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Estate & Infrastructure Group Asbestos Management Plan (AMP)

Version: 3.0 Doc Date: 18 July 2018

Estate & Infrastructure Group Asbestos Management Plan

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Table of Contents

ACRONYMS AND ABBREVIATIONS ........................................................................................................................... 5 PART 1 ASBESTOS MANAGEMENT PLAN ................................................................................................................. 7 SECTION 1 DEFINITION OF A CONTRACTOR ........................................................................................................... 7 SECTION 2 ROLES AND RESPONSIBILITIES ............................................................................................................. 7 SECTION 3 ASBESTOS CONTAINING MATERIAL .................................................................................................. 11 SECTION 4 GOVERNANCE .......................................................................................................................................... 12 SECTION 5 SCOPE AND LIMITATIONS ..................................................................................................................... 12 SECTION 6 AIM .............................................................................................................................................................. 13 SECTION 7 USERS OF THE ASBESTOS MANAGEMENT PLAN ............................................................................ 13 SECTION 8 MANAGEMENT OF ASBESTOS ON THE DEFENCE ESTATE ............................................................ 14 SECTION 9 ASBESTOS SURVEYS AND INSPECTIONS .......................................................................................... 14 SECTION 10 ASBESTOS RISK ASSESSMENTS ......................................................................................................... 15 SECTION 11 RISK CONTROL MEASURES................................................................................................................. 16 SECTION 12 DEFENCE ASBESTOS REGISTER ......................................................................................................... 17 SECTION 13 ASBESTOS EDUCATION AND THE PROVISION OF HAZARD INFORMATION ........................... 19 SECTION 14 INCIDENT AND EVENT NOTIFICATIONS .......................................................................................... 20 SECTION 15 ASBESTOS INCIDENT RESPONSE ....................................................................................................... 22 SECTION 16 THE ROLE OF ID, BSM, PDS, HRU OR THE PROJECT MANAGER IN THE MANAGEMENT OF AN ASBESTOS INCIDENT ................................................................................................................................................. 24 SECTION 17 ASBESTOS INCIDENT INVESTIGATIONS .......................................................................................... 24 SECTION 18 ASBESTOS LABELLING AND SIGNAGE ............................................................................................ 25 SECTION 19 ASBESTOS REMOVAL CONTROL PLAN ............................................................................................ 26 FIGURE 1: COMMUNICATION PROCESS FOR ASBESTOS WORKS .................................................................... 28 SECTION 20 WORKS THAT CAN POTENTIALLY DISTURB ASBESTOS ............................................................. 29 SECTION 21 ASBESTOS PERMITS TO WORK .......................................................................................................... 29 SECTION 22 REGULATOR NOTIFICATION OF ASBESTOS WORK ...................................................................... 30 SECTION 23 ASBESTOS REMOVAL WORKS ............................................................................................................ 31 SECTION 24 DEMOLITION WORKS ........................................................................................................................... 32 SECTION 25 ASBESTOS WORK DELIVERED THROUGH THE ESTATE WORKS PROGRAM ........................... 32 SECTION 26 DUTIES OF THE COH/CIH ..................................................................................................................... 34 SECTION 27 AIR MONITORING FOR RESPIRABLE ASBESTOS FIBRES ............................................................. 35 SECTION 28 CLEARANCE INSPECTIONS AND CLEARANCE CERTIFICATES .................................................. 36 SECTION 29 RECORD KEEPING ................................................................................................................................. 36 SECTION 30 HEALTH MONITORING ......................................................................................................................... 37 SECTION 31 ASBESTOS TRAINING............................................................................................................................ 38 SECTION 32 IMPORTATION OF FILL MATERIAL ................................................................................................... 39 SECTION 33 FIRE DAMAGED BUILDINGS ............................................................................................................... 39 SECTION 34 UNEXPECTED ASBESTOS FIND WITHIN A MILITARY PLATFORM ............................................ 39 PART 2 ASBESTOS IN SOILS AND SURFACE CONTAMINATION ........................................................................ 40 SECTION 1 LEGISLATION GOVERNING ASBESTOS IN SOILS ............................................................................. 40 SECTION 2 WORKING WITH SOIL SUSPECTED OF HAVING ASBESTOS CONTAMINATION ........................ 41 SECTION 3 DETERMINING HOW TO MANAGE ASBINS AT DIFFERENT SITES ............................................... 42 SECTION 4 DETERMINING MANAGING UNDISTURBED ASBINS ....................................................................... 42 SECTION 5 MANAGING ASBESTOS IN DISTURBED SOILS .................................................................................. 44 SECTION 6 REMEDIATION OF ASBESTOS IN CONTAMINATED SOILS ............................................................. 46 SECTION 7 MANAGING AN ASBESTOS CONTAMINATED SITE ......................................................................... 47 SECTION 8 MANAGING ASBESTOS CONTAMINATED WASTE ........................................................................... 48 SECTION 9 ONSITE DISPOSAL OF ASBESTOS CONTAMINATED WASTE ......................................................... 49 SECTION 10 MANAGING NATURALLY OCCURRING ASBESTOS IN SOILS ...................................................... 49 SECTION 11 RECORDING ASBESTOS CONTAMINATED SOIL SITES IN THE ASBESTOS REGISTER ........... 50 REFERENCES ................................................................................................................................................................. 51 INTERPRETATION ........................................................................................................................................................ 51 TABLE A1 GROUNDS REMEDIAL MEASURES AND MAINTENANCE TECHNIQUES ...................................... 52 ANNEX A - SCOPE OF SERVICES – ASBESTOS SURVEYS .................................................................................... 53 SECTION 1 SERVICES REQUIRED .............................................................................................................................. 53 SECTION 2 PARTICULARS .......................................................................................................................................... 53 SECTION 3 SURVEY PLANNING ................................................................................................................................ 54


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SECTION 4 SURVEY PHYSICAL INSPECTIONS ....................................................................................................... 56 SECTION 5 SAMPLING PARTICULARS ..................................................................................................................... 57 SECTION 6 RISK ASSESSMENT .................................................................................................................................. 60 SECTION 7 DETECTION OF VERY HIGH OR HIGH RISK ASBESTOS .................................................................. 61 SECTION 8 SIGNAGE AND LABELLING ................................................................................................................... 61 SECTION 9 UPDATING THE ASBESTOS REGISTER WITH THE SURVEY DATA ............................................... 62 SECTION 10 SURVEY REPORT ................................................................................................................................... 63 ANNEX B - ASBESTOS INCIDENT RESPONSE ......................................................................................................... 65 ANNEX C - ASBESTOS SURVEY SERVICES CHECKLIST ...................................................................................... 66 ANNEX D - DEFINITIONS ............................................................................................................................................ 80 ANNEX E – ASBESTOS REMOVAL PERMIT TO WORK ............................................................................................. 84


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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

This document has been approved by

Name Signature Date reviewed

1 Justine Nordin DWHSPC

18 July 2018

Control Revision and Amendments E&IG Asbestos Management Plan (known through this document as this AMP) is subject to ongoing 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 plan 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 Policy and Compliance (DWHSPC) 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 • Defence SafetyMan Part 2, WHS Hazards and Risks

The following areas have been consulted in the development of this AMP:

• Zones • Product Directors – Estate Upkeep and Estate Works Program Office • Infrastructure Division • WHS Branch DC Occupational Health • Directorate of Environmental Engineering

mailto:E%[email protected]


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ACRONYMS AND ABBREVIATIONS

ACM Asbestos Containing Material

ACD Asbestos Contaminated Dust or Debris

ASBINS Asbestos in Soils

ASRS Assistant Secretary Regional Services

BSM Base Support Manager

BSC Base Services Contract

BSSC Base Services Support Centre

CA Contract Authority

CFI Capital Facilities &Infrastructure

CIH Certified Industrial Hygienist

COH Certified Occupational Hygienist

CRAT Contamination Risk Assessment Tool

CSAP Contaminated Site Assessment Practitioner

DAHCES Defence Asbestos and Hazardous Chemical Exposure Scheme

DEIS Defence Estate Information System

DEPU Directorate of Estate Planning and Upkeep

DERP Directorate of Environmental Remediation Programs

DEWPO Directorate of Estate Works Program

DPN Defence Protected Network

DWHSPC Directorate of Work Health and Safety Policy & Compliance

EA Estate Appraisal

E&IG Estate & Infrastructure Group

EEB Environment and Engineering Branch

EMOS Estate Maintenance and Operations Service

EPA Environment Protection Authority

EWP Estate Works Program

GEMS Garrison Estate Management System

GDL GEMS Data Load

HCO Hazardous Chemicals Officer

HRU Head of Resident Unit

ID Infrastructure Division

MIC Management Integration & Coordination

NAD No Asbestos Detected

NPS National Program Service

PD Product Director

PDS Project Delivery Service


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PPE Personal Protective Equipment

SDD Service Delivery Division

SFARP So far as is reasonably practicable

SME Subject Matter Expert

WHS Work Health and Safety


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PART 1 ASBESTOS MANAGEMENT PLAN

SECTION 1 DEFINITION OF A CONTRACTOR

1. In this AMP the following definitions of a contractor apply:

a. 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.

b. 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).

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

SECTION 2 ROLES AND RESPONSIBILITIES

2. Defence and Officers of PCBU - The WHS Act requires Defence as a ‘person conducting a business or undertaking (PCBU)’ to ensure, so far as reasonably practicable, the health and safety of all workers (including contractors and sub-contractors). Consultants and contractors engaged by E&IG (as PCBU in their own rights) must also meet this requirement. The requirement to ensure the health and safety of workers extends to the health and safety of other persons who may be affected by E&IG activities. Examples of duties owed to workers and others in relation to asbestos management include:

a. Eliminating or minimizing, so far as reasonably practicable, the risk of exposure to

airborne asbestos and ensuring the exposure standard for asbestos is not exceeded. b. Providing suitable and specific information, training and instruction to workers,

including contractors and sub-contractors. c. Programming assurance activities to verify all workers, contractors and sub-contractors

are complying with their legislative obligations.

3. 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.

4. Directorate of Work Health and Safety Policy and Compliance (DWHSPC) - As the authority for E&IG asbestos policy, DWHSPC 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).

5. 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 a Hazardous Chemicals Officer (HCO) and/or other E&IG staff are appointed to support oversight.

6. Base Support Manager (BSM) - The BSM has the authority and responsibility for


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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 BSM responsibilities are to be agreed with the SADFO and HRU. These responsibilities include:

a. 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 HCO.

b. 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.

c. Ensuring employee, contractor, consultant and visitor concerns about asbestos are dealt with in a satisfactory and timely manner, with support of the HCO.

d. Raising and coordinating an asbestos “Hot Issues Brief” when required, with support of the HCO.

7. 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 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 duties include ensuring that:

a. 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 the Defence asbestos register

b. their contractors are appropriately qualified/licenced and aware of their responsibilities with regards to asbestos management requirements

c. this AMP and the Defence asbestos register is reviewed by all contractors prior to any work commencing on the Defence estate

d. the licenced asbestos removalist notifies Comcare whenever undertaking asbestos removal works

e. all notifiable incidents are reported to Comcare.

8. Chief Information Officer Group (CIOG) – CIOG are 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 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:

a. 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 the Defence asbestos register

b. their contractors are appropriately qualified/licenced and aware of their responsibilities with regards to asbestos management requirements

c. this AMP and the Defence asbestos register is reviewed by all contractors prior to any work commencing on the Defence estate

d. the licenced asbestos removalist notifies Comcare whenever undertaking asbestos removal works

e. all notifiable incidents are reported to Comcare.

9. 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,


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maintenance, waste disposal and other services on Defence bases.

10. 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. Contractors are responsible for:

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

b. ensuring their workers and sub-contractors are provided with asbestos awareness training

c. 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

d. complying with relevant Commonwealth/State/Territory legislation and Defence procedures, including this AMP

e. ensuring the licenced asbestos removalist notifies Comcare and the State regulatory authorities when required

f. reporting asbestos related notifiable incidents to Comcare, State/Territory Regulators and Defence.

11. EMOS Contractor - The EMOS Contractor is to undertake its contractual obligations1 in- line with legislation and the processes set out in relevant Defence policy, including this AMP. The EMOS Contractor is engaged to:

a. act as first response for asbestos incidents including: (i) initial make safe (ii) engaging a Certified Occupational Hygienist (COH)/Certified Industrial Hygienist

(CIH) (iii) remediation (iv) providing the clearance certificate from a COH/CIH prior to re-occupation

b. deliver the program of asbestos inspections on the Defence estate and perform quality assurance on the data delivered by the inspection program

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

d. update, maintain and make available the Defence asbestos register. e. place and maintain asbestos warning signs and labels f. conduct asbestos remediation projects2

g. provide project support.

12. 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 and this AMP. This includes:

a. 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 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. 2The 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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b. ensuring that the supplied works are to the standard required c. ensuring that the Defence asbestos register is maintained (including quality assurance of

the data delivered under the asbestos inspections program).

13. DEPU is also responsible for ensuring that any EMOS Contractor related non-compliance is rectified or escalated to the Contract Authority for rectification.

14. 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 and this AMP. This includes:

a. ensuring that contractors (and sub-contractors) conduct any asbestos related project

works to the standard required b. that all instances of ACM being removed, disturbed, enclosed or sealed are updated in

the Defence asbestos register c. ensuring that asbestos surveys are scheduled and undertaken in accordance with that

schedule.

15. DEWPO is also responsible for ensuring that any EWP related asbestos non-compliance is rectified or escalated to the Contract Authority for rectification.

16. Project Delivery Service (PDS) – 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.

17. The PDS contractor is also responsible for ensuring that any EWP related asbestos non- compliance is rectified or escalated to the PD (DEWPO) for rectification.

18. Contract Authority (CA) – The CA for the Contract for the provision of Estate Maintenance and Operation Services (EMOS) is responsible for ensuring that non-compliances relating to asbestos services delivered through the Contract are rectified effectively, so as to ensure that Defence is legislatively compliant in both its asbestos related activities and its management of facilities containing asbestos.

19. Head Of Resident Unit (HRU) - HRU are accountable for the implementation of the relevant Group/Service Work Health and Safety Management System (WHSMS). HRU are represented at the Base Management Forum (BMF) and contribute to base-wide WHS planning and risk management, including ensuring the availability of the HRU WHS representative to assist the BSM with coordination activities.

20. If HRU 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 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:

a. ensuring that ALL sponsored works are authorised through E&IG in accordance with

the Sponsored Works Procedure on DEQMS3 (including providing all asbestos documentation and information related to the sponsored works to the EMOS

3 Sponsor funded works through the “Self Help Works” option is for low risk works and should not include any asbestos work.


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Contractor for recording on the Defence asbestos register) b. ensuring that their contractors are appropriately qualified/licenced and aware of their

responsibilities with regards to asbestos management on the Defence estate c. ensuring that this AMP and the Defence asbestos register is reviewed by all contractors

prior to any work commencing on the Defence estate d. reporting all asbestos related notifiable incidents to Comcare and creating a Sentinel

Event report for all such incidents e. informing the EMOS Contractor via a Service Request to the Base Services Support

Centre (BSSC) telephone 1300 658 975 if ACM that is not recorded in the Defence asbestos register has been identified

f. 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.

21. Hazardous Chemicals Officer (HCO) – In the context of this document, the HCO is a person employed or appointed in a Service Delivery Division zone to coordinate asbestos within a defined geographic area. This appointment may be a HCO, Asbestos Officer (AO) or WHS Officer. The HCO is to:

a. provide advice on ACM b. contribute to reviews of this AMP, through the provision of SME advice c. undertake review and provide comment on draft, updated or any other Defence asbestos

policy d. support the PD (DEPU or DEWPO) and the BSM through either leading or

participating in incident investigations and fact finding activities e. support the PD (DEPU or DEWPO) and DWHSPC through undertaking assurance

activities to ensure the integrity of: the asbestos register; asbestos surveys; asbestos re-inspections; and general asbestos management activities on the estate.

22. Employees, Visitors and Third Parties - Employees, visitors and third parties are to:

a. comply with all lawful health and safety instructions b. follow signage directions (including asbestos warning signage and labelling) c. 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

d. avoid creating or increasing any unnecessary risk of health and safety to themselves or others

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

f. report damaged ACM or suspected ACM to occupants in the immediate area, their sponsor/escorting officer and/or the BSM.

SECTION 3 ASBESTOS CONTAINING MATERIAL

23. Asbestos Containing Material (ACM) was used in the Australian construction industry until the Australia wide ban on the manufacture and use of all types of asbestos and ACM took effect in 1990; however, only buildings built post 31 December 2003 are legally assumed to be asbestos- free (buildings built after this date can be presumed to be asbestos free unless there is evidence to the contrary). As many structures and buildings on the Defence estate were constructed prior to 2003, many Defence buildings contain ACM within their fabric. Within these pre-2003 structures, ACM is commonly found in:

https://www.asbestossafety.gov.au/asbestos-information


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a. insulating materials b. lagging material c. electrical backing board d. roofing material e. wall cladding f. eave linings g. ceiling paneling h. air conditioning ducts i. asbestos containing pipes j. Asbestos Contaminated Dust or Debris (ACD) in ceiling and floor cavities.

24. Asbestos in soils (ASBINS) as fibrous asbestos or ACM can be present in (but is not limited to) landfill sites and workplace areas with surface contamination as a result of previous poor demolition techniques. The management of ASBINS is addressed in Part 2 of this AMP.

25. This AMP has been written to ensure the safe management of asbestos on the Defence estate and, pursuant to Regulation 429 of the WHS Regulations, is the official Defence Asbestos Management Plan for the Defence estate.

SECTION 4 GOVERNANCE

26. The management of asbestos on the Defence estate is governed by the Commonwealth Work Health and Safety (WHS) Legislation, the WHS Act 2011and WHS Regulations.

27. 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).

28. State regulations apply to E&IG contractors and sub-contractors who are not Commonwealth Licensees.

29. 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 must be entered into Sentinel irrespective of whether the individual registers their details with the DAHCES.

30. ADF members should also refer to 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.

SECTION 5 SCOPE AND LIMITATIONS 31. E&IG is the Defence Group 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 (including land, buildings, equipment and infrastructure).

http://intranet.defence.gov.au/home/documents/data/ADFPUBS/DHM/volume2/part14/09.pdf

http://intranet.defence.gov.au/home/documents/data/ADFPUBS/DHM/volume2/part14/09.pdf


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Consequently this AMP, as E&IG’s asbestos management plan for the Defence estate, 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.

32. 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 a military platform containing asbestos must create their own asbestos management plan, in accordance with Regulation 429 of the WHS Regulations.

33. 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 6 AIM

34. 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 fibre. This overarching aim is to be achieved by implementing and maintaining the following 8 asbestos management objectives:

a. Objective 1 - To eliminate all very high and high risk instances of ACM from the estate. b. Objective 2 - To develop a safety and environmental incident response plan applicable

to typical instances of asbestos found on the estate. c. Objective 3 - To deliver an effective asbestos management strategy, including

remediation works programs. d. 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 fibre.

e. Objective 5 – To ensure that the asbestos register is up-to-date and accurate, through a robust survey inspection program and the timely entry of asbestos data onto the register.

f. Objective 6 - Ensure Defence meets all of its statutory WHS obligations relating to asbestos and asbestos management.

g. Objective 7 - To provide a consistent and effective approach to the management of ACM in buildings, plant and infrastructure across the Defence estate.

h. 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.

35. 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 7 USERS OF THE ASBESTOS MANAGEMENT PLAN 36. 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


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of this AMP (as either duty-holders or stakeholders) include:

a. Service Delivery Division: (i) Base Support Manager (BSM) and team (ii) Product Directorates (PD) – Estate Upkeep and Estate Works Program Office (iii) Estate and Facilities Services (EFS)

b. Infrastructure Division (ID) (i) Capital Facilities and Infrastructure (CFI) (ii) CFI engaged contractors (iii) Environment and Engineering Branch (iv) Property Management Branch

c. EMOS Contractors and their sub-contractors d. Project Delivery Service (PDS) e. Australian Defence Force (ADF) f. Head of Resident Unit (HRU) g. CIOG h. building occupants i. voluntary staff and workers j. Regulatory Authorities

SECTION 8 MANAGEMENT OF ASBESTOS ON THE DEFENCE

ESTATE 37. The key principles of asbestos management used for making management decisions relating to asbestos on the Defence estate are summarised below:

a. 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.

b. 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.

c. 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.

38. The policy for the management of asbestos in soils is set out in Part 2 of this AMP.

SECTION 9 ASBESTOS SURVEYS AND INSPECTIONS 39. Defence has an obligation under Regulation 422 of the WHS Regulations to undertake the identification of all asbestos on the Defence estate. Defence meets this obligation by undertaking surveys, inspections and incident reporting to identify and record the presence and condition of ACM.

40. Surveying all ACM is to be undertaken by the EMOS Contractor in-line with the Estate Appraisal Contract deliverables and Annex A - Scope of Services – Asbestos Surveys set out in this AMP. The EMOS Contractor is to undertake an annual desktop review of all identified ACM/ACD and assumed ACM/ACD to assess its current condition as it relates to the associated recommendations for control and how these controls are being maintained / implemented.


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Asbestos desktop reviews are to be undertaken in- line with the Estate Appraisal Contract deliverables.

41. The ACM survey and inspection program ensures that all instances of asbestos managed in- situ on the estate are managed according to the risk they pose. This process of ongoing reviews addresses the risks posed by any deterioration in the condition of the asbestos or any other change in circumstances that might affect the risk that the asbestos poses. The Commonwealth representative will assess the completed asbestos survey in-line with the Annex C - Asbestos Survey Services Checklist.

SECTION 10 ASBESTOS RISK ASSESSMENTS 42. All known instances of asbestos on the Defence estate built environment have been assessed by a Certified Occupational Hygienist (COH) or Certified Industrial Hygienist (CIH) who holds an asbestos assessor licence relevant to the State/Territory.4 Risk ratings for each instance of asbestos are recorded in the Defence asbestos register.

43. The factors used to determine the level of risk under the risk assessments conducted by the COH/CIH are:

a. the type of asbestos (friable or non-friable) b. the condition of the asbestos (good condition or poor condition - as ACM in poor

condition is likely to deteriorate into friable asbestos) c. if the asbestos is accessible d. if the asbestos is likely to be disturbed by activities undertaken in the area.

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

a. Very High: The material is either friable asbestos containing material likely to pose a

risk to health from exposure as the material is readily accessible and prone to further disturbance by routine activities, or the material is unsealed friable asbestos material located in air conditioning systems.

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

c. 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.

d. 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 effectively controlled.

45. Risk assessments and corresponding risk control measures are to be reviewed by a COH or CIH if an inspection finds that the controls measures have been ineffective or have failed. Only a COH or CIH can amend a risk assessment recorded in the Defence asbestos register.

46. Risk assessments for asbestos are also to be reviewed when any of the following occurs:

a. there is evidence that the control measures are ineffective or have failed b. a significant change is proposed for either the workplace or for work practices/

procedures relevant to the asbestos risk assessment 4 For work performed in the ACT the COH/CIH must hold an Asbestos Assessors Licence issued in the ACT.


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c. there is a change in the condition of the ACM d. the ACM has been removed, disturbed, enclosed or sealed e. upon confirmation of an exposure or following a dangerous incident (a potential worker

exposure).

47. Revised risk assessments/risk ratings must be supplied to the EMOS Contractor and HCO as soon as possible after they are undertaken, but no later than 14 calendar days after the revision. The EMOS Contractor is to update the Defence asbestos register with the newly supplied documentation/information within 14 calendar days of receiving the information.

48. An asbestos survey of all of the Defence estate is undertaken every 5 years by the EMOS Contractor, in-line with the Estate Appraisal Contract deliverables. The physical inspections involved in the survey must include an assessment of the condition of the ACM and the associated level of risk.

49. The ACM inspection program ensures that all instances of asbestos managed in-situ on the estate are managed according to the risk they pose. This process of ongoing reviews addresses the risks posed by any deterioration in the condition of the asbestos or any other change in circumstances that might affect the risk that the asbestos poses.

SECTION 11 RISK CONTROL MEASURES

50. Each instance of asbestos managed in-situ on the Defence estate needs to have appropriate control measures5 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 Section 10 “Asbestos 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:6

a. 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.

b. 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.

c. 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 Table A1 Grounds Remedial Measures and Maintenance Techniques.

7

5 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. 6 Regulation 36 sets out the hierarchy of controls and the requirement to implement them. Regulation 37 mandates maintaining the control measures required by Regulation 36. 7 Before asbestos/ACM in the soil can be sealed with bitumen or concrete, the requirements of Sub-Regulation 419(5) have to be met, see “Asbestos in Soils”.


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d. 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.

e. 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.

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

51. 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”. 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 upkeep works program.8 Each recommendation must state how the ACM should be managed and the timeframe in which the recommendation needs to be implemented (i.e. remove asbestos within one year or encapsulate immediately etc.).

52. 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 either a COH or a CIH 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:

a. an asbestos survey or inspection is undertaken b. an asbestos incident occurs or controls are assessed as insufficient to control the risk c. there is evidence to indicate that an assessment is no longer valid d. an adverse health monitoring report is received e. there is a significant change in the function or layout of a space to which the assessment

relates f. new information on asbestos is released.

SECTION 12 DEFENCE ASBESTOS REGISTER 53. The Department of Defence utilises the Defence Estate Information System (DEIS) for the management of Defence estate assets. The Defence asbestos register is located on the DEIS and details all known instances of asbestos for each Defence property.

54. The Defence asbestos register records all asbestos data on the estate collected during:

a. asbestos surveys b. inspections c. project works d. Estate Appraisal (EA) activities e. asbestos removal works f. new asbestos finds.

55. Before undertaking any works on the Defence estate which may involve the potential disturbance of ACM, the Defence asbestos register must be checked. It is the responsibility of any contractor undertaking works with the potential to disturb asbestos to obtain a copy of the Defence asbestos register and to check the register as it pertains to their project. It is the responsibility of

8 In accordance with the E&IG Estate Appraisal Policy.


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the project manager who is acting as the point of contact for the works to ensure that the Defence asbestos register is made available to all relevant contractors. The EMOS Contractor will meet this requirement by providing the relevant register information to their trades personnel or sub- contractors as part of their service orders.

56. Where there is objective evidence to suggest that the asbestos register does not accurately reflect the estate’s asbestos footprint in a certain area, material should be tested. Where testing is to be conducted on areas already covered by the asbestos register, justification based on objective evidence must be supplied to justify the testing prior to the testing being conducted.

57. 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. If requested, an E&IG HCO is able to provide advice on how to obtain and interpret the information on the Defence asbestos register.

58. For Defence Protected Network (DPN) users only, the Defence asbestos register can be found via the DEIS link. It is the responsibility of Groups and Services to ensure that any of their personnel who require access to the Defence asbestos register are trained on how to access and use the register. On request, the HCO can provide advice on how to navigate to and within the Defence asbestos register.

59. The Defence asbestos register provides the following information for Defence buildings and/or facilities:

a. the presence or absence of asbestos (recorded in the Defence asbestos register as

asbestos present or No Asbestos Detected [NAD]) b. the location and secondary location of the asbestos c. the type of asbestos material and the quantity d. the condition of the material e. the control measures recommended as a result of a risk assessment f. the status of asbestos labelling at the site (i.e. labels attached or labels required) g. the risk level of the asbestos h. the date that the asbestos was identified i. the accessibility of the material being tested.

60. The Defence asbestos register is linked to associated asbestos documentation, such as work permits, clearance certificates, air monitoring results, survey reports and photos. Asbestos documents are currently recorded against the Environmental Factor Record (EFR) in the Garrison Estate Management System (GEMS).

61. Where there is any ambiguity about the meaning of the information in the Defence asbestos register, a HCO should be contacted for clarification.

62. The Defence asbestos register is maintained and updated by the EMOS Contractor.9 The requirement for timely up-dates to the asbestos register is mandated by WHS legislation10, which requires that Defence maintain an up-to-date asbestos register at all times. The EMOS Contractor is to ensure that:

a. the Defence asbestos register is up to date and accurately reflects the state of buildings,

plant, equipment and facilities across the estate

9 See clauses 3.19.1-3 of Section 1.1 Management, Integration and Coordination Section 1.1 Management, Integration and Coordination Description and Deliverables. 10 WHS Regulation 425(2).

http://drnet/dsrg/GEMS/InterfaceAssets/GEMSGateway.aspx


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b. all instances of identified asbestos materials are recorded in the Defence asbestos register and Contaminated Site Register (CSR) as required, regardless of whom identifies the asbestos

c. changes to asbestos status must be updated in the Defence asbestos register 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

d. all new and updated asbestos documentation must be loaded to Objective and linked to the relevant EFR in the Defence asbestos register by the EMOS Contractor. Documentation may include asbestos work permits, asbestos removal control plans, site barrier drawing, safe work method statement, clearance certificates, traceable waste documentation, updated site services drawings and photos.

63. DEPU is tasked with, and is responsible for, ensuring that the EMOS Contractor is maintaining the Defence asbestos register in-line with both Defence’s legislative obligations and contractual requirements.11 If tasked, a HCO shall undertake independent quality assurance checks and reviews of the currency and accuracy of the Defence asbestos register, as it relates to the state of asbestos on the Defence estate to assist DEPU. DWHSPC will work in conjunction with the HCO to assist DEPU and the Contract Authority to undertake periodic legislative compliance assurance activities over the asbestos register to ensure that the register is legislatively compliant and readily provides all necessary information to users of the register; however, the responsibility for ensuring that the integrity of the Defence asbestos register remains with DEPU and the Contract Authority.

64. The EMOS Contractor is to undertake 5 yearly inspections of known instances of asbestos and desktop inspections of the Defence asbestos register 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.12 DEPU is responsible for ensuring that the annual desktop reviews 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 13 ASBESTOS EDUCATION AND THE PROVISION OF HAZARD INFORMATION

65. All known instances of asbestos on the Defence estate are recorded in the Defence asbestos register. 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.

66. 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.

67. HRU 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. Upon request, the HCO will support the BSM and the HRU in the provision of asbestos hazard information and, where necessary, supply relevant asbestos information regarding facilities and plant.

68. Contractors have the primary duty to ensure that their workers (including sub-contractors)

11 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). 12 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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are trained in the identification, safe handling, and suitable control measures pertaining to the control of asbestos and ACM risks. Contractors must ensure that all of their workers (including sub-contractors) are made aware of any potential asbestos hazards associated with their workplace and work activities.

69. Contractor inductions need to be specific to the hazards associated with their geographic location on a Defence base, as well as the contractor’s activities (i.e. generalised base wide inductions are unlikely to appropriately address hazards associated with contractor activities where the contractor is undertaking asbestos works or asbestos related works).13

70. It is the responsibility of DEPU to ensure, through regular assurance activities, that EMOS Contractor staff and sub-contractors are supplied with relevant information relating to asbestos hazards on the Defence estate.

71. 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.

72. The EMOS Contractor is to ensure the provision of appropriate written asbestos warnings on all Work Orders relating to works that could involve ACM or disturb ACM. Work order warnings and the Defence asbestos register must be provided to both internal contractor personnel and any sub-contracted personnel undertaking works on the estate that could involve ACM or disturb ACM.

SECTION 14 INCIDENT AND EVENT NOTIFICATIONS 73. When an individual suspects that they have been exposed to respirable asbestos fibres, the following process is to be followed:

a. the individual (including contractors) must notify their supervisor or manager through

their normal chain of command or management control system of the suspected exposure;

b. the supervisor or manager checks the asbestos register to see if the suspect material has been previously identified and recorded. If the material has been previously identified, the next step is to confirm whether or not worker exposure has occurred;

c. after checking the asbestos register, if asbestos has not been previously identified, a competent person is required to determine whether the material is, or is not, suspected of being asbestos;

d. the competent person may determine without testing that it is reasonable to suspect a substance is asbestos or contains asbestos. From then, the substance must be managed the same as asbestos;

e. the competent person may also take samples and send them to a laboratory accredited by the National Association of Testing Authorities for analysis and confirmation. Contact details for National Association of Testing Authorities -accredited laboratories may be obtained at http://www.nata.com.au (search for Facilities and Labs/Chemical Testing/Asbestos) or by calling 1800 621 666.

74. After a competent person has determined that a substance is likely to be asbestos or contains asbestos, the potential exposure site must be isolated and preserved to ensure no other person is

13 Beyond the general requirement for the provision of information, instruction and training, pursuant to Regulation 39 of the WHS Regulations, workers undertaking asbestos works or asbestos related works have an additional requirement for information, training and instruction, pursuant to WHS Regulations 445 and 480.


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exposed to the asbestos. Hazard management controls must continue until a competent person decides otherwise, or until a subsequent test by a National Association of Testing Authorities accredited laboratory confirms the substance is not asbestos.

75. Once the presence of asbestos has been determined by a competent person or confirmed by a National Association of Testing Authorities accredited laboratory, the manager must engage a competent person to conduct an initial investigation aimed at determining whether personnel have been exposed to asbestos fibres. The site must be preserved until the investigation has confirmed (or otherwise) the potential for exposure.

76. If asbestos has been identified, the information is to be provided to the EMOS Contractor to update the asbestos register.

77. Exposure to asbestos fibres is a reportable incident. 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.14 Commonwealth employees are only required to notify Comcare of a notifiable event in which they are involved.15

78. Upon confirmation of an exposure or following a dangerous incident (i.e. a potential worker exposure) contractors must undertake the following actions:

a. Immediately notify Comcare of the incident by telephone 1300 366 979 and report the

notifiable incident to the State/Territory Regulator. The site must be preserved until Comcare have conducted an investigation and have released the incident site back into Defence management control;

b. Report the exposure in Sentinel in accordance with SafetyMan – Work Health and Safety Event (Incident) Reporting Policy as soon as is reasonably practicable. The Event report entered into Sentinel will automatically be submitted to Comcare as soon as the ‘submit' prompt has been activated; and

c. Complete the “Follow on Actions” in Sentinel.

79. Defence investigates all work health and safety events to determine the cause or causes of the event and the measures that may be required to prevent recurrence.

80. Contractors are responsible for informing the appropriate PD (DEPU or DEWPO), the PDS, project manager, BSM and HCO as soon as practical whenever:

a. unplanned disturbance to ACM occurs during the course of the contractor’s activities b. unplanned damage to ACM occurs during the course of the contractor’s activities c. an incident that disturbs or damages ACM involves or affects the contractor’s personnel d. any other contractor activities result in persons being exposed or potentially being

exposed to asbestos fibres.

81. Reporting of asbestos incidents to the appropriate PD (DEPU or DEWPO), the PDS, project manager, BSM and HCO should in the first instance be made verbally via telephone; however, all verbal reports must be followed up with a detailed written report within 24 hours of the incident.

14 Contractors are contracted to undertake the notification to Comcare and are legislatively required to also notify the State/Territory regulator, as contractors work under the sate/territory regulator’s jurisdiction. 15 Contractors have dual reporting responsibilities, as they are covered by both the State/Territory legislation and the Commonwealth legislation when undertaking works on the Defence estate. Commonwealth employees are only covered by the Commonwealth legislation.


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82. Notifiable incidents sites must be preserved and made safe until the site is released by Comcare.

83. The appropriate PD (DEPU or DEWPO), the PDS, project manager, BSM and HCO must be informed of any asbestos disturbance or damage incidents, even when the incident is not considered to constitute an exposure (i.e. the incident would not be considered a notifiable event by the Regulator).

84. DEPU is responsible for ensuring that the EMOS Contractor undertakes their reporting and notification requirements. For other contractors, the relevant project manager or PDS is responsible for ensuring that contractors undertake their reporting and notification obligations.

85. HRU are responsible for informing the BSM and HCO as soon as practical whenever suspected ACM has been disturbed or damaged on the Defence estate in the resident unit controlled area, or if an asbestos incident involves resident unit personnel.

86. Where HRU personnel have been exposed or potentially exposed to respirable asbestos fibres, the HRU must ensure that a Sentinel Event is raised for their personnel.

87. If an incident occurs during an “A class” removal activity and air monitoring records respirable asbestos fibre levels above 0.02 fibre/ml, the contractor must notify both Comcare and the State/Territory Regulator immediately, with the exception of WA where only Comcare needs to be notified.16 Following the immediate notification to Comcare and the State/Territory Regulator, the contractor must notify the relevant PD (DEPU or DEWPO) or the PDS or project manager and the BSM and HCO.

SECTION 15 ASBESTOS INCIDENT RESPONSE 88. Potential asbestos fibre exposure incidents require a swift coordinated activity, including making the area of concern safe and delivering timely and accurate information about any potential level of risk to human health to all stakeholders.

89. A WHS Asbestos Event is any accident (including Near Miss Events) or incident that occurs on the Defence estate, which involves any of the following:

a. worker illnesses (i.e. asbestos related illness) b. a dangerous incident which did or did not expose any person to airborne asbestos fibres

above the exposure standard c. exposure of a person to airborne asbestos fibres above the exposure standard d. any other serious asbestos related incident that could put workers at risk.

90. Asbestos exposure is mostly likely to occur where ACM is disturbed through activities such as:

a. routine maintenance b. contractors or visitor activities c. in-ground or above ground excavation d. vandalism or criminal entry e. damage by severe weather conditions (storm/cyclone damage).

91. The following procedure must be followed by all Defence employees and contractors whenever previously unknown of material, dust or debris that is suspected of containing asbestos

16 In accordance with Sub-Regulation 476(b) of the WHS Regulations.


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fibres is detected in the workplace or where ACM is disturbed or damaged:

a. stop work immediately b. isolate the area and restrict access (i.e. seal off, close doors, erect barricades, post signs) c. interrogate the asbestos register to determine if a record exists for the suspect material d. if ACM is recorded on the asbestos register, or if unsure, and there is a potential for the

release of airborne fibres, immediately notify the EMOS Contractor, the HCO and the BSM regarding the location and the nature of the incident

e. upon notification of an incident, the EMOS Contractor is to: (i) recheck the Asbestos register (ii) ensure that the site has been made safe (iii) ensure that the relevant stakeholders have been informed (iv) the EMOS Contractor is then to ensure that all relevant sampling and air monitoring

is undertaken by a suitably qualified Occupational Hygienist or Industrial Hygienist f. For non-EMOS Contractors undertaking the works, the contractor is to ensure that

steps “a” to “d” above and step “g” below are undertaken and that air monitoring and sampling of suspect material is undertaken (sampling and air-monitoring must be undertaken by a suitably qualified Occupational Hygienist or Industrial Hygienist [see section 27 regarding air monitoring])

g. Regardless of the contractor undertaking the sampling and air monitoring (EMOS Contractors or other contractors) there are only two possible outcomes and subsequent procedures for sampling: (i) negative result: if the sample analysis confirms that the suspect material is

‘negative’ for asbestos, the area can be re-occupied and works recommenced following the provision of the test results to the HCO, BSM, EMOS Contractor and the HRU

(ii) positive result: if the sample analysis confirms the suspected material is ACM (i.e. ‘positive’ result for asbestos), then the site is to remain secured until removal/remediation can be arranged (see below for Asbestos Removal/Remediation Works) and clearance certificates supplied to the HCO, BSM, EMOS Contractor and the HRU (see below for “Clearance Inspections and Clearance Certificates”).

92. Relevant E&IG stakeholders who must be informed of asbestos incidents include:

a. Base Support Manager b. HCO c. WHS Officer d. DWHSPC e. Project Manager (DEPU, DEWPO or ID etc.)

93. Other relevant stakeholders that need to be considered and informed of asbestos incidents:

a. ID WHS b. SADFO c. HRU d. Relevant contractor WHS Managers e. Health and Safety Representative (HSR) designated to an affected Work Group f. Unit Safety Representatives

94. This incident procedure is summarised in a flow chart at Annex B.


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SECTION 16 THE ROLE OF ID, BSM, PDS, HRU OR PROJECT MANAGER IN THE MANAGEMENT OFAN ASBESTOS

INCIDENT 95. In the case of an asbestos incident relevant to them ID/BSM/PDS/HRU/Project Manager is to react to the suspected asbestos exposure notification by:

a. Monitoring all the details of the incident provided by the EMOS Contractor using

the Sentinel ‘Event report’. b. Sentinel ‘Event report’ to be completed by the exposed person or their supervisor on

their behalf. c. Engaging with the HCO to provide technical advice and assistance with providing a

coordinated response to the incident. d. Providing feedback to the occupants on the management of the incident. e. Ensuring that appropriate site controls are put in place and that the controls prevent

unauthorized access to the incident site. f. Reviewing the Sentinel ‘Event report’ in order to brief appropriate managers and discuss

the requirement to submit the Sentinel ‘Event report’ to the Director General Work Health and Safety Compensation Branch (DGWHSC), and coordinate with the Public Affairs Division.

g. If required, prepare Part 2 of the Sentinel ‘Event report’ for appropriate managers, and if the Sentinel ‘Event report’ is formally submitted to DGWHSC and Comcare, prepare any necessary response to any relevant Comcare follow-up investigation of the incident (see below section “Asbestos Incident Investigations”).

h. Where requested, the HCO will assist in undertaking management of the incident and subsequent reporting.

SECTION 17 ASBESTOS INCIDENT INVESTIGATIONS

96. It is Defence policy that all confirmed asbestos exposure incidents on the Defence estate must be investigated to examine the cause of the incident, and ensure that appropriate controls are in place to minimise any reoccurrence. The incident investigation report:

a. must be stored in Objective and attached to the Sentinel Event b. must be provided to the HCO and BSM c. must be provided to relevant management lines and stakeholders.

97. It is the responsibility of the controlling authority to undertake investigations, such that:

a. contractors are responsible for investigating incidents associated with contractor- controlled areas or activities

b. EMOS Contractor is to engage with the E&IG WHS team to conduct a joint investigation of any Comcare notifiable events

c. the BSM is responsible for investigating incidents in Base Common Areas or BSM controlled areas, unless the activity associated with the incident is under the control of an HRU or contractor

d. HRU is responsible for investigating incidents associated with resident unit controlled areas or activities.

98. The controlling authority undertaking an investigation must ensure that all relevant stakeholders are informed of the progress and outcomes of the investigation.

99. DEPU or DEWPO respectively are responsible for ensuring that any EMOS or PDS


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contractor investigation is jointly conducted with the zone HCO and that any such investigation adequately addresses the cause of the incident and provides actionable recommendations to ensure future incidents are prevented.

100. The HCO is to provide assistance to DEPU, DEWPO, the EMOS Contractor, PDS, BSM or HRU when requested. The HCO will undertake independent investigations at the direction of E&IG.

SECTION 18 ASBESTOS LABELLING AND SIGNAGE 101. Regulation 424 of the WHS Regulations specifies the requirement for asbestos labelling and signage for ACM material and structures containing asbestos. Regulation 424 stipulates that products containing ACM or products that are assumed to contain ACM must be identified as containing asbestos either with a label or by the use of signage.

102. 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. Where it is not practicable to use labels, signage must be used to provide warning of the asbestos hazard. Where it is unclear which material the label or signage is referring to, the Defence asbestos register should be checked to clarify which material contains asbestos, as labelling is not always placed directly on the ACM material (e.g. labels are often placed on skirting boards to indicate the presence of ACM tiles located under the carpet, or a label may be placed on an adjacent part of equipment when an asbestos gasket is located in an inaccessible or hot position).

103. Labelling and signage predominately works to raise awareness of asbestos hazards and to direct inquires back to the Defence asbestos register for relevant information. To properly understand the location of the asbestos and risks associated with any one instance of asbestos, the on-site labelling and signage needs to be used in conjunction with the Defence asbestos register.

104. All Defence buildings which are either known to contain ACM or are suspected of containing ACM must have a warning sign affixed on all entry ways to the building indicating that the building contains asbestos.

105. The provision of signage and labelling is to be undertaken by the EMOS Contractor either during the asbestos inspection and surveying process or under an associated Estate Upkeep process. The condition and positioning of labels and signs needs to be inspected on as part of the asbestos survey by the EMOS Contractor as part of the Estate Appraisal processes, and any identified deficiencies rectified.

106. During the labelling process, any labels that are found to be damaged, faded, illegible or contain obsolete information must be removed and, where applicable, replaced with new labels.

107. This AMP sets out a labelling protocol that is to be used across the estate. The protocol takes into account the requirements of Commonwealth legislation and the relevant Australian Standard.17 The protocol which sets out the locations and frequency of the required labels is as follows:

a. Walls - Labels are to be placed at the top right corner of each wall of 3 metres or less.

For walls greater than 3 metres, labels to be placed at the top of wall at the ceiling join and then at 3 metre intervals thereafter.

17 Australian Standard Safety Signs for the Occupational Environment AS 1319-1994.


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b. Ceilings - Labels are to be placed at opposite corners adjacent to wall joins for each ceiling of 3 metres or less. For ceilings greater than 3 metres, labels are to be placed on adjacent wall joins at 3 metre intervals thereafter. Where the ACM identified is above the ceiling, this strategy needs to be utilised using specifically worded labels that indicate the asbestos hazard is located above the ceiling.

c. Floors - Labels to be placed at opposite corners adjacent wall joins for flooring of 3 metres or less. For floors greater than 3 metres, labels are to be placed at wall joins at 3 metre intervals thereafter.

d. Roof / Ceiling Void Access Points - Labels are to be applied on each access hatch using appropriately worded labels. The label wording must accurately reflect the situation and will be dependent on whether the hatch itself has been identified as ACM or whether the identified ACM is situated above the hatch in a ceiling space.

e. Door Linings – Labels are to be placed on known ACM containing doors at the top left corner on both sides of the door.

f. Gaskets to Pipe work -Specifically worded labels are to be placed either side of any readily accessible flanges to indicate the presence of any asbestos containing gasket or sealant material.

g. Insulation to Pipe work – Labels are to be wrapped around the pipe at readily accessible locations at 3 metre intervals.

h. Asset Access & Egress Points - Specifically worded asset sticker / metal labels are to be attached to all access and egress points to buildings.

i. Window Sealants - Labels are to be placed on all windows sills adjacent to the ACM. j. Electrical Mounting Boards - Labels are to be placed directly onto the electrical

mounting board such that the label is visible when the cover / door to the box containing the electrical mounting board is opened.

k. Fire Hydrants - Labels are to be wrapped around pipe work adjacent to any hydrant flanges that contain asbestos gaskets.

l. Eave Lining / Fascia - Labels are to 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).

m. Boundary Fences - A pre-defined spray template stating ‘Asbestos’ will be utilised at 5 metre intervals where appropriate.

n. Cable Pits - An aluminium backed label will be affixed to the cover panel of any pits containing ACM.

o. Expansion Joints - Aluminium backed labels need to be affixed at all accessible joint locations.

SECTION 19 ASBESTOS REMOVAL CONTROL PLAN

108. 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.

109. 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


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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.

110. The asbestos removal control plan must include details of:

a. how the asbestos removal will be carried out, including the method, tools, equipment

and PPE to be used b. the asbestos to be removed, including the location, type and condition of the asbestos.

111. 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.

112. The asbestos removal control plan must be endorsed by a Certified Occupational Hygienist (COH)/Certified Industrial Hygienist (CIH) 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 the Defence asbestos register. The asbestos removal control plan must also be provided to the HCO and BSM and any relevant HRU. All documentation is to be recorded on the Defence asbestos register and Objective, as per Figure 1: Communication Process for Asbestos Works. 113. 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.

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


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FIGURE 1: COMMUNICATION PROCESS FOR ASBESTOS WORKS

Information requested by

Project Manager / Asbestos Removal

Contractor

Initial engagement with stakeholders – Point of Contact established

Stakeholder Consultation dates/access/security/specific HRU requirements

Customer Issues

Information

provided to Project Manager/Asbestos Removal Contractor

for scope development

Project Scoping Brief - lock in dates

- address access and security requirements

- address any Unit specific requirements

Feedback to Point of

Contact/Unit

Project start up Stakeholders / HCO / BSM / Asbestos Removal Contractor

Formal notification of works to affected parties. Access to ARCP to be made available.

If removal works are for friable or non-friable >10m² then licensed Asbestos Removalist notifies Comcare & relevant State Regulators within legislated timeframe. Confirm notification to HCO.

Progress updates as required / agreed

Point of Contact / Unit raises a concern with PM / Asbestos Removal Contractor

Provide feedback to Point of contact / Unit

A clearance certificate is issued by the independent hygienist to the removalist or project manager. The clearance certificate is then provided to the building occupants, the BSM and the HCO. The EMOS

Contractor updates the asbestos register.

Handover meeting


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SECTION 20 WORKS THAT CAN POTENTIALLY DISTURB ASBESTOS

115. 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.

116. 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 register. The HCO is also able to provide advice on the Defence asbestos register in order to address any uncertainty.

117. 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.

118. 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:

a. the drilling of ACM b. the sawing of ACM c. screwing into ACM d. sealing, painting, coating of Asbestos Cement Products and/or other forms of ACM e. cleaning leaf litter form the gutters of asbestos cement roofs f. replacing cabling in asbestos cement conduits or boxes g. working on asbestos pipes h. working on electrical mounting boards (switchboards) containing asbestos.

119. 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:

a. decontaminated or a. placed in sealed containers (and used only for asbestos works) or b. disposed of as asbestos waste.

120. 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 21 ASBESTOS PERMITS TO WORK

121. An Asbestos Permit to Work is required if examination of the Defence asbestos register determines that ACM is present in the vicinity of planned works and asbestos will be disturbed.

122. The EMOS Contractor, through the Estate Upkeep product line, is responsible for establishing and maintaining the asbestos permit to work system, including providing permits and


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maintaining an asbestos permit register at establishment level, to be provided to Defence upon request.18

123. The EMOS Contractor will ensure that all Asbestos Permits to Work issued will acknowledge this AMP as amended as well as statutory guidance, legislation and relevant Defence asbestos register extracts. For non-EMOS Contractor asbestos works, where circumstances do not allow for permits to be obtained from the EMOS Contractor, permits can be obtained from the HCO as per Annex E.

124. The following minimum requirements must be included in an asbestos permit to work:

a. service request number or project ID b. detailed location of the work including site & building number/s c. asbestos quantity, type and whether material is friable or non-friable d. EFR number/s e. commencement date and duration of work f. communication plans to show that all stake-holders have been informed of the works

and any necessary controls g. details of the Certified Occupational Hygienist (COH)/Certified Industrial Hygienist

(CIH) supervising the work including full name, company and assessor’s licence number and state issued

h. details of the asbestos removalist including full name, company, licence number and state issued

i. confirmation of notification of asbestos removal work if friable or >10m2 to Commonwealth & State Regulator (where required) including date notified and reference number

j. confirmation that the contractor has received a copy of the Defence asbestos register k. acknowledgment that a copy of the asbestos removal control plan has been received (a

copy of the asbestos removal control plan is to be attached to the permit application) l. the name, email and contact number of the project manager overseeing the work.

125. There are two types of asbestos removal licenses: Class A and Class B. The type of licence required will depend on the type and quantity of asbestos or ACM that is being removed. Workers engaged in asbestos removal work must not be issued with a permit to work unless they hold the appropriate licence for the work being performed.

126. The Asbestos Permit to Work is designed to ensure safe work practices are employed for all asbestos works and/or asbestos associated works. The Asbestos Permit to Work will document what ACM is to be removed, encapsulated and/or otherwise protected, prior to the contracted maintenance or building works proceeding. The Asbestos Permit to Work must have a copy of the asbestos removal control plan attached.

127. When a project involves a team of more than one worker, the person in charge of the team will be issued with an Asbestos Permit to Work. They will be responsible to ensure that their workers are aware of all of their responsibilities.

SECTION 22 REGULATOR NOTIFICATION OF ASBESTOS

WORK 128. In accordance with Regulation 466 of the WHS Regulations, a licensed asbestos removalist engaged to carry out asbestos removal works on the Defence estate, where notification is

18 Clause 3.18.6(d) of Section 1.1 Management, Integration and Coordination. EM00.09 (d) Specifications of Contract Deliverables.


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necessary, is to give written notice to both Comcare and the relevant State Regulator19 at least five days before commencing the licenced asbestos removal works. Comcare do not require notification of non-friable asbestos removal works of less than 10m². 129. Pursuant to Sub-Regulations 466(2) and 466(3) of the WHS Regulations, 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. The Regulator has advised that commercial expediency or convenience does not constitute an emergency removal. Emergency removal works are limited to:

a. 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. b. An unexpected breakdown of an essential service that requires immediate rectification

(gas, water, electricity, sewerage or telecommunication services). c. An unexpected asbestos find that needs to be removed because it poses a safety hazard.

SECTION 23 ASBESTOS REMOVAL WORKS

130. All asbestos removals on E&IG plant, buildings or infrastructure must be undertaken by a licensed asbestos removalist and supervised by a licensed asbestos assessor, regardless of the type or amount of ACM being removed. The type of asbestos removalist required will depend on the type and amount of 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 bonded asbestos in accordance with Regulations 485 and 487 of the WHS Regulations.

131. All asbestos assessors working on the Defence estate built environment must also be COH or CIH (see below “Duties of the Occupational Hygienist”). A COH or CIH includes the employees of a COH or CIH company/business overseen by a qualified COH or CIH.

132. 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:

a. the asbestos removalist holds the appropriate licence20 for the State/Territory in which

the work is to be conducted b. Comcare and State/Territory regulators are notified of licensed asbestos removal

works21

c. an appropriate asbestos removal control plan is provided (see Section 19 Asbestos Removal Control Plan)

d. an asbestos permit to work is obtained prior to the commencement of any removal works (see above “Asbestos Permit to Work”)

e. a communication plan is developed and relevant information is communicated to all stakeholders

f. air monitoring is undertaken by an independent COH or CIH (see Section “Air monitoring for Respirable Asbestos Fibres”)

g. 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

h. that at the completion of all asbestos removal works a clearance inspection is undertaken 19 State variation – WA does not require notification; ACT must be notified for ANY amount including <10m2. 20 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. 21 WHS Regulation 466.


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and a clearance certificate is provided by an independent licensed asbestos assessor/hygienist before the workplace can be reoccupied (see Section 28 Clearance Inspections and Clearance Certificates)

i. 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 up-loading onto the asbestos register (see below “Record Keeping”).

133. 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 24 DEMOLITION WORKS

134. 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.

135. Additionally, a full hazardous materials survey must be undertaken of the proposed demolition works by a Certified Occupational Hygienist (COH)/Certified Industrial Hygienist (CIH) and the hazardous materials survey results for asbestos/ACM are to be compared to the Defence asbestos register.

136. 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 the Defence asbestos register 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.

137. Copies of the hazardous materials surveys are to be forwarded to the EMOS Contractor and the HCO. The EMOS Contractor is to up-load the hazardous material survey onto the asbestos register.

SECTION 25 ASBESTOS WORKS DELIVERED THROUGH THE ESTATE WORKS PROGRAM

138. 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.

139. Both the Estate Upkeep program and the Estate Works Program 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 full 5 yearly surveys and annual desktop reviews through the Estate Appraisal process22 and uploads the information onto the Defence asbestos register and Objective.’

140. As noted above in Section 11 Risk Control Measures, all control measures recorded on the asbestos register as recommended controls necessary to control the risk of asbestos must be up- loaded into the Estate Up-keep program in accordance with paragraphs 61-63 of the E&IG Estate

22 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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Appraisal Policy.

141. 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 register) 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.

142. The NPS contractor, in consultation with each zone’s stakeholders (including, but not limited to, the EMOS Contractor,23 relevant BSM, and the HCO) 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.

143. 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.

144. 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 at Section 9 “Asbestos 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:

a. 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).

b. 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 meets those same requirements).

c. 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.

d. 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.

e. 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).

145. As part of the start-up meeting, contractors are to consult with stakeholders to ensure:

a. building occupants are aware of the works b. any issues and/or safety concerns identified by the occupants have been adequately

addressed in the asbestos removal control plan and that occupants have been provided with a copy of the asbestos removal control plan

c. the contractor/sub-contractor has all necessary access d. any security requirements have been addressed e. there is an agreed start date f. the expected work schedules are known g. the project completion date is known.

23 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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146. Prior to the project start-up meeting, it is the responsibility of the contractor to seek input from all relevant stakeholders (including the HCO and the relevant BSM).

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

148. 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.

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

150. For incidents involving asbestos where the works to remediate are estimated to cost more than $20,000 (excluding GST), the site shall firstly be made safe by the EMOS Contractor, then the EMOS Contractor is to provide an alternative proposal to remediate the asbestos and submit the proposal to the Contract Authority. Remediation in these cases may be directed through the EMOS Contractor under the alternate proposal or be delivered through the EWP.

SECTION 26 DUTIES OF THE COH/CIH

151. The specific duties of the Certified Occupational Hygienist (COH)/Certified Industrial Hygienist (CIH) when supervising asbestos removal/remediation works include, but are not limited to:

a. endorsing the asbestos removal control plan and ensuring the he asbestos removal control plan adequately addresses all foreseeable risks and is compliant with the WHS legislation

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

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

d. undertaking asbestos fibre air monitoring in accordance with the Code of Practice Membrane Filter Method. Air monitoring needs to be undertaken both during the asbestos removal works and as clearance air monitoring after the removal of asbestos

e. undertaking a clearance inspection f. providing either a clearance certificate or partial clearance certification with an updated

risk assessment upon completion of all ACM remediation works

152. Occupational hygienists 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. 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 hygienist in each survey to ensure the recommendations remain relevant.

153. All sampling of asbestos on the Defence estate is to be undertaken by a COH/CIH, 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 up loading onto the Defence asbestos register.


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SECTION 27 AIR MONITORING FOR RESPIRABLE ASBESTOS FIBRES

154. 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:

a. Chrysotile (white) asbestos – 0.1 fibres per millilitre (f/mL) b. Amosite (brown) asbestos – 0.1 fibres per millilitre c. Crocidolite (blue) asbestos – 0.1 fibres per millilitre d. other forms of asbestos or a mixture of asbestos types - 0.1 fibres per millilitre.

155. 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 fibre counts below the detection limits are within normally expected background levels.

156. 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 for a minimum of four hours.

157. 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 fibre is classed as those fibres that:

a. are less than 3 microns (µm) wide b. are more than 5 microns (µm) long c. have a length to width ratio or more than 3:124

158. Air monitoring is required as part of both the incident response protocol and any removal/remediation activities and must be overseen by a Certified Occupational Hygienist (COH)/Certified Industrial Hygienist (CIH) to ensure that the exposure standards are not being exceeded during the activity.

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

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

161. All air monitoring for A Class removals must be carried out by a licensed asbestos assessor, the assessor must also be a COH or CIH.

162. The COH or CIH 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)]. 163. 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

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


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licensed removalist, in accordance with Regulation 476 of the WHS Regulations, must immediately:

a. notify Comcare and the relevant State/Territory regulator b. implement the incident response procedure (see Section 15 Asbestos Incident Response) c. investigate the cause of the release (see above “Asbestos Incident Investigations”).

SECTION 28 CLEARANCE INSPECTIONS AND CLEARANCE

CERTIFICATES 164. Clearance monitoring is essential for asbestos removal works and should be considered as part of the planning of any asbestos removal work. A COH/CIH must verify all asbestos removal work by issuing clearance certificates for both inspections and air monitoring.

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

166. 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/CIH) and a clearance certificate is supplied to the following (as a minimum):

a. EMOS Contractor b. HCO c. HRU d. BSM e. Contract Administrator for CFI Projects

167. 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.

168. 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).

169. 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.

SECTION 29 RECORD KEEPING 170. 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:

a. HCO b. HRU c. BSM


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d. Contract Administrator for CFI Projects e. EMOS Contractor (for entry into the Defence asbestos register).

171. 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 the Defence asbestos register.25 Records that must be maintained and uploaded include documents such as: work permits, 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.

172. 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 the Defence asbestos register as soon as reasonably possible after obtaining the documents and in all circumstances within 14 days.

173. The EMOS Contractor, pursuant to its MIC function, is to coordinate the flow of information from other contractors, including the PDS, CFI and CIOG contractors.26

174. 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.27

SECTION 30 HEALTH MONITORING 175. 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 switchboards.

176. All contractors are to determine whether there is a need for health monitoring for its workers based on:

a. the potential for exposure b. the frequency of potential exposure c. the duration of the work being undertaken.

NOTIFIABLE HEALTH MONITORING REPORTS

177. Health monitoring reports must be provided to Comcare and Defence if the report contains:

25 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. 26 See EMOS Contract Schedule 2, Statement of Works - Estate Maintenance and Operations Services (EMOS) Section 1.1 Management Integration and Coordination Description and Deliverables Clauses 2.1.3, 2.1.4 and 5.1.1(EM00.02). 27 Regulation 50(2) requires that all asbestos air monitoring results are kept for 30 years. Defence requires all applicable asbestos documentation to be kept for that time (including sampling results, clearance certificates, air monitoring results, tipping dockets and any survey results).


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a. 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

b. any recommended remedial measures, including whether the worker can continue to carry out the work.

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

179. Contractors are responsible for notifying respective state regulators as applicable.

ADMINISTRATION OF HEALTH MONITORING RECORDS

180. Health monitoring records are to be retained for a period of 40 years28 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.

SECTION 31 ASBESTOS TRAINING

181. 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 training program is available on Campus.

182. 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:

a. information on the health risks associated with asbestos b. availability of asbestos training on CAMPUS which will provide information on the

health risks associated with asbestos c. information on the presence of asbestos in the Defence estate, including the typical

locations where asbestos may be encountered on that specific base d. roles and responsibilities under this AMP e. information on the Defence asbestos register and how to access the Defence asbestos

register f. direction to this AMP for information on the correct processes and procedures to

follow to prevent exposure.

183. 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.

184. 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. Pursuant to regulation 445(3) of the WHS Regulations 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.

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


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SECTION 32 IMPORTATION OF FILL MATERIAL

185. Imported material, such as fill, is a possible source of asbestos contamination. No individual or organisation is permitted to dump any type of fill on the Defence estate. Fill shall only be brought onto a Defence site as part of necessary works and all fill must be accompanied by the appropriate Defence environmental clearance certificate and the appropriate certificate certifying the fill as clean (i.e. free of asbestos and chemical contaminants) or as suitable for reuse, in accordance with the waste soil classification certificate.

SECTION 33 FIRE DAMAGED BUILDINGS 186. Where a Defence facility or building is damaged or destroyed by fire, any ACM present may have deteriorated due to the heat. ACM that is damaged by fire poses a significantly increased risk of fibre release. A Certified Occupational Hygienist (COH)/Certified Industrial Hygienist (CIH) is to be engaged at the earliest to determine the immediate safety action requirement and to determine the appropriate restricted area distance. In all circumstances of fire damage to a building or structure, access must be controlled and restricted. Unprotected persons must be kept well clear from any fire damaged building where the building is known to contain, or is assumed to contain, ACM.

SECTION 34 UNEXPECTED ASBESTOS FIND WITHIN A

MILITARY PLATFORM 187. Where no other incident response plan exists units should upon the discovery of ACM or suspicion that a military platform contains ACM:

a. secure and isolate the items b. inform the unit chain of command (reporting requirements) c. contact the HCO for assistance (if necessary) d. contact the fleet manager, CASG AITT for inventory e. engage competent person to undertake sampling (sample analysis must be conducted by

a NATA accredited laboratory) f. engage Competent (licenced) Persons to remove confirmed ACM products and

undertake air-monitoring g. dispose of equipment (or parts containing asbestos) in accordance with current

Instructions h. where appropriate fill out Sentinel ‘Event report’.

Note: it is incumbent upon all HRU to ensure that they have an Asbestos Management Plan (AMP) in place to manage any military equipment or items of inventory that they control and

that contain ACM.


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PART 2 ASBESTOS IN SOILS AND SURFACE CONTAMINATION 188. Part 2 of the AMP applies to asbestos in soils (ASBINS) only. It does not apply to asbestos contained in buildings, equipment, structures or pipes in or on the ground. For asbestos in structures, equipment, buildings or pipes in or on the ground, please refer to Part 1 of this AMP.

SECTION 1 LEGISLATION GOVERNING ASBESTOS IN SOILS 189. Asbestos can be contained in soil in the following manner:

a. as Asbestos Contaminated Soil b. as asbestos in soil at an Asbestos Contaminated Site c. as Asbestos Contaminated Waste d. as Naturally Occurring Asbestos in Soil

190. Asbestos contaminated soil, asbestos contaminated sites and asbestos contaminated waste and Naturally Occurring Asbestos in Soil are all predominately governed by the WHS Regulations, in particular Sub-Regulations 419(1) to (5), Regulation 420, Regulations 431-434 and Sub- Regulations 472(1)(a)(b).29 Additional guidance on the management of these sites is provided in:

a. Codes of Practice “How to Manage and Control Asbestos in the Workplace” b. Codes of Practice “How to Safely Remove Asbestos” c. “National Environmental Protection (Assessment of Site Contamination Measure 1999”

(the “NEPM”).

191. Of particular importance in managing asbestos in soil is Sub-Regulation 419(5) that specifically addresses the issue of asbestos contaminated soil and is integral to understanding when and how asbestos contaminated soil can be managed. Sub-Regulation 419(5) works as an exception to the general prohibition on all asbestos works given under Sub-Regulation 419(1). Sub-Regulation 419(5) states:

“Sub-Regulation (1) does not apply to the following:

a. soil that a competent person30 has determined:

(i) does not contain any visible ACM or friable asbestos (ii) if friable asbestos is visible - does not contain more than trace levels of asbestos determined in accordance with AS 4964:2004 (Method for the qualitative identification of asbestos in bulk samples)”31

b. naturally occurring asbestos managed in accordance with an asbestos management plan prepared under Regulation 432.32

29 Note - Regulation 484 parallels the requirements of Regulation 472 in regards to asbestos disposal requirements for asbestos removed during asbestos related works, as opposed to the requirements set out in Regulation 472 for asbestos removal works. However, all asbestos works on the Defence Estate, in accordance with this AMP, must be undertaken as asbestos removal works by a licensed Asbestos Removalist, rather than asbestos related works. Therefore Regulation 472 is the relevant Regulation in regards to disposal of asbestos waste from the Defence estate. 30 It is a requirement of this policy that for the purpose of making the determination of whether or not soil meets the requirements of Sub- Regulation 419(5) a ‘competent person’ is an Occupational Hygienist. 31 The requirements set out in Sub-Regulation 419(5) are explicitly repeated in the National Environmental Protection (Assessment Offsite Contamination Measure 1999) (“NEPM”) at section 4.3 of Schedule B1- Guideline on Investigation Levels for Soil and Groundwater. 32 The requirements set out in Sub-Regulation 419(5) are explicitly repeated in the National Environmental Protection (Assessment Of Site Contamination Measure 1999) (“NEPM”) at section 4.3 of Schedule B1- Guideline on Investigation Levels for Soil and Groundwater.


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192. The Australian Standard AS 4964:2004 (Method for the qualitative identification of asbestos in bulk samples) states at section 8.4:

“For this standard, the term ‘trace asbestos detected’ implies a detection limit of 0.1 g/kg, unless nature and type of sample indicates otherwise….if trace asbestos fibres have not been detected in soils and ores, then this implies that ‘respirable’ asbestos fibres have not been detected”.

SECTION 2 WORKING WITH SOIL SUSPECTED OF HAVING

ASBESTOS CONTAMINATION

193. Where soil is suspected of having asbestos contamination and it is unknown if the soil contains visible ACM, friable asbestos or more than trace elements of friable asbestos33, then the soil must be assumed to contain asbestos and managed accordingly.

194. Where work is being conducted involving soil suspected of containing asbestos, any work on the site which may disturb asbestos or put workers at risk of coming into contact with airborne asbestos fibres, must cease. A Certified Occupational Hygienist (COH), Certified Industrial Hygienist (CIH) or Contaminated Site Assessment Practitioner (CSAP) needs to take a sample of the soil and send it to a NATA accredited laboratory34 for analysis to determine if the soil does contain asbestos material. Until the presence or absence of asbestos is verified, asbestos must be assumed present and the appropriate risk mitigation control measures put into place before any works can re-commence. Appropriate control measures include:35

a. engaging a COH/CIH/CSAP to determine the level of risk and advise on the appropriate risk mitigation controls (i.e. developing a management plan for the site)

b. having the area signed as containing an asbestos hazard c. cordoning off the site d. suppressing dust where necessary (i.e. using wetting agents) e. encapsulation (for interim periods, for instance whilst works are conducted at a site, soil

encapsulation is most effectively achieved using plastic, resins, mastics or flexible plaster)36

f. the use of PPE g. undertaking air monitoring (all asbestos fibre air monitoring shall be undertaken by a

COH/CIH/CSAP - where air monitoring detects any increase in the level of airborne fibres, work must cease and the controls measures need to be reviewed and revised as necessary)

h. consultation process and sharing of information with affected stakeholders.

195. Control measures need to be maintained, until such time as a clearance certificate for the site is supplied or the results of soil testing show that the soil has no detectable signs of asbestos.

196. In some instances where soil is suspected of containing asbestos it may not be practicable to undertake soil sampling for asbestos (i.e. where asbestos contamination covers a large area or where works have to proceed as a matter of urgency). In these circumstances work should proceed under the assumption that the soil does contain asbestos contamination and with the relevant control measures in place. Where soil that is suspected of containing asbestos is not tested, the soil must be disposed of as asbestos contaminated waste (see below regarding disposal of asbestos

33Sub-regulation 419(5) refers. 34WHS Regulation 423. 35Section 7.1 of the Code of Practice How to Safely Remove Asbestos. 36 Section 7.3 of the Code of Practice How to Manage and Control Asbestos in the Workplace.


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waste).

197. For sites on the Defence estate where asbestos contamination is widespread to the point that it has to be assumed that all soils on a particular base is contaminated with asbestos, it may not be reasonably practicable to undertake air monitoring for all works that disturb soil. It is permissible on these sites to undertake works that will disturb soil suspected of containing asbestos contamination without air monitoring IF the contamination typically found on the base is non- friable asbestos debris.

198. In these cases appropriate control measures must be put in place before the works are started to suppress the release of any asbestos fibres. Control measures should include: wetting agents; barriers to isolate the work site; and appropriate PPE. Where material that is suspected of being asbestos / ACD is actually detected during these types of works, work needs to cease until air monitoring is undertaken.

SECTION 3 DETERMINING HOW TO MANAGE ASBINS AT

DIFFERENT SITES

199. Given that each individual site with asbestos contamination will have a multitude of variants which will influence the management decision for that individual site, it is important to determine which of the five types of asbestos in soils situations is being managed. The five types are:

a. undisturbed asbestos in soils (undisturbed soil contaminated with asbestos that is in or

near the workplace) b. disturbed asbestos in soils (disturbed37 soil contaminated with asbestos anywhere on the

estate) c. asbestos contaminated site (area that is not a work site, is undisturbed and is not

reasonably practicable to remediate) d. asbestos contaminated waste e. naturally occurring asbestos in the soil.

200. Each of these five different situations requires specific management strategies, these strategies are set out below.

SECTION 4 DETERMINING MANAGING UNDISTURBED

ASBINS 201. Where asbestos is known to be in the soil at a workplace, but the soil has not been disturbed, the asbestos can be managed as “asbestos in soil” as long as the soil does not contain visible ACM, friable asbestos, more than trace elements of friable asbestos or is naturally occurring asbestos managed in accordance with an asbestos management plan.38

202. For soil that is known to contain ACM/ACD but where the soil has not been disturbed, then the asbestos in the soil can be managed by ensuring that there are no visible signs of ACD or friable asbestos, or if there are visible signs of asbestos that the amounts are only trace amounts.39

37 In this policy “disturbed soil” is defined as soil that has been excavated, dug up or moved post 31 December 2003 or soil that has previously been: stock piled; stored as a contaminated soil pile or pushed into mounds. 38Note the definition of in-situ asbestos under the WHS Regulations is “asbestos or ACM fixed or installed in a structure, equipment or plant, but does not include naturally occurring asbestos’. This means that asbestos in soil can never be managed as in-situ asbestos as the asbestos in soil is not installed or fixed in a structure, equipment or plant. 39 Scientific studies have shown that soil levels of 0.01% of friable asbestos correspond to airborne levels below the detection limit, see the National Environmental Protection (Assessment Of Site Contamination Measure 1999) (“NEPM”) at section 4.7 of Schedule B1- Guideline on Investigation Levels for Soil and Groundwater.


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Where ACM or friable asbestos (above trace amounts) is visible, the asbestos/ACD must be removed by a licensed asbestos removalist. Removal work must be undertaken in conjunction with a Certified Occupational Hygienist (COH)/Certified Industrial Hygienist (CIH) conducting air monitoring. At the end of the removal process a COH/CIH must supply a clearance certificate to verify that no more than a trace amount of asbestos remains. Only the visible asbestos (i.e. the asbestos seen on the surface of the soil) needs to be removed, there is no requirement to excavate or search in the soil to locate buried asbestos that is not visible.

203. Both the licensed asbestos removalist and the COH/CIH used for removal of small amounts40 of asbestos debris on the ground, at undisturbed sites, should be provided under the EMOS contract by ringing the Base Services Support Centre helpline on 1300 658 975 or by raising an AE547 Service Request.

204. The removal of visible ACM / ACD, in the situation of undisturbed ACM or friable asbestos on the surface of the ground will in most cases be conducted via hand-picking. In situations where hand-picking is not a viable remediation option, then the most appropriate remediation strategy needs to be determined based on the advice supplied by the COH/CIH. Appropriate remediation measures need to be determined on a case by case basis given the variables affecting the site.41

205. The use of hand-picking, tilling or screening to manage asbestos in soils should only be used where the licensed asbestos removalist is satisfied that a clearance certificate will be able to be supplied at the end of the hand-picking, tilling or screening. The factors affecting the effectiveness of a hand-picking, tilling or screening will change from site-to-site, but include:

a. the amount of vegetation that might obscure the visibility of the asbestos b. the height and relative thickness of any vegetation/grass c. the size of any ACM pieces d. the accessibility of the area (i.e. steep slope faces may exclude or restrict access).

206. Where it is not possible to obtain a clearance certificate for a site using a hand-picking, tilling or screening the COH/CIH should be recommending alternative remediation strategies (other methods of remediation for asbestos contamination in undisturbed soil include, amongst other things: raking, sealing and encapsulating).

207. In areas where asbestos is managed using hand picking, tilling or screening, but asbestos is known to reappear (usually with heavy rains that weather away the top soil, exposing underlying asbestos debris), hazard signage needs to be erected so as to warn of the asbestos hazard buried in the soils. Signage can be either localised signage if the asbestos contamination is contained to a relatively small area, or the signage can be generalised across the base in situations where asbestos contamination is widely distributed. If required, generalised signage should be prominently displayed at the front entrance to a Base.

208. During excavations works of sites with asbestos contaminated soils, explanatory warning signage needs to be erected around the site to warn those coming onto the excavation site that asbestos could pose a hazard at the site and the control measures that need to be undertaken when entering the site.

209. The issues of reoccurring surface asbestos debris should also be addressed in base

40 Small amounts are those amounts that can be dealt with under $10,000 excluding GST. 41 See section 7.1 of the Code of Practice How to Safely Remove Asbestos.


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inductions. The information supplied in base inductions should include:

a. information on what to do if asbestos debris is detected b. contractor obligations when dealing with instances of asbestos in soil42 c. incident response procedures.

210. An asbestos management program is also required for sites where asbestos surface debris is known to reappear, so as to ensure that controls are maintained and effective (i.e. asbestos is continually removed as it appears, signage is displayed and information is supplied in Base inductions). The management program for reoccurring ground debris should include:

a. inspection of the ground out to 5 metres around the perimeter of all buildings as part of

the asbestos surveys ( surveys are to be conducted by the EMOS Contractor as part of their obligations under the Estate Appraisal Deliverables)

b. risk assessments of all asbestos finds during the inspections undertaken under the Estate Appraisal Deliverables (including for ground debris)

c. removal of all visible ACM or ACD (this is to be undertaken by the EMOS Contractor pursuant to a works request being raised or where debris is detected through survey inspections)

d. updating the Defence asbestos register with locations of asbestos finds and clearance certificates (see Section 9 Recording Instances of Asbestos Contaminated Soil in the Asbestos Register).

211. At sites with asbestos contaminated soil, which meet the requirements of Sub- Regulation 419(5), surface encapsulation can be used to prevent ongoing reoccurring events of visible surface asbestos. Long term encapsulation of asbestos in soils is most effectively achieved using bitumen or cement.43

SECTION 5 MANAGING ASBESTOS IN DISTURBED SOILS

212. Where asbestos is suspected or known to be in the soil and the soil has been disturbed the asbestos can only be managed as “asbestos in soil” IF the soil does not contain visible ACM, friable asbestos or more than trace elements of friable asbestos, or the asbestos is naturally occurring asbestos managed in accordance with an asbestos management plan.44/45/46

213. It is important to note that the management of disturbed ASBINS is fundamentally different to the management of undisturbed ASBINS.47 When managing undisturbed asbestos contaminated soil, it is permissible to simply remove all visible asbestos from the soil surface; however, the effect of Regulation 419 of the WHS Regulations48 means that this same approach is NOT permissible once the soil has been disturbed. Once soil has been disturbed it is only possible

42 Base inductions should reference this policy and any site specific asbestos management plan, so that contractors are made aware of their obligations when dealing with asbestos in soils on the Defence estate. 43 Section 7.3 of the Codes of Practice How to Manage and Control Asbestos in the Workplace. 44 Sub-Regulation 419(5) of the WHS Regulations. 45 Regardless of the definition of the word “fixed” in Sub-Regulation 419(3)(h) soil that is disturbed cannot be managed as in-situ asbestos as the disturbed soil has been moved from the position that it was prior to 31 Dec 2003, thus disturbed soil can only ever be managed as ‘asbestos in soil’ pursuant to Sub-Regulation 419(5), in all other cases disturb soil with asbestos contamination must be managed as asbestos contaminated waste or under a Comcare approved management plan. 46 As noted above the requirements of Sub-Regulation 419(5) are that a competent person has determined that the soil does not contain any visible ACM or friable asbestos; or if friable asbestos is visible, the soil does not contain more than trace levels of asbestos determined in accordance with Australian Standard AS 4964:2004 Method for the qualitative identification of asbestos in bulk samples. 47 This is due to the operation of Sub-Regulations 419(1) and 419(2) of the WHS Regulations. 48 Sub-Regulations 419(1) and 419(2) on S ub-Regulation 419(5).


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to manage asbestos contaminated soil by ensuring that the totality of the material that has been disturbed (i.e. not just the surface layer) contains no visible asbestos/ACM or if there is visible asbestos that the amounts are only trace amounts.49

214. For asbestos contaminated soil that has been disturbed, remediation using hand picking, tilling or screening is not effective except where the quantities of soil are very small. For disturbed soils, remediation usually needs to proceed via sieving or some other method that is capable of removing all visible asbestos/ACD from the totality of the disturbed soil (see below for remediation).

215. The requirement to remove visible asbestos/ACD includes removing visible fragments of non-friable ACM from exposed trench faces and those areas of the site where intrusive works may be carried out (i.e. in areas where utilities are to be installed).

216. Where asbestos contaminated soil has been excavated, and the soil is to be re-used as fill to cover in the hole or trench from which the soil was removed, then the soil can only be used IF:

a. the soil does not contain visible ACM, friable asbestos or more than trace elements of friable asbestos

b. the soil can be remediated such that it does not contain visible ACM, friable asbestos or more than trace elements of friable asbestos.

217. In all other cases where the soil contains visible ACM, friable asbestos or more than trace elements of friable asbestos, the soil must be disposed of as asbestos contaminated waste at a site authorised to receive asbestos waste.

218. Where the soil from an excavation cannot be reused to fill the resulting hole or trench, certified clean fill is to be sourced and used to replace the contaminated waste in filling in the excavation, while the contaminated waste soil is to be removed by a licensed asbestos removalist in conjunction with a Certified Occupational Hygienist (COH)/Certified Industrial Hygienist (CIH) undertaking air monitoring.

219. The cost of dealing with asbestos contaminated soil that is disturbed during works is to be borne by the project undertaking the works. This means that all asbestos related costs, including disposal costs, need to be factored into the projected costs for projects that are undertaken on any sites with potential asbestos contamination.

220. Where the soil contains visible ACM, friable asbestos or more than trace elements of friable asbestos, there are three possible courses of action:

a. the soil is remediated (see Remediation Of Asbestos In Contamination Soils) b. the soil is disposed of at a site authorised by the state or territory Environmental Protection

Authority50/51 to accept asbestos contaminated waste (see contaminated waste below) c. approval to manage the asbestos in a different manner is granted by Comcare.52

49 The term ‘trace amounts’ is as defined by Australian Standard AS 4964:2004 Method for the qualitative identification of asbestos in bulk samples. 50 Section 5. 5 of the Code of Practice How to Manage and Control Asbestos in the Workplace. 51 Section 7.1 of the Code of Practice How to Safely Remove Asbestos. 52 In accordance with WHS Regulation 419(4).


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SECTION 6 REMEDIATION OF ASBESTOS IN CONTAMINATED SOILS

221. Where soil contains visible ACM or more than trace elements of friable asbestos it is important to determine at an early stage whether or not the soil should be remediated or disposed of as asbestos contaminated waste.

222. Undisturbed asbestos contaminated soil remediation can usually be achieved by a combination of hand picking, signage and encapsulation as outline above in the section for managing undisturbed asbestos contaminated soil. For disturbed asbestos contaminated soil effective remediation is much more complex and will normally require an expensive process of sieving the totality of the material.

223. There are many considerations that will determine whether disturbed asbestos contaminated soil can viably be remediated, these include:

a. the amount of soil to be remediated b. the concentration of asbestos contamination c. the condition of the asbestos contaminates (non-friable/friable/large or small pieces of

non-friable material etc.) d. the types of soils that are involved (it is often not viable to remediate hard clay soils that

need clumps of soil to be broken down, as this is likely to result in asbestos fibres becoming airborne during the process)

e. any other contaminates that are in the soil (multiple contaminates may require very complex and expensive processes that make remediation in these situations economically unviable [the process and resultant cost will depend on the other type of contaminates that might be present]).

224. The decision whether or not to remediate disturbed asbestos contaminated soil, needs to be made on a case by case basis, and should be based on the advice received from the Certified Occupational Hygienist (COH)/Certified Industrial Hygienist (CIH)/Contaminated Site Assessment Practitioner (CSAP), as well as the requirements to ensure value for money results for Commonwealth expenditure. In general, remediation is most likely to be viable where there are small amounts of non-friable contaminates that can be easily separated from the soil.

225. Disposal is likely to be the most viable option for:

a. very large amounts of material b. materials with high concentrations of asbestos c. for soil types that are not conducive to asbestos being separated out of the soil matrix, (see

below regarding disposal).

226. Regardless of whether a site is remediated or the asbestos contaminated waste is removed, clearance certificates and any associated soil validation sampling must be supplied once the remediation or removal of asbestos has been undertaken. Copies of the clearance certificates and other documentation must be supplied to:

a. HRU b. BSM c. HCO d. the EMOS Contractor for up-dating of the Defence asbestos register e. ID / CFI / PMCA (if applicable to the activity)


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227. The EMOS Contractor will upload the clearance certificate and other documentation onto the Defence asbestos register and record it against the relevant EFR (where a previously unknown instance of asbestos is being recorded, a new EFR shall be added to the Defence asbestos register by the EMOS Contractor).

SECTION 7 MANAGING AN ASBESTOS CONTAMINATED SITE

228. An asbestos contaminated site is:

a. a site that is not a work site b. a site that has not been disturbed53 c. a site in an area that is not being used as a workplace or to access or egress from a

workplace (i.e. the area is on the Defence estate, but that particular part of the estate is not being accessed and does not have activities taking place on or around it)54

d. where the soil on the site is not reasonably practicable to remediate.

229. Contaminated sites need to be managed in accordance with the WHS Legislation55, and assessed in accordance with the National Environmental Protection (Assessment of Site Contamination) Measure 1999 (NEPM). However, all decisions related to the management of asbestos contaminated sites need to give primary consideration to WHS requirements.56

230. Contaminated sites should be managed in accordance with the site/base environmental management plan. All potential or actual asbestos in soil contaminated sites should be risk assessed by a COH/CIH/CSAP using the Contamination Risk Assessment Tool (CRAT) prior to entry on the asbestos register and the contaminated sites register.

231. Contaminated sites should be cordoned off to prevent inadvertent access and the sites need to have clear asbestos hazard warning signage placed around them to clearly designate the area as containing asbestos and prohibit entry.

232. Contaminated sites need to be recorded on both the DEIS asbestos register and the contaminated sites registers.

233. If work is conducted on a contaminated site, the site becomes a workplace and, in accordance with the WHS Regulations, will immediately need a site-specific asbestos management plan. The site-specific AMP is to be developed by a Certified Occupational Hygienist (COH)/Certified Industrial Hygienist (CIH)/Contaminated Site Assessment Practitioner (CSAP) independent to the contractor undertaking the works.

234. Where works are undertaken on a contaminated site and asbestos is disturbed the disturbed asbestos must be managed either as “asbestos in soil” or as “asbestos contaminated waste”.

235. Under the WHS Regulations, it is not permissible to use an already contaminated site to

53 In this policy “undisturbed soil” is defined as soil that has not been excavated dug up or moved post 01 January 2011 and that has not previously been: stock piled; stored as a contaminated soil pile or pushed into mounds. 54 An area that is being used as a work site cannot be managed as a contaminated site, as the operation of Sub-regulations 419(1) and 419(2) exclude contaminated sites being located at work places where asbestos could disturbed. 55 Note that the NEPM states: “Site assessors should be aware of (and where relevant comply with) the requirements of both national and jurisdictional work health and safety legislation and guidance relating to asbestos and its removal, such as: The national model Work Health and Safety Regulations and related jurisdictional legislation and guidelines How to manage and control asbestos in the workplace Code of Practice (Safe Work Australia 2011a) How to Safely Remove Asbestos Code of Practice (Safe Work Australia 2011b) Code of Practice for the Management and Control of Asbestos in Workplaces [NOHSC: 2018 (2005] Code of Practice for the Safe Removal of Asbestos 2nd Edition [NOHSC: 2002 (2005]”. 56 The NEPM at Volume 1 (sections 1-6, schedules A and B) section 6(11) states: “Human health should be a primary concern when assessing land use and exposure scenarios”.


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dispose of ACM or ACD unless the site is authorised pursuant to the relevant State or Territory Environmental Protection Authority’s Act to receive asbestos contaminated waste.57

SECTION 8 MANAGING ASBESTOS CONTAMINATED WASTE

236. Where asbestos in soil has been disturbed and the soil contains visible ACM, friable asbestos or more than trace elements of friable asbestos then the contaminated soil cannot be treated as “asbestos in soil”, but instead must be either remediated (as above) or treated as asbestos contaminated waste and disposed of at a site authorised by the State or Territory Environmental Protection Authority58/59 to accept asbestos contaminated waste.

237. Disposal of asbestos waste can be achieved one of three ways:

a. disposing of ACM off site, the contaminated waste material must be disposed of at a site authorised by the State/Territory Environment Protection Authority (EPA) to accept asbestos waste

b. disposing of the waste on the Defence estate in a containment cell at a site the State or Territory EPA approves to receive asbestos contaminated waste or

c. disposing of the waste on the Defence estate in a containment cell under Sub-Regulation 419(4), where Comcare approves the method adopted for managing the associated risks.

238. A COH/CIH/CSAP is to assess the friability of the asbestos against the National Environmental Protection (Assessment of site contamination) Measure 1999 (April 2013), Schedule B1. Friable, asbestos / ACD is to be removed by a Class A asbestos removalist and non-friable ACM can be removed by a Class B asbestos removalist; however, in both cases air monitoring must be undertaken. For friable removals air monitoring must be undertaken by a licenced Asbestos Assessor.

239. Once a removal is complete the COH/CIH is to supply a clearance certificate. Copies of the clearance certificates must be supplied to:

a. any impacted HRU b. BSM c. HCO d. the EMOS Contractor (to update the asbestos register).

240. Clearance certificates are to be supplied to the above as soon as reasonably practicable after they have been issued, but in all circumstances within 10 working days.

241. The Defence asbestos register must be updated by the EMOS Contractor with the relevant information and documents relating to asbestos removal and recorded against the relevant EFR. Where a previously unknown instance of asbestos is being recorded, the EMOS Contractor must add a new EFR to the register.

57 Sub-Regulations 472(1)(a)(b) of the WHS Regulations. 58 Section 5. 5 of the Code of Practice How to Manage and Control Asbestos in the Workplace. 59 Section 7.1 of the Code of Practice How to Safely Remove Asbestos.


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SECTION 9 ONSITE DISPOSAL OF ASBESTOS CONTAMINATED WASTE

242. Asbestos contaminated waste can ONLY be disposed of on the Defence estate where either the State or Territory EPA approves the site to receive asbestos contaminated waste or Comcare approves the method adopted for managing the associated risks.60

243. Note the general prohibition on working with asbestos / ACD set out at Sub- Regulations 419(1)(2) includes manufacturing, storing, using, removing, installing, handling,

treating and disposing of asbestos or ACD, thus it is also not permissible to store asbestos / ACD on the Defence estate even if the storage is not ‘classed’ as a disposal solution.

244. The requirements to prepare a site for onsite asbestos disposal will change between different States / Territories, as individual State / Territory EPAs determine the guidelines in their respective jurisdictions. Where on-site disposal is being contemplated advice on obtaining approvals is to be sought from contaminated site consultants in consultation with the State/Territory EPA.

245. Onsite disposal of asbestos contaminated soil will inevitably involve burial. However once the asbestos contaminated waste is buried, it can significantly impact any future development that takes place in that area. Therefore long term future developments must be given strong consideration as part of any decision to dispose of asbestos onsite. Consultation with Regional Planning Officers and Estate Planning Branch in Infrastructure Division needs to be undertaken before any onsite disposal of asbestos contaminated waste takes place.

246. Where on-site burial is undertaken, a site specific asbestos management plan needs to be created and provided to the emos register, hco and bam. The site specific management plan needs to set out all requirements of managing the asbestos containment cell into perpetuity. Further the burial site needs to be recorded on both the asbestos register and the contaminated sites register, so all relevant information and documentation (including clearance certificates, site specific asbestos management plans and approvals) need to be supplied to the EMOS Contractor for up-loading onto the asbestos register.

SECTION 10 MANAGING NATURALLY OCCURRINGASBESTOS IN SOILS

247. Sub-Regulation 419(5)(b)(ii), which works as an exception to the general prohibition on all asbestos works, states:

“Sub-Regulation (1) does not apply to the following:

(b) naturally occurring asbestos managed in accordance with an asbestos

management plan prepared under regulation 432.61

248. This means that where naturally occurring asbestos is known to occur in a workplace on the Defence estate, the asbestos needs to be managed under a site specific management plan.62 The management plan for the naturally occurring asbestos needs to set out appropriate risk

60 Sub-Regulation 419(4) of the WHS Regulations. 61 Sub-Regulation (1) being the prohibition on asbestos works. 62 Regulation 432 of the WHS Regulations sets out a requirement for having a management plan for naturally occurring asbestos and that the plan must be made in accordance with the requirement of Part 3.1 of the WHS Regulations.


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mitigation controls in accordance with the identified risks63 and the level of risk identified under a site specific risk assessment.

249. A risk assessment for a site with naturally occurring asbestos needs to be undertaken by a Certified Occupational Hygienist (COH)/Certified Industrial Hygienist (CIH)/ and should be made in conjunction with air monitoring results to inform the decision maker of the level of airborne asbestos fibres, and therefore the level of risk.64

250. The site management plan for naturally occurring asbestos needs to include information on any work activities dealing with or disturbing naturally occurring asbestos. Further the decisions and reasons for decisions on the management of naturally occurring asbestos (i.e. the reasons for using the risk mitigation controls deemed appropriate for the site) needs to be recorded as part of the asbestos management plan for the site.65

251. For sites with naturally occurring asbestos, it may not be reasonably practicable to undertake air monitoring for all works that disturb soil. In these cases appropriate control measures such as the use of wetting agents, exclusion zones and appropriate PPE need to be put in place before the start of works, so as to suppress the release of any asbestos fibres.

252. The site management plan for sites with naturally occurring asbestos needs to detail incident response procedures and procedures for the identification of naturally occurring asbestos.

253. Any workers potentially affected by working at sites with naturally occurring asbestos need to be trained in the procedures for identifying naturally occurring asbestos on the site and procedures for undertaking works and responding to asbestos incidents.

254. The issue of naturally occurring asbestos should also be addressed in Base inductions. The information supplied in Base inductions should include:

a. information on what to do if natural occurring asbestos is detected b. contractor obligations when dealing with instances of naturally occurring asbestos66 c. incident response procedures.

255. The site specific management plans for naturally occurring asbestos, made pursuant to Regulation 432 are separate from this AMP, which is a management plan made in accordance with Regulation 429 for the management of man-made asbestos.

SECTION 11 RECORDING ASBESTOS CONTAMINATED SOIL

SITES IN THE ASBESTOSREGISTER

256. All asbestos occurrences are to be recorded in the Defence asbestos register. ASBINS located in a contaminated site also need to be recorded in the contaminated sites register.

257. Each ASBINS EFR is to contain all relevant information necessary to readily identify the contamination, including (not limited to):

63 Part 3.1 of the WHS Regulations set out the requirements to identify risks and to manage identified risks in accordance with the hierarchy of controls. 64 Code of Practice - How to Manage and Control Asbestos in the Workplace. 65 Sub-Regulation 432(4)(b) of the WHS Regulations. 66 Base induction and Base WHS Plans should reference this policy and any site specific asbestos management plan, so contractors are made aware of their obligations when dealing with asbestos in soils on the Defence estate.


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e. GPS co-ordinates f. base & site map indicating contamination g. surrounding assets h. relevant imagery.

258. Historic records must be maintained for all asbestos occurrences and all asbestos records need to be kept for 30 years, as set out above in record keeping.

REFERENCES

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

• 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

• Code of Practice How to Manage and Control Asbestos in the Workplace [Safe Work Australia 2011]

• Code of Practice How to Safety Remove Asbestos [Safe Work Australia 2011]

• Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres

2nd Edition, [NOHSC: 3003 (2005)]. INTERPRETATION

259. 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/.

http://www.defence.gov.au/estate%20management/


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TABLE A1 GROUNDS REMEDIAL MEASURES AND MAINTENANCE TECHNIQUES

Remedial Measure/Treatment

Appropriate When: Maintenance Requirements

Grass seeding and/or laying turf Topsoil has become exposed in areas where asbestos materials may be present below clean soil/clean fill. Low traffic areas.

A visual check to ensure grass cover is adequate at 3 monthly intervals. Periodic resting of area may be required.

Topsoil and laying turf Fill material has become exposed / surface eroded where asbestos materials may be present. Low to Medium traffic areas.

A visual check to ensure grass cover is adequate at 3 monthly intervals. Periodic resting of area may be required otherwise turf will require re- laying if the surface becomes eroded. Adequate watering during drought periods (this option may not be suitable during periods of extended drought when reservoir levels drop below 40%).

Mulching (may be in conjunction with laying topsoil).

Fill material has become exposed / surface eroded where asbestos materials may be present. Low to Medium traffic areas.

A visual check to ensure mulch cover is adequate at 3 monthly intervals.

Locally indigenous plant species can be planted in addition to creating a thicker surface layer, extra indigenous plants should be planted so as and to discourage trafficking across the area.

Asbestos materials may be present. Low traffic areas.

Materials should be re-applied if original application becomes displaced or lessens.

Application of geo-fabric and clean fill. Must be used in conjunction with topsoil and turf/seeding or mulching.

Fill materials (containing asbestos) are exposed and high concentrations are expected. Low to medium traffic areas.

As per maintenance requirements for topsoil/turf and mulch. If geo-fabric becomes exposed, clean fill and surface materials must be re-applied. If geo-fabric becomes damaged, consider replacement.

Terracing. Must be used in conjunction with topsoil and turf/seeding or mulching.

Embankments comprising fill materials become eroded exposing fill and asbestos materials.

As per maintenance requirements for topsoil/turf and mulch.

Restricting access using physical barriers such as fencing, walls etc. Must be used in conjunction with signage topsoil and turf/seeding or mulching.

High traffic areas where asbestos materials have become exposed (this measure diverts traffic away from the area).

As per maintenance requirements for topsoil/turf and mulch. Ensure that physical barrier integrity is maintained.

Concrete/bitumen encapsulation.

High traffic areas, high risk of exposure to asbestos materials in the ground.

Visually inspect periodically to ensure surface is as original application.

Removal of asbestos contaminated fill/soil.

Major works are required in areas that require significant excavations.

n/a – asbestos removed


Annex A – Scope of Services – Asbestos Surveys and Inspections

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ANNEX A - SCOPE OF SERVICES – ASBESTOS SURVEYS

SECTION 1 SERVICES REQUIRED

1. The purpose of the asbestos survey 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.

2. The estate asbestos survey requires the EMOS Contractor undertaking the survey to locate and assess 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).

3. The survey is to 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, 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 must be surveyed unless there is 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.

4. The areas, materials and items to be inspected as part of the survey include, but are not limited to:

a. all construction materials that could reasonably contain asbestos, b. roofing material and structures; c. all assessable roof and/or ceiling spaces; d. all other building spaces (including any assessable spaces under building and/or

structures); e. air conditioner ducts; f. finishing materials; g. sound proofing materials; h. electrical switchboards; i. communication pits; j. fixed plant; k. fire doors; l. buried but still visible asbestos waste; m. known landfill, waste piles; and n. the immediate area surrounding each building and structure for a distance of five metres.

5. 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 register

SECTION 2 PARTICULARS

6. The EMOS Contractor is to ensure that the survey is conducted in consultation with either a Certified Occupational Hygienist holding full membership with the Australian Institute of Occupational Hygienists or a Certified Industrial Hygienist with the American Board of Industrial Hygienists or equivalent.

7. The EMOS Contractor must ensure that any personnel undertaking the asbestos survey and any associated sampling are competent with the appropriate qualifications, applicable training



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(including training required for the identification, safe handling of, and suitable control measures for ACM), and possessing the necessary knowledge in building construction and material that is likely to contain asbestos. Appropriate qualifications 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.

8. The EMOS Contractor must ensure that survey teams undertaking the physical appraisals consist of at least two persons.

9. The EMOS Contractor must ensure survey teams wear appropriate disposable protective clothing and personal protective equipment whilst conducting sampling (i.e. full access sampling), this is to minimise the risk of spreading friable asbestos onto personal clothing, footwear and to other areas.

10. When required, the EMOS Contractor must provide appropriate respiratory protective equipment. Further, the EMOS Contractor 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.

11. The EMOS Contractor must ensure that survey sampling personnel have 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.

12. The EMOS Contractor must ensure that appropriate decontamination and disposal arrangements are available and implemented for surveys of areas likely to contain high levels of friable asbestos contamination or where sampling is required. Decontamination and disposal arrangements, including control measures, must 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).

13. The EMOS Contractor is responsible for supplying all equipment required to undertake all aspects of the survey, including, but not limited to: ladders, scissor lifts, cherry pickers to access heights and personal protection equipment for its survey personnel.

14. The EMOS Contractor is responsible for engaging and managing any sub-contractors who may be required to carry out services required to perform the 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 SURVEY PLANNING 15. When undertaking the survey the EMOS Contractor must attend a contract start up meeting with the Commonwealth Representative (DEPU, Project Manager or HCO) to discuss the conduct and expectations of the survey. At the start up meeting the EMOS Contractor is to provide the Commonwealth Representative with a schedule of the survey and a survey plan that outlines how all of the survey 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) and previous asbestos survey reports (if any).



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16. The EMOS Contractor is to provide the survey 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.

17. The EMOS Contractor must ensure 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).

18. For the purposes of survey planning, the EMOS Contractor must carry out a desk top study of all necessary material to undertake an asbestos survey, such as:

a. equipment and materials to be used; b. previous asbestos survey reports; c. site histories for information on possible sources of asbestos contamination; d. current and where appropriate past asbestos management plans and asbestos registers; e. building plans (if available, as these are especially useful for identifying any hidden

voids) f. consideration of current and past ACM removal projects; g. 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

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

19. The EMOS Contractor and the occupational hygienist (or equivalent) engaged by the EMOS Contractor shall develop a survey plan from the available information. The EMOS Contractor is to provide the Commonwealth Representative with the survey plan for endorsement prior to any physical inspection taking place. The survey plan needs to include:

a. all buildings, structures, fixed plant and workplaces to be included in the survey; b. all buildings, structures, fixed plant and workplaces to be excluded from the survey (and

the reason each building or structure is being excluded); c. information on the type/level of survey that will be conducted on each of the

buildings/structures (i.e. first time visual inspection, visual re-inspection, limited access sampling, full access sampling);

d. 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 inspections;

e. proposed plans for managing access to inaccessible or secure areas; f. the methodology for recording and presenting survey results, in particular data for the

asbestos register and the survey report in accordance with the Defence Estate Quality Management System (DEQMS) Spatial Data Management Plan (SDMP);

g. the sampling methodology, numbers of samples and arrangements for making good any destructive access damage; and

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

20. Before commencing the asbestos survey, the EMOS Contractor must provide to the Commonwealth Representative and have endorsed by the Commonwealth Representative a risk assessment and a safe work method plan endorsed by an occupational hygienist or equivalent. The safe work method plan must address all of the potential risks of injury or harm to survey personnel and building occupants.



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21. 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 must be included in the survey until such time as the correct asbestos status of the building is determined.

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

23. The EMOS Contractor needs to make provision for the Commonwealth Representative to undertake whatever assurance activities on the conduct of the survey that the commonwealth representative deems appropriate. Assurance activities will typically be achieved by two Commonwealth observers joining the survey team and ensuring that the 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.

SECTION 4 SURVEY PHYSICALINSPECTIONS 24. The EMOS Contractor must undertake the survey physical inspections in accordance with the approved plan made in-line with the Survey Planning section above.

25. As many Commonwealth properties have been surveyed previously, the survey will 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 surveys. Surveys have been conducted on the Defence estate regularly since 1998.

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

a. 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;

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

c. review of the existing asbestos register, previous survey reports and visual re- inspections of identified ACM and presumed ACM found in earlier surveys to confirm the data recorded on the 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 up-dated to reflect any changes in the condition of the asbestos;

d. 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.

27. The EMOS Contractor must check 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 EMOS Contractor 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 EMOS Contractor 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



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could contain asbestos have not been sampled, the EMOS Contractors needs to ensure that the materials are sampled.

28. In conducting physical survey inspections of buildings, structures and/or equipment the EMOS Contractor 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 2.3), are inspected.

29. The EMOS Contractor must ensure that signage and labelling is correct and in place as part of the inspection and rectify any signage or labelling issues identified in accordance with the Singing and Labelling section below.

SECTION 5 SAMPLING PARTICULARS

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

31. Where the EMOS Contractor is taking a representative sample the EMOS Contractor must ensure that the sample taken is representative of the whole area that is being tested (this is to be achieved by visually inspecting the whole area to ensure the material is uniformly the same). Materials are considered to be uniformly the same if they appear to be the same (having the same style, (where relevant shape/size), colour, thickness, texture and composition). The EMOS Contractor is to ensure that samples numbers and locations are taken in accordance with the table below.

Product/material

Number of proposed samples

Spray coatings, encapsulated sprays & bulk materials

It can be assumed that asbestos will be distributed evenly throughout the material. Usually two samples if taken at either end of the material. Repairs and patches will require additional sampling. Over spray contamination/debris at such locations will contain similar material.

Pipe/thermal insulation

The number of samples may be determined by any change in colour, texture, size or evidence of repairs. Where plant rooms are due for complete refurbishment, one sample may be sufficient to deem an entire room as containing asbestos. Conversely, several samples may be required to prove that all insulation is asbestos free.

Insulating board/ceiling tiles

One sample per room or every 25 m2 and one representative sample of each type of panel if replacement tiles are evident. To prove that all material is asbestos free, the EMOS Contractor should, where possible, check the hidden side of tiles/boards to ensure there are no variations in the material.

Asbestos cement materials

For health and safety reasons, only limited sampling is required to prove an assumption that a corrugated ‘cement’ roof on an older building contains asbestos. One sample is required of each type of product (gutters, down pipes). It may be necessary to take samples of replacement non- asbestos fibre cement sheets to prove that the material is asbestos free.



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Product/material

Number of proposed samples

Floor tiles (typically contain low percentage of asbestos)

A single sample approximately 100 m2 where tiling is uniform or a single sample for each different type of tile present.

Other materials

Distinct types of materials require one sample from each separate source.

32. All sampling work must be performed according to the procedures defined in the risk assessment conducted during the survey planning stage and the requirements of WHS Legislation.

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

a. Personnel undertaking the sampling must wear the appropriate personal protective

equipment. b. Entry to the sampling area by personnel not connected to the survey must be restricted

and warning notices posted or physical barriers installed. c. Sampling should not occur in occupied workplaces and if necessary arrangements for

sampling should be made for periods of minimal workplace occupation. d. 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).

e. Samples must be individually sealed in their own container. f. 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.

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

34. Where the EMOS Contractor is unable to visually view the material being sampled over the whole of the area, which the sample is representative of (e.g. in circumstances such as vinyl floor being covered by carpet and obscuring the ability of the EMOS Contractor to view the vinyl cover being sampled), then the EMOS Contractor must ensure that at a minimum the EMOS Contractor checks each of the corners of the area, which is to be represented by the sample being taken, to ensure that the material is uniformly the same over the whole space.

35. Where different materials are detected in the same area, each of the materials that reasonable could contain asbestos must be tested. Where samples are taken the EMOS Contractor is to confirm in the comments section of the register, one of the following:

a. that the whole area that the sample relates to was visible; or b. that each corner of the space was checked for consistency of the material; or c. that a sample was taken for each of the different materials identified.

36. There is no need to collect samples from known ACM (proven through laboratory analysis) or from materials that have previously being tested and shown to contain no detectable asbestos, unless there is justification to believe that the previous testing was not correct. Testing of the previously tested materials needs to be justified, and written approval for such testing must be sought and obtained by the Commonwealth Representative.



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37. All samples and the sample sites must be labelled with a unique identifier that is recorded in the survey documents and site plans so that the origin of the samples can be traced. All sample numbers are to be recorded against the relevant EFR number in the Asbestos Register.

38. All sampling will be performed in accordance with Australian Standard AS 4964-2004 Method for the qualitative identification of asbestos in bulk samples. The EMOS Contractor must ensure sampling is conducted by Competent Persons who have the necessary field experience and whose names have been provided to the Commonwealth Representative, prior to sampling. Any damage to ACM / ACD must be minimised and repaired.

39. Without limiting any applicable standards, samples should:

a. be representative of the ACM / ACD b. include a full cross section of the material (through the entire depth) c. also include a sample from any repaired or patched areas d. preferably weigh about 5-100 grams e. be placed in a sealed labelled container showing the specific location from where it was

obtained

40. The EMOS Contractor is to ensure that a complete sample history is recorded in the survey report. 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.

41. 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’.

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

43. 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. 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.

44. Dust sampling can only be undertaken if approved in writing by the Commonwealth Representative. When undertaking dust sampling, dust must be collected from a 10 x 10cm² area by scraping the dust into a clean paper sheet with a business card or similar. The paper sheet is then to be folded to confine the collected dust and then placed into a zip-lock plastic bag for later analysis. Dust will not be placed directly into a plastic bag unless the quantity is more than approximately 10g in weight.

45. 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. Dust on surfaces can be collected only in rare circumstances; the decision to take dust samples must be formally justified.



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46. 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.

47. 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.

48. 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.

49. 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.

SECTION 6 RISK ASSESSMENT

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

51. The factors used to determine the level of risk under the risk assessments conducted by the COH/CIH are:

a. the type of asbestos (friable or non-friable); b. the condition of the asbestos (in good condition or poor condition); c. whether or not the asbestos is accessible; d. whether the asbestos is likely to be disturbed by activities undertaken in the area.

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

a. Very High: The material is either friable asbestos containing material likely to pose a

risk 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.

b. 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.

c. 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.



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d. 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.

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

SECTION 7 DETECTION OF VERY HIGH OR HIGHRISK

ASBESTOS 54. If any high risk or very high risk instances of asbestos are identified during the survey the EMOS Contractor must make the area safe and report this to the Commonwealth Representative immediately. The EMOS Contractor must also notify the Commonwealth Representative of any immediate extra safety or protective measures required to manage the high risk or very high risk instances of asbestos identified.

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

SECTION 8 SIGNAGE AND LABELLING

56. The EMOS Contractor is required to return to each site once laboratory results are known to affix asbestos warning labels/signs to all proven asbestos materials and to the entries ways of any buildings with ACM (in accordance with the AMP labelling protocol). The EMOS Contractor must also remove any erroneously placed or obsolete labels from material that has been proven not to contain asbestos.

57. The EMOS Contractor must ensure that asbestos warning signs are attached, in accordance with the labelling protocol set out in the AMP, to all building entry ways, 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 register. Where the EMOS Contractor identifies that a building does not have the required signage the EMOS Contractor is to immediately rectify this non- compliance by attaching a compliant asbestos warning sign (in accordance with the requirements of the labelling protocol set out in the AMP).

58. The EMOS Contractor must ensure that all warning labels are affixed, in accordance with the labelling protocol set out in the AMP, to all material containing ACM that is noted on the register, whether or not the ACM has been newly identified or was previously noted on the register. Where the EMOS Contractor identifies that a building does not have the required labelling they are to immediately rectify this non-compliance by attaching compliant asbestos warning labels as required (with the requirements being in accordance the labelling protocol set out in the AMP).

59. All asbestos hazard labelling is to be attached in accordance with the requirements of the WHS Legislation and the AMP labelling protocol. The EMOS Contractor is to 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 labels or signs do not meet these requirements the labels or signs must be replaced by the EMOS Contractor.

60. In the case of presumed ACM, the EMOS Contractor must ensure that asbestos warning signs are affixed in rooms where it is presumed to be present. This is to be done in accordance with the



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labelling protocol set out in the AMP. The EMOS Contractor must also ensure that signage is affixed to the building entry ways, 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 EMOS Contractor must ensure that asbestos warning signs are affixed adjacent to the space where asbestos is presumed to be present.

61. 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.

62. 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.

63. All labels and signs to be used during the survey are to be supplied by the EMOS Contractor.

SECTION 9 UPDATING THE ASBESTOS REGISTER WITH THE

SURVEY DATA 64. The EMOS Contractor must prepare an up-dated and accurate asbestos register that includes all of the up-dated information gathered from the survey and all the results of sample testing.

65. The format and terminology used in the register must be consistent with the asbestos register within the Defence Estate Information System.

66. An occupational hygienist or equivalent must prepare a risk assessment and control measure for each identified and presumed asbestos material and these must also be recorded on the register.

67. Unless notified otherwise by the Commonwealth Representative, fields for the bulk data upload tool must include a minimum of the following:

a. Exact location (Commonwealth location reference); b. Asbestos present – yes/no/presumed/post 31 December 2003; c. Date of inspection; d. Date of re-inspection; e. Name, qualifications/experience & company of person conducting the survey who

carried out inspection; f. Name, qualifications and experience of supervising occupational hygienist; g. Asbestos application – acoustic insulation, ceiling lining, decorative coating, eaves

(including surface treatment or equipment); h. Material description - Generic ACM (Bitumen membrane, Millboard, debris, see

Appendix 1) or generic non-ACM (brick, masonry, concrete, metal); i. ACM type (friable, bonded); j. ACM condition (sealed, unsealed, weathered, mixture); k. ACM control (remove, encapsulate, leave & manage) – this needs to include appropriate

timeframes for the implementation of the recommended controls; l. Warning labels (labels affixed, labels required, labels removed); m. Extent of product (area, volume); n. Laboratory details - (Laboratory name, NATA Registration Number); and o. ACM Analysis results – (sample ID number, sample result - amosite, chrysotile,

crocidolite); p. Accessibility of the material.



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68. 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 survey must ensure that there are no blank data fields in the register for mandatory fields such as location, status or material inspected. Fields containing comments such as “to be determined” or “unknown” are completely unacceptable as the survey needs to have determined the data for each of the different aspects of each of the EFR. 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.

69. Presumed status will only be acceptable on an EFR where it is also recorded that the material in question is not assessable (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 survey taking place, the register records presumed asbestos in accessible areas, the EMOS Contractor must determine the status of the asbestos by either:

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

b. undertaking physical inspections 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.

70. 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.

71. At the completion of the survey all labels that need to be affixed and all labels that need to be removed must have been affixed or removed accordingly. 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 survey.

72. 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 register.

73. The findings of the asbestos survey inspection and the results of the analysis for any samples collected during the survey must be presented in the required format prescribed in the GEMS Data Load (GDL) – the prescribed GDL is to be up-loaded to the Defence asbestos register by the EMOS Contractor.

74. The format for the register up-date must be in the form required to allow the data to be up- loaded into GEMS.

SECTION 10 SURVEY REPORT

75. The EMOS Contractor must prepare a written final asbestos survey report containing the following information within one month of the inspection date:

a. Executive summary; b. Statement detailing who commissioned the survey report and the purpose of the report; c. Identity of Facility, structures, fixed plant and workplaces surveyed;



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d. Dates of inspection, identity of person conducting the survey and date of report;

e. Scope and extent of asbestos survey;

f. Applicable disclaimers or limitations detailing any area not inspected and the reason those limits prevented the survey been conducted in those areas;

g. Methodology including steps undertaken in safety planning, sampling, inspection and analysis of samples collected;

h. Risk assessment (the risk assessment report prepared by an occupational hygienist or equivalent);

i. Summary of findings; j. List of significant findings requiring immediate attention; k. 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);

l. Marked up building plans showing the location of each instance of asbestos; m. Photos of all identified and presumed instances of ACM; n. NATA endorsed certificates of analysis and associated worksheets; and o. any other information that is required by Defence to ensure the Commonwealth's

compliance with the WHS Legislation.

76. The survey report risk assessment should take into account information derived from the asbestos survey and any subsequent analysis results in particular:

a. The type and condition of the ACM or presumed ACM (loose insulation, spray coatings,

friable, bonded); b. The location (likelihood of damage, weathering); c. Overall work practices (including planned activities) at the location and likelihood of

disturbing the ACM; and d. any information that may be relevant for the purposes of Defence compliance with WHS

Legislation.

77. The survey report risk assessment 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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Annex B – Asbestos Incident Response

ANNEX B - ASBESTOS INCIDENT RESPONSE


Annex C – Asbestos Survey Services Checklist

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ANNEX C - ASBESTOS SURVEY SERVICES CHECKLIST

ESTATE & INFRASTRUCTURE GROUP

ASSURANCE CHECKLIST - ASBESTOS SURVEY SERVICES

Site inspected:

Date/s of inspection:

Lead Inspector:

Inspection Team:



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Introduction

The asbestos survey is the Estate & Infrastructure Group’s (E&IG) chief means of ensuring that the asbestos register is accurate and up-to-date. The survey ensures that the data in the register is reflective of the state of in-situ asbestos being managed across the Defence estate. The survey is essential to enable the correcting of any mistakes on the register and to up-date the register with information on in-situ asbestos as it ages and possibly deteriorates in condition overtime. For this reason the survey is essential for maintaining Defence WHS obligations pursuit to Regulations 34-38 of the WHS Regulations, which requires Defence to: identify hazards; implement risk mitigation controls in accordance with the hierarchy of controls; maintain the implemented risk mitigation controls; and periodically review the implemented risk mitigation controls.

Asbestos Survey Assurance Checklist

The Asbestos Survey Assurance Checklist is for use by the Commonwealth Representative assessing the processes and outcomes of the asbestos survey. The checklist is designed to assist the Commonwealth Representative to ensure WHS Regulatory compliance and compliance with the Asbestos Survey Scope of Works.

This assurance tool has been derived from the:

• Work Health and Safety Act 2011 (Cth) (WHS Act); and • Work Health and Safety Regulation 2011 (Cth) (WHS Regulations) • The Codes of Practice “How to Manage and Control Asbestos in the Workplace” • The Codes of Practice “How to Safely Remove Asbestos” • The E&IG Asbestos Management Plan (AMP). • The AMP Asbestos Survey Scope of Works.

The checklist requires a Non-Conformance, Evidence of progress, Conformance, Not Verifiable or Not-Applicable response to each inspection question. A compliance level is to be entered once the evidence has been assessed.

Please note that you will need to input the code for findings as follows:

• 0= Non-Conformance • 1= Evidence of progress • 2= Conformance • 3= Not Verifiable • 4= Not Applicable



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ASSURANCE CHECKLIST - ASBESTOS SURVEY SERVICES

ASSURANCE CHECKLIST

Business unit

Site

Location

Date of inspection

Lead Inspector

Name: Signature:

ASBESTOS COMPLIANCE RATINGS Non Conformance = 0, Evidence of progress = 1, Conformance = 2, Not verifiable = 3, Not applicable = 4 The inspector must make a judgement on the evidence provided to determine the finding on the level of conformance. A ‘conformance’ response can only be allocated if the inspection criterion is fully satisfied. The inspection criterion is satisfied by sighting the evidence and recording an asbestos assurance rating score and supporting details in the ‘comments’ column. If the criterion is not satisfied, it will be assessed against the other ratings with supporting 'comments’ and details listed in ‘action items’ columns.



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ASBESTOS SURVEY ASSURANCE CHECKLIST

Inspection Criteria

Applicable Legislation

Policy / Procedure

Title

Evidence

Compliance

Rating

Comments

Action

No.

Action Description

Survey Scope

(a) Does the survey schedule encompass all of the relevant buildings, structures and fixed plant within the state / territory?

All the buildings and structures in the state / territory need to be considered in the planning of the physical inspection schedule for the survey, even if the building or structure is not ultimately included in the schedule due to being an excluded building or structure.

Reg 422, Reg 426 and Reg 38 Paragraph 2.2 of the

Asbestos Survey Scope of Works.

(b) Can all the buildings left out of the physical inspection schedule for the survey be accounted for as not requiring inspecting (i.e. the building or structure was build post 31 Dec 2003 or falls under another exclusion category, which exempts it from inclusion in the survey schedule).

Reg 425(4) and Reg 425(6) Paragraph 2.2 of the


(c) Does the survey inspection schedule include the surrounding area around all buildings and structures that are to be inspected?

The area around each building and structure is to be inspected for a distance of 5 metres?

Reg 422 Paragraph 4.5(d) of the Asbestos Survey Scope of Works.



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Inspection Criteria


Policy / Procedure

Title

Evidence

Compliance

Rating

Comments

Action

No.

Action Description

Particulars

(a) Is the survey being conducted in consultation with either a Certified Occupational Hygienist or an Occupational Hygienists?

Paragraph 3.1 of the Asbestos Survey Scope of Works.

(b) Do the personnel undertaking the survey hold relevant qualification and/or have the relevant experience / training to undertake the survey?


(c) Has the EMOS Contractor ensured that all the necessary safety tools and equipment (including appropriate PPE) is supplied?

Reg 39 Paragraphs 3.4-3.9 of the Asbestos Survey Scope of Works.

Survey

(a) In conducting the physical inspections for the survey, has the EMOS Contractor ensured that all of the relevant construction materials, comprising the buildings and structures have been checked?

Checking of materials is predominately to be achieved using visual inspections, but will also include sampling where required.

Regs 422 and Reg 423 Paragraphs 2.3 and 5.5

of the Asbestos Survey Scope of Works.



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Inspection Criteria


Policy / Procedure

Title

Evidence

Compliance

Rating

Comments

Action

No.

Action Description

(b) As part of the survey inspection activities are all areas surrounding buildings being checked by the EMOS Contractor?

The surrounding distance around building and structure being checked should be a distance of at least 5 metres out from each building / structure.

Reg 422 of the WHS Regs Paragraph 2.3(n) of the


(c) As part of the survey inspection activities are all areas that are possible to access being accessed?

Reg 422(2)(b) of the WHS Regs Paragraphs 2.3 and 5.5


(d) Are all inaccessible areas, where it is reasonable to believe that asbestos could be present, being recorded on the asbestos register as inaccessible and recorded in the status field on the register as being “presumed asbestos” as part of the survey?

Reg 422(2)(b) of the WHS Regs Paragraphs 2.3 and 5.5


Sampling and sampling procedures

(a) Was all necessary sampling undertaken to determine the presence or absence of asbestos (sampling should take place for any material that it is reasonable to believe could contain asbestos and where sampling has not previously taken place)?

Reg 425 and Reg 426 Paragraphs 6.1-6-12, of the Asbestos Survey Scope of Works.



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Inspection Criteria


Policy / Procedure

Title

Evidence

Compliance

Rating

Comments

Action

No.

Action Description

(b) Was all sampling undertaken in-accordance with Table 6.2 of the Scope of Works?

Regs 34-37 Paragraphs 6.1-6-12, of the Asbestos Survey Scope of Works.

(c) When a sample was taken, did the sampler ensure that the material was homogenous and that a sample was taken for each different material in an area that had not previously been sampled and that could contain asbestos?

Regs 34-37 Paragraphs 6.1-6-12, of the Asbestos Survey Scope of Works.

Data collection

(a) Are there any data cells on the asbestos register still showing data cells with the status – “To be determined”?

At the end of the survey there should be no data cells with a status recorded as “To Be Determined”.

Reg 425 and Reg 426 Paragraphs 6.1-6-12, of the Asbestos Survey Scope of Works.

(b) Are there any data cells on the asbestos register still showing cells recorded as “Unknown” or any similar type of unusable status?

At the end of the survey there should be no data cells with the status recorded as “Unknown” and/or with any type of similar unusable status.

Reg 425 and Reg 426 Paragraphs 5.3 and 10.4 of the Asbestos Survey Scope of Works.



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Inspection Criteria


Policy / Procedure

Title

Evidence

Compliance

Rating

Comments

Action

No.

Action Description

(c) Are there any data cells in the “location” fields or “asbestos status” fields on the asbestos register still showing blank cells?

At the end of the survey there should be no data cells in the “location or “asbestos status” fields that are blank.


(d) Has the asbestos register been up-dated with the data from the survey as well as data obtained from other parts of the EMOS Contractor activities including Estate Appraisal processes and all relevant up-loads of project data?


(e) Does the asbestos register have all the correct documents attached, such as clearance certificates and tipping dockets (including documents from all the projects that must have data up-loaded)?

Paragraphs 5.3 and 10.4 of the Asbestos Survey Scope of Works.

(f) Are there any EFR with a status of “presumed asbestos” where the material presumed to be asbestos is accessible?

The presumed status should only be used where material cannot be accessed and tested.

Reg 466 Paragraphs 68 and 69 of the Asbestos Survey Scope of Works.



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Inspection Criteria


Policy / Procedure

Title

Evidence

Compliance

Rating

Comments

Action

No.

Action Description

Register up-dates

(a) Has the up-dated register been up-loaded onto GEMS?


(b) Has each EFR had the correct information entered for the relevant fields including: location, status, date of inspection, material application, ACM type, ACM condition, ACM condition?

Reg 466 Section 22 Paragraph 120(b) of the AMP - Requires the Contractor to notify the relevant regulators prior to commencing asbestos removals of friable asbestos and /or ACM (greater than 10 square metres).

c) Has the recommendation field on all EFR with asbestos noted as present in the “asbestos present” field been filled out to accurately reflect the required controls to safely manage the ACM?

Do all recommendations have an associated timeframe in which the recommendation is to be completed

Have all of the recommended controls been appropriately actioned by works requests being raised or projects being created in the estate up-keep schedule?

All EFR that record asbestos as being present must have a recommended control with an appropriate timeframe in which to implement the control and these controls must be up-loaded into the estate up-keep works schedule.



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Inspection Criteria


Policy / Procedure

Title

Evidence

Compliance

Rating

Comments

Action

No.

Action Description

(d) Has the condition field of all EFR with asbestos noted as present in the “asbestos present” field been filled out to accurately reflect the current condition of the ACM on the estate?

The condition field must be filled out for all EFR which record asbestos as being present.

(e) Have all the building and structures on the Defence estate been accounted for by the data going into the asbestos register? Even buildings and structures that are excluded from the physical survey, such as buildings built post 31 Dec 2003, need to be accounted for.

(f) Do all the buildings and structures excluded from the physical survey have a relevant exclusion status recorded against the relevant ERF no (i.e. an exclusion status such as post 31 Dec 2003)?


Asbestos Incident Response

(a) Have all high and very high level risks identified in the survey been made safe and immediately reported to the Commonwealth Representative.

S 46 of the WHS Act Paragraph 8.1 of the Asbestos Survey Scope of Works.



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Inspection Criteria


Policy / Procedure

Title

Evidence

Compliance

Rating

Comments

Action

No.

Action Description

(b) Were all high and very high level risks instances of asbestos identified and reported followed up with a written notification within 48 hours of the risk being identified?

S 46 of the WHS Act Paragraph 8.2 of the Asbestos Survey Scope of Works.

Asbestos Labelling and Signage

(a) Did the EMOS Contractor ensure that all asbestos signage was affixed on the relevant external entries to any buildings containing asbestos, in accordance with the AMP labelling protocol?

Reg 424 Paragraphs 9.1, 9.2 and 9.4 of the Asbestos Survey Scope of Works.

Paragraph 89 of the AMP - Requires the Contractor to ensure that all building containing asbestos have appropriate asbestos signage on all entry ways into the building.

(b) Did the EMOS Contractor ensure that all the asbestos instances recorded on the asbestos register as being either present or presumed have appropriate asbestos warning labels affixed either to the material or in close proximity so as to warn of the asbestos hazard? This includes for any pits identified as containing ACM.

Reg 424 Paragraphs 9.1, 9.3, 9.4, 9.5 and 9.6 of the Asbestos Survey Scope of Works.

Paragraph 88 of the AMP - Requires the Contractor to ensure that all asbestos has appropriate asbestos warning labels attached to or near to it.



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Inspection Criteria


Policy / Procedure

Title

Evidence

Compliance

Rating

Comments

Action

No.

Action Description

(c) Was all the previously attached asbestos warning signage and labelling checked to ensure that it was in good condition and factually correct?

Incorrect signage and labels include signs and labels with redundant contact numbers or other incorrect information).

Reg 424 Paragraph 9.4 of the Asbestos Survey Scope of Works.

Paragraph 90 of the AMP - Requires the Contractor to ensure that all asbestos warning labels are in good condition and correct.

(d) If there was any damaged, faded, illegible pealing or incorrect signs or labels, were they replaced?


Paragraph 90 of the AMP - Requires the Contractor to ensure that all asbestos warning labels are in good condition and correct.

(e) If there were any obsolete or redundant asbestos warning signs or labels, were they removed as part of the survey?

Where asbestos has been removed from the estate old labels and signage will likely need to be removed to reflect this).


Paragraph 90 of the AMP - Requires the Contractor to ensure that all asbestos warning labels are correctly placed in accordance with asbestos that is present.



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Inspection Criteria


Policy / Procedure

Title

Evidence

Compliance

Rating

Comments

Action

No.

Action Description

(f) As part of the survey inspection activities, have all asbestos warning signs and labels been checked to ensure that they are: in- place; clearly visible; legible; correctly positioned (i.e. in- line with the labelling protocol set out in the AMP); and in good condition (i.e. not faded, cracked, peeling or otherwise damaged)?

Reg 425 and Reg 426 Paragraphs 5.6 and 9.1 – 9.8 of the Asbestos Survey Scope of Works.

(g) Where signage and/or labelling is not correct (i.e. labelling or signage is: not present, not correct; or the labelling is in poor condition and/or otherwise damaged) has this issue been rectified by the provision of the correct signage and/or labelling?

Reg 425 and Reg 426 Paragraphs 5.6 and 9.1 – 9.8 of the Asbestos Survey Scope of Works.

(h) Have all pits with known ACM been labelled appropriately?

Reg 425 and Reg 426 Paragraphs 5.6, 9.5 and 9.6 of the Asbestos Survey Scope of Works.

(i) Have inaccessible spaces been appropriately labelled?

Reg 425 and Reg 426 Paragraphs 5.6, 9.5 and 9.6 of the Asbestos Survey Scope of Works.



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Inspection Criteria


Policy / Procedure

Title

Evidence

Compliance

Rating

Comments

Action

No.

Action Description

Survey Reports

(a) Did the EMOS Contractor supply a survey report with all the relevant information, in accordance with Clause 11.1 of the Survey Scope of Works (including photos of all identified or presumed instances of asbestos and marked up building plans showing the location of any identified or presumed asbestos?


(b) Did the Survey Report contain a risk assessment that conducted was in-line with the requirements of clause 11.2 of the Survey Scope of Works?

Reg 420 Paragraph 11.1 and 11.2 of the Asbestos Survey Scope of Works.

(c) Did the Survey Report contain copies of all the sampling conducted as part of the survey?

Reg 420 Paragraph 11.1 and 11.2 of the Asbestos Survey Scope of Works.

Additional Comments


Annex D -Definitions

ANNEX D - DEFINITIONS

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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 asbesti form 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.

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.

Bonded asbestos See non-friable asbestos.



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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).

Competent Person A competent person is a person who has acquired the knowledge and skills of relevant asbestos removal industry practice through training or experience and holds a certification in relation to the specified vocational education and training course for asbestos assessor work or a tertiary qualification in occupational health and safety, occupational hygiene, science, building, construction or environmental health. A licence may be required for some of the tasks described in this document as requiring a ‘Competent Person’.

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 (3 μm).

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

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. 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’.



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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. 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.

Permit to Work A permit to work is a formal written document to control certain types of work identified as potentially hazardous. The terms "P.T.W.", "permit" or "work permit" refer to the form used by a company to meet its needs. The aim is to ensure proper planning and consideration of the risks involved in a particular job, at a specific time and place, with designated precautions.

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

A fibre of asbestos small enough to penetrate into the gas exchange regions of the lungs. Respirable asbestos fibres are technically defined as 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).

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.

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.



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Worker A person who does work, whether or not for reward or recognition.

‘Workers’ include persons working under contracts of employment, apprenticeships, traineeships and other contracts of service, but also other persons subject to direction by ‘persons with control’, such volunteers and work experience students.

Workplace Any place where a person works.


Annex E - Asbestos Removal Permit to Work

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ASBESTOS REMOVAL PERMIT TO WORK

** The use of a permit to work system is compulsory for all asbestos removal works undertaken on E&IG controlled parts of the Defence estate**

PERMIT NO: DATE PERMIT RAISED:

LICENCED ASBESTOS REMOVAL SUB-CONTRACTOR:

LOCATION: WORK ORDER:

DESCRIPTION OF ASBESTOS WORKS:

HYGIENIST: WORK ORDER:

ASBESTOS REMOVAL CHECKLIST DATE

ASBESTOS REGISTER: Has the asbestos register for this facility been consulted by the Asbestos Removal Subcontractor and the EMOS Contractor?

OCCUPANT NOTIFICATION: Have the occupants of the facility involved and/or occupants of neighbouring buildings been consulted and fully informed of each step of the asbestos removal process – as required in the Code of Practice for the Safe Removal of Asbestos?.

ASBESTOS REMOVAL CONTROL PLAN: Has the sub-contractor developed and submitted to the EMOS Contractor a safe asbestos removal plan compliant with the requirements of the Code of Practice for the Safe Removal of Asbestos?

COMCARE NOTIFICATION: Has the Comcare Notification been provided? Contractor to provide objective qualitative evidence of notification.

EMOS CONTRACTOR ASBESTOS REMOVAL SUBCONTRACTOR – DECLARATION I agree to adhere to the approved safe system of work to control any exposure to airborne fibres. ASBESTOS REMOVAL

SUBCONTRACTOR NAME: ………………………………………….. SIGNATURE: …………………………...……………

CERTIFIED HYGIENIST - DECLARATION I am satisfied that the sub-contractor will conduct the above work IAW: the Permit; the requirements of the E&IG AMP; and the How to Safely Remove Asbestos Code of Practice.

CERTIFIED HYGIENIST NAME:

…………………………………………..

SIGNATURE:

………………..…………………..………

ACM Removal plan received

Y / N

REMEDIATION APPROVAL (ADREM, HCO or EMOS PM)

NAME:

………………………………………..

SIGNATURE:

................................................

POST ASBESTOS REMOVAL CHECKLIST (To be completed by BSC Project Manager)\

Clearance Air Monitoring Occupancy Tip Fees Asbestos Register updated Y/N

estate & infrastructure group asbestos management plan … · estate & infrastructure group...

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