Before we begin, it is important to remember that removing asbestos is not always the best course of action. Sometimes it is actually safer or more practical not to remove the asbestos that has been identified. Equally, there are occasions were sadly due to finance and budgeting, it can be deemed too expensive an option to remove asbestos - thus alternative ‘next-best-scenario’ solutions are chosen instead.
This is why even today; despite asbestos having been completely banned from importing and use since 1999; millions of tonnes of asbestos are still present within UK buildings.
Under the Control of Asbestos Regulations (CAR) 2012 Regulation 4 - ‘The Duty to Manage Asbestos’ - there is an on-going requirement to manage any asbestos, presumed or identified, if it has not been removed.
As a duty holder, an important part of your Asbestos Management Plan, strategy; and continued compliance with UK law, should be to regularly inspect and assess the condition of any asbestos containing materials (ACMs) identified that are still present. This is most easily achieved by carrying out Asbestos Re-Inspections.
Regulations require that the condition of asbestos-based products need to be inspected regularly and records updated accordingly. The frequency of the asbestos inspection regime must not exceed 12 months. ACOP L143 stipulates ‘’Any identified or suspected ACM must be inspected and its condition assessed periodically, to check that it has not deteriorated or been damaged’’.
Asbestos re-inspection surveys are designed to allow a competent person to monitor and record the condition of any previously identified asbestos products within a building.
The purpose of this type of assessment is to check the materials condition and inspect for any signs of deterioration. The reasoning behind this requirement is that asbestos can become damaged or deteriorate over time. When an asbestos containing materials condition changes, the associated risks (material risk) with the product can change substantially and may no longer be safe and manageable.
The re-inspection comprises of a visual inspection and the reassessment of the risk associated with the condition of the material and the environment that it sits in. ACM’s are reassessed to ensure they remain in the same state they were in when initially/previously inspected (unless removed). The materials are photographed and a full report, including findings and recommendations are provided. If upon reinspection the state/condition of an ACM has changed, the management of it should be revised appropriately and accordingly with immediate effect.
During reinspection surveys any areas which were previously inaccessible – either in part or in full – should also be attempted to be inspected. This will enable a buildings asbestos register to provide a fresher, more accurate and comprehensive picture of the asbestos situation from the data collected. This information in turn helps better manage the building and control the risks of asbestos exposure.
Regulation 10 of the Control of Asbestos Regulations emphasizes the need for persons carrying out the assessment to have sufficient information, instruction and training to carry out the assessment.
It is always advisable to appoint a UKAS Accredited Consultancy who will have suitably qualified, trained and experienced Surveyors to undertake Surveys and Re-Inspections for you.
Failure to follow and comply with UK asbestos regulations not only endangers health and safety in general, but it also invites the possibility to be prosecuted as a duty holder. It is your legal obligation and duty to manage asbestos within your buildings. Appropriate and regular reinspection’s of ACMs should be seen and treated as compulsory and not optional. It is mandatory compliance driven requirement and not merely a choice you can naively ignore.
The Health and Safety Executive (HSE) is the governing body responsible for overseeing health and safety in the UK; and it undertakes regular compliance checks and audits with regard to asbestos. If an asbestos incident or emergency occurs as a result of compliance failure, you will likely face a fine and/or prosecution.
Asbestos materials, like many materials, get damaged, deteriorate and degrade over time. Only by re-inspecting them through a regular programmed schedule can you ensure that the risks can be suitably managed.
Asbestos fibres are microscopic. They are not visible to the naked eye if they are released from damaged or deteriorating materials. Therefore potential asbestos exposure should always be a serious, real, and constant concern; and at the fore front of your asbestos management plan.
An asbestos emergency can be very dangerous. It would require the immediate closure of the direct and affected area(s) to control the release and spread of fibres. Therefore careful asbestos management better protects you and others in the buildings you oversee. It also minimises the risk of disruptions, and even a possible unplanned shutdown of your site.
It should never be underestimated how important and critical regular reinspection’s of ACMs are as part of your asbestos management plan.