Asbestos Management Plan

Asbestos Management Plan V2 April 2015 Page 1 of 35 ISSUE LOG Version Date Approved by V1 Oct 2014 16.10.2014 Estates Senior Management Team ...
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Asbestos Management Plan

V2 April 2015 Page 1 of 35

ISSUE LOG Version

Date

Approved by

V1 Oct 2014

16.10.2014

Estates Senior Management Team

Approved by e-mail.

V1 Oct 2014

02.10.2014

University Safety Services

Approved by e-mail.

V2 Apr 2014

15.05.2015

Estates Senior Management Team

SMT Meeting 15.05.2015

Revision No

Date

Reason for Revision

Issued by

1

April 2015

1) Para 1.1 Addition of tenants, leaseholders and staff occupying University buildings. 2) Para 2.6 Addition of building occupiers. 3) Para 12.1 Extension of training to staff occupying University buildings. 4) Appendix 4 Matrix extended to include Heads of Buildings and Building Occupiers.

Asbestos Responsible Person.

Distribution List Job Title, Location and Contact Details

Page 2 of 35

Contents 1.0

General Statement 1.1 Asbestos and Building Fabric

2.0

Responsibility 2.1 Director of Estates and Buildings Division 2.2 Responsible Person 2.3 Estates and Buildings Division Managers 2.4 Estates and Buildings Division Employees 2.5 Heads of School, Directors of Divisions, Heads of Department and Heads of other non-School Spending Units 2.6 All other University staff, students and University building occupiers 2.7 Asbestos Management Hierarchy Diagram

3.0

Surveying Premises for Asbestos Containing Materials

4.0

Asbestos Register 4.1 Re-inspection Process 4.2 Management of Asbestos Containing Materials (ACM’s) 4.3 MICAD Asbestos Register Database 4.4 Labelling of ACM’s

5.0

Asbestos Removal & Environmental Cleaning Works (Licensed Materials)

6.0

Airborne Monitoring 6.1 Clearance Testing 6.2 Reassurance Monitoring 6.3 Personal Monitoring

7.0

Non-Licensed work on Asbestos Containing Materials

8.0

Control of Waste Asbestos 8.1 Storage and Disposal of ACM’s

9.0

Work Carried Out By/On Behalf of the University, Faculties, Schools or Divisions

10.0

Non Removal of Asbestos during Building Work

11.0

Emergency Procedure - Reporting of Suspected ACM’s

12.0

Training 12.1 University Staff 12.2 Contractors

13.0

Permit to Work and Contractor Control

Appendix 1 - Hazard Warning Sign Appendix 2 - Approved Asbestos Contractor List Appendix 3 - Asbestos Project Flowchart Appendix 4 – Asbestos Management Responsibility Matrix Page 3 of 35

Asbestos Management Plan 1.0

General Statement University of East Anglia recognises the responsibilities and duties under the Health and Safety at Work etc Act 1974, to provide as healthy and safe an environment as is reasonably practicable for all employees, contractors, visitors and members of the public. Under the Control of Asbestos Regulations 2012 the University recognises and accepts its duty to manage asbestos in non-domestic premises. This plan relates solely to the management of asbestos containing materials (hereafter known as ACM’s), it is a live document and will be reviewed at least every six months and as and when new legislation, Approved Code of Practice (ACOP) and good practice is changed. Management of asbestos in the University buildings will be achieved by: -

-

identifying the location of asbestos containing materials (ACMs) on the University premises; maintaining an Asbestos Register which records those locations and the condition of the ACMs; assessing the risk from ACMs based on their condition and accessibility; removing ACMs which are in poor condition, easily accessible and thus readily disturbed, or that may be disturbed in the conduct of maintenance or other building works; managing and regularly inspecting any ACMs left in place; University staff will not carry out any work on asbestos containing materials; all such work on ACM’s will be carried out by licensed contractors.

The University’s Asbestos Management Plan shall be controlled within the Estates and Buildings Division and will ensure that asbestos management of all its buildings is compliant with current HSE Guidance and Control of Asbestos Regulations 2012 (CAR) legislation; staff will be informed of this during their annual asbestos awareness training. This Plan will be made available on the Estates and Buildings Division and University Safety Services websites. Copies of the Plan and subsequent revisions will also be circulated to all University Mangers responsible for the management, organisation and supervision of ‘works’ or projects carried out by general Contractors. Page 4 of 35

It is the responsibility of all persons to whom this Asbestos Management Plan applies (as detailed in the following paragraphs) to ensure that they comply with the requirements of this plan.

Failure to do so may render University staff liable to the University disciplinary procedures; Contractors who fail to comply with this management plan will be told to leave University property and the contract terminated. 1.1

Asbestos and Building Fabric No work or other activity shall be undertaken by any member of University staff or other staff occupying University Buildings, any tenant, leaseholder or Contractor or any person working on behalf of the University or anyone occupying a University Building that involves drilling into, removing, damaging or disturbing the building fabric, e.g. surface coatings, ceilings, panels, removing blackboards, etc. without the approval of the Estates and Buildings Division Head of Maintenance, Head of Engineering and Infrastructure or Head of Projects and Estates Development. This includes minor work such as fixing picture hooks or knocking in nails or drilling walls. Uncontrolled work on or damage to the fabric of the University buildings can potentially cause a number of health and safety issues, for example: release of asbestos fibres, damage to concealed cabling, and damage to structural elements that provide fire safety protection. It is important therefore that such work is only undertaken by Estates and Buildings Division or with Estates and Buildings Division approval from the Heads of Maintenance, Engineering and Infrastructure or Projects and Estates Development. Any damage to building fabric should be reported immediately to the Estates Customer Services Helpdesk by telephone on extension 2121 or e-mail at [email protected] . Asbestos is only dangerous when disturbed. If it is safely managed and contained, it does not present a health hazard.

2.0

Responsibilities The University has an explicit duty to assess and manage the risks from asbestos.

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2.1

Director of Estates and Buildings Division •





• •

2.2

To ensure the survey of ALL buildings within the site built prior to 2000 (which are owned or leased by the University) and take reasonable steps to determine the location of ACM’s. (Any materials for which it is not possible to confirm they are free of asbestos will be presumed to contain asbestos). To ensure that an electronic record is made and maintained of the locations of asbestos and presumed to contain asbestos materials within the MICAD Asbestos Database. To ensure that the risk of exposure is assessed and that actions are documented necessary to manage the asbestos and document within the MICAD Asbestos Register of ACM’s system. To appoint, in writing, a competent individual (the Responsible Person) to oversee these arrangements (the Asbestos Management Plan). To ensure that the Responsible Person is provided with sufficient training, resources and time to carry out their duties effectively. Responsible Person (or in their absence, the Project Administrator (Technical) (Asbestos))

• •











The Responsible Person and Deputy Responsible Person to acknowledge, in writing, their responsibilities as the Responsible Person. To ensure that the MICAD Asbestos Register of ACM’s shall provide a record of the location, condition, maintenance and removal for all ACM’s on the University’s estate and the Responsible Person will include an action plan for minimising the risk through appropriate works . To ensure that the Register is updated following any asbestos removal works; any identified changes to the material or priority assessment; the discovery of any previously unknown ACM’s; and after each re-inspection of known ACM’s (see paragraph 4.1 for re-inspection procedures). To instruct for the repair, encapsulation, labelling or removal of asbestos if there is a risk of exposure due to its condition or location or if of concern on the Register. Will commission and monitor the re-inspection of ACM’s on at least an annual basis through the appointed surveyor, seeking advice from the appointed surveyor on the frequency of re-inspections if items require more than an annual survey and then re-assess the risk and update the MICAD database. To make information available to those who may come into contact with or disturb ACM’s. Information shall be provided in written / electronic format and shall be correct on the date it is presented. Access may also be granted to the MICAD Asbestos Portal as and when required to make this information available. To ensure that, when Refurbishment and Demolition Surveys are requested, both the request and the subsequent completed survey report are circulated to the Project Manager, other relevant Project Office staff and the Head of Maintenance for dissemination to Maintenance staff, so that they are immediately fully aware of the presence of any additional asbestos identified beyond the Management Page 6 of 35

• • •









2.3

Surveys; the Responsible Person will also update the MICAD Register with the findings of any R&D Survey and subsequent removal works. To put in place arrangements so that work which may disturb the ACM’s comply with current legislation. All asbestos work MUST be routed through the Responsible Person before work is commenced on site. To provide MICAD training for staff that is practical to enable staff to effectively search the asbestos register database; training to be recorded and updated at the annual asbestos awareness training for staff and as technological changes occur. To monitor on a monthly basis the use of MICAD to make sure it is effective and take action by advising line managers and Estates Senior Management Team if it is not being used appropriately. To arrange annual asbestos awareness training for Estates Division staff and other relevant staff in Faculties, Schools and Divisions; and arrange for training to be recorded and records maintained. Training will be conducted by an accredited external company. To arrange training on a quarterly basis for Estates Managers in Maintenance, PODS and the Cross Divisional Managers Group on ‘Asbestos Awareness in Practice and Understanding Asbestos Management in Buildings’. To arrange for the procurement (for retention at Central Stores) of all necessary PPE and RPE (protective coveralls, gloves, masks) for the purposes of emergency procedures (as outlined at Paragraph 11.0) and ensure the PPE and RPE is freely available to staff.

Estates and Buildings Division Managers •





2.4

To ensure that prior to the commencement of any works which may have the potential to bring staff into contact with ACM’s, the Asbestos Register and Asbestos Management Plan are to be consulted and information used within the risk assessment for the works, following the University Asbestos Policy and this plan. To consult the Responsible Person and notify him via the Project Initiation Form (PIF) as soon as notification of a project or potential project is received so that consideration of the requirement of a Refurbishment and Demolition (R&D) Survey takes place at the earliest opportunity. To consult the Responsible Person prior to the commencement of any refurbishment and demolition works (it will be necessary to carry out a full R&D Survey subject to the age of the building). Estates and Buildings Division Employees



It is University policy that the University staff will not work with ACM’s but only in extreme emergency situations to contain the situation. Page 7 of 35

• •

• • • • • 2.5

To report any defects or suspected ACM’s immediately to their Line Manager and prior to starting / continuing with work. To ensure that if at any time ACM’s are accidentally damaged or exposed, they stop work immediately, isolate and seal the area and implement the emergency procedures as at paragraph 11.0 and inform the Responsible Person. To follow carefully all the procedures set out in the ‘Plan of Work’ for the works. To keep the work place clean. To eat and drink only in agreed locations. The University Smoking Policy must also be followed. Not to enter into areas of risk that have been made subject of a ‘Permit to Enter’ without the necessary permit and appropriate PPE. Ignoring Permit to Work Procedures will result in disciplinary measures. Heads of School, Directors of Divisions, Heads of Department and Heads of other non-School Spending Units Heads of School, Directors of Divisions, Heads of Department and Heads of other non-School Spending Units have an explicit duty under the University Health and Safety Policy to ensure that no activity shall be undertaken within their School/Department that involves drilling into, removing, damaging or otherwise disturbing the building fabric unless approval has been obtained from the Estates and Buildings Division. The Responsible Person will keep Faculties, Schools and Divisions apprised of the MICAD Asbestos Register and how to effectively use it and arrange Asbestos Awareness Training for their staff annually by arrangement with University Safety Services who will identify appropriate responsible persons within Faculties, Schools and Divisions.

2.6

All other University staff, students and University building occupiers All other University staff, students and occupiers of University buildings have an explicit duty under the University Health and Safety Policy not to undertake any work or other activity that involves drilling into, removing, damaging or disturbing the building fabric, e.g. surface coatings, ceilings, panels, removing blackboards, etc. without the approval of the Estates and Buildings Division. This includes minor work such as drilling walls to erect shelving, running cabling, fixing picture hooks etc.

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2.7

Asbestos Management Hierarchy

Management Reporting Lines Page 9 of 35

3.0

Surveying Premises for ACM’s In order to manage the risk from asbestos, the University shall ensure that a suitable and sufficient assessment is carried out through a survey carried out by a competent surveyor as to whether asbestos is or is not liable to be present within any University building owned or leased. An initial assessment shall be made as to whether ACM’s may be present within the University buildings and areas of the Estate. This will be followed by full Asbestos Management survey as recommended in HSE Guidance document HSG264. The survey shall be undertaken by a competent surveyor with relevant experience qualified to at least BIOH P402 level. Companies undertaking asbestos surveys shall be UKAS accredited to ISO 17020 and ISO 17025. Asbestos survey reports shall be presented in a format compatible with the current MICAD Asbestos Register database and shall provide the following minimum information:• • • • • • •

Purpose and date of survey Annotated floor/site plans indicating sampling points and unique references Asbestos material assessment Priority Assessment (to be prepared in consultation with the Responsible Person) The Material score and priority score are added to give the Total risk. Asbestos risk assessment Recommendation

Once an area has been surveyed and the results known, consideration shall be given by the Responsible Person as to whether or not the identified ACM’s will be labelled as per paragraph 4.4. In advance of all major refurbishment and demolition work a Refurbishment / Demolition (R&D) asbestos survey shall be carried out as recommended in HSG264. The Responsible Person will ensure that the full copy version of the R&D Survey is recorded in MICAD and the MICAD Asbestos Register Database will be updated with the survey results. When commissioning surveys, the Responsible Person shall ensure (through written instructions when requesting the surveys) that they are informed immediately by the surveyor of any high risk areas identified during the survey.

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The Responsible Person will then take action to contain or mitigate the risk and prepare and ensure the implementation of an action plan to deal with the high risk items identified. This action plan will be detailed in individual building plans which will form addendums to this Asbestos Management Plan. Survey reports shall be presented in a format compatible with the current MICAD Asbestos Register database. All information from the R & D Survey shall be made available to the Principal Contractor and included in the Pre-Tender Health and Safety Plan where appropriate by the Project Manager and CDM Coordinator (if appointed). If this is not possible before contract award, the Management Survey will be issued in the Pre-Tender Health and Safety Plan with amendments that the R&D Survey will be made available pre-construction / demolition. No works will be undertaken before the R&D Survey is made available. All University buildings constructed pre-2000 have been subject of an Asbestos Management Survey. Asbestos risk assessments have been prepared and form part of the University Asbestos Register. Future properties shall be assessed and surveyed for ACM’s where appropriate as they become part of the University estate. In the absence of information relating to ACM’s within the University it shall be assumed that asbestos is present and therefore appropriate controls dependant on activity shall be put in place to avoid any exposure to asbestos.

4.0

Asbestos Register Current ACM risk assessments are based on a material/priority score and algorithm which is compatible with that recommended in HSG264. The register lists the type and location of ACMs and will make prioritised recommendations for action (e.g. removal or regular re-inspection). The register also contains photographs and plans which have been annotated to show the location of ACMs. Data contained within the MICAD asbestos register database will be reviewed at least annually and updated in line with physical alterations of the University along with asbestos removal, encapsulation and dust and debris cleaning works being carried out. The Responsible Person will ensure that re-inspections of ACM’s and updating the MICAD will be undertaken by a competent person. Page 11 of 35

It is important to note that any asbestos register may not be complete – there may be inaccessible or very rarely accessed areas that cannot be examined during a management survey. In cases of doubt, such areas MUST be inspected as part of an R&D Survey prior to disturbance and the Responsible Person contacted in advance to arrange such a survey (see paragraph 3.0). Information regarding ACM’s and general information on management of asbestos may be obtained by contacting the Responsible Person who will check the register and provide appropriate information. The University strives to raise awareness of Asbestos materials and encourage staff to check the MICAD asbestos register prior to commencing any work activity. The Responsible Person will ensure that the MICAD register is useful, accessible and effective by continuous monitoring of the information contained in it and it’s usage by employees and contractors and by regular liaison with MICAD Systems to ensure the University avails itself of system updates and improvements in technology. Asbestos awareness training has been provided to key personnel within the University, in particular ITCS and Science school staff, to ensure asbestos is considered in all activities and that appropriate checks are made from the asbestos register. The Responsible Person will monitor, record and arrange delivery of Asbestos Awareness Training for University staff as detailed at paragraph 12 below. Asbestos in buildings, when it is properly sealed, is not a hazard. However, staff who observe what may be damaged or unsealed asbestos must report it immediately in person to their Line Manager and the Responsible Person for investigation and appropriate treatment.

4.1

Re-inspection Process Asbestos materials identified within the University asbestos register shall be reinspected at least annually; certain areas e.g. areas subject to frequent maintenance will be subject of a shorter re-inspection period. The frequency of these re-inspections will be determined by the Responsible Person and the Project Administrator (Technical) (Asbestos) (Deputy Responsible Person) seeking advice from the appointed surveyor and taking into account the type of asbestos, its condition and the level of risk. The re-inspection process shall involve a visual inspection of all ACM’s listed in the asbestos register. Each material shall be re-assessed on its condition and likelihood of disturbance by a qualified and competent asbestos surveyor. Page 12 of 35

Results from the re-inspection survey shall be directly input into the MICAD asbestos database by the surveyor using an i-Pad. The surveyor will be given appropriate training on MICAD and the i-Pad to be able to perform these tasks. The Responsible Person will then review the actions to be taken in the light of any changes in condition of the ACM’s and the likelihood of any disturbance. Where changes are identified, the Responsible Person will ensure that risk assessments will be revised and priorities adjusted and in liaison with the Head of Maintenance ensure that appropriate management controls are put in place including as appropriate the sealing of rooms and implementing a Permit to Enter regime. 4.2

Management of ACM’s Identified ACM’s have been assessed for risk and are categorised in priority order High, Medium, Medium/Low and Low Risk based on guidelines using a numerical rating given to the parameters which are considered when conducting the risk assessment; the higher the numerical rating, the higher the risk. Surveys will also identify items that have been assessed as having No Asbestos Detected (NAD) or No Suspect Materials Identified (NSMI) and will be given a zero rating. High Risk Situations falling within this category warrant urgent consideration which will be directed by local conditions - for example, the intensity of use of a heating system or the nature of airflow and movement around a damaged ceiling. Immediate steps will be implemented for removal or repair / encapsulation of the asbestos concerned and decontamination of all associated areas as far as reasonable practicable. Access will be restricted and subject to a ‘Permit to Enter’ regime until remediation works have been carried out. After remediation, if the ACM’s are to remain in-situ, the Responsible Person will give consideration to labelling the ACM’s and ensure that MICAD is updated with action taken, management of the ACM’s and any change to re-inspection periods. Medium Risk Situations within this category still warrant urgent consideration, again directed by local conditions. Page 13 of 35

Steps will be implemented for removal or repair / encapsulation of the asbestos concerned and decontamination of all associated areas as far as reasonable practicable on a programmed basis but within a specified timescale. It is recommended that the maximum period for programming removal should be one year and that in the meantime, emergency repair and sealing operations should be undertaken where deterioration or damage occurs. After remediation, if the ACM’s are to remain in-situ, the Responsible Person will give consideration to labelling the ACM’s and ensure that MICAD is updated with action taken, management of the ACM’s and any change to re-inspection periods.

Medium / Low Risk Situations within this category do not pose an imminent risk and the likelihood of fibre release is low under existing conditions. It would be most appropriate within this category to monitor the situation, as deterioration will occur with the passage of time. Situations within this category will be re-inspected at least annually and certain locations, such as Plant Rooms, will be subject of a shorter re-inspection period to ascertain any change in circumstances, which could require re-assessment of priority rating. Low Risk Situations within this category are low priority and will be re-inspected at least annually to ascertain any change in category. Zero Rating No asbestos detected; no further action required. The University is committed to reducing the risks from asbestos to a minimum by acting on items in the asbestos register with an action plan as detailed in the addendum to this management plan, which will be determined and implemented by the Responsible Person and managed within Estates by the Heads of Maintenance, Engineering or Projects and Design through the projects and minor works programmes. The programme for asbestos removal and dust / debris cleaning work shall continue in accordance with the University Asbestos Management Plan and within available budgets. Page 14 of 35

Regardless of priority, Project Managers and those responsible for any works must be aware that all ACM’s shall as far as practicable be identified and removed by specialists in advance of any major refurbishment and demolition works or managed and controlled.

4.3

MICAD Asbestos Register Database The MICAD Asbestos Register can be accessed by the following link: http://asbestosuea.micadipr.net MICAD is extremely user friendly and will contain all Asbestos Management information for all University Buildings. Access to the database is available for all Maintenance staff, designated Estates Managers, PODS staff, Security, Helpdesk staff and, on a temporary basis, to certain Contractors and it is a requirement of all users that MICAD is interrogated before commencing any activity that may impact upon the fabric of any University building or before carrying out any maintenance or refurbishment tasks. To access MICAD, staff will require individual user names and a password which will be issued by the Responsible Person. A generic user name and password will be issued to Security for ease of logging in to the Register. Access is also available to the MICAD Intranet Property Register by the following link: http://uea.ac.micadipr.net This link provides more detailed information for asbestos and space management purposes than the day-to-day operational information of the Asbestos Register and access is restricted to the Responsible Person, Space Manager, CAD Technician and Business Systems Manager, who should be contacted if additional information is required. MICAD is a valuable and necessary tool to the maintenance and refurbishment of all University buildings constructed before the year 2000. It is absolutely essential that all staff and contractors involved in the maintenance, repair or refurbishment of these buildings consult with the MICAD Asbestos Register BEFORE planning or commencing any work in an area that could potentially contain ACM. Page 15 of 35

MICAD contains an audit process to enable use of the register to be checked and verified. The Responsible Person will carry out monthly audit checks on all persons (University staff and Contractors) who have access to MICAD to verify their use of the register; where any under usage of MICAD is noted, the Responsible Person will inform the Head of Maintenance, Head of Engineering and Infrastructure and Head of Projects and Estates Development immediately and Estates Senior Management Team by report. Faculty, School and Divisional Managers who require such audit checks should contact the Responsible Person. The Head of Maintenance, Head of Engineering and Infrastructure and Head of Projects and Estates Development and Faculty, School and Divisional Managers who commission works are expected to make regular checks on University staff and Contractors to ensure that the register is being checked before commencement of any works in areas likely to contain asbestos materials. Confirmation that MICAD has been interrogated will be carried out during Contractor induction and recorded as part of the induction process. The Responsible Person will inform the above Managers if they believe MICAD is not being used responsibly.

4.4

Labelling of ACM’s The University policy is to label known ACM’s in non-public areas, e.g. plant rooms, risers, storage area, etc. A sample of the standard Asbestos ‘Hazard Warning’ Label is at Appendix 1. The absence of any labels in public and non-public areas indicating that asbestos is not present is not conclusive proof that none exists. If there is any doubt about the type of material, a specialist analysis should be undertaken or arranged by the appointed asbestos surveyor or contractor, instructed by the Responsible Person.

5.0

Asbestos Removal and Cleaning of Dust and Debris in Affected Areas (Licensed Materials) Works involving the treatment, encapsulation or removal of licensed ACM’s shall be undertaken by University approved HSE licensed asbestos contractors. All such works will be carried out in accord with the current HSE guidance and relevant HSE document and, where required, subject of notification to the HSE Page 16 of 35

prior to the commencement of the works – 14 days’ notice to the HSE is required before the commencement of any such works. The approved asbestos contractor list is detailed at Appendix 2. Licensed asbestos contractors engaged by the Estates and Buildings Division or the Principal Contractor appointed for the removal or treatment of asbestos shall: • •

• •

• •

6.0

Consult the MICAD Asbestos Register and survey information to assess the risk and ascertain the scope and extent of asbestos removal. Provide a ‘Plan of Work’ for the Project Manager / Principal Contractor as to how the asbestos shall be removed in compliance with current legislation and the University Asbestos Policy. Notify the Health and Safety Executive at least 14 days prior to works to which CAR 2002 applies. Notify the Responsible Person when preparing the works for removal to allow independent validation of the Plan of Works and smoke testing to be carried out if required. Smoke testing will be validated by an independent and suitably qualified and competent person (in accordance with HSE ACOP). Licensed asbestos contractors will also be bound by the Permit to Work and Contractor Procedures at paragraph 13.0 below.

Airborne Monitoring An independent analytical company UKAS accredited to ISO17025 (or equivalent) shall be employed to carry out these works on behalf of the University. The analyst must not be employed as a sub-contractor to the asbestos removal contractor. In locations where asbestos removal works are taking place, the location will remain under the control of the asbestos removal contractor until satisfactory air tests have been carried out, a Certificate of Re-Occupation issued and the location handed back to the University. In locations that are subject to ‘Permit to Enter’ and awaiting re-assurance air testing, the ‘Permit to Enter’ regime will remain in place until satisfactory air tests have been carried out and the Project Manager or Responsible Person has approved the removal of the ‘Permit to Enter’ regime.

6.1

Clearance Testing

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All available information from the University’s Asbestos Register (applicable to areas concerned) shall be made available to the independent analyst prior to commencing these works. On satisfactory completion of these works, the analyst shall produce a report that will allow the University’s Asbestos Register (MICAD) to be updated. The Project Manager / Principal Contractor shall ensure that this report is provided to the Responsible Person who will be responsible for ensuring that the report is scanned and recorded in the University Asbestos Register (MICAD) and the register record is updated. 6.2

Reassurance Monitoring Airborne monitoring shall be carried out in areas where it is considered appropriate based on risk assessment, or in situations where it is considered necessary, i.e. possible exposure to asbestos, to provide documentary evidence that no leakage has occurred. Reassurance monitoring shall be carried out at the discretion of the University. On satisfactory completion of any reassurance monitoring, the analyst shall produce a report that will be scanned and recorded in the University Asbestos Register (MICAD) by the Responsible Person.

6.3

Personal Monitoring Licensed contractors ‘working with asbestos’ shall take adequate steps to monitor the exposure of their employees to asbestos, all in accordance with current legislation, HSE guidance and the Contractor risk assessment.

7.0

Non-Licensed Work on Asbestos Containing Material It is the University’s policy to use licensed contractors to carry out all work on ACM. Certain low risk tasks have been identified by the Health and Safety Executive in their publication Asbestos Essentials Task Manual (HSG210 Asbestos Essentials) which can be carried out by Category B trained non-licensed operatives. However, to ensure the safest possible working environment for Estates staff and Contractors, even where work is required on low risk ACM, licensed contractors will always be used. Page 18 of 35

Only in emergency circumstances should Estates staff or Contractors work on ACM’s. Estates staff may only carry out such emergency work on ACM where they have received training in asbestos safe working procedures and where the work falls within the emergency procedures identified in the Control of Asbestos Regulations 2012. The Head of Maintenance will determine and identify if any staff are to receive training in asbestos safe working procedures. All equipment (including PPE and RPE) and materials used during emergency situations with asbestos must be disposed of as asbestos waste. All asbestos waste will be immediately disposed of by a licensed asbestos removal contractor or licensed carrier of hazardous/special waste. All asbestos waste skips must be kept locked and clearly labelled.

8.0

Control of Waste Asbestos

8.1

Storage and Disposal of ACM’s During and on completion of asbestos removal and of any dust and debris cleaning, ACM’s shall be double bagged / wrapped as it is produced. Bags shall be sealed, labelled and cleaned prior to removal from the enclosure. Bags containing asbestos waste shall be transported along an agreed route for immediate removal from site, or safe storage within a lockable container located in an agreed position on site. Asbestos waste material generated from ‘non licensed’ works either by contractors or direct labour such as asbestos cement and bitumen products shall be double bagged / wrapped and stored in a secure lockable location where damage cannot occur. Final removal and disposal of these items shall be arranged via a licensed asbestos removal contractor or licensed carrier of hazardous/special waste. These procedures for the storage and disposal of ACM’s will be recorded in the Contractor’s risk assessments and method statements (RAMS) and they are to be checked for compliance by the Project Manager. All asbestos waste shall be disposed of strictly at a site licensed to receive it all in accordance with the Hazardous Waste (England and Wales) Regulations 2005. The Contractor responsible for disposal of asbestos waste shall provide the Page 19 of 35

Responsible Person with documentary evidence of safe disposal via copies of consignment notes. The consignment notes will be scanned and recorded in the University’s Asbestos Register (MICAD) by the Responsible Person.

9.0

Work carried out by / on behalf of the University, Faculties, Schools or Divisions Prior to commencement of any work on University property the procedures on the flow chart at Appendix 3 should be followed. A check for the presence of ACM’s should be made by checking the MICAD Asbestos Register or contacting the Responsible Person who will provide an assessment report either verbally, electronic or written. The Responsible Person is able to interpret the information and correctly assess any risks identified. If an initial enquiry is negative it must not be assumed that there is no asbestos. Although every effort has been made to identify locations, destructive investigations through Refurbishment and Demolition Surveys (R&D Surveys) have not taken place and no building can be said to be completely free of asbestos. Where there is a possibility of disturbing ACM’s (however minor), the person who is intending to commission the work shall carry out a risk assessment. In relation to work to be carried out in Science Schools, this will be the Head of Infrastructure and Facilities; in relation to ITCS, this will be the ICT Systems Director or the Head of IT Support. If any suspect material is encountered prior to or during works, works must cease and the area isolated as per paragraph 11.0 and the incident must be reported to the Responsible Person. If there is any uncertainty as to the accuracy of the details in the Register and prior to any refurbishment or demolition works taking place, then a R&D Asbestos Survey must be carried out. The responsibility for checking information on the MICAD Asbestos Register database in respect of proposed works or maintenance by Estates and Buildings Division will be that of the:

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• • •

Project Administrator, Head of Projects and Design or Head of Engineering Maintenance Manager responsible for commissioning the works or issuing the works order Maintenance staff who are allocated work tasks either as hard copy job sheets or electronically via the Estates Helpdesk.

The responsibility for checking information on the MICAD Asbestos Register database in respect of any proposed works, installation or maintenance arranged directly by Faculties, Schools or Divisions, without involving Estates and Buildings Division will be that of the: • •

10.0

Project Manager, Head of Department or Faculty Manager Manager responsible for commissioning the works or issuing the works order

Non-Removal of Asbestos During Building Work During building work, there will always be a recommendation to remove ACM’s, however in exceptional circumstances where a decision is taken by Project Administrators or the person responsible for managing a project not to remove ACM’s then precautionary measures shall be put in place. This will include: • Information regarding ACM’s shall be made available to the Contractor prior to the commencement of works. • The Contractor shall provide details of the measures to be taken in order to protect the material from damage / disturbance of ACM’s arising from the works by means of a risk assessment. • Routine airborne monitoring of the working area may be requested as reassurance that the work is not disturbing ACM’s. • Limitation of access controls to be put in place by means of the ‘Permit to Enter’ regime. • Limitation of extent of works to be put in place by means of the ‘Permit to Work’ regime.

11.0

Emergency Procedure: - Reporting Of Suspected ACM’s and Identification of Disaster Zone Emergency procedures form part of the Asbestos Awareness Training syllabus and are required by the HSE to be included in the risk assessments for asbestos removal companies.

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These emergency procedures will be explained to contractors as an element in the contractor induction process and contractors should ensure that these emergency procedures are written into their risk assessments and method statements (RAMS). The following procedure (which is to be included in the RAMS) must be followed whenever suspected ACM’s or a disaster zone is identified:• • • • •









Stop work immediately. Isolate the area, i.e. shut doors and windows etc. Post warning notices (available from the Responsible Person) and inform people in the immediate area and request that everyone keep away. Make contact with the Responsible Person and provide details of the occurrence. If occurring out of hours, inform Security so that the Emergency Coordinator Procedures of the Estates Incident Management Plan can be implemented. Security staff have received training on the use of the MICAD Asbestos Register and have access to MICAD at the Security Lodge to enable the register to be checked to establish whether ACM’s are known to be present. In circumstances where no records are available, the University shall organise for samples to be taken for analysis by a UKAS accredited testing, sampling and analysis laboratory. Appropriate risk assessments and control procedures shall be agreed following consultation with the Responsible Person and the University Safety Services Division and implemented to avoid exposure of ACM’s to building users. Encapsulation, treatment or removal of disturbed ACM’s shall be carried out in accordance with current legislation before areas are re-occupied. In circumstances where a ‘site’ is under the control of a Principal Contractor and ACM’s are discovered the Procedures contained in the Health and Safety Plan and the Contractors’ RAMS should be followed and the Project Administrator or Head of Projects and Estates Development or Project Manager informed as soon as practical.

The following points should be noted: • •

All staff and contractors must not allow works to continue on any materials, which are suspected of containing asbestos. If suspected ACM’s have been damaged or disturbed during work(s) in progress, the person discovering the damage / disturbance will ensure the materials are left in-situ, the work(s) suspended and the area isolated pending further investigation. Page 22 of 35





12.0

Do not attempt to take a sample. The actual act of sampling asbestos can expose the sampler to dangerous levels of fibres and it is possible to contaminate the surrounding area. Samples should only be taken by a suitably qualified and competent person (in accordance with HSE ACOP); the Responsible Person will arrange for a surveyor to attend and take samples once notified.

Training It is essential that as well as recognising the hazard, every effort is made to minimise/eliminate the risks to the working population by effectively controlling and managing all work where asbestos is present. Training can play an important role to help reduce the risk of exposure. The University is committed to reducing the potential of this risk to both staff and anyone who visits or undertakes maintenance or other works at the University. Asbestos awareness training sessions will be provided annually to all University staff detailed below and recorded. New staff will receive asbestos awareness training as soon as reasonable practicable. This training will include details contained within the Asbestos Management Plan and staff responsibilities to ensure compliance with the Plan. Asbestos awareness training and refresher course have been arranged during 2015 in March, May, October and December. Assistant Maintenance Managers will carry out quarterly asbestos toolbox talks with Maintenance staff in addition to the annual awareness training. These toolbox talks are to be recorded in the Maintenance training records. All Contractors working on University property are required to ensure their Operatives have undertaken asbestos awareness training (see paragraph 12.2 below). Project Managers will ensure that this requirement is included in the tender and contract selection process and confirm and record that that Operatives have been trained at the time of site induction. The Responsible Person will ensure that Asbestos Awareness refresher training shall be provided annually by an accredited external contractor to all University staff detailed below to keep abreast of changes in legislation and working practices. In addition, the Responsible Person will ensure that Estates Managers are briefed quarterly so that Managers are able to identify the University’s requirement for contractors instructed by them. Page 23 of 35

Records of training will be kept on the appropriate Faculty, School or Divisional training database. All records of training and toolbox talks will be forwarded to the Responsible Person who will maintain a central record of staff who are trained; these records will also be recorded in the MICAD asbestos register database. All University Managers who commission Contractors to undertake work on University buildings will ensure that those Contractors provide appropriate confirmation that their staff have received asbestos awareness training and refresher training. This confirmation is to be provided in writing at the time of site induction.

12.1

University Staff and Staff occupying university buildings Managers (Estates Division) responsible for: •



• •

Commissioning and management of specialist asbestos removal / environmental cleaning works – Heads of Projects and Design, Engineering and Maintenance; Project Managers; Maintenance Managers. Management, organisation and supervision of ‘works’ or projects carried out by the University Maintenance staff or contractors - Heads of Projects and Design, Engineering and Maintenance; Project Managers; Maintenance Managers. Management of the University’s Asbestos Register – Responsible Person only. Commissioning of asbestos surveys / bulk sample analysis – Responsible Person only.

Managers (University wide) responsible for: •

Management, organisation and supervision of ‘works’ or projects carried out by general Contractors.

University Maintenance, Contractors, other University staff and staff occupying University buildings: •

Any persons who may come into contact with ACM’s.

Page 24 of 35

12.2

Contractors The University shall actively select Contractors for inclusion on the approved contractors list that can demonstrate their competence and understanding of asbestos issues and provide evidence that their staff have received asbestos awareness training. These requirements will be included in the contractor selection process. Managers who commission Contractors (Head of Projects, Head of Engineering and Maintenance Managers) will ensure that this evidence is provided and recorded at the site induction process before work commences. The site induction process and PowerPoint presentation are available on the PODS intranet drive at: V:\Project Process\Flowchart - CURRENT Records of site induction will be kept by Managers on the Estates ‘T’ Drive. The effectiveness of training will be evaluated by those Managers who commission Contractors by audit compliance to policy and procedure at the Project Review stage and recorded within the project review documents. Managers are to notify any issues arising regarding non-compliance of contractor asbestos awareness training to the Responsible Person.

13.0

Permit to Work and Contractor Control The Estates and Buildings Division has in place a Health and Safety Policy for Construction Management which applies to all University staff and Contractors. All University Maintenance staff, Contractors and Consultants employed by the University are required to confirm agreement to this policy. Managers who commission Contractors (Head of Projects, Head of Engineering and Maintenance Managers) will ensure that this agreement is recorded at the site induction process before work commences. Contractors are responsible for making their staff and Sub-Contractors aware of the requirements of the Health and Safety Policy for Construction Management, Permit to work controls and the requirements of this Asbestos Management Plan. Contractors are to be provided with a copy of the policy prior to commencing any work at the University; the policy and associated construction procedures, including working in areas where asbestos is likely to be present, will be explained during the induction process by the Heads of Projects and Design, Engineering or Maintenance or delegated Authorised Person responsible for the works programme.

Page 25 of 35

This policy includes details of Permit to Work that are required and Site Possession Certificates. In relation to asbestos, the Policy states: “Asbestos building and lagging materials are present in many of the University's buildings. Before starting work, Contractors should confirm with the Authorised Person (the Project Manager or person commissioning the works) whether asbestos is known to be present in the areas of work. The University has a comprehensive 'Asbestos Register', a copy of which (for the work area) may be provided on request. However, the University cannot guarantee that every location of asbestos is listed, so it is important that Contractors consult the Authorised Person or the Responsible Person if any doubt arises before there is any risk of asbestos fibres being released. In cases where it is known or suspected that asbestos containing materials are present, appropriate safeguards and working procedures must be followed, in accordance with the requirements of the Control of Asbestos at Work Regulations 2012. The Authorised Person must discuss procedures and action to be taken with the Responsible Person. If during the works, materials are discovered that are suspected to contain asbestos, ALL work in the immediate area must stop and the Authorised Person informed who will consult with the Responsible Person. Operations involving asbestos materials may not be undertaken except by licensed contractors. The University Asbestos management Plan must be complied with.”

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Appendix 1 Labelling of Asbestos. Hazard Warning Sign.

This sign will identify an item of known asbestos:

Page 27 of 35

Appendix 2 APPROVED ASBESTOS CONTRACTOR LIST This below list is controlled by the Responsible Person - Estates Risk Management Advisor. Contractors seeking to be included on this list must contact the Responsible Person. Where the Responsible Person is satisfied that the Contractor can meet the University requirements the Contractor details will be added to this list. The Removal Contractors below can be contacted in situations where asbestos is in need of immediate repair or removal. In all other cases of asbestos removal, the removal project will be subject of a tender process as per the University standard procedures. Consultants (Surveys and Analysis):

Address:

Telephone & Fax:

Thames Laboratories

Hollow Farm 9 Hilton Road Fenstanton Cambridgeshire PE28 9LJ

T: 01480 891 800 F: 01480 890 008

Contact: Francesca (Franky) Manderson [email protected]

Date added: 2011

N.B. Thames Laboratories are the appointed University consultants for management surveys, refurbishment and demolition surveys, air clearances and asbestos analysis and should always be contacted – use the following only in exceptional circumstances. Riverside Environmental Unit 12 Whiffens T: 0870 2015 950 0161 Contact: Farm F: 0870 Adrian Dracup Clement Street 950 0162 07912 120 825 Hextable [email protected] Kent Johnathan Francis BR8 7PQ 07860 374 250 [email protected] T: 01603 Broadland Group Henderson 2012 251 707 Contact: Business Centre [email protected] Ivy Road Norwich NR5 8BF

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Removal Contractors:

Address:

Telephone & Fax:

East Coast Insulations Contact: Keith Mortlock [email protected] Jason Boast [email protected]

Hendee House Battery Road Great Yarmouth Norfolk NR30 3NN

T: 01493 745111

Asbestech Contact: Gary McComb [email protected] 07825 746 109

Head Office & S.E. Region Unit Q2 Penfold Ind. Estate Imperial Way Watford Herts. WD24 4YY

Shield Environmental Services Contact: Jason Gillett [email protected] 01992 478 759 07747 808 823

London Office Unit 9 Maple Park Essex Road Hoddesdon EN11 0ES

Page 29 of 35

Date added : 2001

F: 01493 745222

2011 T: 0845 680 0055 F: 0845 680 0066

2014 T: 01992 808 823

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Appendix 4 ASBESTOS MANAGEMENT RESPONSIBILITY MATRIX University

Policy Management UEA H&S Policy, formulation and review Monitor compliance with UEA H&S Policy Asbestos Management Plan Review Monitor compliance with asbestos plan Estates Construction Management Policy Estates Permit to Work Procedures Legal Responsibility Duty Holder Responsible Person Asbestos Register (MICAD) Ensure register of asbestos is kept Ensure University buildings are surveyed Ensure associated asbestos risks are assessed Maintenance of register Assess asbestos risks and put in place appropriate actions. Appropriate actions to include immediate removal of identified high risk items Update register following asbestos removals / encapsulation Arrange reinspections and recording and review action to be taken

Director of Estates

Estates Responsible Person

Estates Managers

Estates Staff

Heads of Schools / Divisions / Buildings

School / Divisional Managers

X

X

X

X X

X

X

X

X

X

X

X

X

X

X

X X

X X

X

X X

X

X

X

X

Page 31 of 35

School / Divisional Staff / Building Occupiers

University

Director of Estates

Arrange Refurbishment and demolition (R&D) surveys and recording Provide register information as appropriate Provide register information to staff and third parties as appropriate Provide access to MICAD to staff and third parties as appropriate Monitor use of MICAD by staff and third parties and advise managers appropriately Known Asbestos Items Manage the risk Manage asbestos in accordance with relevant ACOP and HSE guidance Arrange labelling of asbestos as per UEA Policy Items not to be disturbed, drilled or worked upon Report any defects, damage, disturbance immediately Take immediate action if any item is disturbed, damaged, etc. High risk items – arrange immediate removal or encapsulation Medium risk item – programme removal or encapsulation Medium to low risk item – monitor and manage item Low risk item – monitor and manage

Estates Responsible Person

Estates Managers

Estates Staff

Heads of Schools / Divisions / Buildings

School / Divisional Managers

School / Divisional Staff / Building Occupiers

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X Page 32 of 35

item University

Works / Project Management MICAD asbestos register to be checked prior to planning / commencement of work Asbestos Management Plan to be consulted prior to planning / commencement of work Consult with Responsible Person for asbestos prior to any works If decision made not to remove any known asbestos materials, inform the Responsible Person Confirm all Contractors involved in work have had asbestos awareness training and record Comply with Plans of Work If suspect materials found during works – stop work and inform the Responsible Person If suspect materials found, implement emergency procedures and use correct PPE if appropriate Asbestos Awareness Training Annual training to be identified and recorded and Heads / Managers informed Annual Duty to Manage training to be arranged and recorded

Director of Estates

Estates Responsible Person

Estates Managers

Estates Staff

Heads of Schools / Divisions / Buildings

School / Divisional Managers

School / Divisional Staff / Building Occupiers

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

Page 33 of 35

University

Annual training to be arranged for relevant staff and recorded Annual training to be arranged for relevant managers and recorded Regular toolbox talks to be held and recorded All training and toolbox records to be recorded on the MICAD database. Asbestos Removals / Works List of HSE approved removal contractors and asbestos surveyors to be maintained Consult with Responsible Person to arrange R&D survey if applicable Arrange R&D survey and inform Project Manager of outcome Arrange asbestos removal quotes if appropriate Consult with Responsible Person before appointing asbestos removal contractor Notify Responsible Person of appointed removal contractor and date of removal Ensure ASB5 submitted to HSE Provide Plan of work to Principal Contractor Ensure asbestos removal contractors are given H&S site induction Arrange independent smoke test before commencement of asbestos removal

Director of Estates

Estates Responsible Person

Estates Managers

Estates Staff

X

X

Heads of Schools / Divisions / Buildings

School / Divisional Managers

X

X

X

X

X

X

X

X

X

X

X

X

X X

X

X

Page 34 of 35

X

School / Divisional Staff / Building Occupiers

University

Director of Estates

Estates Responsible Person

Estates Managers

Arrange final air clearance with asbestos contractors Collate RAMS, ASB5, air test and waste certificates and forward to Responsible Person

X

X

Page 35 of 35

Estates Staff

Heads of Schools / Divisions / Buildings

School / Divisional Managers

School / Divisional Staff / Building Occupiers