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Do I have to / How do I remove asbestos?

The relevant legislation that would need to be considered is listed below:

The Control of Asbestos at Work Regulations 1987, as amended 1992 and 1998. These regulations set down requirements for the protection of persons being exposed to asbestos.

The Asbestos (Licensing) Regulations 1983, as amended 1998. These regulations require company's to be licensed to carry our work with asbestos insulation, asbestos coatings and asbestos insulating board.

The Asbestos (Prohibitions) Regulations 1992, as amended 1999. These regulations prohibit the importation, supply and use and reuse of crocidolite and amosite. The same prohibitions apply to chrysotile following the 1999 amendments.

The Special Waste Regulations 1996. These regulations require the waste to be consigned to a site which is authorised to accept asbestos waste.

(To what extent these regulations are discussed will be determined by how the question is developed, i.e. do you know which type of asbestos is to be removed, is it a domestic or commercial premise etc)

To safely remove the asbestos cement you would need to follow the requirements of the Control of Asbestos at work Regulations 1987 (as amended). These regulations apply to all work with asbestos, including asbestos cement. 

Essentially the regulations require the following:

Reg. 4 - Requires that the type of asbestos is identified before work starts.

Reg. 5 - Requires that an assessment is carried out to identify the nature & degree of exposure and then to set steps to reduce exposure. This regulation also requires the preparation of a written plan of work detailing how the work will be carried out. The plan must be retained until the work is complete.

Reg. 6 - Notification of work. For work which does not require an asbestos license from the HSE (i.e. all work with asbestos cement), the duty to notify the enforcing authority applies only on the first occasion when work with asbestos is liable to result in employees' exposure exceeding the appropriate action level.

Reg. 7 - Information, instruction & training of employees must be provided.

Reg. 8 - Requires employers to prevent exposure or reduce it to the lowest level which is reasonably practicable without the use of respiratory protective equipment (RPE). RPE must be provided if the control limits are likely to be exceeded.

Reg. 9 - Requires employers to ensure control measures are applied and used properly.

Reg. 10 - Requires Local exhaust ventilation (LEV) and RPE to be examined and tested at suitable intervals. Records must be kept for 5 years.

Reg. 11 - Requires protective clothing is provided. The clothing must be adequately disposed of or cleaned at suitably equipped premises. Contaminated clothing removed from the site must be packed in a suitable container and labelled. 

Reg. 12 - Requires employers to prevent/reduce the spread of asbestos.

Reg. 13 - Ensure premises and plant are kept in a clean state.

Reg. 14 - Where action levels are likely to be exceeded the work area must be designated as an asbestos area and where the control limits may be exceeded a respirator zone must be in place. Notices must be displayed. 

Reg. 15 - Employers should monitor the exposure of employees to asbestos where appropriate and keep records. Monitoring will be appropriate unless:

(a) exposures are known to be low and not likely to approach the relevant control limits and/or action levels;

(b) the work is intermittent and of short duration and adequate information is available to enable the appropriate protective equipment to be provided; and

(c) the protective equipment provided is of such a standard that no foreseeable measurement result could indicate a need for equipment of a higher standard.

Persons carrying out measurements of asbestos fibres in air must be accredited to EN45001.

Reg. 16 - If exposure of employees is likely to exceed the action levels, medical surveillance must be carried out and a health record kept for 40 years.

Reg. 17 - Provide washing and changing facilities

Reg. 18 - Requires asbestos which is stored or distributed to be in a suitable container and be clearly labelled.

Reg. 19 - Any person supplying a product containing asbestos must ensure the product is labelled.

(Reference: L27, The control of asbestos at work, ISBN 0717616738, £6.75)

(Any of the above regulations may need to be discussed depending on the answers given to further questioning during the call)

(Action Levels)

A control limit is that concentration of asbestos in the air (averaged over any continuous four-hour or ten-minute period) to which employees must not be exposed, unless they are wearing suitable RPE. The four-hour and ten-minute periods have their own control limits, the values of which varies depending on the type of asbestos present.

Action levels apply to exposure in the longer term, and are cumulative exposures calculated over any continuous 12-week period. The 12-week period should not be chosen to avoid exceeding an action level; it should represent a 'worst-case' for the work being undertaken. If the exposure of any employee exceeds or is likely to exceed an action level, the regulations in Control of asbestos at work Regulations on notification, designated areas and medical surveillance, apply. 

Removal:

The HSE produce a guidance publication, 'Working with asbestos cement', setting out basic guidelines for the Removal and Demolition of Asbestos Cement:

Dismantling and demolishing buildings, roofed or clad with asbestos cement sheet, presents special problems, especially if they are old and crumbling. Many asbestos cement products, such as roof sheets, cladding, drainpipes and gutters, are located at height and therefore present a risk of falls. Asbestos cement sheet is a fragile material, and people must not walk on it. You cannot rely on it to support the weight of a person, even with new sheets. It is important to emphasise that falls from, and through, fragile roofs are a major source of deaths in construction work, and precautions to prevent such accidents should be given priority. Further advice is given in HSE guidance HSG33, Health and Safety in Roof Work (1998).

In order to minimise exposure and control the spread of asbestos, you need to consider the following general precautions:

· where reasonably practicable, remove the asbestos cement before the rest of the structure is demolished;

· where possible, avoid further breaking the sheets;

· keep the material wet when working on it;

· where possible, lower the material onto a clean hard surface;

· remove waste and debris from the site as soon as possible to prevent it being crushed underfoot or by moving vehicles;

· do not bulldoze broken asbestos cement or sheet into piles;

· do not dry sweep asbestos cement debris;

· dispose of the waste and debris safely.

Manual dismantling methods

If asbestos cement sheets are in good condition and it is reasonably practicable to produce a safe system of work and provide safe access, they should be taken down whole. Roof sheets should preferably be removed from underneath with mobile elevating work platforms, for example scissor lifts or cherry pickers.

When adopting this method, the sheets should not be dropped or damaged. Methods such as careful transfer to covered lorries or skips, or wrapping intact in polythene sheeting, provide the best form of disposal.

Remote dismantling methods

If the sheets are disintegrating or the risk of falls is too great, remote demolition techniques such as deliberate controlled collapse should be used. Remote demolition will give rise to low exposures for the equipment operators, and to those who subsequently load the waste into lorries for disposal.

When remote techniques are used, the work area must be continually sprayed with water to suppress the spread of asbestos fibres. The roof sheeting should be broken into the building in a controlled manner onto the floor or hardstanding, for instance by using excavators fitted with suitable demolition attachments. You should ensure that this area is clear of other materials before work commences. The system of work should be designed to minimise breakage of sheets. Before, and while loading the broken sheeting into lorries, you should kept it damp by spraying with water. The lorries should be securely sheeted over to prevent the asbestos waste drying out on its way to the tip.

To members of the public, the remote method can appear noisy, dusty and often uncontrolled. They are often concerned about demolition of this type when they know or suspect the building was roofed or clad with asbestos cement. In order to alleviate these concerns about this type of work, contractors can:

keep the neighbours informed about the work;

carry out background air sampling at the perimeter of the site.

(Reference: HSG 189/2, Working with asbestos cement, ISBN 0717616673, £7.50)

Licensing:

This type of work, with asbestos cement, will not require removal by a licensed contractor. The Asbestos Licensing Regulations do not apply to asbestos cement products.

(Reference: L11, A guide to the Asbestos licensing regulations 1983 as amended, ISBN0717624358, £6.00)

Waste:

Asbestos waste, defined as containing more than 0.1% w/w asbestos in the waste, is subject to the waste management controls set out in the Special Waste Regulations 1996. These Regulations require the waste to be consigned to a site which is authorised to accept asbestos waste. This is enforced by the Environment Agency or local authorities in England and Wales, and the Scottish Environment Protection Agency in Scotland.

Whatever type of waste container (for example, plastic sacks) is used, it is important to emphasise that the container should be:

made of a material which in normal handling is strong enough to contain the waste and which takes account, if necessary, of materials in the waste sharp enough to cause punctures;

capable of being readily decontaminated before leaving the work area;

kept secure on site until sent for disposal for example in a locked skip;

properly labelled.

(Reference: HSG 189/2, Working with asbestos cement, ISBN 0717616673, £7.50)

For further information on the safe disposal of asbestos waste, either contact your Local Authority, or the Environment Agency, Tel: 08459 333111

As well as the priced publications, there are also a number of free publications that may be relevant to you:

INDG187 - Asbestos dust : the hidden killer! Are you at risk? : essential advice for building maintenance, repair and refurbishment workers 

INDG188 - Asbestos alert for building maintenance, repair and refurbishment workers 

INDG223 - Managing asbestos in workplace buildings : the hidden killer! Are you putting others at risk

INDG255 - Asbestos dust kills : keep your mask on : guidance for employees on wearing respiratory protective equipment for work with asbestos 

INDG289 - Working with asbestos in buildings

Although extensive information is included here, any one of the aspects listed may be discussed in some way. Again this subject encourages many subsidiary questions, for example, how do we dispose of asbestos, queries regarding the prohibitions regulations and PPE. 

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Lonsdale Health And Safety Consultants

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