Asbestos Management Plan. 12 th Edition. September 2014

Transcription

1 Asbestos Management Plan 12 th Edition September 2014

2 University of Sheffield Asbestos Management Plan Revision 12, September 2014 Contents 1.0 The University of Sheffield Asbestos Management Plan Aims and Objectives Background What is Asbestos and its health effects? Legislative Framework Structure and Responsibilities Identification and Location of Materials Containing Asbestos (ACMs) Background, Context & History Plant Areas Pre-construction information Management Surveys General review Asbestos Abatement Work Analysts and Surveyors Asbestos Removal Contractors Types of Abatement Work Monitoring the Condition of ACMs Communication Training Procedures Asbestos Key Risk Review Group Providing Information to Those Who Need It Directly employed personnel Maintenance External contractors Maintenance Activities External contractors Projects Review of Asbestos Management Plan Buildings which do not contain asbestos Disposal of Asbestos Waste Products PPE Resulting from Accessing Plant Areas Categorised as Red Departmental Equipment Containing Asbestos Emergency Procedures & Escalation Protocol Personal Protective Equipment PPE (including RPE) FFP3 Respiratory Protective Equipment (RPE) Re-usable half face mask maintenance... 35

3 13.3 Disposable overalls and over boots (PPE) APPENDIX PF16A and Guidance Note APPENDIX Current Abatement Program APPENDIX Visual Appraisal/ Assessment Pro-forma APPENDIX Asbestos Management Flow Chart APPENDIX RPE Maintenance Log RPE Inspection Record APPENDIX LARC Audit Form APPENDIX Quality Assurance Assessment - Analyst APPENDIX Standard detail for the temporary separation of areas Appendix Signing Out Procedures for Security 1 Keys Appendix Departmental Equipment Inventory- List of items known or suspected to contain asbestos... 67

4 1.0 The University of Sheffield Asbestos Management Plan Aims and Objectives The Asbestos Management Plan has been prepared in order to document the management strategy that the University of Sheffield has put in place in order to manage the risk presented by asbestos within the portfolio. The Control of Asbestos Regulations 2012 (Regulation 4) requires every duty holder to prepare a plan that sets out in detail how the risks presented by asbestos containing materials (ACMs) will be managed. This document discharges this responsibility. It is the University s intention for the Asbestos Management Plan to be the subject of regular review (at least annually) so that it continues to reflect the most current situation with regard to asbestos management practices and procedures within the portfolio.

5 1.1 Background The University of Sheffield is one of the United Kingdom s leading Universities, with over 24,000 students from 131 countries and almost 6000 staff. The University s history stretches back to 1828 when the Sheffield School of Medicine was founded. The University Charter was granted in With such a strong historic background many older buildings are present within the substantial portfolio. Given the age of the portfolio, asbestos has been extensively utilised particularly during periods of extensive development such as the 1960s and 1970s. This is a period which coincides with a peak in the importation of asbestos containing products into the UK What is Asbestos and its health effects? Asbestos is the common name for a number of naturally occurring minerals. The three main types used in Great Britain are Amosite (Brown), Crocidolite (Blue) and Chrysotile (white) asbestos. Amosite (Brown) and Crocidolite (Blue) are members of the amphibole group of minerals and Chrysotile (white) asbestos a member of the serpentine group of minerals.. Asbestos-containing products have been widely used in buildings as construction materials, fireproofing, thermal insulation, electrical insulation, sound insulation, decorative plasters, roofing products, flooring products, heat-resistant materials, gaskets, friction products etc. Since 1985 the new use of any material containing Amosite (Brown) and Crocidolite (Blue) asbestos has been prohibited. This means that in Britain there are many thousands of tonnes of asbestos still in buildings, where, so long as it is in good condition and remains undisturbed, it does not present a significant risk. Since 1999 the use of any building materials containing Chrysotile (white) asbestos has been prohibited in the UK. When asbestos is disturbed or damaged, the fibres are released into the air and are respirable which creates a risk to human health. The types of work that release fibres include, for example, drilling holes with power tools, sawing or sanding asbestos containing materials (ACM s). Simply working near to material containing asbestos might result in disturbance, particularly if it is in poor condition. Accidental damage, general wear and tear or vandalism can release fibres from the ACMs, for example in walls, ceilings and floor coverings. Asbestos is classified as a class 1 carcinogen by the World Health Organisation (WHO). All forms of asbestos may cause asbestosis (scarring of the lungs affecting a person s ability to breathe), lung cancer and mesothelioma (cancer of the lining of the lung or peritoneum). Exposure to amphibole asbestos fibres poses a greater health hazard than exposure to serpentine asbestos fibres, but all types can cause asbestos-related diseases. Therefore, where exposure to asbestos cannot be prevented entirely, exposure need to be reduced and controlled as far as is reasonably practicable.

6 2.0 Legislative Framework 2.1 The duties imposed by Regulation 4 of the Control of Asbestos Regulations 2012 supplement the provisions of the Health and Safety at Work etc Act 1974 (the HSW Act) and some of the duties imposed by other sets of regulations: 2.2 the HSW Act requires employers to conduct their work in such a way that their employees will not be exposed to health and safety risks, and to provide information to other people about their workplace which might affect their health and safety. Section 3 of the HSW Act contains general duties on employers and the selfemployed in respect of people other than their own employees. Section 4 contains general duties for anyone who has control, to any extent, over a workplace; 2.3 the Management of Health and Safety at Work Regulations 1999 (the Management Regulations) which require employers and self-employed people to make an assessment of the risks to the health and safety of themselves, employees and people not in their employment, arising out of or in connection with the conduct of their business and to make appropriate arrangements for protecting those people s health and safety. Any assessment made for the purposes of the Asbestos Regulations will not need to be repeated for the Management Regulations; 2.4 the Workplace (Health, Safety and Welfare) Regulations 1992 which require employers to maintain workplace buildings so as to protect occupants and workers; 2.5 the Construction (Design and Management) Regulations 2007 (CDM) which require the client to pass on information about the state or condition of any premises (including the presence of hazardous materials such as asbestos) to the CDM Coordinator before any work begins and to ensure that the health and safety file is available for inspection by any person who needs the information; 2.6 the Defective Premises Act 1972 in England and Wales or the Civic Government (Scotland) Act 1982 in Scotland place duties on landlords to take reasonable care to see that tenants and other people are safe from personal injury or disease caused by a defect in the state of the premises. Any premises in such a state as to be prejudicial to health constitute a statutory nuisance under section 79 of the Environmental Protection Act As well as imposing a duty to manage asbestos in premises, the Control of Asbestos Regulations 2012 require employers to: (i) (ii) (iii) Undertake risk assessments before commencing work which exposes, or is liable to expose, employees to asbestos; Produce a plan of work detailing how the work is to be carried out; and Either prevent exposure to asbestos or reduce it to as low a level as is reasonably practicable. 2.8 A range of other legislative requirements are also included, for example on the use and maintenance of control measures, protective clothing and equipment, and a duty to prevent the spread of asbestos.

7 The Regulation 4 duty of CAR 2012 complements the above duties and makes general legal duties specific to ensure that all the risks from asbestos are properly addressed. Regulation 4 of the Control of Asbestos Regulations places an obligation upon duty holders to manage the risk from asbestos in non-domestic premises. It explains the duties of building owners, tenants and any other parties who have any legal responsibility for the premises. It also sets out what is required of people who have a duty to co-operate with the main duty holder to enable them to comply with the regulation. The University of Sheffield, as an organisation, is defined as a duty holder under the terms of the Control of Asbestos Regulations (CAR) Regulation 4 of CAR 2012 requires duty holders to: (a) (b) take reasonable steps to find materials in premises likely to contain asbestos and to check their condition; presume that materials contain asbestos unless there is strong evidence to suppose they do not; (c) make a written record of the location and condition of asbestos and presumed asbestos-containing materials (ACMs) and keep the record up to date; (d) (e) assess the risk of the likelihood of anyone being exposed to these materials; and prepare a plan to manage that risk and put it into effect to ensure that: (i) (ii) (iii) any material known or presumed to contain asbestos is kept in a good state of repair; any material that contains or is presumed to contain asbestos is, because of the risks associated with its location or condition, repaired or if necessary removed; and information on the location and condition of the material is given to anyone potentially at risk.

8 3.0 Structure and Responsibilities A diagrammatic representation of the University of Sheffield Estates and Facilities Management structure:

9 3.0 Structure and Responsibilities (contd.) 3.1 The Director of Estates and Facilities Management is ultimately accountable for asbestos management at the University. 3.2 The Head of Property & Business Services is responsible for asbestos management within the portfolio. This responsibility is discharged through the asbestos management team, which is managed by the Asbestos Manager. 3.3 In addition minor projects, surveying, design responsibilities and space management are also discharged through the Property & Business Services team via a team of surveyors and project managers. All personnel within the section who are responsible for designing and instructing work activities which affect the fabric or infrastructure of a building have a responsibility for considering asbestos and ensuring that appropriate information is provided to those undertaking the work. Requests for survey or information relating to asbestos must be directed through the Asbestos Management Team. All personnel within the section have received UKATA approved asbestos awareness training which will assist them in discharging their obligations. 3.4 The Head of Engineering & Maintenance is responsible for the maintenance of engineering services across the portfolio. This responsibility is discharged through a team of engineers, surveyors and also through a direct works organisation, the structure of which is identified in Figure.2. The engineers who are responsible for instructing contractors have a responsibility for considering asbestos and providing relevant information to the contractor prior to any work proceeding. Requests for survey or information relating to asbestos must be directed through the Asbestos Management Team. Maintenance activities, both planned and reactive are undertaken by the direct works organisation known as Technical Services. All operatives within the technical services department have undertaken UKATA approved asbestos awareness and training including the use of appropriate RPE/PPE where appropriate.

10 3.5 The Head of Estates Development is responsible for the delivery of significant construction projects ranging from refurbishment to the construction of new buildings. This responsibility is discharged through a team of project managers, building surveyors, architects and clerk of works. The majority of projects executed by the Capital Projects team fall within the requirements of the Construction Design and Management Regulations 2007.The team represent the client who has a responsibility under the regulations to provide all relevant information to a contractor who will be executing work. A key aspect of the relevant information, particularly in connection with existing buildings, is information relating to asbestos. This would include both historic data and intrusive information gathered during a refurbishment and/or demolition survey specific to a project. Requests for surveys or information relating to asbestos must be directed through the Asbestos Management Team. Under certain circumstances asbestos abatement works may be carried out as part of larger capital projects. It is the responsibility of the Head of Capital Projects to ensure that the aims, objectives and procedures contained within the Asbestos Management Plan are communicated to all relevant project teams and contractors, and that the procedures are followed within all capital projects. 3.6 The Head of Estates and Facilities Management Finance section does not have a direct responsibility with regard to asbestos. 3.7 The administrative team provide support to the department but do not have a direct responsibility for asbestos. 3.8 The Head of Campus Services has a responsibility for facilities management services as listed within Figure 1. The responsibilities are partially discharged through a team of Facilities Managers and Assistant Facilities Managers. 3.9 Where external contractors are instructed or directly employed personal are utilised it is the responsibility of the Head of Campus Services and managerial staff to ensure that sufficient asbestos information is provided to allow any work activity to be undertaken safely The Technical Services Manager has responsibility for co-ordinating the maintenance and small works activities of the direct labour organisation. The structure of the section is identified in Figure The Technical Services manager and his supervisors have responsibility for assessing the likelihood of encountering asbestos during maintenance activities which are to be performed by the in-house operatives. The likelihood of encountering asbestos is determined by use of the flow chart which is contained within Appendix 4 of this document. It is the responsibility of the Technical Services Manager and his Supervisors to ensure that sufficient and relevant asbestos information is provide to those undertaking a work activity. All operatives within Technical Services have received UKATA approved asbestos awareness training and training in the use of RPE and PPE. It is the responsibility of the Technical Services Manager and Supervisors to ensure that all who need it have received the relevant training in order to allow them to undertake their work safely.

11 3.12 The Mechanical and Electrical Supervisors within Technical Services are responsible for directing the work activities of the directly employed operatives and instructing external contractors where necessary. They have responsibilities for assessing the risks associated with each work activity and providing relevant information on asbestos to those undertaking the work The Small Works Supervisor has responsibility for directing an in house team of small works building maintenance operatives. He has responsibility for assessing the risks associated with each work activity and providing relevant information on asbestos to those undertaking the work The Asbestos Management Team are responsible for asbestos management at the University. The team is comprised of the Asbestos Manager, the Assistant Asbestos Manager, One Asbestos Surveyor/ Co-ordinator & the Asbestos Administrator. The Asbestos Manager has the following responsibilities: Assisting the Head of Property & Business Services in discharging his responsibility for asbestos management. Preparing reviewing and updating the asbestos management plan. Programming and project management of annual asbestos abatement projects including administration of contracts under JCT form of contract. Reporting on progress and expenditure with regard to asbestos abatement and management. Project management of the preparation of asbestos management surveys across the portfolio including quality assurance of the same. Maintenance of the asbestos register. Management of the re-inspection of ACMs. Maintenance and review of the approved list of asbestos abatement contractors. Maintenance and review of the approved list of asbestos consultants. Provide a day to day for focus asbestos matters. Providing input on all capital projects involving asbestos. Arranging all asbestos awareness training (Discharged to Asbestos Administrator) Arranging other training appertaining to asbestos as required by individual needs and training needs analysis. Management and control of plant rooms which are categorised as red or amber including controlling access.

12 The Assistant Asbestos Manager has the following responsibilities: Assisting the Asbestos Manager with all aspects of asbestos related statutory compliance. Assisting the Asbestos Manager in reviewing and updating the asbestos management plan. Project Management of asbestos abatement projects including administration of contracts under JCT forms of contract. Undertaking Audits of Contractors & Consultants to provide quality assurance. Assisting in the maintenance of the asbestos register. Assisting in the management of the re-inspection of ACMs. Management and control of plant rooms which are categorised as red or amber including controlling access. Providing input on all capital projects involving asbestos. Assisting with workplace inspections, activity inspections and risk assessments to University areas in relation to asbestos. To deputise for the Asbestos Manager in his absence The Asbestos Surveyor/Co-ordinator has the following responsibilities: Undertake re-inspection of previously identified Asbestos Containing Material (ACMs) and compiling reports with recommendations. Undertake project management of small scale abatement projects. Developing and manage systems to organise the flow of work through the Survey Team. Assisting the Asbestos Managers with the management of asbestos in each building as required. Undertaking Visual Appraisals/ Assessment in relation to asbestos where required. Acting on findings of surveys where asbestos products pose a high risk to people or to the operation of University buildings to isolate or restrict access and to escalate details to the Asbestos Manager. To input and manage data on the University`s Property Management System MICAD and ensure the MICAD Asbestos Register is updated. This includes the validation of data.

13 Undertaking Audits of Contractors & Consultants to provide quality assurance. Providing input and advice into day-to-day activities to ensure all asbestos issues have been addressed for routine maintenance or estates works. The Asbestos Administrator has the following responsibilities: Creating and maintaining orders on Planon. Ordering and maintaining Asbestos Management Team stock (coveralls, masks etc). Processing invoices for payment. Assisting with budget management (e.g. Accruals) Producing permits to work (e.g. out of hours, hot work permits etc.) Key Risk Review Group Producing Papers, Agenda, Minutes of Meeting. Arranging and Administrating the UKATA Asbestos Awareness Course. Production of project boards relating to asbestos abatement projects for public display. Face fit testing of staff who require it. Any other administrative duties as required by the Asbestos Management Team The Asbestos Key Risk Review Group comprises the following members: Director of EFM (Chair) Head of Property & Business Services Asbestos Manager Assistant Asbestos Manager Head of Health and Safety Departmental Representatives Representative from Students Union Technical Services Manager Head of Engineering & Maintenance Management Representative of CICS

14 The group has responsibility for reviewing practices and procedures appertaining to asbestos management including the review and approval of the Asbestos Management Plan and any associated documentation.

15 4.0 Identification and Location of Materials Containing Asbestos (ACMs) 4.1 Background, Context & History. In 2004 the University commissioned Type 2 Asbestos Survey s (MDHS 100) across the portfolio. All Surveys were undertaken by a UKAS accredited organisation. Once complete, this survey information was inputted into a purpose designed module of the estate management data base known as MICAD. The system holds report information, photographs and CAD based plans which have been populated with information identifying the location of asbestos. The MICAD system runs alongside the works ordering system Planon to offer a full suite of tools for asbestos information checking and work ordering. In September 2010, a review of asbestos management procedures identified deficiencies in the information held within MICAD. Since this time the MICAD system has been made available only to the asbestos management team. From that time onwards the University operated a system described in the now superseded document ACOP L143 accompanying the Control of Asbestos Regulations (page 22) as Option 2. Primarily all materials which are not recognised are presumed to be asbestos and are therefore inspected and or sampled by a UKAS accredited organisation. Following a re-structure of the asbestos management team, a new asbestos manager was appointed in June 2012, the assistant asbestos manager and asbestos administrator in December 2012 and the asbestos surveyor in June As determined by the asbestos management team, where a full sampling survey is not required a visual appraisal/ assessment pro-forma has been developed; a copy of which is appended to this document (Appendix 3). All visual assessments shall be allocated a specific VA reference number. Voids within the premises such as ceiling voids, ducts and risers were generally not inspected thoroughly or were excluded from the 2004 survey. All such areas are presumed to contain asbestos and must be inspected before they are accessed. As the new asbestos management surveys become available this practice is expected to decline. The procedures as listed above are considered to be interim measures which are necessary until the portfolio is fully re-surveyed (Management Surveys carried out in accordance with HSG 264) and the MICAD asbestos register is re-populated with an anticipated completion date toward the mid to end of The prioritised methodology for re-survey was developed with buildings considered to be higher risk surveyed first. The first tranche/ batch of buildings to be resurveyed was complete mid The second tranche/ batch of re-surveys commenced in June 2013 and is expected to be complete circa October 2014.

16 4.2 Plant Areas All known plant rooms within buildings constructed prior to the year 2000 have been recorded on the plant room register. All plant rooms have been inspected and risk assessed with the relevant details incorporated into the register. All plant rooms which have been assessed have been categorised as follows: Red High risk ACMs & contamination are present in a friable condition. The contamination is such that any work activity, including inspection activities and basic access in to the room/ area has the potential to disturb asbestos fibres. In order to minimise the risk of exposure to asbestos fibres PPE/ RPE must be worn during all activities including access into the areas. Amber High risk ACMs are present in a condition which is considered safe if left undisturbed. Assessments identify no elevated risk of exposure to asbestos fibres when purely accessing these areas, providing no other work is being carried out on the asbestos which is present. There is no requirement to wear PPE/ RPE when simply accessing these areas. Green A plant room which either does not contain ACMs or contains low risk bonded asbestos products. The main types of asbestos products which may be present are: gaskets, jointing compounds, flash guards or vinyl flooring. There is no requirement to wear PPE when working within green plant rooms unless the work involves the disturbance of low risk asbestos products at which time the appropriate procedures should be followed.

17 Labels as shown above are affixed to plant room doors indicating the colour coding. In addition Plant rooms categorised as red have had the locks changed to a security one type in order to control access. Security-one keys are signed out on an individual basis by either the Head of Property & Business Services or a member of the Asbestos Management Team (See Appendix 9 for (procedures for signing out security 1 keys). Keys can only issued when the staff member or operative has met the criteria set out within the risk assessment and method statement which is specific to each plant room (this information is held by the asbestos management team, on MICAD and also contained with the plant room itself). All plant rooms categorised as RED have undergone reassurance and personal air monitoring by a UKAS accredited organisation whilst simulating inspection activities. In order to gain access into a red categorised plant room the individual must meet the following criteria: Received asbestos awareness training. Undergone face fit testing (in possession of a face fit certificate) and training in the use of RPE and PPE including safe disposal. Be in possession of risk assessment /method statement including the air monitoring certificate and where appropriate the asbestos management survey. Implement the control measures set out within the site specific method statement. All plant rooms categorised as red have also undergone Management Surveys (full sampling) which have been carried out to accord with the recommendations of HSG Pre-construction information Where construction or maintenance work is planned the proposed work area will be subject to an intrusive investigation known as a Refurbishment and Demolition (RAD) survey (HSG 264). This type of investigations is required where ever the fabric of the building will be affected by construction or maintenance activities. All RAD surveys shall be undertaken by one of the University s approved UKAS accredited organisations. In order to undertake a RAD survey the design of the proposed alterations must be sufficiently developed and such information must be provided to the surveying organisation. All asbestos surveys are arranged by the Asbestos Management Team. Requests for surveys to be undertaken are submitted utilising the PF16A form. The surveyor, project manager or engineer requesting the work is responsible for collating sufficient information to allow the survey to proceed. Both the PF16A form and the guidance note on the use of it are appended to this document (see Appendix 1). The timing of the request for survey information is important as the RAD survey report should form part of the pre-construction information formulated by the CDM co-ordinator where ever these Regulations are applicable to a construction project.

18 In some circumstances a project may not require notification under the terms of the CDM Regulations 2007 due to its limited duration. However in these circumstances it may remain necessary to undertake a RAD survey where ever the fabric of the building or infrastructure is worked upon unless the building has been constructed post A copy of the RAD survey must be maintained on site for the duration of the construction or maintenance activity. 4.4 Management Surveys General review The procedures set out within section 4 of this document are considered to be interim measures. It is the University s intention to implement a programme of Asbestos Management Surveys compliant with the recommendations of HSG 264:: The Survey Guide. The portfolio of buildings has been prioritised and broken down into two tranches. Tranche I contained the buildings which were considered to be of a higher risk. These surveys were complete mid The re-survey of the second tranche of surveys commenced in June 2013 and is to be finalised and complete around October An asbestos management survey will be undertaken for each University building constructed prior to The information contained within each survey report will be inputted into the MICAD asbestos register and a PDF copy uploaded.. Although all surveys must comply with the requirements of HSG 264: The Survey Guide. The University Asbestos Management Team has also produced an additional document: Specification for Undertaking & Reporting of Asbestos Management Surveys. All surveys undertaken at the University must also comply with this document.

19 5.0 Asbestos Abatement Work Based upon the findings of inspections and surveys a prioritised programme of abatement work within each financial year is being continually developed, focusing primarily upon plant areas. Abatement works have been prioritised based upon asbestos risk, the frequency of access required to an area and the impact of potential failure upon business continuity. It is the immediate aim of the abatement programme to improve the environment of plant rooms by the removal of asbestos contamination. However it is acknowledged that this programme may change as a result of the re-survey of the portfolio. For this reason the asbestos abatement programme will be subject to regular review. A copy of the current abatement programme is contained within Appendix 2 of this document. A robust methodology has been developed for implementing asbestos abatement work. All abatement projects are to follow the following sequential methodology: An appropriate survey (either management or refurbishment and demolition) to be prepared by a UKAS accredited organisation. Scope of work accurately detailing the extent of the work prepared by an asbestos consultant for all projects. Works package tendered by the University to approved list of asbestos removal contractors. The University will determine if the CDM Regulations apply to the works. If so the University will appoint a CDM coordinator. The asbestos consultant will receive the contractor s plan of work and copy of the form ASB 5 which is submitted to the HSE. The analyst will confirm to the University that the plan is appropriately developed to allow the work to commence. A copy of the ASB 5 Notification and the plan of work are to be forwarded to the University Asbestos Management Team. Upon commencement of the work, the analyst will monitor quality and progress of the work. This may involve enclosure entry where appropriate. The University Asbestos Management Team will also undertake an unannounced audit of the licensed asbestos contractor. A copy of the audit form is contained within Appendix 6. At completion of the project and specifically before the issuing of the certificate of re-occupation, each project shall be subject to an quality assurance audit by an appropriate member of the University Asbestos Management Team or if unavailable a separate independent UKAS accredited analyst. This audit will be undertaken between Stages 3 & 4 and then also post stage 4 of the 4 Stage Clearance process (as detailed in HSG 248: The Analysts Guide). A copy of the form is contained within Appendix 7. The consultant shall be responsible for providing a project information pack following the successful execution of the work. The project completion pack shall include the following elements:

20 a. Asbestos Survey b. Specification for the scope of removal c. ASB5 notification d. Contractor plan of work e. Analyst confirmation of POW acceptance f. Certificate of re-occupation g. Air monitoring paper work h. Waste consignment notes where received prior to completion. i. Updated copy of survey/ Re-inspection report reflecting changes following abatement The project completion pack will ultimately be held within the MICAD asbestos module as a PDF file in a directory that is specific to the building. 5.1 Analysts and Surveyors The University of Sheffield will utilise external organisations for analytical and survey activities who hold the relevant UKAS accreditations. The University maintains an approved list of organisations which are deemed competent to carry out this work. The performance of all asbestos consultancies will be carefully monitored by the Asbestos Management Team and the approved list will be reviewed regularly. 5.2 Asbestos Removal Contractors The University of Sheffield will utilise external organisations for asbestos abatement and maintain an approved list of organisations which are deemed competent to carry out this work In general, any abatement contractor working on the University of Sheffield must: Hold a valid 3 year licence for work with asbestos insulation, asbestos coatings and asbestos insulating board as defined by The Control of Asbestos Regulations Hold Employers Liability Insurance to a minimum of 10,000,000 and Public Liability Insurance to a minimum of 5,000,000. Be a member of a relevant Industry Association (i.e. ARCA/ACAD) Only use licensed sub-contractors for all ancillary work where applicable (i.e., scaffolding etc).

21 Be registered under the Construction Health and Safety (CHAS) Scheme, or be able to demonstrate they are actively seeking registration The performance of contractors will be reviewed regularly by the asbestos management team. Part of this will involve a site audit as detailed in the University document LARC Audit Form Rev.01. Inadequate performance will lead to the contractor being removed from the approved list. 5.3 Types of Abatement Work When considering plant areas, it is preferable to remove the asbestos in its entirety, however this may not be possible due to programme, cost, physical or other constraints. For this reason a suite of options have been considered. In some cases these options are a short term solution in order to maintain the operation of a building. All of the options considered other than complete removal have continued maintenance and re-inspection implications. All options will be executed by a licensed contractor irrespective of the scale or type of work. 1. Sheeting out / separation of contaminated areas. In some plant areas, contamination may be limited to a defined area. In such circumstances the area can be sheeted out by the erection of timber and polythene screens or plasterboard and overlaying of the floor. This is by no means a permanent solution but can be considered as a holding measure in order to allow continued access and maintenance. However this option will necessitate a robust inspection and maintenance regime. Under normal circumstances this work would not be notifiable to the HSE as it is work adjacent to asbestos containing materials rather than upon such materials. However this work would be carried out by a licensed contractor working under the supervision of an analyst. Any sheeting out will require a strict maintenance regime to ensure that it remains intact. Maintenance of such areas will be undertaken by a licensed contractor. A standard detail for the temporary separation of areas has been developed, a copy of which is appended to this document (Appendix 8). 2. Permanent separation. Where a contaminated plant area adjoins an area which is free from contamination it may be possible to permanently divide the two areas. The divided area would then not be restricted due to contamination. This category of work could be considered as a quick win being potentially non notifiable (depending upon the nature of the environment) and producing a permanent solution for at least one of the areas. 3. Environmental clean and encapsulation. This option will be notifiable to the HSE as asbestos abatement work in all cases. It may be possible to clean loose debris from an area and encapsulate materials which have minor damage. This is considered to be a longer term holding measure but will limit some maintenance activities and the work will be abortive when a final clean is executed. This category should therefore only be considered where absolutely necessary and when a full strip will

22 not be achieved for a few years. This methodology is also inappropriate where asbestos residues are present upon plant and equipment. 4. Full strip. This is the preferable solution which is also notifiable to the HSE and will be considered wherever plant rooms are heavily contaminated or residues are present on plant and pipe work which will hinder maintenance operations. This option whilst preferable incurs the greatest cost and requires significant advanced planning.

23 6.0 Monitoring the Condition of ACMs As part of the University s ongoing duty to manage asbestos, the condition of known and suspected ACM s must be assessed and recorded. Regulation 4 CAR 2012 L143: 9) The measures to be specified in the plan for managing the risk must include adequate measures for: (a) Monitoring the condition of any asbestos or any substance containing or suspected of containing asbestos. All ACMs identified are currently re-inspected by a UKAS accredited consultancy. In the longer term, the asbestos management team may assume responsibility for undertaking re-inspections. The frequency of re-inspections is primarily determined by risk; identified by the material assessment score and the priority risk assessment. As no re-inspection frequencies are specified in L143 Managing and working with asbestos. To arrive at a practical and achievable working practice, the University has adopted the following practice: Products identified as high risk are re-inspected every 6 months, Products identified as medium risk every 12 months Products identified as low risk products every 24 months Should a material risk rating change upon re-inspection (e.g. low to high), the frequency of re-inspection for all similar materials will increase. Abatement works found as a result of the re-inspection process will be implemented utilising the procedures set out within Section 5. The abatement actions will ultimately be recorded within the MICAD database when it is re-populated. Until this time the information is held on a spread sheet which is maintained by the Asbestos team. Plant rooms that have been categorised as red will be re-inspected every six months. Plant rooms categorised as amber or green will be re-inspected every 12 months. The re-inspection of plant rooms will be undertaken by either the Asbestos Management Team and/or a UKAS accredited surveying organisation. The inspection will primarily be carried out to confirm that the conditions of ACMs within the room have not deteriorated. The inspection will also be utilised to review the following housekeeping matters and provide additional relevant information: The room is correctly labelled and referenced in accordance with the colour coding set out within section 4 of this document. The room is secured by the use of a security 1 key (Red Plant Rooms only). Facilities are available for the disposal of RPE and PPE. Installing relevant information about the plant room to the rear of the door. Reviewing the potential for asbestos abatement work. Reviewing and confirming the appropriateness of the risk assessment and method statement

24 Further categorise the plant room to assist in the prioritisation of abatement work.

25 7.0 Communication The University recognises the importance of communicating the content of the asbestos management plan including the requirements of current legislation so that those who may encounter asbestos are aware of their obligations and the obligations of others. 7.1 Training All staff members who are likely to encounter ACMs during the course of their normal work activity have received asbestos awareness training (Category A) delivered by a UKATA registered organisation. The training meets the requirements of Regulation 10 of the CAR and includes the following: The properties of asbestos and its effect on health, including the increased risk of developing lung cancer for asbestos workers who smoke. The types, uses and likely occurrences of asbestos and asbestos materials in buildings and plant. The general procedures to deal with any emergency e.g. an uncontrolled release of asbestos dust into the work place. How to avoid the risk of exposure to asbestos. The training course includes a written assessment, with the University requiring all operatives to achieve the minimum pass mark. In addition, bespoke training has been developed and delivered by the asbestos management team which are specific to the University such as the categorisation of plant rooms, Interpreting asbestos surveys and the requirement for visual assessments prior to implementing work affecting the building fabric. All individuals who have received training are recorded within the online database and managed by the asbestos administrator.. Refresher asbestos awareness training will be provided annually. During the course of their work activity it may be necessary for certain personnel to enter areas which have been categorised as red. The University s policy is to require the use of PPE/RPE in such areas. Training and face fit testing is provided for those who need it by either the asbestos management team or an external accredited organisation. All plant rooms which have been categorised as red have received air monitoring, a risk assessment and method statement.

26 7.2 Procedures A flow chart illustrating the University s interim asbestos management procedures has been developed and published on the University s Intranet for internal access only. A copy of the chart is appended to this document (see Appendix 4). The asbestos management plan will also be published on the University s intranet along with the current abatement program and access will be provided to all who need to see it. 7.3 Asbestos Key Risk Review Group The asbestos key risk review group has been established as an interface between the Department of Estates and Facilities Management, (which has a direct responsibility for managing asbestos) and other departments of the University, including building occupiers. The group meets every 6-7 weeks to discuss asbestos management and asbestos related issues. The meeting is chaired by the Director of Estates and Facilities Management and a report is produced and tabled at each meeting by the Asbestos Manager. This provides an opportunity to disseminate information whilst receiving feedback from the various affected parties. The Asbestos Key Risk Review Group comprises the following members: Director of EFM (Chair) Head of Property & Business Services Asbestos Manager Assistant Asbestos Manager Head of Health and Safety Departmental Representatives Representative from Students Union Technical Services Manager Head of Engineering & Maintenance Management Representative of CICS The group has responsibility for reviewing practices and procedures appertaining to asbestos management including the review and approval of the Asbestos Management Plan, the Asbestos Management Operational Procedures (currently under development) and any associated documentation.

27 8.0 Providing Information to Those Who Need It Any person who is likely to carry out work upon the building fabric or infrastructure, or enter any void which is not normally occupied will need relevant asbestos information. Information on asbestos will need to be provided to; personnel employed directly by the University and external contractors who are commissioned to carry out work upon the University s behalf. 8.1 Directly employed personnel Maintenance All maintenance activities are entered onto the Planon system. Planned Preventative Maintenance (PPM s) activities are generated automatically at set intervals. The Technical Services Manager and supervisors will assess the nature of a maintenance activity considering the activity flow chart and the age of the building. (all managers and operatives have received UKATA approved asbestos awareness training) Where appropriate, based upon the activity flow chart (contained within Appendix 4), an activity will be placed on hold pending an asbestos survey or visual assessment. Where no reliable existing survey information is available, a visual assessment or survey will be arranged by the asbestos management team. A UKAS accredited surveying organisation will be used to either undertake a visual assessment, utilising the pro-forma appended to this document (See Appendix 1) or to undertake a full sampling survey. Visual assessment may also be undertaken by an appropriate member of the asbestos management team. Once complete a member of the asbestos management team will review the findings of the assessment and advise accordingly.

28 8.1 Directly employed personnel Maintenance (Contd.) Where the work activity can proceed, the survey information is provided to the operative undertaking the work. Where work can proceed with control measures in place the instigator of the work is required to liaise with the asbestos management team. Relevant information shall be sent to the individual undertaking the work by the instigator of the order. 8.2 External contractors Maintenance Activities The project manager, surveyor or engineer instructing the work activity is responsible for providing relevant asbestos information to those undertaking the work. All external contractors shall follow the University s control of contractors procedures. (Version 3). Information relating to plant rooms can be obtained from the plant room register as described within Section 4 of this document. Requests for RAD surveys are made by reference to the asbestos management team and shall all be allocated a Planon and WKS reference number (for RAD) or VA reference number (for Visual Assessment/ Appraisal) as detailed below in Figure 3. Work cannot proceed until adequate asbestos information has been made available to those intending to undertake the work; they have assessed the risks posed by ACMs (if any) and have appropriate control measures in place.

29 8.2 External contractors Maintenance Activities (contd.)

30 8.2 External contractors Maintenance Activities (contd.) All operatives working on the University of Sheffield s property portfolio must have undertaken appropriate asbestos awareness training. It is the responsibility of those instructing the work to ensure that organisations have provided their operatives with appropriate training. In order to gain approval onto the Universities approved suppliers list, contractors must demonstrate that their staff/ operatives have undertaken asbestos awareness training. Where the training is not UKATA approved, a copy of the training material is requested and vetted by the asbestos management team to ensure it meets the requirements of Regulation 10 of CAR External contractors Projects It is a client responsibility where ever a project is notifiable under the CDM Regulations (30 days or 500 person days) to provide relevant information upon a project. The University employs a team of professional engineers and project managers who represent the client on all projects. In relation to buildings constructed prior to 2000 relevant information includes information about asbestos. All projects will require a refurbishment and demolition survey (HSG264) as defined in section 4.1 of this document. Sufficient planning is required to ensure that this information is available pre-tender, and will be collated by the CDM coordinator as part of the preconstruction information pack. All Refurbishment and Demolition surveys (HSG: 264) are undertaken by approved external UKAS accredited consultants who are instructed by the University Asbestos Management Team. The procedure for requesting a RAD survey is set out within section 4.1 of this document. Where projects are not notifiable under the terms of the CDM Regulations a RAD survey will be required where the building was constructed prior to 2000 and the fabric of the building or infrastructure is likely to be affected by the works. The Estates Development team shall ensure that budgets are established which are sufficient to accommodate all necessary and associated asbestos abatement works. Project managers shall liaise with the asbestos team with regard to asbestos abatement work in connection with all capital projects. All significant capital projects shall make adequate provision for the removal of asbestos in all refurbished and associated areas of the building. All refurbished buildings shall be free, as far as reasonably practical, of all restrictions upon maintenance following asbestos abatement work. All projects, irrespective of the procurement route employed shall adopt the procedures set out within this document.

31 9.0 Review of Asbestos Management Plan At present the Asbestos Management Plan is considered to be an interim plan. To support the management plan, asbestos management operational procedures are currently being and developed. As sections of the procedures are developed they are reviewed by the asbestos key risk review group as part of the meetings. The plan is set out at a high level establishing the current practices and procedures which are adopted by the University of Sheffield in managing asbestos. As the portfolio is re-surveyed the procedures will be amended to reflect the comprehensive use of the MICAD asbestos register.

32 10 Buildings which do not contain asbestos The importation, use and supply of Crocidolite (blue) and Amosite (brown) asbestos products was prohibited in the United Kingdom in All other remaining asbestos products were banned in It is therefore safe to conclude that buildings constructed post 2000 were not constructed with asbestos containing materials (ACM s) and it is therefore not necessary to survey them or follow the procedures which have been set out within this document when working within them. The following buildings were constructed after 2000: Building Code (BC) Building Name 346 The Edge 639 Arthur Willis Environmental Centre 640 Arthur Willis Environmental Research Centre Green house 1225 Florey Building 1305 Hicks Neutron Block 1507 Information commons 1611 ICOSS 1620 Health Centre 1663 Bio Incubator 1664 Jessop West and Visitor Centre 1665 Sound House 1811 St Georges rainfall Chamber Hoyle Street Opal ELTC 8301 Humphrey Davy House 8304 AMRC Waverley 8306 AMRC Phase Sitran No BC No BC Alfred Denny Substation CICS Generator Building The Ridge Pam Liversidge Building The Diamond (Under Construction)

33 11 Disposal of Asbestos Waste Products The disposal of all asbestos waste products which are encountered outside of an asbestos removal project shall be disposed of by an external asbestos licensed contractor, obtained from the University s approved list only PPE Resulting from Accessing Plant Areas Categorised as Red. The University will enter into an agreement with a licensed asbestos removal contractor to undertake the following activities. The frequency of this agreement will depend on access requirements into the specific area. 1. Visit plant areas categorised as Red (depending upon the frequency of use) and remove all used PPE/ RPE. 2. Install new waste bags. 3. Maintain and provide waste consignment notes. 4. Repair any minor damage to air lock systems that have been constructed (where applicable) 5. Ensure that the entrance to the area is clean, tidy and safe Departmental Equipment Containing Asbestos Where equipment is believed to contain asbestos, the asbestos management team are to be advised, via contact from the EFM help desk. The asbestos management team will arrange for a licensed asbestos removal contractor to attend site and remove the equipment to an appropriate waste disposal site. The contractor will provide a waste disposal certificate directly to the asbestos management team. In addition, the asbestos management team will maintain a log of equipment which has been disposed of and relevant waste consignment notes. Where departments are un-sure as to the asbestos content of equipment, they shall refer to the asbestos management team by contacting the EFM help desk. A copy of the equipment ledger send out to departments is contained within Appendix 10 of this document.

34 12.0 Emergency Procedures & Escalation Protocol Refer to Asbestos Management Operational Procedures (AMOP) Section 12: Emergency Procedures Escalation Protocol

35 13.0 Personal Protective Equipment PPE (including RPE) The University of Sheffield will provide appropriate PPE and RPE to all university staff personnel requiring it. This is supported by the leaflet ASB-1 Procedures for the use of PPE & RPE as produced by the Asbestos Management Team. Copies of the leaflet have been given to staff members requiring access to areas categorised as red. In addition, copies of the leaflet are also available from EFM Helpdesk FFP3 Respiratory Protective Equipment (RPE) Either re-usable half face masks or disposable masks are provided as respiratory protection. All RPE shall be of an FFP3 type. Both re-usable and disposable masks provide an identical level of protection. All employees who need to use respiratory protection are face fit tested. An individual certificate is issued to record the testing procedure which is undertaken by the asbestos management team and/ or the appropriate external consultancy. Disposable masks (RPE) following a single use shall be disposed of as contaminated waste. In plant areas which are categorised as red, asbestos waste bags are provided for this purpose. Re-usable half face mask are issued to those employees who regularly enter areas which are categorised as red or who may prefer to use this type of mask. Personnel are instructed in the maintenance and cleaning of masks as part of the face fit testing procedure Re-usable half face mask maintenance It is the responsibility of each staff member to ensure the cleanliness and maintenance of the RPE which have been provided. RPE which has been damaged must not be used and will be replaced by the asbestos management team. The following maintenance schedule will be adopted: Before use After use Annually Visual inspection Functional check Cleaning Membrane change Head harness change

36 Each individual will record their RPE maintenance inspections. A copy of the log produced for this purpose is appended to this document (see Appendix 5). Supervisors shall review the maintenance log of individuals, for whom they have a management responsibility at regular intervals. The asbestos management team will also undertake spot checks to ensure this is being followed Disposable overalls and over boots (PPE) Disposable overalls which conform to BS EN ISO Category 3, Type 5/6 standards shall be utilised together with disposable over boots when entering plant rooms which are categorised as red (see section 4.2), in addition to the use of respiratory protection identified above. The use of such overalls and the disposal of the same are covered within the face-fit training. All necessary RPE and PPE shall be obtained by the operative prior to attending site. For member of University staff these can be obtained via a member of the asbestos management team.

37 APPENDIX 1 PF16A and Guidance Note

38 Estates & Facilities Management. PF16a Asbestos Survey Request Ref No: In order to assess asbestos presence/removal, please arrange an asbestos survey for: Please see guidance note for information required 1 Project Title: 2 Project Officer/Manager: Contact No: 3 Building: Building Code: 4 Department: 5 Uses, Processes, Hazards and Priority Areas: 6 Room Numbers/Key Numbers 7 Department Contact: Contact No: 8 Ceiling Heights (for access) 9 Details of Restricted Access and/or Occupied Areas 10 Out of Hours Contact: 11 Drawing Enclosed: YES/NO* 12 Service Routes YES/NO* Identified: 13 Project Start: 14 Working Hours: Normal Hours/Out of Hours* 15 Additional Information: 16 Charge Code: 17 Signed Project Officer/ Manager: Date: * Please delete as necessary NB: all fields must be completed before a request can be actioned. Continued/

39 For Asbestos Team Use Only Proposed Asbestos Survey Start: Proposed Asbestos Survey Finish: Quotation: Date of Report: Recommendations Summary: Budget Cost/Quotation for Removals: 14 Day Notification to HSE Required?: Yes/No* Estimated Period for Removal Works: CDM applies?: Yes/No* Action Required: Survey acknowledged by Asbestos... Management Team: Date:... * Please delete as necessary

40 Guidance Note for Asbestos Survey Request 1 Project Title: Self explanatory. 2 Project Officer/Manager: Person in charge of project. 3 Building: Name of building and building number. 4 Department: Department work to be carried out for. 5 Uses, Processes, Hazards and Priority Areas: Identify the activities which currently take place in the space to be surveyed. Do the activities or the equipment pose a potential hazard to the surveyor? 6 Room Numbers/Key Numbers: All rooms to which access is required and the numbers of keys, or if department contact is required for access. 7 Department Contact: For access and arrangements for survey times, dates. 8 Ceiling Heights: For access (ladders, tower scaffold etc). 9 Details of Restricted Access and/or Occupied Areas: To arrange access or for area to be vacated during the survey. 10 Out of Hours Contact: Who should be contacted out of hours in the event of an query or incident? 11 Drawings Enclosed: These should be marked up showing all areas to be surveyed and service routes to be used (including vertical). 12 Service Routes Identified: This should include all service routes including CICS data cable routes. (If these are not identified at the time of the survey it will result in extra costs to be surveyed at a later date). 13 Project Start: The proposed start date for works (this must take into consideration the size/ scope of the works to allow sufficient time for a detailed survey to be undertaken, the report produced and if required any subsequent asbestos abatement works. 14 Working Hours: Can the survey be carried out in normal working hours or must it be carried out/arranged out of normal working hours? 15 Additional Information: Any other relevant information. 16 Charge Code: Must be provided before survey can commence. 17 Signed Project Officer/Manager: Signature required. Note: Ideally, there will be a meeting between the individual instructing the work, a member of the asbestos management team and the asbestos surveyor before commencement of the survey. The meeting will enable all concerned to discuss the scope of works, and if areas need to be vacated/furniture removed. RAD surveys can only be undertaken in unoccupied areas. Ideally areas should be vacant. If this cannot be achieved then the survey must be undertaken outside normal working hours.

41 APPENDIX 2 Current Abatement Program

42

43 APPENDIX 3 Visual Appraisal/ Assessment Pro-forma

44 Estates & Facilities Management. Asbestos Management Visual Appraisal This form is utilised to record the findings of a visual assessment undertaken by a qualified Asbestos Surveyor so as to allow minor works, which may affect the fabric of the building, to proceed. The assessment is specific to the activity and location identified and should not be relied upon for any other purpose. Building Code / Name Floor Assessor Name Signed Drawings Appended VA Number Room(s) / Areas Assessed Survey Organisation Date Photographs Appended Elements Inspected Ceiling Void Ceiling Wall Void Walls Floor Void Floor Riser Duct Fabric Fixing Nature and location of proposed work: Inspection description: Inspection findings: Special considerations / limitations: Sampling Required? Further inspection required? CAN THE WORKS PROCEED? YES NO

45 Guidance Notes The visual assessment form is to be utilised in connection with simple work only which would normally rely upon information contained within a management survey or within the asbestos register. Typically it will be utilised to facilitate minor work such as installing shelves and notice boards or accessing voids for routine maintenance work. All assessments will be undertaken by either the Asbestos Management Team and/or qualified asbestos surveyors working for UKAS accredited organisation. The form should also be accompanied by a drawing locating the extent of the visual assessment unless not required for a specific reason. Where a drawing is unavailable then the surveyor will provide a sketch to be appended to the completed form. The assessment will culminate in a positive or negative response clearly determining whether a piece of work can proceed. Where further investigation is required or the surveyor recommends a full survey then the work cannot proceed. The surveyor will use his professional judgement to determine whether the assessment is sufficient or not. The pro-forma will be completed by hand but will either be scanned or typed so that the information can be retained centrally. The procedure will be necessary only until a building has received a full management survey or unless otherwise specified.

46 Completing the Form 1. Building code and name. 2. Floor level and room number/ area accessed of the intended work. 3. The name of the surveyor undertaking the visual assessment/ appraisal.all spaces are allocated a MICAD reference which must be utilised to define areas of work. 4. If drawings are appended to the form. 5. The specific VA number Produced and recorded by the Asbestos Administrator. 6. The date the visual assessment/ appraisal was undertaken on. 7. If photographs were taken and appended. 8. The exact elements that were inspected (i.e. ceiling void) 9. Identify the reason for the inspection (e.g. access to within ceiling void in order to facilitate filter change of air handling plant). 10. The findings of the inspection (i.e. no suspect materials identified) 11. Any special consideration that need to be taken into account. 12. Based upon the visual assessment the surveyor, based upon his professional judgement will determine if the work can proceed. Any matters of concern will prevent the work from proceeding and will necessitate a full sampling survey. 13. The surveyor will determine where a full survey will be necessary in order to allow the work to proceed. Where a full survey is recommended the work will not proceed. 14. The surveyor will clearly set out any limitations which may be imposed upon the work. 15. Can the work proceed? - Based upon the visual inspection and considering the criteria identified above, the surveyor will ring YES or NO indicating whether the works can proceed.

47 APPENDIX 4 Asbestos Management Flow Chart

48 Interim Asbestos Management Plan Flow Chart Planon Request to Engineer or Surveyor. Yes/ Unsure Is the work in a Plant Room and on the plant room list? No Review plant room spreadsheet & contact Asbestos Management Team Green Proceed with caution and see conditions on order. Red Amber Consider scope of work. Is work likely to disturb sealed asbestos eg encapsulated asbestos? No Yes Is building constructed post 2000? Yes Has risk assessment been done? No Request risk assessment from Asbestos Team before work proceeds. No Yes Proceed with work. Is work covered by method statement? Yes Proceed with work based on risk assessment & method statement or survey. No Provide details of activity request to Asbestos Management Team to obtain assessment & method statement &/or asbestos survey. Does work involve any of the following activities: 1. Drilling/fixing to or opening up the structure 2. Dismantling 3. Access into any void floor ceiling vertical riser, trench or duct? 4. Work on any pipes, flanges or flues? 5. Internal parts of plant & No Yes Note: If any asbestos products are found stop work immediately and contact the Asbestos Management Team.

49 APPENDIX 5 RPE Maintenance Log

50 RPE Inspection Record User Name Size Model/Type Date Head Harness Face Piece Valves Filters Changed Remarks/Comments Signature

51 APPENDIX 6 LARC Audit Form

52

53

54

55

56

57

58

59

60 APPENDIX 7 Quality Assurance Assessment - Analyst

61

62

63 APPENDIX 8 Standard detail for the temporary separation of areas

64

65 Appendix 9 Signing Out Procedures for Security 1 Keys

66