accept asbestos contaminated waste.

SECTION 2 WORKS POTENTIALLY AFFECTING ASBESTOS

4.7 Prior to commencing any works that could potentially disturb ACM (including maintenance works, construction works or demolition activities), contractors must interrogate the Defence asbestos register, to determine if any ACM is present.

4.8 If any ambiguity arises from the information on the Defence asbestos register as it applies to the estate, the EMOS Contractor must be contacted prior to the commencement of work to provide advice on the current asbestos records in the asbestos module.

4.9 Any work associated with the removal, repair, and/or maintenance of ACM or work which has the potential to disturb known instances of ACM must be risk assessed (see above “Asbestos Risk Assessments”). Contractors are to develop a risk mitigation control plan from this risk assessment.

4.10 Estate maintenance tasks that may involve the disturbance of ACM must only be undertaken under controlled conditions to prevent the risk of airborne asbestos fibres to the maintenance staff themselves and/or any other person. Maintenance tasks include but are not limited to:

4.10.1 The drilling of ACM

4.10.2 The sawing of ACM

4.10.3 Screwing into ACM

4.10.4 Sealing, painting, coating of Asbestos Cement Products and/or other forms of asbestos containing material

4.10.5 Cleaning leaf litter form the gutters of asbestos cement rooves

4.10.6 Replacing cabling in asbestos cement conduits or boxes

4.10.7 Working on asbestos pipes

4.10.8 Working on electrical mounting boards (switchboards) containing asbestos.

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4.11 Tools and equipment used for works that may disturb asbestos are to minimise the generation of airborne asbestos fibres. High-speed abrasive power or pneumatic tools such as angle grinders, sanders, saws, high speed drills and high pressure cleaners must never be used in a way that could disturb ACM or asbestos. Hand tools are preferred over power tools for any work with the potential of disturbing ACM or asbestos. At the end of any asbestos works or asbestos related works, all tools must be:

4.11.1 Decontaminated or

4.11.2 Placed in sealed containers (and used only for asbestos works) or

4.11.3 Disposed of as asbestos waste.

4.12 Where possible, any planned works that will or potentially will disturb ACM which may impact on resident unit activities are to be scheduled during periods of low resident unit activity.

SECTION 3 ASBESTOS WORKS DELIVERED THROUGH ESTATE WORKS PROGRAMS

4.13 The remediation of ACM on the Defence estate is conducted either through the EMOS Contract scheduled Estate Upkeep program or through the Estate Works Program.

4.14 The policy in the AMP is intended to complement the Handover/Takeover (HOTO) Process which applies to all estate projects delivered on the Defence estate. The purpose of the HOTO policy is to ensure that all estate related projects adhere to a systematic process to demonstrate that the project management practices, actions and deliverables comply with legislation, Australian Standards and Defence policy and instructions to deliver safe, compliant and fit for purpose facilities.

4.15 Both the Estate Upkeep program and the Estate Works Program (EWP) require accurate survey and inspection data to be able to effectively determine the best remediation strategies and priorities for future works. Therefore it is essential for the EWP that the EMOS Contractor conduct regular asbestos re-inspections and regular desktop reviews of the asbestos data in GEMS which are then uploaded through the Estate Appraisal process33 in order to inform future asbestos remediation works.

4.16 As noted in Chapter 6 Section 8 Risk Control Measures, all control measures recorded on the asbestos module as recommended controls necessary to control the risk of asbestos must be uploaded into the Estate Upkeep program in accordance with paragraphs 66-70 of the E&IG Estate Appraisal Policy.

4.17 DEWPO (in conjunction with the National Program Services [NPS] contractor) is to develop a rolling three year program of works for the delivery of asbestos works (including the works required to implement all necessary asbestos control measures recorded on the asbestos module) and create a budget plan to secure funding for the EWP. The program of works is to be delivered by the Project Delivery Service (PDS) contractors.

33 See Clauses 4.1.2 EM0015.010, 4.1.2 EM0015.015 of the Estate Maintenance and Operations Services Section 1.1 Management, Integration and Coordination – Estate Appraisal.

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4.18 The NPS contractor, in consultation with each zone’s stakeholders (including, but not limited to, the EMOS Contractor,34 relevant BM) will develop the three year EWP for asbestos. The NPS contractor is to use the Estate Appraisal (EA) information (including information from the asbestos surveys, asbestos inspections, the Defence asbestos register and any other third party appraisal information) to create the three year program.

4.19 The EMOS (MIC) is responsible for managing the de-confliction of any contractor activities (including those of the PDS contractor) that might interrupt the delivery of asbestos works.

4.20 As part of the EWP priorities, asbestos removals need to be programmed so that the removal of ACM is prioritised in accordance with both risk levels (as outlined in Chapter 6 Section 6 ‘Risk Assessment’) and consideration of value for money. Consideration must also be given to the timing of removals, to ensure works minimise impacts to Defence / HRU capability requirements. Other considerations that need to be factored into any EWP removal schedule include:

4.20.1 Scheduled refurbishment works - it makes good use of limited resources to remove ACM as part of a refurbishment where there is a refurbishment already scheduled into the program (i.e. to ensure the building is not refurbished twice).

4.20.2 Security requirements - this includes the possibility of having to upgrade security in older structures with DPN capability to match new DPN security requirements (i.e. if DPN is required to be removed as part of the removal/remediation process it can only be put back into the structure if the structure meets the current security requirements for DPN, even if the structure previously did not meet those same requirements).

4.20.3 Scheduled demolitions - buildings should not be remediated of ACM shortly before it is scheduled for demolition. Therefore it is important that the demolitions program is checked as part of the planning for scheduled works.

4.20.4 Weather conditions - in some parts of the country it is not possible to undertake asbestos removals at certain times of the year due to unacceptable weather conditions.

4.20.5 Access to assets - any schedule needs to consider any Defence operational requirements for the use of the structure or plant (i.e. ADF surge times or major exercises need to be factored into the project timing as buildings and assets maybe in use).

34 The EMOS contractor has an obligation to consult, co-ordinate and manage pursuant to the Estate Upkeep and Estate Appraisal Deliverables and the Estate Maintenance and Operations Services Section 1.7 Management, integration and Coordination Description and Deliverables.

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4.21 Start up meetings are described in Estate Meeting Guide for the Handover/Takeover (HOTO) Process. As part of the start-up meeting, contractors are to consult with stakeholders to ensure:

4.21.1 Building occupants are aware of the works.

4.21.2 Any issues and/or safety concerns identified by the occupants have been adequately addressed in the asbestos removal control plan and that occupants have access to a copy of the asbestos removal control plan.

4.21.3 The contractor/sub-contractor has all necessary access.

4.21.4 Any security requirements have been addressed.

4.21.5 There is an agreed start date.

4.21.6 The expected work schedules are known.

4.21.7 The project completion date is known.

4.22 Prior to the project start-up meeting, it is the responsibility of the contractor to seek input from all relevant stakeholders (including the relevant BM).

4.23 Oversight and auditing of scheduled programs is the responsibility of the PD (DEWPO).

4.24 Project personnel shall be made aware of the requirements of this AMP and given a copy of the Defence asbestos register extract prior to tendering, to ensure they allow for such requirements when quoting.

4.25 For incidents involving asbestos, where the costs for works to remediate are less than $10,000 (excluding GST), these incidents shall be directed through the EMOS Contractor for immediate remediation, as part of the fixed fee base services contract.

4.26 Where the work is on a EWP-managed site and comes about as a part of the respective works then the expectation is that the EWP project will undertake the works. User pays can occur with the EMOS if parties agree.

SECTION 4 ASBESTOS WORKS THROUGH OTHER PROGRAMS

4.27 Within Defence there exists Service Providers such as, but not limited to; Defence Housing Authority and Australian Munitions, that manage property on behalf of Defence. The requirements of this AMP shall apply when works are programmed on assets managed by these service providers.

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SECTION 5 DEMOLITION WORKS

4.28 In accordance with Regulation 449 of the WHS Regulations, any contractor engaged to undertake demolition work must be provided with a copy of the asbestos register before the demolition work commences.

4.29 Additionally, a full hazardous materials survey35 must be undertaken of the proposed demolition works by a COH and the hazardous materials survey results for asbestos / ACM are to be compared to the Defence asbestos register.

4.30 The hazardous materials survey report shall reference the EFR for each asbestos occurrence. Where new occurrences of asbestos are discovered, the contractor must request that a new EFR be created through the EMOS/BSSC prior to demolition. Any variances between GEMS EFR (such as condition, presumed asbestos confirmed positive) and the results of the hazardous materials survey must also be notified to the EMOS Contractor. All new asbestos information is to be provided to the EMOS Contractor as soon as practical and in all circumstances within 14 calendar days of the new asbestos information being identified.

4.31 Copies of the hazardous materials surveys are to be forwarded to the EMOS Contractor. The EMOS Contractor is to upload the hazardous material survey into Objective and linked to the asbestos module.

SECTION 6 SECTION 6 WORKS INVOLVING ASBESTOS IN SOILS (ASBINS)

4.32 An asbestos contaminated site is:

4.32.1 Contaminated – remediation required. The site is contaminated and needs to be investigated and cleaned up to ensure it does not present a risk to human health or the environment. This classification will remain until remediation is complete.

4.32.2 Contaminated – restricted use. The site is contaminated but suitable for limited uses (e.g. the site may be suitable for commercial use, but not residential use; or for residential use provided groundwater bores are not used and soil is not accessed).

4.32.3 Remediated for restricted use. The site was contaminated but has been cleaned up to a standard where it is suitable for limited uses (e.g. the site may be suitable for an apartment block, but not for a kindergarten).

4.32.4 Possibly contaminated – investigation required. There are grounds to indicate soil, groundwater and/or surface water at the site may be contaminated but further inquiry is needed to confirm or dismiss the possibility of contamination.

4.32.5 Decontaminated. The site has been remediated and is suitable for all uses. It does not pose a risk to the environment or human health.

35 Hazardous substance surveys are conducted prior to demo which shall include lead-based paints, PCBs SMFs and asbestos containing materials etc.).

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4.32.6 Not contaminated – unrestricted use. After investigation, no contamination was found at the site.

4.32.7 Report not substantiated. There is not enough information to indicate that the site could be contaminated.

NOTE: Under the Contaminated Sites Act (WA) 2003, in-situ naturally occurring asbestos (NOA) is not considered contamination.

However, due to the serious health concerns associated with asbestos, affected areas should be effectively managed in the short and long term. NOA is most likely encountered during geological sampling and mining operations. Management measures similar to those for free fibre usually apply, however, WA DOH Department of Defence may require a site-specific approach (i.e. Site Asbestos Management Plan).

For further information about ASBINS refer to Chapter 5 Asbestos in Soils (ASBINS).

SECTION 7 THE ROLE OF THE COH / LAA DURING ASBESTOS WORKS

4.33 The COH/LAA shall be independent of the asbestos removal works and not in a business or undertaking involved in the removal of the asbestos (shall not be engaged by the asbestos removalist).36

4.34 The specific duties of the COH/LAA when supervising asbestos removal/remediation works include, but are not limited to:

4.34.1 Endorsing the asbestos removal control plan and ensuring the asbestos removal control plan adequately addresses all foreseeable risks and is compliant with the WHS legislation.

4.34.2 Inspection of the asbestos removalist equipment, including decontamination and negative air units, water filtration systems, vacuum equipment, personal protective equipment (PPE) etc.

4.34.3 Undertaking an assessment of the asbestos removalist work methods; the removalist use and maintenance of PPE and the removalist decontamination procedures.

4.34.4 Undertaking asbestos fibre air monitoring in accordance with the Code of Practice Membrane Filter Method. Air monitoring shall be undertaken both during the asbestos removal works and as clearance air monitoring after the removal of asbestos.

4.34.5 Undertaking a clearance inspection.

4.34.6 Providing either a clearance certificate or partial clearance certification with an updated risk assessment upon completion of all ACM remediation works.

36 WHS Reg 474(3) Note - If it is not reasonably practicable for the licensed asbestos assessor or competent person to be independent, the person or licenced asbestos removalist may apply to the Regulator for an exemption under Part 11.2 from the requirement that the assessor or competent person be independent. This shall be provided to the responsible Defence Project Manager at the same time as the asbestos removal control plan.

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4.35 COH / LAA are also required to risk assess all newly identified instances of asbestos and to provide recommended relevant risk mitigation controls dependent on the level of risk. The recommendations need to be accompanied by a timeframe in which the recommendations should be implemented - timeframes should not exceed the period between scheduled surveys.

4.36 Where a timeframe is greater than the period between scheduled surveys, the recommendation should only be “manage in-situ” (i.e. the recommendation ‘manage in-situ’ should be limited to ACM that is deemed safe to manage in-situ at least until the next survey). ACM must be re-assessed by a COH / LAA in each survey to ensure the recommendations remain relevant.

4.37 All sampling of asbestos on the Defence estate is to be undertaken by a COH / LAA, who is to ensure that, in accordance with Regulation 423 of the WHS Regulations, samples are sent to a NATA-accredited laboratory for analysis and that formal written results of all sampling is supplied back to all relevant stakeholders including the EMOS Contractor for updating of asbestos records (including GEMS and Objective).

SECTION 8 AIR MONITORING FOR RESPIRABLE ASBESTOS FIBRES

4.38 In accordance with Section 19 of the WHS Act, Defence as a PCBU has a legal obligation to ensure the health and safety of each of its employees and of third parties at or near Defence controlled workplaces, buildings and structures. Under Regulation 420 of the WHS Regulations, Defence also has a specific obligation to ensure that no persons are exposed to airborne asbestos fibres due to Defence activities. The current occupational exposure standards for asbestos are:

4.38.1 Chrysotile (white) asbestos – 0.1 fibres per millilitre (f/mL)

4.38.2 Amosite (brown) asbestos – 0.1 fibres per milliliter

4.38.3 Crocidolite (blue) asbestos – 0.1 fibres per milliliter

4.38.4 other forms of asbestos or a mixture of asbestos types - 0.1 fibres per millilitre.

4.39 Airborne concentrations of asbestos fibres of less than 0.01 fibres/ml are below the detection limit of the membrane filter method for estimating airborne asbestos fibres. It is industry practice to assume that fibres counts below the detection limits are within normally expected background levels.

4.40 Occupational exposure is measured using the Membrane Filter Method. The Membrane Filter Method works by continuously sampling air from the breathing zone of a person fora minimum of four hours.

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4.41 Respirable asbestos fibres are those fibres that are capable of lodging in a person’s lungs. These fibres are not so large that they are prevented from being drawn into the lungs and not so small that they will be breathed back out. Respirable asbestos fibres is classed as those fibres that:

4.41.1 are less than 3 microns (µm) wide

4.41.2 are more than 5 microns (µm) long

4.41.3 have a length to width ratio or more than 3:137

4.42 Air monitoring is required as part of both the incident response protocol and any removal/remediation activities and must be overseen by a COH/LAA to ensure that the exposure standards are not being exceeded during the activity.

4.43 Air monitoring is used to establish the levels of asbestos fibres in or near an affected workplace and to determine the effectiveness of any implemented controls.

4.44 All air monitoring conducted in conjunction with asbestos and/or asbestos works or asbestos related works must be undertaken by a COH/LAA.

4.45 All air monitoring for A Class removals must be carried out by a COH/LAA.

4.46 The COH/LAA conducting the air-monitoring must ensure air monitoring is conducted in accordance with the Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres 2nd Edition, [NOHSC: 3003 (2005)].

4.47 Where asbestos works are being conducted and levels of asbestos are detected above 0.01 fibres per millilitre, work must be stopped and the source of the fibres must be investigated and adequate control measures implemented to reduce the number of airborne fibres below the 0.01fibres per millilitre detection limit. Where an A class removal is being conducted and levels of asbestos fibres are detected at 0.02 fibres per millilitre or more, work must be stopped and the licensed removalist, in accordance with Regulation 476 of the WHS Regulations, must immediately:

4.47.1 notify Comcare and the relevant State/Territory regulator;

4.47.2 implement the incident response procedure (see Section 15 Asbestos Incident Response);

4.47.3 investigate the cause of the release (see above “Asbestos Incident Investigations”).

37 See section 1.3 of the Code of Practice “How to Manage and Control Asbestos in the Workplace”.

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SECTION 9 REGULATOR NOTIFICATION OF ASBESTOS WORKS

4.48 A licensed asbestos removalist engaged to carry out asbestos removal works on the Defence estate, where notification is necessary, is to give written notice to both Comcare and the relevant State Regulator38 at least five39 days before commencing the licenced asbestos removal works.40 With the exception of the ACT, Comcare do not require notification of non-friable asbestos removal works of less than 10m2.41

4.49 The Regulator must be notified of any emergency asbestos removal works immediately via telephone and in writing within 24 hours of the removal taking place.42 The Regulator has advised that commercial expediency or convenience does not constitute an emergency removal. Emergency removal works are limited to:

4.49.1 An unexpected event that may lead to a situation where there is a risk of exposure. For example a burst pipe with asbestos lagging or an accidental impact into an asbestos wall.

4.49.2 An unexpected breakdown of an essential service that requires immediate rectification (gas, water, electricity, sewerage or telecommunication services).

4.49.3 An unexpected asbestos find that needs to be removed because it poses a safety hazard.

SECTION 10 ASBESTOS REMOVAL CONTROL PLAN

4.50 In accordance with Regulations 464 and 465 of the WHS Regulations, any contractor undertaking asbestos removal work must create an asbestos removal control plan. An asbestos removal control plan is a document that identifies the specific control measures the contractor will use to ensure workers and other persons are not put at risk when asbestos removal work is being conducted. As a matter of necessity, an asbestos removal control plan must focus on the specific control measures necessary to minimise any risk from exposure to asbestos at the site where asbestos is to be removed and must ensure that no persons are exposed to airborne asbestos fibres above the exposure standard.

4.51 Prior to preparing the asbestos removal control plan, the contractor must prepare a communication plan to ensure that all stakeholders are kept fully informed throughout the duration of the works. The communication plan is to outline how consultation will be undertaken to inform all stakeholders of the nature of the proposed works, including the start and finish dates for the proposed works. Full and open communication and consultation with Defence employees, contractors, occupants in adjoining buildings and any affected Defence neighbours will assist in mitigating delays to the process, preventing potential asbestos exposure incidents and minimising potential asbestos-related claims against Defence or claims that might bring Defence’s reputation into disrepute.

38 The Australian Capital Territory requires notification for all asbestos works, regardless of type or quantity 39 Calendar days (includes weekends and public holidays) 40 Regulation 466 of the WHS Regulations 41 The Australian Capital Territory requires notification for all asbestos works, regardless of type or quantity 42 Sub-Regulations 466(2) and 466(3) of the WHS Regulations

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4.52 The asbestos removal control plan must include details of:

4.52.1 How the asbestos removal will be carried out, including the method, tools, equipment and PPE to be used.

4.52.2 The asbestos to be removed, including the location, type and condition of the asbestos.

4.52.3 Specifications or drawings that are relevant to the asbestos removal should also be attached to the asbestos removal control plan to provide additional information about the asbestos works to be undertaken.

4.53 The asbestos removal control plan must be endorsed by a COH/LAA prior to work commencing to ensure the adequacy of the risk mitigation controls. The asbestos removal control plan is to be provided to the EMOS Contractor for uploading onto Objective for visibility through GEMS. The asbestos removal control plan must also be provided to the BM and any relevant HRU. All documentation is to be recorded on GEMS and Objective, in accordance with Figure 2: Communication Process for Asbestos Works.

4.54 The asbestos removal control plan must set out any requirement to vacate a premises or part of the estate occupied by stakeholders. The communication plan needs to detail the safety processes designed to minimise any risk to health and safety.

4.55 Once the asbestos removal control plan is prepared, a copy must be readily accessible on- site for the duration of the licensed asbestos removal work and made available for inspection by Defence upon request.

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FIGURE 2. COMMUNICATION PROCESS FOR ASBESTOS WORKS

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SECTION 11 FINAL CLEARANCE AND CLEARANCE CERTIFICATES

4.56 Clearance monitoring is essential for asbestos removal works and should be considered as part of the planning of any asbestos removal work. A COH/LAA must verify all asbestos removal work by issuing clearance certificates for both inspections and air monitoring.

4.57 Clearance certificates shall reference each individual EFR which was subject to remediation.

4.58 In accordance with Regulation 473 of the WHS Regulations, before a building, facility or structure can be reoccupied, the licensed asbestos removalist must ensure that a clearance inspection of the asbestos removal area is carried out by an independent assessor (whom Defence requires to be a COH/LAA) and a clearance certificate is supplied to the following (as a minimum):

4.58.1 Depending on the type of project:

(a) PDS (for issue to EMOS Contractor for uploading to Objective for visibility through GEMS);

(b) Contract Administrator for CFI Projects (for issue to EMOS Contractor for uploading to Objective for visibility through GEMS).

4.58.2 HRU (issued by EMOS Contractor upon storage of clearance certificate and associated documents in Objective)

4.58.3 BM (issued by EMOS Contractor upon storage of clearance certificate and associated documents in Objective)

4.59 In exceptional circumstances, where it is not practical to have the relevant independent hygienist/assessor or competent person undertake a clearance inspection (as the minimum requirement of Regulation 473), it is possible that Defence can seek an exemption (pursuant to Regulation 684 of the WHS Regulations) from the relevant Regulator. The granting of this type of exemption removes the requirement to have an independent person undertake the inspection. However, pursuant to Regulation 473(1), the exemption must be sought by the Defence Point of Contact for the removal (as the person commissioning the works), not the contractor.

4.60 An exemption must be sought from both the State/Territory Regulator and Comcare (i.e. Defence must seek the exemption to meet its own Commonwealth legislative obligations, whilst the Removalist will require the exemption to meet their parallel State/Territory obligations).

4.61 The matters to be considered in granting an exemption are set out in Regulation 685 of the WHS Regulations. These matters include whether exceptional circumstances justify the granting of an exemption. The Regulators will only grant an exemption in truly exceptional circumstances, for example where there is only one asbestos removal company and the nearest independent removalist is located an extremely large distance from the removal site.

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SECTION 12 RECORD KEEPING

4.62 Any contractor undertaking asbestos removal/remediation works must ensure that all documentation associated with the removal/remediation works (including clearance certificates and air monitoring results) are provided to the following:

4.62.1 Depending on the type of project:

(a) PDS (for issue to EMOS Contractor for uploading to Objective for visibility through GEMS)

(b) Contract Administrator for CFI Projects (for issue to EMOS Contractor for uploading to Objective for visibility through GEMS)

4.62.2 HRU (issued by EMOS Contractor upon storage of clearance certificate and associated documents in Objective)

4.62.3 BM (issued by EMOS Contractor upon storage of clearance certificate and associated documents in Objective)

4.63 The Handover/Takeover (HOTO) Process requires Data Provision Checklist (DPC) which aims to provide contractor representatives with sufficient information to plan and document a schedule for the submission of project information and data throughout the project lifecycle and for the PD / PMCA / PM and EMOS to validate receipt and completion in accordance with the contract conditions and HOTO requirements. Records that must be maintained and uploaded include documents such as: clearance certificates, air monitoring results, waste disposal/tipping dockets (i.e. documentation to show materials have been correctly disposed of at a licensed landfill facility), asbestos surveys, inspection reports and any relevant photos or maps associated with asbestos incidents or recorded ERF.

4.64 The EMOS Contractor must ensure that all records relating to asbestos on the Defence estate including records provided by Defence and third parties (including CFI projects) as well as records that the EMOS Contractor obtains through their own activities are maintained and uploaded to Objective and linked to the applicable GEMS EFR.43.

4.65 HRU and/or non-EMOS Contractors undertaking asbestos works on the Defence estate must supply the EMOS Contractor with all relevant documentation for uploading to Objective and linked to the applicable GEMS EFR as soon as reasonably possible after obtaining the documents and in all circumstances within 14 days.

4.66 The EMOS Contractor, pursuant to its MIC function, is to coordinate the flow of information from other contractors, including the PDS, CFI and contractors engaged by other Groups and Services including, but not limited to CIOG, CASG and DSTG.

4.67 For assurance purposes, documents held by a contractor (or a contractor’s sub-contractor) relating to asbestos works on the Defence estate must be made available and provided to any Defence representative upon request. Requested documents are to be provided as soon as reasonably practical and in all circumstances within 10 business days of the request being made. All asbestos-related records and documents are to be retained for 30 years after the removal of the ACM or after a structure containing ACM has been demolished.

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CHAPTER 5 ASBESTOS IN SOILS AND SURFACE CONTAMINATION

*UNDER DEVELOPMENT

Any queries about ASBINS should be directed to the Directorate of Contamination Assessment, Remediation and Management, Environment and Engineering Branch.

DEQMS DCARM Contacts

43 For the EMOS contractual obligation to maintain an asbestos database see EMOS Contract Schedule 2, Statement of Work - Estate Maintenance and Operations Services (EMOS) Section 1.1 Management Integration and Coordination – Estate Appraisal Supplementary Information Annex B, C, D, E or F Attachment 2 - EM00.15.010 Manage Estate Appraisal Information.

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CHAPTER 6 ASBESTOS RE-INSPECTIONS AND ASBESTOS SURVEYS

SECTION 1 SERVICES REQUIRED

6.1 DEPU engages the EMOS Contractor to conduct asbestos re-inspections and ‘as required’ asbestos surveys. This is achieved either internally (i.e. Estate Appraisal personnel with the appropriate qualifications) or externally (engaging a suitably qualified third party). Regardless of which process is used, the EMOS Contractor has the overall responsibility to ensure the requirements stated in this AMP are achieved.

6.2 The purpose of conducting asbestos re-inspections and ‘as required’ asbestos surveys44 is to assist the Commonwealth to ensure a safe estate for all estate users and to aid the Commonwealth in fulfilling its obligations under the WHS Legislation, including ensuring the Commonwealth appropriately identifies and manages the work health and safety risks associated with asbestos.

6.3 The estate asbestos re-inspection (and ‘as required’ asbestos surveys) requires the EMOS Contractor programming the asbestos re-inspection / ‘as required’ asbestos survey to ensure locating and assessment of both the extent and condition of all asbestos containing materials (ACM) which are contained in or on the Defence estate (including in fixed plant and structures).

6.4 The asbestos re-inspection (and ‘as required’ asbestos surveys) shall cover all buildings, structures, facilities and any associated infrastructure (including items of fixed plant) erected or built prior to 31 December 2003 that are owned, leased,45 maintained or otherwise under the management or control of E&IG (this does not include military platforms or parts for military platforms). All buildings built prior to 31 December 2003 shall be surveyed unless there are reasonable grounds to believe that there is no asbestos present in the structures – an example of reasonable grounds would be that previous surveys and testing have found the building or structure to hold no detectable asbestos.

6.5 The frequency of conducting asbestos re-inspections shall be not more than five years or as recommended by a competent person (i.e. hygienist report).

6.6 The areas, materials and items to be inspected as part of the asbestos re-inspection / ‘as required’ asbestos survey include, but are not limited to:

6.6.1 all construction materials that could reasonably contain asbestos,

6.6.2 roofing material and structures;

6.6.3 all assessable roof and/or ceiling spaces;

44 During the asbestos re-inspection, ‘as required’ asbestos surveys may be conducted when there is doubt to the status of the asbestos instance (i.e. physical condition of the asbestos instance is now considered poor, the previously inaccessible asbestos instance is now accessible to building occupants and maintenance personnel) 45 including permissive leases such as Cadet facilities

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6.6.4 all other building spaces (including any assessable spaces under building and/or structures);

6.6.5 air conditioner ducts;

6.6.6 finishing materials;

6.6.7 sound proofing materials;

6.6.8 electrical switchboard components;

6.6.9 communication pits within five metres of a structure;

6.6.10 fixed plant;

6.6.11 fire doors;

6.6.12 buried but still visible asbestos waste;

6.6.13 known landfill, waste piles; and

6.6.14 the immediate area surrounding each building and structure for a distance of five metres.

6.7 Any inaccessible areas where it is reasonable to believe that asbestos could be present must be presumed to contain asbestos and labelled, signed and recorded on the asbestos register.

SECTION 2 PARTICULARS

6.8 Asbestos Re-inspections. The EMOS Contractor is to ensure that the asbestos re-inspection is conducted by competent personnel46 with the appropriate qualifications, applicable training , and possessing the necessary knowledge in building construction and material that is likely to contain asbestos. Personnel with necessary knowledge in building construction may include licensed builders, electricians, plumbers and building surveyors with a minimum of 3 years’ experience; or an occupational hygienist, or equivalent, with a minimum of 3 years of ACM survey experience.

6.9 The EMOS Contractor must ensure that asbestos re-inspection teams undertaking the physical appraisals consist of at least two persons.

6.10 Asbestos Surveys / Sampling. Any requirement for asbestos sampling (during the asbestos re-inspection) shall be conducted by a Certificated Occupational Hygienist (COH).

46 WHS Reg 05 – Definitions (f) / SafeWork Australia Code of Practice

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6.11 The EMOS Contractor must ensure that during any requirement for asbestos sampling, the asbestos survey team wear appropriate disposable protective clothing and personal protective equipment whilst conducting sampling (i.e. full access sampling), this is to minimise the risk of potentially spreading friable asbestos fibre onto personal clothing, footwear and to other areas.When required, COH/LAA/CSAP shall provide appropriate respiratory protective equipment as detailed in submitted Safe Work Method Statements (SWMS). Further, the competent person must ensure the respiratory protective equipment provided conforms with and is selected, used and maintained in accordance with the applicable standards, including the requirements of AS/NZS1716-2003 Respiratory Protective Devices and AS/NZS 1715-1994 Selection Use and Maintenance of Respiratory Protective Devices.

6.12 During asbestos sampling, the COH shall provide access to an asbestos vacuum cleaner that complies with the requirements of AS 4260-1997 High Efficiency Particulate Air Filters (HEPA) – Classification, Construction and Performance.

6.13 The COH is responsible to ensure that appropriate decontamination and disposal arrangements are available and implemented for re-inspection of areas likely to contain high levels of friable asbestos contamination or where asbestos sampling is required.

6.14 Decontamination and disposal arrangements, including control measures, shall comply with the Work Health and Safety Legislation and with the guidance contained in the two asbestos Codes of Practice: How to Manage and Control Asbestos in the Workplace (Safe Work Australia) 2011 and How to Safety Remove Asbestos (Safe Work Australia) 2011.

6.15 The competent person and or COH is responsible for ensuring the supply of all equipment required to undertake all aspects of the asbestos re-inspection, including, but not limited to: ladders, scissor lifts, cherry pickers to access heights and personal protection equipment for its re-inspection personnel.

6.16 The EMOS Contractor shall be responsible for engaging and managing any sub-contractors who may be required to carry out services required to perform the asbestos re-inspection / ‘as required’ asbestos survey (e.g. electricians if the electricity supply is to be disconnected when collecting samples from electrical backing boards). This includes any sub-contractor requirements to ensure compliance with the requirements of the WHS legislation.

SECTION 3 ASBESTOS RE-INSPECTION AND SURVEY PLANNING

6.17 When undertaking the re-inspection the EMOS Contractor must attend a contract start up meeting with the Commonwealth Representative (DEPU, Project Manager or Base Support Officer) to discuss the conduct and expectations of the asbestos re-inspection. At the start up meeting the EMOS Contractor is to provide the Commonwealth Representative with a schedule of the asbestos re-inspection and an inspection plan that outlines how all of the asbestos re-inspection requirements will be met. This meeting is to be arranged by the EMOS Contractor and the agenda shall include information about site specific aspects, such as site familiarisation, risks and hazards, security arrangements, building plans (where available or issued) and previous asbestos re-inspection / asbestos survey reports (if any).

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6.18 The EMOS Contractor is to provide the asbestos re-inspection team with all available information on the relevant risks on the estate. For sites on which the EMOS Contractor has not already been supplied hazard information or does not have hazard information, the Commonwealth Representative will provide the EMOS Contractor with any known, available and relevant information about the site and workplace specific risks and hazards as well as any information on any additional requirements that might apply, including for security restricted areas.

6.19 The EMOS Contractor must ensure asbestos re-inspection and asbestos survey personnel (including sub-contractors) are provided with an induction to ensure any hazards are known and information on risks control measures are fully understood and conveyed to all personnel (including sub-contractors).

6.20 For the purposes of asbestos re-inspection (and asbestos survey) planning, the EMOS Contractor must carry out a desk top study of all necessary material to undertake an asbestos re-inspection and asbestos survey, such as:

6.20.1 equipment and materials to be used;

6.20.2 previous asbestos survey reports;

6.20.3 site histories for information on possible sources of asbestos contamination;

6.20.4 current and (where appropriate) past asbestos management plans and asbestos registers;

6.20.5 building plans (if available, as these are especially useful for identifying any hidden voids)

6.20.6 consideration of current and past ACM removal projects;

6.20.7 review of the dates of construction of all relevant buildings to determine whether the buildings were built pre or post 31 December 2003, as it is from this date forward that the WHS Regulations presume buildings do not contain asbestos; and

6.20.8 a review of ACM removal projects that have not been uploaded on the current Defence asbestos register.

6.21 The competent person or suitably qualified third party engaged by the EMOS Contractor shall develop an asbestos re-inspection plan from the available information. The EMOS Contractor is to provide the Commonwealth Representative with the asbestos re-inspection plan for endorsement prior to any physical inspection taking place. The asbestos re-inspection plan shall include:

6.21.1 all buildings, structures, fixed plant and workplaces to be included in the asbestos re-inspection;

6.21.2 all buildings, structures, fixed plant and workplaces to be excluded from the asbestos re-inspection (and the reason each building or structure is being excluded);

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6.21.3 information on the type/level of asbestos re-inspection / asbestos survey that will be conducted on each of the buildings/structures (i.e. first time visual inspection, visual asbestos re-inspection, limited access asbestos sampling, full access asbestos sampling);

6.21.4 plans for the inspection of areas surrounding all the building and structures for a distance of 5 metres to be included as part of the physical asbestos inspections;

6.21.5 proposed plans for managing access to inaccessible or secure areas; 6.21.6 for any ‘as required’ asbestos surveys, the sampling methodology, numbers of samples and arrangements for making good any destructive access damage; and

6.21.7 a methodology for the labelling and signposting of all identified or presumed instances of ACM.

6.22 Before commencing the asbestos re-inspection, the EMOS Contractor must provide to the Commonwealth Representative and have endorsed by the Commonwealth Representative a risk assessment and a SWMS endorsed by a COH / LAA. The SWMS must address all of the potential risks of injury or harm to asbestos re-inspection personnel and building occupants.

6.23 Where site plans or data extracts, including those provided by the Commonwealth, show inconsistencies about the status of buildings and structures, the EMOS Contractor must seek direction from, consult with, co-operate with and co-ordinate with the Commonwealth Representative to determine the status of buildings that are unlisted (typically this will include structures that have been relocated, or have been demolished). Unless otherwise instructed by the Commonwealth Representative, any unlisted buildings shall be included in the asbestos re-inspection until such time as the correct asbestos status of the building is determined.

6.24 All buildings on the Defence estate (built prior to 31 December 2003) must be included in the Defence asbestos register. Any building that is deemed to be excluded from the physical asbestos re-inspection must still be recorded on the asbestos register GEMS Data Load (GDL) by the EMOS Contractor against a relevant EFR. Buildings that are excluded from the inspection part of the asbestos re-inspection must have the reason recorded in the status field for the EFR (i.e. built post-31 December 2003).

6.25 The EMOS Contractor shall make provision for the Commonwealth Representative to undertake whatever assurance activities on the conduct of the asbestos re-inspection (and ‘as required asbestos survey) that the Commonwealth Representative deems appropriate.

6.26 Where undertaken, assurance activities will typically be achieved by two appropriately qualified Commonwealth observers joining the asbestos re-inspection or asbestos survey team to ensure that the re-inspection / survey is conducted in-line with the scope of works. As part of this obligation the EMOS Contractor is to ensure that the Commonwealth Representative is supplied a works schedule indicating the dates and times that different buildings and facilities are to be inspected.

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SECTION 4 ASBESTOS SURVEYS (PHYSICAL INSPECTIONS)

6.27 The EMOS Contractor must undertake the asbestos surveys (physical inspections) in accordance with the approved plan made in-line with the Asbestos Survey Planning section above.

6.28 As many Commonwealth properties have been surveyed previously, the asbestos surveys may be a combination of first time visual inspections to identify suspect ACM and visual re-inspections of identified ACM and presumed ACM found in earlier asbestos surveys. Asbestos surveys have been conducted on the Defence estate regularly since 1998.

6.29 Dependent upon the specified particulars of each facility and the facility’s history of asbestos surveys, the asbestos survey will involve:

6.29.1 first time visual inspection in any previously un-surveyed spaces or buildings to verify the presence and extent of any ACM and assess its condition;

6.29.2 sampling and analysis of suspected ACM to conclusively determine the presence or absence of asbestos;

6.29.3 review of the existing asbestos register, previous asbestos survey reports and visual asbestos re-inspections of identified ACM and presumed ACM found in earlier asbestos surveys to confirm the data recorded on the asbestos register is accurate, up-to-date and meaningful. The EMOS Contractor is to ensure that the condition, current level of risk and recommended risk mitigation controls are updated to reflect any changes in the condition of the asbestos;

6.29.4 full sampling and analysis of previously presumed ACM in inaccessible areas where refurbishment or demolition work is intended or where the area has become accessible.

6.30 The COH must ensure that all surfaces that are being inspected are uniformly made from the same material; this includes surfaces that are not visible or completely visible, such as vinyl floor coverings that are underneath carpets. At a minimum the COH must check all four corners of any area that is not completely visible and determine if the material in each corner of the area is uniformly the same. If the material is not the same in each corner of the area, the COH must check that there has previously been relevant sampling done for each of the materials that reasonably could contain asbestos. Where all materials that reasonably could contain asbestos have not been sampled, the COH needs to ensure that the materials are sampled.

6.31 In conducting physical asbestos surveys of buildings, structures and/or equipment the COH must ensure that all the areas, materials and items, which it is reasonable to believe could contain ACM (including all the materials listed above at clause 6.6), are inspected.

6.32 The competent person and COH are both responsible to ensure that signage and labelling is correct and in place as part any asbestos re-inspection or asbestos survey, and rectify any signage or labelling issues identified in accordance with the Signage and Labelling section below.

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SECTION 5 ASBESTOS SAMPLING PARTICULARS

6.33 Where necessary and with the written consent of the Commonwealth Representative, the EMOS Contractor will arrange for the COH to take representative samples (which may include destructive inspection to gain access to inaccessible areas) to be taken from each type of suspect material for analysis to identify or confirm the presence of asbestos.

6.34 All sampling will be performed in accordance with Australian Standard AS 4964-2004 Method for the qualitative identification of asbestos in bulk samples.

6.35 Without limiting the requirements of the WHS Legislation, the COH must ensure the following key points are observed and complied with before and during sampling to ensure the health and safety of all persons (including workers carrying out work at a workplace):

6.35.1 Sufficient notification is provided (through the EMOS Contractor) to all affected building occupants.

6.35.2 Personnel undertaking the sampling must wear the appropriate personal protective equipment.

6.35.3 Entry to the sampling area by personnel not connected to the survey must be restricted and warning notices posted or physical barriers installed.

6.35.4 Sampling should not occur in occupied workplaces and if necessary arrangements for sampling should be made for periods of minimal workplace occupation.

6.35.5 Suspected asbestos products that easily release air borne fibres must be controlled before sampling by wetting the material to be sampled with a suitable wetting agent (not suitable for electrical installations, air conditioning, gaskets).

6.35.6 Samples must be individually sealed in their own container.

6.35.7 Surfaces where asbestos debris may fall must be protected with a sheet of impervious material (e.g. plastic) which can be easily cleaned by wet–wiping or using a HEPA vacuum cleaner.

6.35.8 There should be no evidence of debris from sampling, and sampling points must be sealed to prevent the release of fibres.

6.36 The EMOS Contractor is to ensure that a complete sample history is recorded in the survey report by the COH. The history is to include the exact location of the sample, any chemical and physical conditions affecting the sample, and any relevant factual descriptor of the sample and/or sub-samples.

6.37 The results of analysis (including mandatory trace analysis results that confirm a suspect material has no detectable ACM and the presence or otherwise of ‘respirable’ asbestos fibres) must be contained in a NATA endorsed certificate of analysis, and be a complete record of all facts applying to the sampling and analysis. The report shall include the fact that the analytical method used is ‘polarised light microscopy with dispersion staining’.

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6.38 The results of all samples must be accompanied by a supporting letter providing an informed opinion of the degree of friability, the broad percentage of asbestos and type found in each sample, (as a guide to Commonwealth and other occupational hygienists on potential risk and possible control actions).

6.39 Samples and laboratory worksheets for specific samples may be requested by the Commonwealth for further investigation and/or quality assurance purposes, if requested the EMOS Contractor needs to ensure that these documents are supplied by the COH. Samples and associated worksheets taken for the Commonwealth must be retained for a minimum of three years and be made available to any Commonwealth Representative on request.

Defence specific requirements

6.40 Wipe samples of dust on surfaces will not be collected unless the sampling and analytical method is validated and has been submitted to, and approved by the Commonwealth Representative.47 Dust on surfaces can be collected only in rare circumstances; the decision to take dust samples must be formally justified.

6.41 Soil sampling can only be undertaken if approved in writing by the Commonwealth Representative. When undertaking soil sampling the EMOS Contractor must ensure soil samples are representative of the totality of the material that is being tested with the aim of gathering information about the type, extent and severity of the contamination. When determining whether to undertake soil sampling at a site, the EMOS Contractor must give consideration to factors that could impact on the asbestos contamination at the site or area such as information that the site is known to or should reasonably be known to contain asbestos debris from previous construction or demolition works. The EMOS Contractor must discuss the sampling strategy and the number of samples that will be required with the Commonwealth Representative.

6.42 Destructive sampling may be performed only on suspected asbestos containing materials provided that no obvious or significant damage occurs. The EMOS Contractor is not permitted to damage decorative finishes, waterproofing membranes, plant and equipment items, fire doors, fixtures and fittings, services or impair the structural integrity of the building or plant which may affect the purpose of the material item.

6.43 Destructive sampling will be performed where refurbishment or demolition works are planned for particular buildings. These samples must be discussed with the Commonwealth Representative and the written approval of the Commonwealth Representative should be obtained during the survey planning stage and in all cases prior to any destructive sampling being carried out by the EMOS Contractor.

6.44 All samples must be analysed by a laboratory accredited as an analytical laboratory certified by the National Association of Testing Authorities (NATA) to undertake asbestos testing.

47 Occupational Health and Hygiene Directorate. Email request: [email protected]

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SECTION 6 RISK ASSESSMENT

6.45 As an integral part of the asbestos survey the EMOS Contractor must risk assess all instances of asbestos and presumed asbestos on the Asbestos Register.

6.46 The factors used to determine the level of risk under the risk assessments conducted by the COH/LAA/CSAP 48 are:

6.46.1 the type of asbestos (friable or non-friable);

6.46.2 the condition of the asbestos (in good condition or poor condition);

6.46.3 whether or not the asbestos is accessible;

6.46.4 whether the asbestos is likely to be disturbed by activities undertaken in the area.

6.47 Each instance of asbestos is allocated either a very high, high, medium or low risk rating. The risk ratings are defined as follows:

6.47.1 Very High: The material is either friable asbestos containing material likely to pose risks to health from exposure as the material is readily accessible and prone to further disturbance, or the material is unsealed friable asbestos material located in air conditioning systems.

6.47.2 High Risk: The material is either ACM that has deteriorated significantly; is readily accessible and prone to further disturbance or the material is unsealed friable asbestos and therefore only likely to be disturbed during routine maintenance activities.

6.47.3 Medium Risk: The material is either accessible ACM showing minor deterioration or the ACM is prone to mechanical disturbance due to routine building activity and/or maintenance.

6.47.4 Low Risk: The material is either ACM that shows no or very minor signs of damage/deterioration (i.e. the ACM is in a stable condition [sealed / encapsulated]) or access to the ACM is unlikely to cause significant deterioration.

6.48 Risk ratings shall be recorded against each EFR number in the asbestos register that has a status of asbestos present or asbestos presumed. The determination of the risk rating for each instance of asbestos or presumed asbestos must be set out in the survey report.

48 Where ASBINS is involved, a contaminated site assessment practitioner is qualified to assess ASBINS

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SECTION 7 DETECTION OF VERY HIGH OR HIGH RISK ASBESTOS

6.49 If any high risk or very high risk instances of asbestos are identified during the asbestos re-inspection or asbestos survey the competent person / COH/LAA/CSAP must make the area safe and report this to the EMOS Contractor immediately. The EMOS Contractor shall notify the Commonwealth Representative (by most direct method) of any immediate extra safety or protective measures required to manage the high risk or very high risk instances of asbestos identified.

6.50 Any reports of high risk or very high risk instances of asbestos shall be confirmed in writing to the Commonwealth Representative by the EMOS Contractor within 48 hours of initial notification.

SECTION 8 RISK CONTROL MEASURES

6.51 Each instance of asbestos managed in-situ on the Defence estate needs to have appropriate control measures49 designed in accordance with the hierarchy of controls and implemented to control any risk posed to human health by asbestos. Control measures need to be implemented based on the condition and the risks of potential exposure and determined using the risk assessment process set out above at Chapter 6 Section 6 ‘Risk Assessments’. Control measures should be aimed at eliminating the risk arising from ACM and preventing exposure to airborne asbestos fibres. There are a number of asbestos control measures linked to the hierarchy of controls that are commonly used on the Defence estate. These include:50

6.51.1 Elimination - Removal and disposal of ACM. Elimination control measures must be undertaken where there is an immediate or likely risk of asbestos fibre release (e.g. asbestos insulation) and/or in circumstances where it is practicable to eliminate all instances of asbestos (e.g. asbestos can be cost effectively removed as part of a programmed work schedule, such that all the asbestos is removed from a building, not merely high risk asbestos). In many instances the elimination of all asbestos from a building provides the best value for money consideration at the same time as reducing the overall asbestos liability across the estate.

6.51.2 Substitution - The substitution of ACM material with non-asbestos materials. Substitution control measures should be considered where asbestos can be cost effectively removed as part of a building refurbishment or where old plant parts [e.g. gaskets] can be replaced with non-asbestos containing parts.

6.51.3 Isolation - Isolation control measures include encapsulation, or sealing of in-situ asbestos materials. Isolation control measures are most often activities such as painting exposed surfaces of ACM products or sealing ACM materials in the ground with a bitumen or concrete surfacing layer. See Chapter 5 Table A1 Grounds Remedial Measures and Maintenance Techniques.

49 Control measures need to be implemented based on the condition of the ACM and the risks of potential exposure determined using the risk assessment process set out above at the section “Asbestos Risk Assessments”. The control measures should be aimed at eliminating the risk arising from ACM and preventing exposure to airborne asbestos fibres. 50 Regulation 36 sets out the hierarchy of controls and the requirement to implement them. Regulation 37 mandates maintaining the control measures required by Regulation36.

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6.51.4 Engineering Controls - Engineering controls are measures such as the use of fencing for remote sites and the use of barriers around areas that need to be made safe.

6.51.5 Administrative Controls - Administrative control measures include: asbestos signage/labelling; maintaining the Defence asbestos register; asbestos inductions; asbestos training/education and the production of this AMP. These control measures need to be used for all instances of asbestos managed in-situ.

6.51.6 Personal Protective Equipment (PPE) – PPE control measures need to be used for all asbestos works and asbestos related works.

6.52 Each instance of asbestos managed in-situ on the Defence estate must have a corresponding risk control measure recommendation recorded against it on the Defence asbestos register. This information is recorded under the field “ACM Controls”. When new risk information is established, the EMOS needs to ensure the ACM Controls record is updated. The management of the instance is based on risk with high risk instances immediately controlled and all other instances submitted to the Estate Works Program (EWP) via an Estate Investment Requirement (EIR).or The EMOS Contractor must ensure that all asbestos register recommendations are provided to the relevant estate upkeep team (i.e. the team responsible for the creation and maintenance of the estate upkeep schedule plan) for inclusion in the estate works program.

6.53 Regulation 36 of the WHS Regulations requires that any risk that cannot be eliminated must be controlled. All risk mitigation controls for the management of in-situ asbestos on the Defence estate must be prepared by or endorsed by a COH to ensure that the recommended controls will adequately control the risk posed by the ACM. Regulation 38 of the WHS Regulations requires that control measures are reviewed to ensure that they remain effective. Defence undertakes these reviews when:

6.53.1 an asbestos survey or inspection is undertaken;

6.53.2 an asbestos incident occurs or controls are assessed as insufficient to control the risk;

6.53.3 there is evidence to indicate that an assessment is no longer valid;

6.53.4 an adverse health monitoring report is received;

6.53.5 there is a significant change in the function or layout of a space to which the assessment relates;

6.53.6 new information on asbestos is released.

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SECTION 9 SIGNAGE AND LABELLING

6.54 The EMOS Contractor is responsible to ensure that asbestos warning labels are attached (in accordance with the labelling protocol set out in the AMP) to all entrances of buildings with recorded ACM. This requirement is for all buildings with ACM whether or not the ACM has been newly identified in the building or was previously noted on the asbestos register. Where the EMOS Contractor identifies that a building does not have the required labelling the EMOS Contractor is to immediately rectify this non- compliance by attaching a compliant asbestos warning label (in accordance with the requirements of the labelling protocol set out in the AMP).

6.55 EMOS Contractor is responsible to return to each site once laboratory results are known to affix asbestos warning labels to all proven asbestos materials and to the entry points of any buildings with ACM (in accordance with the AMP labelling protocol). The EMOS Contractor is responsible for removing any erroneously placed or obsolete labels from material that has been proven not to contain asbestos.

FIGURE 3. SAMPLE ASBESTOS HAZARD WARNING LABELLING

6.56 All asbestos hazard labelling is to be attached in accordance with the requirements of the WHS Legislation and the AMP labelling protocol. During the asbestos re-inspection, the competent person shall ensure that all asbestos warning labels used to identify ACM that are either newly placed or are pre-existing on the estate are in a good condition, are legible, are not faded, cracked, damaged or factually incorrect. If any asbestos hazard labelling do not meet these requirements the competent person should make the necessary recommendations for the EMOS Contractor to replace the labelling.

6.57 Where it is reasonably practicable to identify ACM material with a label, a label must be attached to the material itself or as close as possible to the material in a way that identifies the asbestos hazard.51

6.57.1 Example: External building fabric / Eave Lining / Fascia – asbestos warning labels shall be placed at 5 metre intervals for the entire length of all accessible material (this includes material that is accessible using a cherry picker or other means of working at heights).

51 WHS Reg 424 Presence and location of asbestos to be indicated. A person with management or control of a workplace must ensure that: (a) the presence and location of asbestos or ACM identified at the workplace under regulation 422 (assumed) is clearly indicated; and (b) if it is reasonably practicable to do so, indicate the presence and location of the asbestos or ACM by a label.

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FIGURE 4. SAMPLE ASBESTOS WARNING LABEL SPACING

6.58 In the case of presumed ACM, the competent person shall ensure that asbestos warning labels are affixed in rooms where it is presumed to be present. This is to be done in accordance with the labelling protocol set out in the AMP. The competent person must also ensure that asbestos warning labelling is affixed to the building entry points, in accordance with the labelling protocol set out in the AMP. In the case of ACM that is presumed due to the space being inaccessible, the competent person shall ensure that asbestos warning signs are affixed adjacent to the space where asbestos is presumed to be present.

6.59 If a communication pit is identified as ACM material then the pit is to be labelled using either a metal label or stencil (paint) on the top of the pit.

6.60 In the case of plant, equipment, or other instances where it is not practical to place asbestos hazard labels directly onto the ACM, a prominent warning sign must be posted in the immediate vicinity of the asbestos. Warning signs must comply with AS 1319 Safety Signs for the Occupational Environment and the labelling protocol in the AMP.

6.61 All labels to be used during the asbestos re-inspection survey shall be applied by the competent person.

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SECTION 10 UPDATING THE ASBESTOS REGISTER WITH THE ASBESTOS RE-INSPECTION OR ASBESTOS SURVEY DATA

6.62 The EMOS Contractor is responsible for updating the GEMS Asbestos module that includes all of the updated information gathered from the asbestos re-inspection and asbestos survey and all the results of sample testing.

6.63 The format and terminology used in the asbestos register must be consistent with the headings in the GEMS asbestos module (see paragraph 6.66 sub-paragraphs 6.66.1 to 6.66.16).

6.64 A COH (or equivalent) shall prepare a risk assessment and control measure for each identified and presumed asbestos material and these must also be recorded on the asbestos register.

6.65 Unless notified otherwise by the Commonwealth Representative, fields for the GEMS Data Load (GDL) tool must include a minimum of the following:

6.65.1 Exact location (Commonwealth location reference);

6.65.2 Asbestos present – yes/no/presumed/post 31 December 2003;

6.65.3 Date of inspection;

6.65.4 Date of re-inspection;

6.65.5 Asbestos application – acoustic insulation, ceiling lining, decorative coating, eaves (including surface treatment or equipment);

6.65.6 Material description - Generic ACM (bitumen membrane, millboard, debris, see Appendix 1) or generic non-ACM (brick, masonry, concrete, metal);

6.65.7 ACM type (friable, non-friable);

6.65.8 ACM condition (fair, good, poor, very good, unknown, asbestos removed, no asbestos detected);

6.65.9 ACM control (remove, encapsulate, leave & manage)

6.65.10 Warning labels (labels affixed, labels required, labels removed);

6.65.11 Extent of product (area, volume); and

6.65.12 Accessibility of the material.

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6.66 It is a requirement of WHS legislation that asbestos registers are accurate and up to date. Therefore it is essential that all of the data fields in the Defence asbestos register contain up-to-date and meaningful data, therefore the asbestos re-inspection / asbestos survey must ensure that there are no blank data fields in the asbestos register for mandatory fields such as location, status or material inspected. Further it is expected for all EFR where the status field records that asbestos is either present or presumed that all remaining fields will be complete, i.e. they will contain the information in each field as to the amount of material, the type of material, risk rating, recommended controls etc.

6.67 Presumed status will only be acceptable on an EFR where it is also recorded that the material in question is not accessible (i.e. asbestos should only be presumed where material is inaccessible and therefore testing cannot be conducted to determine the actual status of the material). Where, prior to the asbestos re-inspection or asbestos survey taking place, the asbestos register records presumed asbestos in accessible areas, the competent person / COH/LAA/CSAP (or equivalent) must determine the status of the asbestos by either:

6.67.1 cross checking the data on the date the facility was constructed to ascertain if the facility was built post 31 December 2003, or

6.67.2 undertaking physical surveys and any appropriate testing of the facility to determine the facilities correct status in relation to asbestos if the facility was built prior to 31 December 2003.

6.68 The status of buildings built post-31 December 2003 should be “post-31 December 2003” rather than “presumed”, as any record of presumed status for buildings built post-31 December 2003 is a consequence of data transfer between systems rather than a previous finding of presumed asbestos.

6.69 At the completion of the asbestos re-inspection, all labels that need to be affixed and all labels that need to be removed must have been affixed or removed accordingly prior to project completion. Any data fields in the asbestos register that state that labels need to be affixed or removed are unacceptable as the affixing of labels and the removal of obsolete labels needs to be done as part of the asbestos re-inspection or asbestos survey.

6.70 For any communication pits surveyed, the location of the pit must be give a reference to available site plans and reported against either the environmental code for the site or the nearest structure code. GPS co-ordinates, the nearest street and/or nearest structure code and relative direction of the pit in relation to these structures is to be included in the comments section of the asbestos register.

6.71 The findings of the asbestos re-inspection or asbestos survey and the results of the analysis for any samples collected during the survey must be presented in the required format prescribed in the GDL – the prescribed GDL shall be uploaded to the Defence asbestos register by the EMOS Contractor as soon as reasonably practicable.

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SECTION 11 RE-INSPECTION / SURVEY REPORT

6.72 The competent person shall prepare a written final asbestos re-inspection report. A spreadsheet containing data is not considered acceptable as these reports are often provided by Defence for Regulator documentary evidence, freedom of information or request for information (for compensation claims). The Report shall contain the following information within one month of the asbestos re-inspection date.

6.72.1 Executive summary;

6.72.2 Statement detailing who commissioned the re-inspection report and the purpose of the report;

6.72.3 Identity of Facility, structures, fixed plant and workplaces re-inspected;

6.72.4 Dates of re-inspection, identity of persons conducting the re-inspection and date of report;

6.72.5 Scope and extent of asbestos re-inspection;

6.72.6 Applicable disclaimers or limitations detailing any area not inspected and the reason those limits prevented the re-inspection been conducted in those areas;

6.72.7 Methodology including steps undertaken for safety planning, conducting ‘as required’ asbestos sampling (conducted by a COH) safety planning, inspection and analysis of samples collected;

6.72.8 Attached Risk Assessment (prepared by a COH [or equivalent]);

6.72.9 Summary of findings;

6.72.10 List of significant findings requiring immediate attention;

6.72.11 Recommendations linked to the findings of the risk assessment on the management of in situ asbestos to reduce or eliminate the risk to building users (recommendations must include appropriate time frames for any remediation);

6.72.12 Photos of all identified and presumed instances of ACM;

6.72.13 NATA-endorsed certificates of analysis and associated worksheets; and

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6.72.14 any other information that is required by Defence to ensure the Commonwealth's compliance with the WHS Legislation.

6.73 The asbestos re-inspection and asbestos survey report risk assessments should take into account information derived from the asbestos re-inspection and asbestos survey and any subsequent analysis results in particular:

6.73.1 The type and condition of the ACM or presumed ACM (loose insulation, spray coatings, friable, bonded);

6.73.2 The location (likelihood of damage, weathering);

6.73.3 Overall work practices (including planned activities) at the location and likelihood of disturbing the ACM; and

6.73.4 any information that may be relevant for the purposes of Defence compliance with WHS Legislation.

6.74 The asbestos re-inspection and asbestos survey report risk assessments must show the risk level and score (rating) for each particular asbestos hazard to allow informed decisions and management about the risks and the required control measures. It is expected that the risk assessment will provide the Commonwealth with best practice risk treatment options on how to best manage in situ or remove the asbestos including a priority for action.

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CHAPTER 7 INFORMATION ON ASBESTOS IN THE ESTATE FOR ALL DEFENCE WORKERS

SECTION 1 HOW DO I IDENTIFY ASBESTOS?

7.1 Asbestos products were a widely used material within commercial buildings, homes and machinery until Dec 2003, when it was banned.

7.2 Asbestos products were

7.2.1 building material as flat asbestos cement (FAC) sheeting, gaskets and seals, window putty especially in aged steel and aluminium puttied windows, thermal and acoustic insulation and various fireproofing fabrics including seals to flammable liquid cabinets and fire door cores.

7.2.2 ships and aircraft for pipe lagging, fire retarding and soundproofing, some adhesives, brake pads.

7.3 It can be difficult to identify the various asbestos forms (blue asbestos [crocidolite], brown asbestos [amosite] or white asbestos [chrysotile]), as it is often mixed with other materials. The images below are typical of how asbestos may be found in Defence buildings and other recognisable situations that may contain asbestos.

Typical locations of asbestos

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7.4 Asbestos sample labels on walls, eaves, fascia’s, under floor tiles, do not necessarily indicate the location has asbestos containing material. It is merely indicating that sampling was conducted at this location. The sample label ID / serial number (see Figure 5. below ID# 62411.108.04) would be reviewed in conjunction with the corresponding asbestos survey report that can be provided by engaging with the local EMOS Contractor.

FIGURE 5. ASBESTOS SAMPLE DESCRIPTOR LABEL (i.e. Sample ID# 62411.108.04)

SECTION 2 WHY DOESN’T DEFENCE JUST GET RID OF ALL THE ASBESTOS?

7.5 Defence are conducting asbestos remediation projects and proactively removing asbestos and replacing with suitable products. However, there are instance where the asbestos is located in areas that are not possible to access without causing considerable damage to the building and infrastructure.

7.6 Therefore, the current approach is for Defence to engage the services of a competent person to undertake regular asbestos re-inspections and as required asbestos surveys. The report outcomes allows Defence to use a risk managed approach to maintain the instances of installed asbestos by taking into account the considerations:

7.6.1 the type of asbestos (friable or non-friable);

7.6.2 the condition of the asbestos (in good condition or poor condition);

7.6.3 whether or not the asbestos is accessible; and

7.6.4 whether the asbestos is likely to be disturbed by activities undertaken in the area.

7.7 Historically, unauthorised ‘self-help’ works (in the workplace or living in accommodations) is regularly the cause of accidental asbestos exposures.

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SECTION 3 HOW DO I ASK FOR THE ASBESTOS REGISTER?

7.8 Where persons require visibility of the Asbestos Register applicable to the area in which they are working, an extract of the latest Asbestos Register from the Garrison Estate Management System (GEMS) can be obtained by:

7.8.1 Downloading the Asbestos Register from GEMS; or

7.8.2 Raising a Service Request via the AE547 webform; or

7.8.3 Calling the Base services Support Centre (BSSC) on 1300 658 975.

SECTION 4 WHAT’S THE HEALTH RISK TO ME?

7.9 The mere presence of asbestos is not an immediate risk. In fact, if asbestos can be maintained in good condition, it is recommended that it be left alone and inspected periodically to monitor its condition. It is only when ACMs are disturbed or the materials become damaged and the asbestos contained within could potentially become friable and loose that it becomes a risk. Exposure to airborne asbestos should therefore be kept to as low as reasonably practicable and regardless of the activity should be kept below the national exposure standards.

7.10 The Australian Mesothelioma Registry reported that 641 Australians died from mesothelioma in 2014. Approximately 80% were men and the age range of those affected were 70 to 79 years old.

7.11 Younger people, if routinely exposed to asbestos fibres over time, are at greater risk of developing asbestos-related disease than older workers. This is due to the time it takes for the body to develop symptoms after exposure to asbestos (latency). Exposure to asbestos can cause four main diseases:

7.11.1 Mesothelioma (a cancer of the lining of the lungs; it is always fatal and is almost exclusively caused by exposure to asbestos)

7.11.2 Asbestos-related lung cancer (which is almost always fatal)

7.11.3 Asbestosis (a scarring of the lungs which is not always fatal but can be a very debilitating disease, greatly affecting quality of life)

7.11.4 Diffuse pleural thickening (a thickening of the membrane surrounding the lungs which can restrict lung expansion leading to breathlessness.)

7.12 It can take anywhere between 15-60 years for any symptoms to develop after exposure, so these diseases will not affect you immediately but may do later in life.

SECTION 5 HOW DOES ASBESTOS ENTER THE BODY?

7.13 Hazard. A hazard can be defined as ‘a source or a situation with a potential for harm in terms of human injury or ill health, damage to property, damage to the environment or a combination of these’. This means that the mere presence of ACM in a workplace does not of itself pose a risk to health.

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7.14 Risk. Risk is a function of consequence and likelihood, while likelihood is a function of exposure (i.e. actually entering the body) and probability. With respect to ACM:

7.15 Exposure. Notwithstanding the potentially serious consequences of airborne asbestos fibres entering the body, they can only result from inhaling them.

7.16 Probability. Although there is no safe limit for individuals who have inhaled airborne asbestos fibres, this does not mean that disease is inevitable for those who have done so. The probability and type of asbestos-related disease depends on the:

7.16.1 Dose of inhaled fibres.

7.16.2 Frequency at which fibres are inhaled.

7.16.3 Duration of time that fibres are inhaled.

7.16.4 Type of asbestos inhaled (in particular, the shape of the fibres).

7.16.5 Smoking history and genetic predisposition of the individual.

SECTION 6 I BELIEVE I HAVE FOUND ASBESTOS AT MY WORK OR ACCOMMODATION BLOCK. WHAT DO I DO NEXT?

7.17 The following actions must be observed by the initial observer:

7.17.1 Stop work immediately, advise your next level supervisor;

7.17.2 Evacuate / isolate the affected area and restrict access;

7.17.3 Seal off, close doors leading to the affected area, post warning signs (where safe to do so);

7.17.4 Report the issue via the Base Support Service Customer Centre on 1300 658 975.

SECTION 7 WHAT ACTIONS WILL BE TAKEN AFTER I REPORT THE ASBESTOS?

7.18 For the majority of building occupants, the EMOS Contractor will attend and ‘make safe’ the affected area as well as consult the asbestos register for the building and confirm the status for the affected area. If physical sampling had previously occurred then the EMOS Contractor will advise building occupants the results return the area to normal activities.

7.19 Where there has been no previous asbestos testing or the results are positive for asbestos, the EMOS Contractor will take further actions. See Chapter 2 Figure 1. Flow of Asbestos Incident Response.

SECTION 8 IF THE RESULTS ARE POSITIVE WHAT DO I DO NEXT?

7.20 Where the results are positive for asbestos the actions in Chapter 2 Figure 1. Flow of Asbestos Incident Reporting will commence to make safe the affected area.

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7.21 For Defence personnel, where there has been potentially a bulk exposure the HRU may elect to take the required Sentinel action to create a single Sentinel Event and add all affected building occupants. If this has not occurred, you can request a copy of the sampling results and initiate the Sentinel Event report (be sure to attach the sampling results) which notifies your Supervisor who will take the follow up (investigation) actions in Sentinel.

7.22 The Defence Asbestos and Hazardous Chemicals Exposure Scheme (DAHCES) is open to current and former employees of the Department of Defence and Australian Defence Force members (including Cadets) who suspect that they have been exposed to asbestos or a hazardous chemical as a result of their employment with Defence.

7.23 Current employees of Defence who think that they have been exposed should submit a Defence WHS Incident Report via Sentinel - WHS Event Reporting. Note: Sentinel is not a legacy reporting tool and exposures can only be raised for events post August 2014. If your exposure occurred prior to August 2014 you are not required to raise a WHS Sentinel event, simply register with DAHCES.

7.24 Serving ADF employees who have been or think that they may have been exposed are encouraged to contact their local ADF Health Service.

7.25 For Contractors and visiting personnel to Defence establishments – under the Work Health and Safety Act 2011, Defence has a duty to take all reasonably practical steps to protect the health and safety of contractors, their staff and other persons at or near Defence controlled workplaces. Contractors (and their employees) employed by Defence can register their details with DAHCES by contacting 1800 DEFENCE (1800 333 362). However, they have no entitlement to medical counselling and preliminary medical examinations. They will need to contact their employer for further information.

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DEFINITIONS

Accredited laboratory A testing laboratory accredited by the Australian National Association of Testing Authorities (NATA) accredited for the relevant test method.

Air monitoring Airborne asbestos fibre sampling undertaken which allows the assessment of exposure in comparison to the asbestos exposure standards. Air monitoring includes ‘exposure monitoring’ and ‘control monitoring’ (see below).

Airborne asbestos fibres

Unbonded fibres of asbestos capable of becoming airborne with minimal disturbance. For the purposes of monitoring airborne asbestos fibres, only fibres smaller than three micrometres (3 μm) in width, larger than five micrometres (5 μm) long and with a length-to- width ratio greater than three to one (3:1) are counted.

Airborne asbestos fibres are generated by the mechanical disintegration of asbestos-containing materials (ACMs) and subsequent dispersion of fibres into the air from activities such as the use, removal and disposal of asbestos- containing materials. Airborne dust may contain respirable asbestos fibres.

Asbestos The asbestiform varieties of mineral silicates belonging to the serpentine or amphibole groups of rock-forming minerals, including actinolite asbestos, grunerite (or amosite) asbestos (brown), anthophylite asbestos, chrysotile asbestos (white), crocidolite asbestos (blue) and tremolite asbestos.

Asbestos containing material (ACM)

Any material or thing that contains asbestos as part of its design.

Asbestos Contaminated Dust or Debris (ACD)

Dust or debris which has settled within a workplace and is (or is assumed to be) contaminated with asbestos.

Asbestos related work Work involving asbestos (other than licensed asbestos removal work) that is permitted under exceptions set out in regulation 419(3), (4) and (5).

Asbestos removalist A licensed Competent Person who performs asbestos removal work. A Class A licence allows the holder to remove any amount or quantity of asbestos or ACM as specified in the licence. A Class B licence holder can remove any amount of non-friable asbestos or ACM and ACD associated with the removal of non-friable asbestos or ACM.

In Australia, a Class A asbestos removal licence is required for the removal of friable asbestos containing materials.

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Asbestos Removal Control Plan

A document that identifies the specific control measures which will be implemented to ensure workers and other persons are not at risk when asbestos work is being conducted. The content of an asbestos removal control plan is described in the Code of Practice How to safely remove asbestos.

Asbestos removal works

Asbestos removal works is any works on the Defence estate that involves the removal of asbestos or ACM, regardless of the amount of Asbestos or ACM being removed. All asbestos removal works must be undertaken by an appropriately licensed asbestos removalist.

Asbestos vacuum cleaner

A vacuum cleaner fitted with a high-efficiency particulate air (HEPA) filter and complies with Australian Standard 3544-1988 Industrial Vacuum Cleaners for Particulates Hazardous to Health.

A domestic vacuum cleaner is not suitable for use with asbestos.

Asbestos waste All removed asbestos-containing materials and disposable items used during asbestos work, such as plastic sheeting used to cover surfaces in the asbestos work area, disposable coveralls, disposable respirators and rags used for cleaning.

Asbestos work area The immediate area where work on asbestos-containing materials occurs. The boundaries of the asbestos work area shall be determined by a risk assessment.

ASBINS Asbestos in Soils

May also include asbestos contaminated waste, asbestos contaminated sites and naturally occurring asbestos in soils.

Breathing zone A hemisphere of three hundred millimetres (300 mm) radius extending in front of a person’s face, and measured from the midpoint of an imaginary line joining the ears.

Clearance monitoring Air monitoring using static or positional samples to measure the level of airborne asbestos fibres in an area after work on asbestos-containing materials. An area is ‘cleared’ when the level of airborne asbestos fibres is measured at below 0.01 fibres per mL (0.01/mL).

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Competent Person In relation to carrying out clearance inspections of asbestos removal areas under WHS Regulation 473—a person who has acquired through training or experience the knowledge and skills of relevant asbestos removal industry practice and holds:

− a certification in relation to the specified VET course for asbestos assessor work, or

− a tertiary qualification in occupational health and safety, occupational hygiene, science, building, construction or environmental health.

Contaminated Site Assessment Practitioner

Due to the cross-disciplinary nature of contaminated site work, a CSAP must have the ability to apply knowledge and experience in numerous aspects. Abilities include:

1. Determining the nature, causes and significance of site contamination

2. Conduct preliminary assessment of site contamination 3. Detailed assessment involving the characteristics of site

contamination 4. Risk assessment of site contamination 5. Remediation and management of site contamination 6. Professional practice in relation to site contamination

Control level The airborne concentration of a particular substance which, if exceeded, indicates a need to implement a control, action or other requirement. Control levels are generally set at no more than half the National Exposure Standards (NES) for the substance. Control levels are occupational hygiene ‘best practice’, and are not health-based standards.

The first control level for asbestos is set at 0.01 fibres per millilitre (0.01/mL) of air.

Control monitoring Monitoring using static or positional samples to measure the level of a hazardous substance in an area. Control monitoring is designed to assist in assessing the effectiveness of implemented control measures. Control monitoring is not representative of actual occupational exposures and should not be used for that purpose.

Countable fibre Any object that has a maximum width smaller than three micrometres (3 μm), a length greater than five micrometres (5 μm) and a length-to-width ratio greater than 3:1, and which does not appear to touch any particle with a maximum width (that is, the smaller of the two dimensions) greater than three micrometres (3μm).

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Dangerous incident

(asbestos)

Under section 37 of the WHS Act, a dangerous incident is an incident in relation to a workplace that exposes a worker or any other person to a serious risk to a person’s health or safety emanating from an immediate or imminent exposure to:

an uncontrolled escape, spillage or leakage of a substance

an uncontrolled implosion, explosion or fire

an uncontrolled escape of gas or steam

an uncontrolled escape of a pressurised substance

electric shock

the fall or release from a height of any plant, substance or thing

the collapse, overturning, failure or malfunction of, or damage to, any plant that is required to be authorised for use in accordance with the regulations

the collapse or partial collapse of a structure

the collapse or failure of an excavation or of any shoring supporting an excavation

the inrush of water, mud or gas in workings, in an underground excavation or tunnel

the interruption of the main system of ventilation in an underground excavation or tunnel.

A dangerous incident includes both immediate serious risks to health or safety, and also a risk from an immediate exposure to a substance which is likely to create a serious risk to health or safety in the future, for example asbestos or chemicals.

Defence estate All workplaces, facilities (buildings and land) and the associated infrastructure that are owned, leased, maintained or managed and under the control of E&IG for and on behalf of Defence.

Exposure monitoring Monitoring in a person’s breathing zone to measure their likely exposure to a hazardous substance. Exposure monitoring is designed to estimate exposure reliably so that it can be compared with the occupational exposure standard estimate a person’s exposure.

In relation to asbestos, exposure monitoring includes airborne asbestos fibre sampling, analysis, estimation of time-weighted average exposure and interpretation.

Exposure standard For asbestos is a respirable fibre level of 0.1 fibres/ml of air measured in a person’s breathing zone and expressed as a time weighted average fibre concentration calculated in accordance with:

The Membrane filter method

A method determined by the relevant regulator

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Friable asbestos Asbestos-containing material which, when dry, is or may become crumbled, pulverized or reduced to powder easily (for example, by as little as hand pressure).

This may include asbestos-containing materials affected by weathering, physical damage, and water damage and so on.

Hazard Any matter, thing, process or practice that may cause death, injury, illness or disease.

GEMS asbestos module

Common term used in this AMP. Actual location in GEMS is:

Risk Compliance & Environmental Management \ Environmental Management \ Environmental Factor Record.

Select Environmental Factor Type \ Asbestos or CSR

Health monitoring The monitoring of a person to identify any changes in their health as a result of exposure to a hazardous substance.

High efficiency particulate air (HEPA) filter

A disposable, extended media, dry-type filter, in a rigid frame, with a minimum filtration efficiency of 99.97% for nominal three micrometres (0.3 μm) diameter thermally generated dioctylphthalata (DOP) particles, or an equivalent efficiency for a specified alternative aerosol and with an initial maximum resistance to airflow of 250 pa when tested at its rated airflow capacity (see Australian Standard 4260-1997 High Efficiency Particulate (HEPA) Filters – Classification, Construction and Performance).

In-situ asbestos Fixed or installed in a structure, equipment or plant but does not include naturally occurring asbestos.

Inaccessible areas Areas that are difficult to access, such as wall cavities and the interiors of plant and equipment.

Micrometre Also ‘micron’; the millionth part of a metre. Symbol: μm, using ‘mu’, the 12 letter of the Greek alphabet. See also ‘micrometre’ and ‘μm’.

micron Also ‘micrometre’; the millionth part of a metre. See ‘micrometre’ and ‘μm’.

μm Symbol for micrometre; one millionth of a metre. See ‘micrometre’ and ‘micron’.

National Exposure Standard (NES)

An airborne concentration of a particular substance, within the worker’s breathing zone, which according to current knowledge, should not cause adverse health effects or undue discomfort to nearly all workers. National Exposure Standards are established, from time to time, by the National Work Health and Safety Commission (NWHSC) and are published on the NWHSC website.

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The NES for all forms of asbestos is 0.1 fibres per mL of air, measured using the membrane filter method (MFM).

Naturally occurring asbestos (NOA)

The natural geological occurrence of asbestos minerals found in association with geological deposits including rock, sediment or soil.

Non-friable asbestos Material containing asbestos that is not friable asbestos, including material containing fibres reinforced with a bonding compound.

Person with control In relation to premises, a person who has control of premises used as a workplace. The ‘person with control’ maybe:

the owner of the premises

a person who has, under any contract or lease, an obligation to maintain or repair the premises

a person who is occupying the premises

a person who is able to make decisions about work undertaken at the premises

an employer at the premises.

Personal protective equipment (PPE)

Equipment and clothing used or worn by an individual person to protect themselves against, or minimise their exposure to, workplace risks. PPE includes face masks, respirators, coveralls, goggles, helmets, gloves and footwear.

Respirable asbestos fibre

An asbestos fibre that

− is less than 3 micrometres (µm) wide

− is more than 5 micrometres (µm) long, and

− has a length to width ratio of more than 3:1

Risk The likelihood of a hazard causing harm to a person. In this document, ‘risk’ relates to illness or disease arising from exposure to airborne asbestos fibres.

Settled dust sampling The sampling and analysis of settled surface dust to provide an indication of cleanliness after disturbance of asbestos-containing materials. Settled dust sampling does not provide an indication of risk to health. Sampling techniques include the use of adhesive tape, business card method of non-humongous material, wipe or micro vacuum (using an air sampling pump and filter).

Analysis can be by polarised light microscopy (PLM) or transmission electron microscopy (TEM).

Contamination may occur as a result of deterioration of, or work processes involving asbestos- containing materials.

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SFARP An acronym for ‘so far as is reasonably practicable’. The risk of asbestos exposure to a worker shall be eliminated or reduce SFARP, ensuring in all circumstances the National Exposure Standard (NES) is not exceeded.

Shadow vacuuming The operation of an asbestos vacuum cleaner that is either directly attached to a tool or hand- held by a second worker as close as possible to the source of released asbestos fibres throughout the use of the tool.

Static samples (positional)

Samples taken at fixed locations, usually between one and two metres above floor level.

Structure Any construction, whether temporary or permanent. A structure includes any building, premises, bridge, erection, edifice, wall, chimney, fence, earthworks, reclamation, ship, floating structure or tunnel.

Work Any activity, physical or mental, carried out in the course of a business, industry, commerce, an occupation or a profession.

Worker Any person who carries out work for a person conducting a business or undertaking, including work as an employee, contractor or subcontractor (or their employee), self-employed person, outworker, apprentice or trainee, work experience student, employee of a labour hire company placed with a 'host employer' or a volunteer.

Workplace Any place where work is carried out for a business or undertaking and includes any place where a worker goes, or is likely to be, while at work. This may include offices, factories, shops, construction sites, vehicles, ships, aircraft or other mobile structures on land or water.

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REFERENCES

o Australian Standard AS 4964-2004 Method for the qualitative identification of asbestos in bulk samples

o Australian Standard AS 4482.1-2005 Guide to the investigation and sampling of sites with potentially contaminated soil; Part 1: Non-volatile and semi-volatile compounds

o Code of Practice - How to Manage and Control Asbestos in the Workplace [Safe Work Australia 2015]

o Code of Practice - How to Safety Remove Asbestos [Safe Work Australia 2015]

o Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres 2nd Edition, [NOHSC: 3003 (2005)].

INTERPRETATION

Unless the context requires otherwise, capitalised terms in the AMP will have the meaning given to them by the Commonwealth as published on the DEQMS website at http://www.defence.gov.au/estate management/.