Thursday, January 17, 2008

Small firms are risking big costs

Second-rate or inadequate surveys will increase the danger of workers being exposed to asbestos on site, says Mick Dawson

The Health and Safety Executive is trying to instil a greater awareness of regulations and best practice in companies working on smaller building sites.

The HSE has focused on raising awareness. One example is the Safety and Health Awareness Days, which involve partnership and support between the HSE and large contracting firms, ConstructionSkills and the Federation of Master Builders.

Asbestos has been a particular focus of the HSE's Disease Reduction Programme. A new document, 'Inspection pack for duty to manage asbestos in premises', outlines the risk control indicators which will be used by enforcement officers against which the performance of dutyholders will be measured.

The HSE's name-and-shame database shows that from January to September 2007, 26 out of the 120 asbestos-related enforcement notices were issued on construction sites, the majority for failing to identify asbestos-containing materials (ACM) prior to work starting.

Asbestos can't be ignored

The vast majority of these notices were immediate prohibition notices, meaning that the site was closed straight away and would not be allowed to re-open until there was evidence that each fault had been rectified.

Asbestos issues need addressing at the inception of a project and many clients, construction managers and main contractors have realised that independence and accredited asbestos expertise is the only way to solve the problem.

The most important piece of information required is a Type 3 survey report. A Type 3 survey (as defined in the HSE Guidance document, MDHS 100) is an intrusive inspection identifying ACMs that have been used as part of a building's fabric - not only during the original construction, but during subsequent refurbishments.

A common mistake is to assume that any existing asbestos information will be adequate for the project to proceed. This is unlikely to be the case.

A Type 3 survey is appropriate if it can satisfy the following criteria:

  1. It has been commissioned with the intended building work taken into consideration;
  2. It has been carried out while the building is unoccupied Đ to facilitate the required level of intrusion - unless the work is a minor refurbishment;
  3. It has been carried out by surveyors accredited to ISO 17020 or ISO 17024 who are insured for the commensurate risk.

The CDM Coordinator is responsible for ensuring that this information is available and for checking the survey.

A Type 2 survey is not adequate - it does not have the required level of intrusion because it is a management, not a refurbishment, survey - and an asbestos management plan is not sufficient because this usually only documents procedural arrangements. If there is any doubt, a tailor-made survey should be commissioned.

The skills required to carry out a Type 3 survey mean that not only is a knowledge of asbestos products required, but also of construction techniques.

Expert surveyors essential

Only the most experienced surveyors can produce the level of information required.
And only those companies with robust quality procedures accredited to ISO 17020, or ISO 17024 for individuals, will be able to produce a document that reports the information gathered on site in a manner that is impartial and independent.

An insurance broker speaking off the record recently referred to "hundreds" of pending claims for poor Type 3 surveys.

This illustrates that there are many organisations that are not competent and are employing unqualified surveyors.

Another area of enforcement is the 2006 Control of Asbestos Regulations, which made it explicit that contractors working within buildings had to provide awareness training.

Many clients are making this a condition of approved supplier status, and some are making it a barrier to entry onto site. The HSE has already made three firms train hundreds of staff at a cost in excess of £100,000.

On 27 February 2008, the HSE will launch an asbestos campaign, called 'You're more at risk than you think'.

This is also the date of National Mesothelioma Day and serves as a reminder that in an average week six electricians and three plumbers die from asbestos-induced deaths.

Mick Dawson is commercial director for Bureau Veritas.



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