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Managing Asbestos in Schools 2021 – Why is it such a headache?

In our experience, everyone understands the basic issues. The Duty Holder (typically the Head Teacher) has to ensure that the following statutory obligations are met:–

  • Find asbestos (surveys)
  • Prevent exposure through an Asbestos Management Plan (AMP) e.g. risk assessment of activities; conducting abatement works where required; control work is done by staff or contractors and most importantly maintenance and refurbishment work – using an asbestos register and access controls; train staff and keeping records.
  • Review the plan annually & having a competent person inspect asbestos-containing materials (ACMs) on a risk-based programme (typically annually)
  • Where remedial work/abatement required – ensuring a proper Plan of Work is in place – normally done by licensed contractors although there is some flexibility; managing cradle to grave issues for any project including waste management obligations.

Managing Asbestos in Schools Correctly

From experience, one of the biggest problems that schools face is coping with management legacy issues caused by poor data management, often exacerbated by changes in premises staff overtime. Often, when we are called in to help a school sort out issues, we find that significant resources have been historically allocated to surveying the school, but the data available is often confusing and hard to decipher, often duplicated for no good reason and currently inaccurate.

That results in the data not being used or not being used correctly to manage the risk. The other major and frequent issue is that schools rely on non-intrusive surveys as the basis of managing the risk of intrusive works – undertaken often by in-house maintenance workers or odd-job contractors.

To explore these issues further, we need to understand the surveying process and what constitutes an ‘asbestos register’.

For expert advice on how to manage Asbestos correctly in your workplace, we provide an Advisor Service to ensure you are following all of the current requirements.

Asbestos Surveys and Asbestos Registers

There are three main survey types. These are asbestos:-

  1. Management Surveys
  2. Re-inspection Surveys
  3. Refurbishment & Demolition Surveys

1. Management Surveys

Management surveys are your basic survey and by now most schools have had one of these for all the buildings on site. They are non-intrusive – that means that significant areas of the building are excluded. They are designed to, as far as reasonably practicable, record the location, extent and product type of any presumed or known ACMs.

A good management survey only ever has to be done once in the lifetime of a site/building. In meeting the standard of good, we mean:-

  • All areas were accessed i.e. no missed rooms or cupboards etc
  • The surveyor was competent – ideally, the company was UKAS accredited.
  • It was done to appropriate standards (we’d set the benchmark at post–2006 and ideally, if done post–2010, in accordance with HSG 264 Asbestos The Survey Guide).

After completion (assuming all areas were inspected and the surveyor is competent), the findings can be used to generate an ‘asbestos register’.

Unfortunately, there is no particular definition of what that means. It could be the survey report or part thereof, or it could be a separate document or spreadsheet. For most sites, the latter is what is required, What it is supposed to be is a source of clear information to help manage risk and should be accessible and understood to all who need it. It must be up to date.

2. Reinspection Surveys

As you are required to monitoring the condition of known or suspected ACMS, these materials have to be inspected by someone competent (for this task this isn’t clearly defined). These inspections are risk-based but are typically annually.

After this inspection, the ‘asbestos register’ should be updated. If you get an external surveyor to do this, problems may arise. For example:-

  • They may not have completed the original management survey – therefore their liability is restricted to what is known on your register already. This means that any missed areas or mistakes may be set in stone but also that the subsequent report issued will be missing important information from the original management survey – so if it is used as your latest ‘register’ this may lead to important gaps appearing.
  • You will get a report – but that alone does not lead to your asbestos register being updated (unless the register update was part of the scope and the same company supplied the original management survey and register – or the report is used as your register and the issues raised above become relevant.

3. Refurbishment and/or Demolition Survey (AKA R&D)

These are needed before any refurbishment or demolition work is carried out or when more intrusive maintenance and repair work will be carried out or for plant removal or dismantling.

It is important to understand that ‘intrusive’ in this context could include something minor like removing a fixed panel, drilling into a wall or lifting up floorboards.

For minor refurbishment, this would only apply to the room involved or even part of the room where the work is small and the room large. If demolition is planned it would be the whole building.

After the survey, you will have to either remove the newly identified ACMS or update the register – the same issues apply as before. As a building can have multiple R&D surveys, you cannot use the reports as your register or to supplement your register without significant risk of confusion.

It is worth pointing out at this stage, that after any asbestos abatement works, even if an R&D survey was not required, you will still need to update the register in some shape or form.

The overall process of data acquisition and management is set out in fig 1 below.

Duty Holder Questions

These are the questions you should be asking yourself or your designated representative.

  1. What exactly are we using as our asbestos register?
  2. Does it contain all of the data obtained from any survey undertaken on this site? i.e. the management survey, any reinspection surveys and the findings of any R&D survey conducted?
  3. Is it in a format which we can update ourselves or if externally hosted will we get a copy of it in a format we can update ourselves at the end of any contract?

There are plenty of other challenges around meeting your statutory obligations for asbestos, but at the heart of it is having reliable data. If you fail at this stage, everything else is likely to be below the standard required.

Head over to our Advisor Service on the In House website to get clear, concise information about how to handle Asbestos on your school premises.

Frequently Asked Questions

Yes we do. We can either adapt the current accredited course materials so that they better meet the requirements of your company and refer to specific company standards or policies etc or to refer to case studies which relate to your business type.

Alternatively, we can provide a fully adapted non-accredited training course to the business on just about any health and safety matter. Contact us for any detail on the process.

Our accredited and bespoke training courses can be delivered at your premises assuming there is a large enough facility to accommodate the learners.

Alternatively, our courses can be delivered remotely via Zoom or Teams.

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