There is a lot of paperwork involved when it comes to managing asbestos.
In this blog we will show you how to make sure you are on top of your asbestos management and compliance.
Obviously, the bigger your property portfolio is, the more complex and complicated this can be. Some desktop studies of one site can take a couple of hours, whereas we have spent months reviewing information and going through documents for some clients with multiple sites.
The first thing to start with is historical information. This refers to asbestos historical information and historical building information. Generally, we would start with asbestos historical information. If you have no asbestos information you would refer back to the historical building information concerning the age of the building and its construction.
What makes a good survey report?
Each asbestos survey report is different. Prior to 2010, there was no real guidance on what should be included in an asbestos survey report and how that survey should be produced. In 2010, the HSG264 asbestos surveyors guide guidance was released to help standardise reports. Advice was issued about what an asbestos survey report should look like and what it should include to make it easier for different duty holders to make sense of asbestos reports belonging to different companies.
According to the guidance, plans shouldn’t have multiple colours or different symbols and markings to identify asbestos, but we still see plans like that. We understand why some people still don’t follow the guidance because it is only guidance. However, it does simplify a lot of things that prior to this were over-complicated.
What we are trying to do is make the information readily available for clients and staff to use. If you are looking at a plan you don’t want to be referring back to a key, you should instantly know what it is. Keep it simple. Use one colour for asbestos, another for no access or presumed asbestos and mark on the asbestos locations because it’s good to see where they are. Also, show where asbestos is within a room. It’s better to highlight exactly where the asbestos is.
We’re not saying every report after HSG264 came out is good and every report before is rubbish. There are old reports that hold good information but in older reports there were no specifications on what should be sampled and not all materials were being sampled. Generally speaking, lower risk stuff was left out.
So, if you have a report that is 30 years old and it states there is asbestos, it gives you an insight but it is not in line with the guidance. Between 2000 and 2010 the industry was forewarned by HSE that guidance would be coming in and reports started to get better so you can rely more on a report from this period. Looking at companies that are UKAS accredited gives you that level and benchmark of certainty to a point.
To know what to look for in a good report, get a copy of HSG264 and review what should be in that report. For example, executive summary, scope of work, data, plans, analytical certificates. If all this information is in there and it is a UKAS accredited report, you can generally rely on the report.
Other documents need to be reviewed too, such as asbestos removal paper work, waste notes, refurbishment paperwork and old CDM files.
When you are trying to identify what asbestos is left within the building, you have your report and removal documents. Read these carefully because items which appear in the historical paperwork you have paid for may have since been removed.
Sometimes 90% of the material could have been removed but there was a bit that was left and that will only be recorded on the certificate so you need to cross reference to the register as well.
If you look at what you have paid for versus the contractors’ plan of works, the plan of works might say it needs to be fully removed, but when they came to do the job they ran into difficulties and something couldn’t be removed fully. As a result, a waste note doesn’t tell you the full story. It doesn’t give you adequate information that that material has been removed safely but if licensed works have taken place there should always be a certificate issued.
Today, our project completion pack has everything in it so if in the future we need to review it, or the client needs to, they have everything in one place.
If you’ve had removal works carried out in the past, the only way to discover whether that material is still there is to have a look. This may entail employing a surveying company to review the information and works to see what is there and you may need a re-inspection.
The more information that you can get hold of, the better as it will save you money in the long run.
What do you do with the information?
So you’ve tracked down survey reports, removal paperwork, building stuff – what are you going to do with this? You are going to use it to review your current situation and prioritise what you need to do.
If you only have one property, it can be straight forward and by the end of reading all the documents, you should have an idea of where you are at.
If you have a portfolio of 100 properties, you will need to do something more. I’d create a spreadsheet and start detailing the surveys for each property. Start with property types; the surveys you have and if they are up to date and up to specification; removal paperwork. Do your records highlight that asbestos is there? Is it of high or low risk? Start to pinpoint all the information because when you have your complete spreadsheet for your portfolio, you can start looking at it in detail.
Break the information down and see if there are obvious issues that need dealing with straight away.
For example, if you have a property that was built in the 1960s or 1970s, that you have no information on and it is in a bad condition you can tell from this basic information alone that you need to have a survey done.
Do you need help?
When you have lots of different reports, you need to extract all the different types of information. It can be a minefield looking back through old reports and extracting the useful information out of them. You may want to think about employing a consultant to do this for you as they may be able to do it quicker for you and will save lots of time.