Implications for Redundant Plant Management
The implications of dealing with asbestos in redundant plant can thus either be minor or extensive dependent on how much asbestos is present and in what form. Regulation 4 of CAR 2006 requires the removal of all asbestos materials from premises, as far as reasonably practical, prior to the demolition or refurbishment. It requires a “demolition and refurbishment” Asbestos survey be carried out to establish where all asbestos is located. The scope of such D&R survey goes well beyond the requirement for a management survey which is carried out for all premises so that ACMs may be identified, the risk of exposure assessed and an asbestos management plan put in place. Although not referred to specifically in CAR 2006, a survey (or assessment) similar to a D&R survey will be needed if the plant is to be sold or supplied or simply earmarked for use elsewhere within the same organisation.
Where asbestos insulation is present, and the plant is not to be scrapped, this will need to be removed and the plant certified as being asbestos-free prior to (or possibly during) demolition and certainly before transportation elsewhere. Almost certainly, the exposure risk assessment will flag that the proposed work will be licensable and such work will have to be carried out by a licensed asbestos removal contractor. The work will need to be notified to either the HSE or the local authority, dependent on who has jurisdiction, at least 14 days prior to the start of the work and an appropriate risk assessment and method statement (RAMS) prepared. Most likely, except where the work is to be carried out in a remote location and the erection of an enclosure is impracticable, the work will need to be carried out under fully-controlled conditions within a tented enclosure kept under negative static pressure relative to the atmosphere. Following the removal of all the asbestos, the enclosure can only be dismantled once a Certificate of Reoccupation has been obtained. This will involve an independent, UKAS-accredited analyst carrying out a 4-stage clearance within the enclosure. This comprises of the following:
Stage 1 – a preliminary evaluation of job completion, external transit routes, provision of decontamination facilities, whether the area is dry and free from obvious debris and whether all the equipment and waste has been removed from within the enclosure or work area (where no enclosure has been erected). Access equipment and lighting must remain however.
Stage 2 – a thorough visual inspection of the area (and the plant within it) to ensure that all asbestos material has been removed and that no debris, dust or visible evidence of asbestos remains either within the enclosure or has been encapsulated (although this would not be acceptable for plant destined to be used elsewhere unless an exemption certificate has been issued by the HSE – normally limited to materials such as compressed asbestos fibre (CAF) gaskets). Such an asbestos inspection can take many hours to complete, particularly where complex pipework or plant is involved.
Stage 3 – Clearance air monitoring within the enclosure or work area (although usually not required if the area has been open to the outside environment) to ensure that fibre levels are below the clearance indicator (a.k.a. reoccupation level) of 0.01 fibres per cubic centimetre of air. Once achieved, the analyst may then give permission for the removal of the enclosure or removal of work area demarcation and/or barriers.
Stage 4 – Following dismantling of the enclosure or work area, the analyst will conduct a further visual inspection to ensure all asbestos materials have been removed and that no debris remains. Minor clean-up work may be necessary or, in the case of extensive contamination being discovered, the analyst may require the reconstruction of the enclosure or demarcation of the area and the job starts again from scratch.
If the plant is scheduled for scrapping then some equipment lagged with asbestos, especially pipe-work, may be removed using the wrap and cut method. Although still carried out within an enclosure (unless in a remote location and the risk assessment has indicated a low fibre exposure risk) this method involves wrapping of the pipes and insulation in polythene, prior to cutting or dismantling. In practice, this is usually limited to pipes no more than 150 mm in diameter and will result in increased costs associated with disposal to landfill as well as increased volume of waste production which is not environmentally friendly.
An alternative to landfill disposal of such contaminated items is recycling by vitrification of the lagged steelwork. The pipes can be added to steelworks’ furnaces and the asbestos will be converted to a form of glass which can then be tapped off as slag and re-used in road-works for example. Such recycling is more common on mainland Europe than in the UK.
Once any asbestos lagging has been dealt with, the remaining asbestos is likely to be in the form of CAF gaskets, rope seals or asbestos cement electrical phase barriers or shields. It may also be present as asbestos bandage around cables or paper/cloth cable wrapping. Dependent on the condition of such material, the risk assessment may flag the work as either licensable or non-licensable. For licensable work then the same procedure as described above for managing the removal of asbestos lagging will need to be followed. For non-licensable work, which will have a lower exposure risk, then less stringent controls can be applied. They must still be effective however, and all personnel performing such work will need to be trained in such work and wear protective clothing and suitable respiratory protective equipment (RPE). The HSE guidance document HSG 210, “Asbestos Essentials: Task Manual” consists of work sheets covering just about every conceivable job which can be undertaken with asbestos without a licence being required.
For plant containing asbestos in the form of CAF gaskets or other low-risk ACMs, the HSE can issue an asbestos exemption certificate (giving exemption from the prohibition regulations within CAR 2006) thus allowing such plant to be re-sold.
Training Requirements
Licensable or not, all work with asbestos must be undertaken in accordance with the Control of Asbestos Regulations 2006. Asbestos awareness training is important and there must be a practical component to the training of people whose work will involve asbestos materials. Regulation 10 of CAR 2006 describes the level of asbestos training (referred to as Category B) required for non-licensable work with ACMs. This training must be refreshed annually.
Cautionary Note
Asbestos is a hazardous material and is responsible for more industrial deaths in the latter half of the 20th century than any other substance or cause. Asbestos is a carcinogen and as such there is no threshold of exposure below which there is zero risk.
We need to ask ourselves:
· What is “sporadic exposure”?
· Can low level exposure on a regular basis be regarded as sporadic?
· If not, then should not removal of CAF gaskets, if undertaken regularly (say in a central facility prior to recycling of pumps etc.) be regarded as licensable work?
· What about demolition contractors working almost daily with asbestos cement roofing sheets? Is this sporadic exposure?
· Should we continue to condone even sporadic exposure to asbestos fibres?
Alexander Nicoll CCP (Asb.), AFOH
Senior Consultant, Asbestos Consultants to the Environment Ltd
