CP 347 ASBESTOS POLICY Broad Recommendations / Summary Asbestos is a naturally occurring mineral present in many building materials, found particularly in the older buildings built prior to 2000. Inhalation of a significant quantity of asbestos fibres can lead to asbestosrelated diseases. Asbestos is the greatest single cause of work related deaths in the UK. Hull and East Yorkshire Hospitals NHS Trust has a duty under the Health and Safety at Work Act 1974 to ensure, so far as is reasonably practicable, the health, safety and welfare of employees, self-employed persons, contractors, members of the public in general and those whom are specifically in our care. Asbestos is only a risk to health if asbestos fibres are released into the air and breathed in. There is usually a long delay between first exposure to asbestos and the onset of disease; this can vary from 10 to 60 years. The Control of Asbestos Regulations 2012 requires employers to prevent the exposure to asbestos so far as is reasonably practicable. The Trust will take all reasonable precautions to reduce the exposure to asbestos to the lowest levels, by methods such as; restrictions of access, permit to work, marking of known or presumed asbestos and making available appropriate PPE. The Trust s Asbestos strategy is:- i) To identify and safely manage wherever practicable the presence of identified asbestos containing material; ii) To remove asbestos whenever the opportunity presents itself as part of alteration or refurbishment work, prior to demolitions, where necessary due to its condition or where maintenance work would require any potential disturbance of asbestos. It is not the Trust's strategy to systematically remove asbestos, but to consider the risk level of any asbestoscontaining materials found. In accordance with Regulation 4 - Duty to Manage of the Control of Asbestos Regulations, the Trust has an Asbestos Management Plan which must be referred to and followed whenever work is carried out on buildings built prior to 2000. This is the key document for the safe management of asbestos in the Trust. To assist the Trust in the delivery of the Asbestos Management Plan and to support the Trust s Asbestos an Asbestos Consultant has been appointed. The duties of the Asbestos Consultant are set out in Appendix 1. 1
CP 347 ASBESTOS POLICY 1 PURPOSE / LEGAL REQUIREMENTS / BACKGROUND This document sets out the approach to be adopted by the Trust for the management of asbestos in sites under its control, as detailed in the Asbestos Management Plan. The main aim of this policy is to fully comply with Regulation 4 of the Control of Asbestos Regulations 2012. This document will identify the procedures to follow in order to comply by the following actions:- Take reasonable steps to find materials likely to contain asbestos and to check their conditions. Presume that materials contain asbestos unless there is strong evidence that they do not. Make a written record of the location and condition of asbestos and presumed asbestos containing materials (ACMs) and keep the records up to date. Assess the risk of the likelihood of anyone being exposed from asbestos from these materials. Repair or remove any material that contains asbestos, if necessary because of the likelihood of disturbance, and its location or condition. Prepare an Asbestos Management Plan detailing how the risks are to be managed and ensure that:- Information on the location and condition of ACMs is made available/ given to people who may be at risk of disturbing them during work activities. Any material known or presumed to contain asbestos is kept in a good state of repair. Monitor the condition of known and presumed ACMs. Review and monitor the Asbestos Management Plan and the arrangements made to put in place regularly. This policy applies to all buildings that are owned and/or maintained by Hull and East Yorkshire Hospitals NHS Trust and covers activities where inadvertent exposure to asbestos may occur (e.g. maintenance, IT and telecoms, refurbishment and demolition work). It also applies to all staff in the Trust and appointed contractors who carry out works in all Trust buildings built prior to 2000 which may contain asbestos. 2 ASBESTOS MANAGEMENT PLAN 2.1 The Plan The Asbestos Management Plan has been designed with the purpose of managing the risk from Asbestos Containing Materials (ACMs) identified within Hull and East Yorkshire Hospitals NHS Trust, so that as far as reasonably practicable no one can come to any harm from ACMs on its premises. It is an integral part of the Trust s compliance with all current Health and Safety legislation regarding asbestos. 2
The main principles of Asbestos Management are to:- Assess Record Inform Monitor The Trust Asbestos Management Plan can be viewed on line via the following link: http://asbestos.hey.nhs.micadipr.net/idr-data/lite/policy/ampsept2018.pdf The Trust will endeavor to remove known asbestos in high intensity areas in order to mitigate risks to asbestos exposure, as oppose to the previous mark and manage strategy. 2.2 Training 2.2.1 All staff carrying out works that has the potential to disturb asbestos shall receive UKATA face to face asbestos awareness training every 3 years, this shall include: All Estates Operations staff who undertake or instruct staff on maintenance activities. Project s 2.2.2 Staff with direct responsibilities for projects or maintenance activities shall receive more detailed training in order to manage asbestos activities Training every 3 years. This shall include: Estates Officers Team Leaders Project s 2.2.3 All Estates Operations and Capital Development staff shall receive annual refresher training. This based on a watching a dvd and answering a questionnaire. 2.2.4. All new Estates Operations staff shall, as part of their meet with the Asbestos or one of their deputies in order to be shown the Asbestos Register and how it is accessed. 2.3 PFI The PFI buildings on Trust sites are managed by individual PFI providers and due to the age of construction (post 2000) it is assumed that there is no asbestos present. However as part of the assurance process this will be required to be confirmed as part of the Principles Meeting. 3. REFERENCES Asbestos Management Plan The Control of Asbestos Regulations 2012 and its Approved Codes of Practice, ( The Management of Asbestos in Non-domestic Premises, L127 and Work with Materials Containing Asbestos, L143) and Note HSG227 (A Comprehensive Guide to Managing Asbestos in Premises The Management of Health and Safety at Work Regulations 1999 The Health and Safety (Safety Signs and Signals) Regulations 1996 (as amended) 3
The Hazardous Waste (England & Wales) amended regulations 2016 4. PROCESS FOR MONITORING COMPLIANCE The monitoring arrangements are detailed below Element to be monitored Asbestos Register Staff Training Signage Permit to work Lead Tool Frequency Reporting Arrangements Asbestos Asbestos Asbestos Asbestos Audit of 20% of records on the Asbestos Register, sample information is up to date All staff are up to date with their relevant training An audit of 20 randomly selected samples check for appropriate signage An audit of 10% of permit to work documentation and other relevant forms Annually Annually Annually Annually Estates, Facilities & Development Risk Management & Compliance Committee Estates, Facilities & Development Risk Management & Compliance Committee Estates, Facilities & Development Risk Management & Compliance Committee Estates, Facilities & Development Risk Management & Compliance Committee Actions on recommendations Improvement within 2 months and re-audit for assurance Improvement within 2 months and re-audit for assurance Improvement within 2 months and re-audit for assurance Improvement within 2 months and re-audit for assurance 4
5. APPENDICES Appendix 1 Duties and Responsibilities 2.1 Management Structure chart Chief Executive Officer Chief Finance Officer Director of Estates, Facilities and Development Deputy Director of Estates, Facilities and Development Estates Operations (CHH) Estates Operations (HRI) Property Services Energy Innovation Project Capital Development Estates Operations (CHH) Deputy Asbestos Estates Operations (HRI) Trust Asbestos PFI Services Project s Project s Estates Officer (Fire Safety Compliance) Deputy Asbestos 5
2.2 Chief Executive Officer The Chief Executive Officer has the ultimate responsibility for health and safety and is the duty holder for Trust. The Chief Executive Officer has delegated the duty of the day-to-day running of the Trust, which includes the management of health and safety, to the Director of Estates, Facilities and Development. 2.3 Director of Estates, Facilities and Development The Director of Estates, Facilities and Development is responsible to the Chief Executive for overseeing the running of the estate, including the management of asbestos. 2.4 Deputy Director of Estates, Facilities and Development The Deputy Director of Estates, Facilities and Development has overall responsibility for the strategy and budget allocation (within the limits of the approved budget) of financial and other resources for the control of ACM s at the Trust, and will: Ensure that adequate resources are provided and allocated to enable compliance with this Asbestos Management Plan. Ensure the safe management and operation of Estates activities, including consideration of asbestos issues and compliance with the AMP, within the operational and investment under the Trust s control Devolve the principal functions and strategy of asbestos management to the Asbestos. Appoint, in writing, a competent Asbestos responsible for the day-to-day management of the Trust s Asbestos Management Plan and compliance with current regulations, Trust policy, processes and procedures to undertake all estate activities inclusive of projects, operations and maintenance Ensure that Estates staff have suitable induction, asbestos awareness and refresher training with respect to asbestos issues to comply with legislation and to ensure a high level of asbestos awareness. The Deputy Director of Estates, Facilities and Development through the Asbestos Manger shall ensure appropriate resources and expertise is in place for asbestos management in accordance with the Trust s Asbestos Policy. 2.5 Asbestos The Asbestos has responsibility for the day-to-day management of ACM s in all Trust buildings and sites. Responsibilities shall include: General ACM Management Maintaining a sustainable asbestos management plan and an up to date asbestos management register (referred to as the Asbestos Management System AMS) In conjunction with the embedded Asbestos Consultant: Provide competent professional advice on ACMs and their treatment to those with responsibilities under this Plan 6
Ensure that statutory management surveys and re-inspections of ACMs are undertaken and recorded to the AMS to reflect the current condition of ACMs In conjunction with Estates Officer, Team Leaders and Project s and Consultants/Contractors programming surveys in Trust premises to identify any ACMs that may be present which effect their projects or activities. Maintain the Asbestos register for all Trust owned premises Ensure all asbestos records are maintained up to date, including locations of known asbestos, any exposure to asbestos and all relevant procedural documentation, as detailed in the Asbestos Management Plan Ensure that all records of ACMs include a Material Risk Assessment in accordance with HSG 227 A Comprehensive Guide to Managing Asbestos in Premises Ensure all works comply with Managing and Working with Asbestos. Approved Code of Practice HSG L143 Review and update the AMP Commission an annual report for the Director of Estates, Facilities and Development Ensure that all asbestos identified as being safe to leave undisturbed is adequately labelled. (NB this does not mean that all ACMs will be labelled). Report any incident of alleged asbestos exposure to the Deputy Director of Estates, Facilities and Development and assist with or undertaking any investigation Assist the Trust Safety in liaison with the HSE Promote awareness of hazards of ACMs and the AMP by advising on, and providing, appropriate training and induction, to Trust staff as required and in particular to those whose work might bring them into contact with ACMs Monitor to ensure that all Trust Project Officers/Building Mangers and staff discharge their responsibilities under this AMP Attend in accordance with the Emergency Action Plan: Accidental Release of Asbestos and taking such actions as are required to ensure safety Maintain professional competence, including a thorough understanding of all relevant legislation, codes of practice, guidance and good practice Attend the EF&D Health and Safety Meeting Manage Licensed Asbestos Removal Contractors Reactive ACM management Operation and Maintenance Providing information on ACMs as required 7
Attending site and providing guidance to maintenance staff on remedial actions or precautions to be taken in respect of ACMs Where appropriate, instructing sampling and investigation of any suspected materials, in accordance with prescribed procedures, Instructing analysis by the Asbestos Consultant with the appropriate UKAS accreditation Instructing/advising appropriate asbestos abatement action to facilitate maintenance tasks Planned ACM Management - Project and Estates Management Providing information on existing ACMs as required Reviewing project brief and providing guidance on abatement actions or precautions to be taken in respect of ACMs. Where intrusive work is planned, advise appropriate actions required by the Trust staff Promoting appropriate asbestos abatement actions to facilitate project work in conjunction with the Asbestos Consultants and Trust Project Officers/Management Consultants Ensuring that the AMS is updated following completion of any works on ACMs including providing the relevant Project with details of residual asbestos hazards remaining in the vicinity of any proposed work. Financial Administration Managing any budgets relative to statutory and compliance changes driven by legislation. Providing budgetary cost estimates for asbestos work to other departments for non-project related activities i.e. general operation and maintenance activities In conjunction with the Asbestos Consultant assisting Trust staff with the tendering of asbestos works. Providing advice to Trust Project Officer s/project Teams on commissioning of asbestos consultancy/project management services within their projects and in accordance with the Trust s Standing Instructions. Audit Ensure the AMS is updated following completion of any works on ACMs including providing the relevant Project with details of residual asbestos hazards remaining in the vicinity of any proposed work Audit the AMS to ensure it is up to date (no more than one month old). Audit to ensure the Asbestos Consultant reviews the Licensed Asbestos Contractor s plan of works is adequate. 8
In conjunction with the Asbestos Consultant assessing the appropriate level of analytical support and attendance required. In conjunction with the Asbestos Consultant and Trust Project s inform appropriate staff of asbestos related works in good time. Audit to ensure method statement and risk assessments amendments are assessed by the Asbestos Consultant. Audit to ensure site works comply with relevant Trust requirements, either directly or with the Asbestos Consultants when they are commissioned to project manage surveys/removal works. In conjunction with the Asbestos Consultant manage Licensed Asbestos Removal Contractors to assess their compliance with statutory and Trust requirements Stopping work where a Licensed Asbestos Removal Contractor does not perform to the required health and safety standards, or where his actions appear likely to result in a breach of health and safety. 2.6 Asbestos Consultant A detailed specification for the Asbestos Consultant duties is contained the Contract Agreement. (Copies may be obtained from the Asbestos on request). The scope of the service covers the following activities at any of the Trust sites: Taking and analysing bulk samples as directed. Undertake Statutory Re-inspection Surveys. Undertake Management Surveys. Undertake Refurbishment/Demolition Surveys. General Consultancy Services. Consultancy: Pre-construction support. Consultancy: Procurement support. Consultancy: Monitoring works and analysis. Project Management: Asbestos abatement works. Assist the Asbestos in the monitoring and management of Licensed Asbestos Removal Contractors under the contract agreement. The Asbestos Consultant is also responsible for maintaining the current version of the Trust s Asbestos Register (AR) and managing all uploads to ensure the data contained within the AR is no more than a month old. Attend monthly asbestos management meetings. 9
2.7 Licensed Asbestos Removal Contractor A detailed specification for the Licensed Asbestos Removal Contractors duties is maintained by the Asbestos. (Copies may be obtained from the Asbestos on request). The scope of the service covers the following activities at any of the Trust sites: Unlicensed work. Asbestos Removal. Hazardous Remediation. Asbestos Encapsulation and Treatment. Asbestos Repairs Decontamination Services. Emergency (out of hours) response. Disposal of asbestos waste. Building, validating, maintaining, decontaminating and removing full enclosures (including air locks and pumps) and to be in attendance when asbestos surveyors have to break through ACM during the conduct of a survey. All associated analytical work will be performed by the Asbestos Consultant. In the event of an emergency, the Licensed Removal Contractor must be able to attend within 120 minutes at any time of the day or week. Ensure all operatives have a valid contractors pass. Works to be conducted in compliance with best practice & statutory requirements: Control of Asbestos Regulations The Hazardous Waste Regulations. HSG 247 Licensed Contractors Guide. HSG 210 - Asbestos Essentials. HSG 143 - Managing and Working with Asbestos. Approved Code of Practice Approved Code of Practice: Work with Asbestos Insulation, Asbestos Coating and Asbestos Insulating Board L28. Construction (Design & Management) Regulations. Other Health & Safety at Work Regulations. Trust s Contractors CDM Form. ARCA guidance. All Trust policies, standards and procedures. Develop a plan of work that complies with the documents listed above Makes explicit reference to public protection measures in all plans of work. Site set up plans must be included in the plan of work, to explain the overall management of the project. 10
Notify the HSE (where notification of required). Manage and supervise operative s performance. Co-operate with the Asbestos Consultant in the planning of the works and during the subsequent monitoring of site activities. Do not commence works on asbestos until the Asbestos Consultant/Estates/Project s have issued all relevant permits and approvals. When undertaking abatement works as enabling works prior to the main construct project or the abatement works are in the major constituent of the project and is notifiable under CDM 2015, the Licensed Asbestos Removal Contractor shall undertake Principal Contractor duties. Ensure waste is stored securely. Ensure waste transfer notes are provided and included with the end-of-project documentation. These documents must be legible and compliant. Provision of any other information/documentation requested by the Asbestos Consultant to enable them to perform their duties on behalf of the Trust. Co-operate, free of charge, with an annual audit to verify your competency. Perform health monitoring of operatives as required by legislation. Medical records are to be made available for inspection by Trust or their Asbestos Consultant. Apart from the waste disposal, no element of this work may be subcontracted without the express permission of the Asbestos. Notify the Asbestos/ Asbestos Consultant of any alterations, renewals or revocations to your licences to work with or supervise work with asbestos. Maintain records of all work carried out at the Trust for the duration of the contract. Procedure Manuals to be made available to Asbestos /Asbestos Consultant during the annual audit and to be provided if any significant changes are made to it. Attend regular management/review meetings and abide by the requirement of the Licensed Asbestos Removal Contractors contract terms 2.8 Contractors (and staff appointing contractors) Those who employ Contractors to undertake project work or operation and maintenance activities in the Trust shall: Be responsible for ensuring the work complies with the requirements of this standard and that the works comply with relevant statutory regulations. Be responsible for undertaking reasonable enquiries to confirm the competency and training of contractors in the area of work, before entering into contracts for 11
the removal, treatment, and cleaning of the asbestos, and all other aspects of removal works. Contractors are to be made fully aware of the duties and responsibilities assigned to them, and are to be familiar with the Trust s standards and procedures. Contractors are to have completed the necessary Trust safety induction. Contractors are to comply with the Trust s Health and Safety Policy Safety Rules for Contractors employed on Trust premises, and sign the document accordingly. This includes: Comply with Trust policy, procedures and processes regarding the removal and management of asbestos. Ensuring that any employees undertaking work on Trust properties have received asbestos awareness training in accordance with CAR Ensuring that any employees undertaking work on Trust properties have been made aware of the Trust Site Rules and Guidance (Induction CD) Disseminating information on known ACMs to those undertaking the work Not undertaking any work which may disturb known or suspected ACMs Notifying the Asbestos /Asbestos Consultant immediately and stopping work if they encounter damaged or disturbed known or suspected ACMs Complying with all aspects of this Asbestos Management Plan Ensure that all sub-contractors are informed of relevant procedures; in particular the location of ACMs within the project area Co-operate with the Trust s Safety, Asbestos and Asbestos Consultant and any asbestos contractors or associated contractors working within or adjacent to the known or intended project area Ensure the Trust s emergency asbestos procedures are followed in the event of discovery of or damage to ACM 2.9 Trust Capital Development Project s Trust Project s and the Consultants/Contractors they appoint are responsible for ensuring works are undertaken in compliance with this document and the Trust policies. General refurbishment and maintenance works include amongst other activities; New construction, demolition, refurbishment, maintenance and engineering projects; Security systems, information technology (IT) systems, and telecommunications works. General planned and reactive maintenance / repair works. General business as usual operations (hard and soft facilities management) 12
Any members of staff responsible for people involved in construction, refurbishment, operation and maintenance work that may disturb ACM s within the fabric of a Trust building, whether carried out by Trust staff or an external contractor must; Consult with Asbestos / Asbestos Consultant before commencement of such works which disturb the fabric or building engineering services of a Trust building. Obtain information from the AMS about the location, type and risk level of ACM present in the project work area. Where necessary seek the advice of the Asbestos about ACM s within the area of their project. Contact the Asbestos to arrange for a refurbishment or demolition survey to be carried out where the work is likely to be intrusive and may disturb ACM not identified by a management survey. Allow and scope sufficient time and resources for asbestos management and abatement works to be financed and programmed for their project/activity, and in accordance with the Trust s project lifecycle stages Make arrangements for the removal or containment of the ACM so as to prevent the exposure to asbestos of those working on the project. Inform all staff and contractors involved in the project of the location and condition of any ACM that may be affected by the project. Advise all staff and contractors involved in the project of the actions to be taken if suspect ACM is discovered Inform the Asbestos or their deputies of any suspect material reported to them and ensure that work is halted until the suspect material is investigated by Estates and relevant parties. 2.10 Trust Operations and Maintenance Personnel The Trust s Operations and Maintenance personnel are responsible for: Day to day reactive and operational activities across the estate, termed business as usual activities. Checking the AR and carrying out risk assessments before undertaking any work in properties. Notifying the Asbestos or their deputies immediately and stopping work if they encounter damaged or disturbed known or suspected ACMs 2.11 Trust Safety The Trust s Safety is responsible for: In conjunction with the Asbestos investigating and reporting to the Trust s Fire, Health, Safety and Security Committee on any alleged incident of accidental asbestos exposure and for ensuring reporting of incidents under RIDDOR, where appropriate. 13
Conduct audits/inspections as detailed in the Asbestos Policy, providing a formal report to the EF&D Health and Safety Committee, providing assurance that the Asbestos policy is embedded in the Trust. 2.12 Trust Property Services The Trust s Estates Property shall; As far as reasonably practicable confirm that properties purchased on behalf of the Trust are either free of ACM (normally an asbestos register) or that there is no information about the presence of ACM. Obtain adequate information about the presence of ACM. If this is not available a survey must, as far as possible, be carried out prior to exchange of contracts, if timescales do not permit, a preliminary assessment of risk and cost must be carried out based on visual inspection, the age of the property and such other relevant information as is available. Wherever reasonably practicable any known ACM must be removed from properties newly purchased on behalf of the Trust. The Property Services must keep the Asbestos informed about ACM issues involved in the properties they are dealing with. Provide asbestos survey / register information to the Asbestos for all new property acquisitions, leasehold (long or short term) and freehold, and confirms who is the duty holder, i.e. landlord or Trust, as well define building fabric and engineering services ownership and responsibilities. For any Trust property, request the current asbestos register from the Asbestos for inclusion in the Trust s property disposal transactions 2.13 Trust Occupational Health The Trust s Occupational Health is responsible for: Providing occupational health advice to management and staff on issues relating to asbestos Ensuring that any exposure is recorded on the employee s medical notes and retaining the medical notes for a period of forty years after the date of final exposure. 2.2 All Employees and Contractors All employees and contractors to the Trust have a duty to co-operate with the Duty Holder; as well as the specific roles outlined below and will: Make every effort to avoid disturbing or damaging any ACMs. Report to the Asbestos or their deputies if they suspect that ACMs or materials suspected of containing ACMs have become disturbed and/or damaged, or are likely to become disturbed or damaged. Ensuring that any proposed work does not start until a permit to work/ authorisation has been received and approved by Estates Officer, Team Leaders or Project s, in consultation with the Asbestos. Comply with all aspects of this AMP. 14
Attend health and safety training specified by the Asbestos. Disseminate information about asbestos to staff and contractors they are responsible for, by reviewing the AMS database and obtaining information from the Asbestos /Asbestos Consultant. Report any suspected asbestos materials or damage to the asbestos containing materials to the Trust s Asbestos. 15
Appendix 2 Document Control Reference No: CP 347 First Published: December 2014 Version: Lead Director: V2 Director of Estates, Facilities and Development Current Version Published: Review Date: September 2018 September 2019 Document Managed by Name: Mr Hedley Wilson Ratification Committee: Estates, Facilities and Development Management Committee Document Managed by Title: Asbestos Date EIA Completed: January 2018 Consultation Process Senior Estates s Estates, Facilities and Development Health and Safety Committee Trust Fire, Health, Safety and Security Committee Trust Non-Clinical Quality Committee [For information] Asbestos Policy Key words (to aid intranet searching) Target Audience All staff Clinical Staff Only Non-Clinical Staff Only s Nursing Staff Only Medical Staff Only Version Control Date Version Author Revision description December 2014 V1 Asbestos New Policy January 2018 V2 Asbestos Updated Policy 16
INITIAL EQUALITY IMPACT ASSESSMENT (EIA) Document Name: Date/Period of Document Asbestos Policy Document Author Hedley Wilson February 2018 IEIA Author Hedley Wilson Describe the main aim, objectives and intended outcomes of the above: The Hull and East Yorkshire Hospitals NHS Trust acknowledges the serious risk to health and safety caused by exposure to asbestos and the need for effective management systems to be in place to control the hazard and reduce the risk of exposure to asbestos as far as is reasonably practical. You must assess each of the 9 areas separately and consider how your document in section 1 may affect people s human rights. 2. Assessment of possible adverse impact against any minority group Could the document in section 1 have a significant Response If yes, please state why and the negative impact on equality in relation to each area evidence used in your assessment below? Yes No 1 Age? X 2 Sex (Male and Female? X 3 Disability (Learning Difficulties/Physical or Sensory Disability)? 4 Race or Ethnicity? X 5 Religion and Belief? X 6 Sexual Orientation (gay, lesbian or heterosexual)? X 7 Pregnancy and Maternity? X 8 Gender Reassignment (The process of transitioning from one gender to another)? 9 Marriage and Civil Partnership? X X X You need to ask yourself: Will the document create any problems or barriers to any community of group? No Will any group be excluded because of this document? No Will the document have a negative impact on community relations? No 17
If the answer to any of these questions is yes, you must complete a full Equality Impact Assessment 3. Positive impact: Could the document have a significant positive impact on equality by reducing inequalities that already exist? Explain how will it meet our duty to Response Yes 1 Promote equal opportunities X No If yes, please state why and the evidence used in your assessment 2 Get rid of discrimination X 3 Get rid of harassment X 4 Promote good community relations X 5 Promote positive attitudes towards disabled people 6 Encourage participation by disabled people X 7 Consider more favourable treatment of disabled people 8 Promote and protect human rights X X X 4. Summary On the basis of the information/evidence/consideration so far, do you believe that the document will have a positive or negative adverse impact on equality? Positive Please rate the level of impact Negative HIGH MEDIUM LOW NIL LOW MEDIUM HIGH Date assessment completed: February 2018 Is a full equality impact assessment required? No 18