Asbestos Risk Management

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Procedure for Asbestos Risk Management

Procedure for Asbestos Risk Management

ROO-ALL-HS-PRO-0130

Pictures are for illustration purposes only

Revision history

Revision Rumaila
Date Brief description of change Prepared Checked Approved
number approved
01 22/12/11 Initial draft
02 08/03/12 QA Technical review RS
03 01/05/12 New document format RS
04 31/07/12 Client changes RS
05 11/08/12 Document Numbers Added J.Rae

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Procedure for Asbestos Risk Management
Table of contents
1.0 Summary ................................................................................................................................. 4
2.0 Introduction ............................................................................................................................ 4
2.1 Purpose .................................................................................................................................... 4
2.2 Application................................................................................................................................ 4
2.3 References, abbreviations and definitions ............................................................................... 5
3.0 Responsibilities...................................................................................................................... 6
3.1 Site Controller .......................................................................................................................... 6
3.2 Health Manager........................................................................................................................ 6
3.3 Industrial Hygienist ................................................................................................................... 7
3.4 Performing Authority ................................................................................................................ 7
3.5 Company staff, contractors and visitors ................................................................................... 7
3.6 Approved Contractors .............................................................................................................. 7
4.0 Managing asbestos ................................................................................................................ 8
4.1 Prepare and prioritise ............................................................................................................... 8
4.2 Asbestos signs ......................................................................................................................... 8
4.3 Protect asbestos sites .............................................................................................................. 9
4.4 Asbestos written plan ............................................................................................................. 10
4.5 Identifying asbestos ............................................................................................................... 10
4.6 Pre-assessment hazard identification and task risk assessment .......................................... 11
4.7 Plan of work ........................................................................................................................... 11
4.8 Planning ................................................................................................................................. 12
5.0 Personal Protective Equipment .......................................................................................... 13
5.1 Safety equipment ................................................................................................................... 13
5.2 Use of enclosure area ............................................................................................................ 14
5.3 Glove bags for pipe insulation removal .................................................................................. 15
6.0 Work with asbestos ............................................................................................................. 16
6.1 Introduce an asbestos plan of work ....................................................................................... 16
6.2 Specialised asbestos contractor ............................................................................................ 16
7.0 Emergency actions .............................................................................................................. 18
7.1 Basic responses ..................................................................................................................... 18
7.2 Accidentally discovering asbestos-containing material ......................................................... 18
7.3 Emergency response actions................................................................................................. 18
8.0 Disposing of asbestos waste .............................................................................................. 19
8.1 Asbestos area debris - removal process ............................................................................... 19
8.2 Disposing of asbestos containing material ............................................................................ 19
Appendix 1 - Training, competence and authorisation ............................................................................. 21
Appendix 2 - Compliance and auditing ....................................................................................................... 22
Appendix 3 - Asbestos register .................................................................................................................... 23
Appendix 4 - Procedure for removing CAF gaskets .................................................................................. 25
Appendix 5 - Specialist contractor audit checklist .................................................................................... 26
Appendix 6 – Selection of specialised asbestos contractor ..................................................................... 27
Appendix 7 - Sampling procedure asbestos containing material ............................................................ 28
Appendix 8 – Asbestos emergency action flowchart ................................................................................ 29

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1.0 Summary
ROO no longer use asbestos in any of our facilities, but there are still some Asbestos-Containing Materials
(ACMs) in buildings, plant and equipment. Although asbestos is a hazardous material, it is only a risk to
health if the asbestos fibres are released into the air and are then breathed in. Asbestos-containing
materials only release fibres into the air when they are disturbed by activities such as drilling, sawing and
cutting. Controlled techniques to remove asbestos-containing materials reduce exposure to asbestos and so
the risk of ill health and possibly death. We ban the import of all forms of ACMs to our operations. We no
longer allow the use of ACMs of any type. However, we recognise that ACMs will remain on-site for many
years, and so we have a written procedure to manage asbestos.

This document sets out the procedure we will follow to control and manage Asbestos-Containing Materials
effectively.

2.0 Introduction
2.1 Purpose
The aim of this procedure is as follow:-

 Identify and assess all locations where ACMs have been used and monitor these locations
 Remove or make safe any asbestos-containing materials that are in a condition that could affect the
health of our staff, contractors or visitors
 Prevent or reduce the spread of ACMs as much as reasonably possible
 Prevent or reduce people’s exposure to ACMs as much as reasonably possible
 Involve and consult our staff and contractors in the ACM management process and, where
appropriate, provide suitable and sufficient information and training to staff, contractors and visitors
 Consider the possibility of ACMs being present when planning tasks and before we authorise any
work instructions. Make sure anyone who will be carrying out any work where we know there will be
ACMs present is suitably trained and skilled.
(See Appendix 1 - Training, Competence and Authorisation)
 Make sure that work is carried out by specialist contractors who have the skills needed to carry out
such work, if an initial assessment shows that the work is not sporadic and of low intensity (that is,
ACMs are present as insulation, coating or board, or that the levels of ACMs may be higher than
control-limit levels)
 Ensure that safe systems of work are put into practice at all times, including the use and selection of
Personal Protective Equipment (PPE), particularly Respiratory Protection Equipment (RPE), which
protects the wearer from breathing in harmful substances
 Define the standard for staff and contractors who could be exposed to ACMs during normal or
emergency activities
 Provide staff and contractors with suitable information, instructions and training before they work with
ACMs

Asbestos Containing Materials should be maintained in good condition and only removed if absolutely
necessary. When in good condition and left undisturbed, ACMs will not release fibres into the air, and so do
not pose a risk to life or health.

2.2 Application
This document applies to all staff and contractors working on sites we manage.

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2.3 References, abbreviations and definitions
The following documents are also related to asbestos and you should refer to each document as necessary.

2.3.1.1 Related documents

Document number Title of procedure

ROO-ALL-HS-PRO-0001 Control of Work Manual
ROO-HSE-HH-PRO-10 Asbestos Handling Procedure
ROO-ALL-HS-PRO-0016 Deviations Procedure

2.3.2 Abbreviations
The following abbreviations are used in this document.

Acronym Explanation
AA Area Authority
ACMs Asbestos-Containing Materials
AR Asbestos Register
BOHS British Occupational Hygiene Society
CAF Compressed Asbestos Fibre
CAR Control of Asbestos Regulations
DOP Dioctyle Phthalate
ERTs Emergency Response Teams
HEPA High Efficiency Particulate Arrestor
HITRA Hazard Identification and Task Risk Assessment
HSE Health Safety and Environment
IH Industrial Hygienist
NPU Negative Pressure Unit
PA Performing Authority
PAO Polyaphaolefin
PoW Plan of Work
PPE Personal Protective Equipment

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2.3.3 Category definitions of asbestos

There are two types of ACMs in the oil and gas industry - friable and non-friable.

2.3.3.1 Friable asbestos

Friable asbestos can be pulverized or crumbled by hand and can easily release asbestos fibres into the air.
Examples are thermal and refractory insulation (Figure 1).

Pipe

Figure 1: Asbestos pipe lagging

Friable asbestos must only be removed by suitably trained and qualified asbestos workers (this does not
apply to gaskets, valve packing and roofing materials.

2.3.3.2 Non-friable asbestos

Non-friable asbestos includes bound materials that cannot be pulverized or crumbled by hand and do not
easily release asbestos fibres into the air. Examples are floor tiles, gaskets, valve packing, roofing materials,
floor coverings, mastics, and asbestos-cemented roofing panels and partitions.

3.0 Responsibilities
3.1 Site Controller
The Site Controller (SC) is responsible for making sure that staff and contractors carrying out asbestos
procedures at the facility are aware of, and work in line with, these guidelines.

The Site Controller must approve all work related to Asbestos Containing Materials using the Control of Work
procedure.

(See Appendix 1 - Training, competence and authorisation)

3.2 Health Manager

The Health Manager acts as adviser for all activities involving Asbestos Containing Materials. This is the
responsible person who uses their personal knowledge of Health, Safety and Environment (HSE) practices
and procedures to make sure we are keeping to this procedure.

(See Appendix 2 - Compliance and auditing)

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3.3 Industrial Hygienist
The Industrial Hygienist (IH) is responsible for:-

 Acting as the technical authority for all activities involving ACMs

 Preparing a site written plan and preparing and updating the Asbestos Register (AR)
 Carrying out small-scale asbestos sampling
 Carrying out initial assessments
 Authorising other skilled people to carry out initial assessments
 Making sure that all asbestos initial assessments are recorded
 Organising and monitoring specialist contract work
 Monitoring and training (See Appendix 1 - Training, Competence and authorisation)
 Leading an investigation into any system failure

(See Appendix 2 - Compliance and auditing)

3.4 Performing Authority

In most tasks, the Performing Authority (PA) is the person in charge of the work (for example, the team
leader or supervisor), and will have main responsibility for arranging the assessment process. The
Performing Authority may require this work to be carried out as a condition of the Permit to Work procedure.
They are responsible for regularly reviewing tasks under their control, where ACMs may be present, and for
making sure that information on risks and precautions is communicated effectively to their teams.

The Performing Authority is responsible for:-

 Ensuring considered asbestos HITRA is carried out before the issue any work permit
 Providing information on the location of any ACMs identified in the work area
 Advising the work party on what may happen if any ACMs are disturbed and the emergency
response if ACMs are accidentally disturbed

3.5 Company staff, contractors and visitors

All our staff, contractors and visitors are responsible for:-

 Working in line with safe systems of work

 Stopping all work (or activities causing disturbance) if they suspect asbestos or ACMs might have
been disturbed
 Informing the site Safety Adviser (SA) or Area Authority (AA) if they know or suspect that something
which contains ACMs has failed, has been disturbed or has decayed

3.6 Approved Contractors

There may be a requirement for specialist occupations to work at height to locate, inspect and report on sites
containing ACMs located at high level, which are inaccessible in normal conditions. These may be
steeplejacks, Rope Access Technicians or multi-disciplined specialists as required. On such occasions, a
recognised contracted company will supply suitably qualified and experienced personnel. In such cases, the
approved procedures of such companies shall constitute the control of work. Such standards are set for
example by The Industrial Rope Access Trade Association.

An example of a Working at Height – Rope Access Checklist is in Appendix 4. This checklist is intended to
familiarise the permit authoriser with the pre-requisites to a rope access task commencing, also an aide
memoir for a rope access team leader to ensure all the requirements have been addressed.

(See Appendix 5 - Working at height - rope access checklist)

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4.0 Managing asbestos
4.1 Prepare and prioritise
On all our sites, if we cannot be certain that there are no Asbestos Containing Materials, we must carry out
surveys to find out if there are any ACMs on the site and, if so, assess the condition of these.

The Industrial Hygienist reviews and confirms whether there are ACMs and decides on the steps needed to
manage the asbestos.

Once we know or believe there are ACMs on a site, the risk from these ACMs is assessed and resources
prioritised to manage them. A priority risk assessment has two parts:-

 Material risk assessment

 Exposure risk assessment

4.2 Asbestos signs

To help prevent accidentally disturbing asbestos, all asbestos locations are indicated with one of three types
of signs:-

 Standard asbestos product sign

 Warning and information sign
 Designated area sign

4.2.1.1 Standard product sign

A standard format asbestos product sign (Figure 2) is displayed at locations that are known or suspected of
containing ACMs, including ceiling tiles, for example. If ACMs are used in the internal parts of an item such
as flash guards, the sign is on the part that contains ACMs or as close to the part as possible.

Figure 2: Standard product sign

Not all asbestos products carry a sign. For example, gaskets and many other parts found in plant and
equipment are not normally marked, and personnel should presume these contain asbestos. Where
appropriate, for example asbestos in electrical equipment is indicated by an asbestos product sign displayed
on the outside of the cabinet. The sign is permanent and in a place that is easy to see, particularly to
maintenance workers. The minimum sign size is 50mm high and 25mm wide.

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4.2.1.2 Warning sign
Building containing ACM, for example a roof, will have warning signs (Figure 3) displayed advising staff of
the risk to their health.

Figure 3: Asbestos warning

A warning sign indicates possibilities for hazards or unsafe practices which could result in fatal or severe
personnel injuries or substantial product or property damage, if the correct precautions are not taken.

4.2.1.3 Designated area sign

When ACM is removed from a specific location, designated area signs (Figure 4) will be displayed informing
staff of the hazard and the risk, for example, of breathing in asbestos fibres. Only staff wearing appropriate
personal protective equipment, should enter the area if authorised to do so.

Figure 4 : Asbestos area sign

4.3 Protect asbestos sites

Appropriate care is taken to make sure that no work is carried out in areas, known or suspected of containing
ACMs until the risks are assessed and measures in place to control the risks. This is done through a permit
and using physical barriers to isolate affected areas.

Providing information is a vital part of managing asbestos effectively. For the permit to work effectively there
must be a link between the Asbestos Register and everyone involved in the planning process. The team
leader or supervisor must be aware of any ACMs within their area of responsibility so that they consider this
when planning any work that may disturb such materials.

Appropriate signs are displayed in modules or on plant and equipment and in office-type environments.

(See Appendix 3 – Asbestos register)

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4.4 Asbestos written plan
Once the site Asbestos Containing Materials survey is carried out, the information obtained forms the basis
of a written plan for that particular site. The content of the written plan is summarised below:-

 Management: clear definition of all roles and responsibilities is a basic requirement

 Training needs: these are defined for all levels within each site
 Supplier control: even though ACMs are banned, it is still necessary to maintain supplier control to
restrict the availability of new asbestos products such as gaskets provided in service packs
 Define waste handling: ACMs waste is controlled from the time the waste is generated to when it is
disposed of. This is done by giving and following written instructions, considering the type of waste
and, in particular preventing damage to the waste (for example, to asbestos cement sheets) so that
the waste is intact when disposed of. Waste-storage facilities must be safe and secure
 Encouraging feedback from key stakeholders (people with an interest in our business):
working with staff and contractors to produce a written plan that fully meets the needs of both the site
and site users
 Emergency planning is tested: if left undisturbed ACMs may be harmless. However, ACMs may be
accidentally disturbed through work tasks or as a result of an emergency situation. Emergency
planning is tested by including an element of asbestos risk in routine emergency exercises
 Dealing with the risks: The ACMs risks identified in the survey are prioritised and measures to
reduce these acted on. The Industrial Hygienist decides whether the ACMs can stay where they are
or be removed. This decision deals with emergency situations as well as normal work situations.
Depending on the site conditions, this may extend to a long-term programme with a timetable and a
full plan to deal with the risks
 Information: Information about asbestos shall be readily available, particularly to help carry out an
accurate risk assessment in permit applications. Information on the location and condition (survey
data) of ACMs is supported, where necessary, by instructions on identifying ACMs and an
understanding of the precautions and control measures that are taken when ACMs are present on a
worksite. This information is contained in an Asbestos Register, on asbestos information signs, and
given during the tool box talk. A procedure for updating the information held in the Asbestos
Register, and for removing or repairing asbestos signs is in place
 Review: Recording of near misses and system failures are used to improve the written plan
 Consultation: The Industrial Hygienist works with our staff and contractors to produce a written plan
that fully meets the needs of both the site and all site users

4.5 Identifying asbestos

Before any work on ACMs is carried out the type of asbestos is identified. An assessment of the type and
degree of exposure, and the steps required to prevent or reduce exposure is conducted.

Asbestos can only be identified for definite by laboratory analysis − a visual examination is not reliable. If it
is suspected that a substance contains asbestos, or if there is any doubt about the identity of any fibrous
material, a sample is taken using the following method:-

 Thoroughly soak the area the sample is to be taken from (repeated sponging or light spraying with
water should be enough)
 Wear a disposable respirator when taking the sample
 Remove the wet sample of the suspect material and seal it in a ziplock polythene bag
 Put the ziplock bag containing the sample into another ziplock polythene bag and clearly label it to
show it may contain asbestos dust
 Seal the sample site with paint or mastic until the result of the analysis is known and label it to show
where the sample is from
 Fill in a sample sheet with full details of the site, location of the sampling point, name and the reason
for taking the sample
 The Industrial Hygienist approves the request for having the sample analysed. Keep the original
approval document and send a copy with the sample to an approved laboratory for analysis

The laboratory will give the Industrial Hygienist the results of their analysis.

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All sample results are logged in the site Asbestos Register.

(See Appendix 4 – Removing contains asbestos fibre procedure)

4.6 Pre-assessment hazard identification and task risk assessment

Once it is established that Asbestos Containing Materials are present in a substance to be worked on, the
Industrial Hygienist (or another trained and certified person) carries out a hazard identification and task risk
assessment pre-assessment’.

The pre-assessment shows whether the work is:-

 Approved to go ahead under simple precautions

 Approved to be carried out by a licensed contractor

An assessment would include, but not necessarily be limited to:-

 The fibre and product type of asbestos present, its condition and degree of surface treatment, and
particularly if it is a bonded material
 The type, length and degree of exposure people might face in the course of the work
 The steps taken to prevent or reduce exposure as much as reasonably possible, and whether that
level of exposure will be higher than the control limits
 Emergency planning

Routine tasks on bonded materials, which have low levels of ACMs, may be controlled by procedure. The
procedure will define permit conditions and an outline method, which is tailored to a particular task.

Specialist contractors are used for work on asbestos insulating board, asbestos insulation or asbestos
coatings, or work on any other materials which are not bonded or any work where the level of exposure
could be higher than the control limit. In this case, the contractor carries out an independent assessment.
The Industrial Hygienist keeps the original assessment record.

There could be some difficulty in estimating whether the level of exposure is within the control limit. Short,
non-continuous maintenance activities are dealt with by keeping strictly to defined procedures and training
that is specific to the relevant task in these procedures.

The assessment record is kept in the Asbestos Register.

The Industrial Hygienist keeps a record of all risk assessments carried out within the control of work system.
These records are available for cross-reference when needed to carry out similar tasks.

4.7 Plan of work

The Plan of Work (PoW) is issued together with a permit. The plan of work is specific to the particular job. Its
purpose is to explain the main control measures resulting from the hazard identification & task risk
assessment. These measures are based on the specific features of a particular location and the work
involved. The plan of work is intended to direct the work of the asbestos removal team.

The Plan of Work and permit includes the following:-

 A description of the work (for example, repair, remove or enclosure of ACMs or maintenance and
test plant and equipment contaminated with ACMs) and a note of the scale of the work and duration
 Details of the type of asbestos, the results of any analysis and any control limits that apply
 Type of equipment, including personal protective equipment and procedures used for the protection
and decontamination of the work party carrying out the work
 Details of the hygiene facilities, decontamination arrangements, vacuum cleaners, and air monitoring
measures

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 Details of how other staff who work near the worksite are to be protected, including using barriers
and signs, the location of enclosures and airlocks, the location of skips, air monitoring, cleaning and
emergency procedures

The Plan of Work and permit direct the work and are sources of reference for the asbestos removal team.

The Plan of Work and permit are active documents and if any significant changes are necessary on the site,
the Plan of Work and permit are amended and the changes communicated to the Area Authority or Site
Controller.

4.8 Planning
It is important to have information on the physical condition of the Asbestos Containing Materials. Knowing
the condition and thickness helps determine the finer details of the removal method and establish if any
preparation work is required.

It is important to know how the ACMs are attached or fixed to the material (glued, nailed, screwed, or a
combination of these methods) so that the steps needed are planned. Also make sure the most appropriate
removal technique, or combination of techniques, are used.

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5.0 Personal Protective Equipment
5.1 Safety equipment
Under Personal Protective Equipment regulations, all staff working with asbestos must wear, at the very
least, hard hat, steel toe-capped boots, safety glasses and ear defenders.

Which specialist equipment staff must wear when working with asbestos, depends on the risk assessment
and set out in the permit.

Processes to remove asbestos can lead to fibres being disturbed and released into the air. If the release is
uncontrolled or is not controlled well, the levels of fibres in the air can be extremely high. Even with effective
controls in place, levels of fibres in the air can still be higher than the control limit. It is important that
everyone who works with asbestos takes the strictest precautions to reduce exposure to asbestos fibres as
much as reasonably possible.

5.1.1 Respiratory Protection Equipment

Staff may need to wear Respiratory Protective Equipment as well as the normal personal protective
equipment. This must be appropriate for the work, the wearer and the level of exposure.

Suitable types of Respiratory Protective Equipment are:-

 Disposable respirator to standards EN 149 (type FFP3) or EN 1827( type FFP3)

 Half-mask respirator to standard EN 140 with P3 filter; or
 Semi-disposable respirator to EN 405 with P3 filters

This equipment should be suitable for most non-licensed work which will take a short length of time to
complete. Staff will select a make and size that fits them. Respiratory Protective Equipment (Figure 5) must
be kept clean, be well-maintained and tested regularly.

Figure 5: Coveralls and RPE

The maximum concentration of asbestos fibres which staff may be exposed to without respiratory protection
is 0.1 fibres per ml.

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Coveralls

Disposable coveralls, type 5 (BS EN ISO 13982-1) are suitable for working in an asbestos environment.
Cotton coveralls are not suitable as they hold dust and need specialist laundering.

The following are guidelines for using coveralls:-

 Wear waterproof coveralls for outdoor work

 Wear coveralls that are one size too big as this helps to prevent them from ripping at the seams
 If the cuffs are loose, seal them with tape
 Avoid wearing a long-sleeved shirt as these are difficult to cover properly
 Wear the coverall legs over footwear to avoid entry of dust
 Wear the coverall hood over the straps of your respiratory protective equipment
 Dispose of used coveralls as asbestos waste, never take used coverall home (Figure 6)

Figure 6: Coverall caution sign

5.1.2 Gloves
If protective gloves are required, they should be single-use disposable gloves. If latex gloves are worn, they
should be ‘low protein powder free’ (Figure 7).

Dispose of used gloves as asbestos waste.

Figure 7: Gloves must be worn

5.2 Use of enclosure area

An enclosure is a physical barrier that is put up around the worksite to contain asbestos dust and waste
arising from the work.

The enclosure is designed to prevent fibres and dust being released into the air and also to prevent fibres
from spreading onto surfaces during all the activities associated with asbestos removal, including handling,
bagging and cleaning up the waste.

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Whether an enclosure area is used depends on the risk assessment. If an enclosure area is needed, this
will be shown on the permit. If it is likely that fibres will be released into the air and onto surrounding
surfaces, then an enclosure will be necessary to control their spread.

5.2.1 Negative pressure

Ventilation cabinets equipped with HEPA filtration are used to ventilate and create a slight negative air
pressure differential that ensures net air movement from outside the containment into it. This air movement
reduces the risk of asbestos contaiminated air moving out of the enclosure area.

Negative air units are used to exhaust air from an enclosure, reducing the risk of contaminated air escaping
into the workplace through a leak in the enclosure. Negative air unit efficiency must be tested using a
suitable indicator chemical, such as dioctyl phthalate (DOP) or polyaphaolefin (PAO) aerosols.

5.2.2 Appropriate filtration

A negative pressure unit (NPU), usually portable, contains a fan and one or more high efficiency particle
arrestors (HEPA) filters that is at least 99.97% efficient in collecting an aerosol particle 0.3 micrometre in
size. A HEPA filter ensures that the air exiting an enclosure is properly filtered.

5.3 Glove bags for pipe insulation removal

Asbestos removal glove bags are a type of isolation containment system designed to effectively contain
asbestos fibres within a designated work area where asbestos-containing materials is handled, removed,
encapsulated or enclosed.

Glove bags are clear PVC bags with a zippered top that has two built-in gloves and shoulder access for ease
of fitting. They are the most efficient way to strip asbestos lagging from almost any pipe:-

 Horizontal
 Vertical
 Tee and valve

Some glove bags offer the option of an internal zip to isolate the waste in the bottom of the bag

These bags are attached around a pipe with asbestos insulation; personnel use the provided gloves to
remove the asbestos material off of the pipe and into the bottom of the bag without exposing themselves to
the asbestos fibres.

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6.0 Work with asbestos
6.1 Introduce an asbestos plan of work
If a hazard identification and task risk assessment shows that work may proceed under a simple Plan of
Work (PoW) precautions. Each site will be responsible for setting its Plan of Work for that particular
situation. The Industrial Hygienist must be advised prior to start of work.

The Plan of Work rules may be general, and so may be shared between different sites with only minor
changes, such as removing gaskets which contain asbestos or Compressed Asbestos Fibre (CAF).

Other examples of work that may be performed under Plan of Work rules are:-

 Drilling insulating board panels with a hand tool

 Carrying out minor repairs to Asbestos Containing Materials
 Removing and putting back whole insulating board panels (but not any work involving breaking the
panels)
 Fitting of bituminous asbestos gaskets

In low risk situations of this type it is expected that work on ACMs may go ahead under the control of
maintenance staff as long as they keep to any local rules that apply.

A permit and Plan of Work precisely define the precautions to be taken during all work on asbestos-
containing materials, regardless of who is carrying out the work. The following are examples of the minimum
precautions and steps to take when removing gaskets, valve packing and roofing materials which contain
ACMs.

6.1.1 Removing asbestos gaskets and valve packing material with hand tools
 Thoroughly wet the material with water or with a wetting agent before removing it
 Remove the wet material with hand tools or a scraper
 Thoroughly clean the hand tools and scrapers with water after each use
 Put all wet / dusty materials in labelled asbestos bags
 Dispose of the bags according to the local regulations

6.1.2 Removing roofing materials and transite and marine board

 Avoid breaking, drilling or cutting these materials
 Try to remove the material as a complete section (for example, roof shingle or transite panel)
 Use hand tools to carefully prise nails or other connection points apart
 Wet the immediate area where nails or other connectors are to be removed
 Bag or wrap the material in plastic and carefully lower it to ground level
 Put all wet / dusty materials in labelled asbestos bags
 Dispose of the bags according to the local regulations

6.2 Specialised asbestos contractor

Disturbing certain types of asbestos products can cause significant health risks. This is why work with
the most dangerous forms of asbestos is carried out by specialised asbestos contractors.

(See Appendix 5 – Specialist contractor audit checklist)

Any contractor carrying out work on insulation containing ACMs, asbestos coating or asbestos insulating
board or any work that could go beyond the control limits, must be a specialist asbestos removal contractor
with proven skills and abilities.

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The contracts issued for such work is worded so that contracting companies are fully aware of our
requirements. Contractors who have successfully passed the supply chain management and industrial
hygiene conditions are used.

The Industrial Hygienist will audit contractors’ work to make sure they are keeping to asbestos management
procedures.

If a specialised asbestos contractor is employed to remove ACMs, they will produce a Plan of Work
specifically for the site and will work within the permit instructions. The Plan of Work precisely defines the
equipment and personal protective equipment they use and the precautions they take during all work on
ACMs.

The Plan of Work details the following:-

 Assessment of the work that will expose their employees to asbestos-containing materials
 The protection and decontamination of those carrying out the work
 Details of the hygiene facilities
 Decontamination of personal protective equipment arrangements
 How to use vacuum cleaners
 Air monitoring
 What protective clothing and respiratory protective equipment is used
 Use of enclosures and airlocks
 Communication between the inside and outside of the enclosure
 How to protect other people at or near the worksite
 Barriers and signs that must be put up
 Location of skips
 Decontamination of employees in an asbestos-free decontamination zone
 Showers used by workers after working with asbestos
 Details of the special Class H vacuum clearner used to to clean up the work area
 Cleaning and clearance certification
 Emergency procedures
 How water is used to keep the worksite damp

The Plan of Work also includes:-

 Details of work methods that will disturb asbestos and which will not be used such as blasting or
sweeping
 Details of checks they have carried out for other hazards
 The name of the Supervisor in charge of the work
 The name of the organisation that will certify the site as being clear of asbestos
 Details of other nearby ACMs which they will not be removing

Note: Listing nearby ACMs prevents confusion betw een the w ork they are carrying out and
ACMs w hich w ill remain in place.

No cutting or smoking, for example, shall take place w hilst performing ACM w ork.

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7.0 Emergency actions
7.1 Basic responses
It is important that everyone who might be involved in an emergency situation knows what to do. In an
emergency situation, the main aims are to:-

 Reduce the spread of asbestos

 Communicate the findings via line supervision to the Industrial Hygienist and avoid unnecessary
worry
 Keep exposure to asbestos as low as reasonably possible
 Immediately clean up any contamination safely and completely

There may be disruption to normal activities at the concerned site. The safety of all staff, contractors and
visitors takes priority in every case.

An emergency situation may indicate a system failure and is recorded in the asbestos written plan, together
with causes and potential consequences.

7.2 Accidentally discovering asbestos-containing material

The most likely emergency situation is the accidental damage or discovery of Asbestos-Containing Materials
during maintenance work.

(See Appendix 6 - Selection of specialised asbestos contractor)

7.3 Emergency response actions

The emergency response actions shown within the flowchart in Appendix 6 are explained below.

 Prevent anyone from entering the area: means completely isolating (sealing off) the area from
non-specialist staff. There may be occasions where the area is sealed off, with the rest of the site
being continued to be used. The Site Controller takes this decision after consulting with the Industrial
Hygienist. Isolation involves the use of signs and physical barriers, such as barrier tape and locked
doors. The types of isolation methods used must be appropriate for the level of risk
 Only staff who are trained and wearing the correct Personal Protective Equipment can take samples
of suspect materials
 The Personal Protective Equipment used must be appropriate to the conditions and include
disposable coveralls with a hood, easy-clean boots or overshoes, and Respiratory Protective
Equipment
 Only approved laboratories may analyse samples to identify whether they contain asbestos. If
uncertain whether material contains asbestos, presume that it does and get support in dealing with it
 Assessing the asbestos risk means assessing the Asbestos-Containing Material and the risk of
exposure to it

Assessment Factors factors to include in this assessment include:-

 The type, age and condition of the material

 The location of the material (for example, is it indoors or outdoors, or in a busy or quiet area)
 How to deal with it (for example, the type of tools to use)
 In all but simple cases, the Industrial Hygienist will carry out this assessment, or delegate it in writing
to another person with the necessary skills and training

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8.0 Disposing of asbestos waste
8.1 Asbestos area debris - removal process
On completion of asbestos work (for example, repair or removal) the area must not be returned to
unrestricted or normal use until the concentration of fibres in the air are no longer higher than the clearance
indicator. For all types of asbestos fibres, this indicator is 0.01 fibres per ml and is based on measurements
made using fixed-position air sampling.

Work methods and equipment must be used to prevent or reduce the build-up of asbestos debris and waste
on floors and surfaces in the work area.

Asbestos-containing material must be placed straight into waste bags (Figure 8) when removed as this is the
most efficient way of reducing the need for extra handling and spreading of dust and debris. In all situations,
asbestos dust and debris must be cleaned up and removed regularly to prevent it building up, and where wet
removal techniques are used, drying out.

The area must be cleaned regularly throughout the work period and thoroughly cleansed at the end of each
shift. Controlled wetting techniques (for example, using airless or light sprays) are used to keep residues
damp, particularly before bagging.

As per the Plan of Work, a visual inspection must be carried out once the work is finished to ensure that all
traces of asbestos-containing material, including any debris and fine settled dust, are removed.

Figure 8: Asbestos waste bag

8.2 Disposing of asbestos containing material

Asbestos waste is labelled and contained in ‘sealed containers’ which should show the asbestos warning
label (Figure 9).

Figure 9: Asbestos waste sign

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When disposing of Asbestos-Containing Material:-

 Make sure that the waste material has been dampened down
 Only put waste vertically into bags which are resting on the floor positioned directly below the ACMs
to avoid spreading the fibres
 Ensure that enough suitable bags and polythene sheeting and strong tape to seal the packages are
available before work starts
 Put the waste carefully into a labelled waste bag that “may” be red and seal the bag with strong tape
 Wipe down the red bag
 Put the red bag inside a clear asbestos waste bag and seal that bag with strong tape
 Wipe down the bag
 Securely attach a printed label to the package to show that it is asbestos waste
 Put the bag of waste into a lockable skip or freight container
 Make sure that the waste bags are taken to the skip or vehicle using the waste route agreed in the
Plan of Work
 Make sure emergency procedures include a system for clearing up any spillages that happen if a
waste bag burst or is holed on the site, or while it was being taken to the skip or freight container

Contractor companies that transport asbestos waste shall keep to the relevant laws and guidance in relation
to registering as a waste carrier. They must leave a trail, which can be audited, to show where the waste
came from and where it was disposed.

All skips or freight containers holding asbestos waste should carry the asbestos symbol (Figure 10).

Figure 10: Asbestos waste skip

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Procedure for Asbestos Risk Management
Appendix 1 - Training, competence and authorisation
The Industrial Hygienist or Certified Industrial Hygenist is the person with the main responsibility for keeping
asbestos-related records on-site. They are trained to carry out their responsibilities to a minimum standard,
holding a proficiency certificate in Management of Asbestos in Buildings - P405 issued by the British
Occupational Hygiene Society (BOHS) or a certificate issued by the American Board of Hygiene or
equivalent.

All staff and contractors whose work could expose them to asbestos must have awareness of the following:-

 Properties of asbestos and its effects on health, including on people who smoke
 Types of products or materials likely to contain asbestos
 Work which could result in asbestos exposure
 Safe work practices, control measures and protective equipment
 Purpose, choice, limit, proper use, fit and maintenance of breathing equipment
 Emergency procedures
 Hygiene requirements
 Decontamination procedures
 Procedures for handling and disposing of waste
 When medical examinations are necessary requirements
 Control limits and the need for air monitoring

Asbestos awareness training is necessary and available, for everyone who could disturb Asbestos-
Containing Material while visiting one of our facilities. How to provide, control and record training is set out in
a written document.

Confirm skills and training: part of the permit includes checking that people (including scaffolders,
operators and supervisors) have the training and skills needed for all levels of work with asbestos, especially
licensed work.

Monitoring: Asbestos-Containing Materials which are left in place, deteriorate with time. A reliable
monitoring programme is in place to identify decay and carry out repairs before it becomes a hazard. How
ACMs are monitored depends on the level of risk. Material which is in good condition and not easy to
access, should be examined every 12 months. We should also monitor the condition of any enclosure and
signs we have used at regular intervals during the year.

Safe sampling: is needed to reassure and to discover new sources of Asbestos-Containing Material.
Always check the Asbestos Register before taking a sample.

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Appendix 2 - Compliance and auditing
Records are kept to show that the workforce has been suitably trained, and has appropriate knowledge and
expertise in understanding the risks from asbestos.

Training courses are audited to check that they meet the course criteria set out in this procedure and that the
syllabus is effectively delivered.

All locations where Asbestos Containing Materials is present will be registered in the local site Asbestos
Register and the main office Asbestos Register.

Auditing
The results of the site ACMs survey are reviewed and updated dependent upon the level of risk, at least
once every 12 months, unless there is some significant change, for example:-

 Changes to operations, processes or work procedures

 New information on health effects related to handling asbestos
 Adverse results from exposure or hazard reports

Regularly checking that people are following the processes and procedures help to ensure that the process
is working properly. Reviewing the way that processes and procedures are managed ensures they are
effective in meeting expectations and delivering performance targets. For further information on this audit
process, see the Procedure for Health and Hygiene Auditing (ROO/HSE/HH/PRO/002).

Asbestos Survey

An asbestos survey is an effective way to manage asbestos in the facility by providing accurate information
about the location and the amount and type of ACMs.
The asbestos survey can help provide enough information to prepare an Asbestos Register, a risk
assessment and a management plan. The survey involves sampling and having the samples analysed to
find out whether they contain asbestos. Asbestos surveys are carried out by surveyors who can clearly show
that they have the necessary skills, experience and qualifications.

Asbestos Register
The Asbestos Register records the presence of all known asbestos materials at a site. Locations where
samples of insulating material are taken, and where analysis shows that these samples do not contain
asbestos, they will be listed in the register to ensure that the records are complete.

The Asbestos Register is used as part of the asbestos management programme designed to ensure that:-

 Everyone involved in relevant work knows the location of all asbestos or ACMs at a site, including
the workforce and contractors
 An inspection of the condition of all ACMs is maintained at site, with a record of the results to ensure
that action is taken as soon as it is necessary

Any work involving ACMs must be carried out in line with this procedure.

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Appendix 3 - Asbestos register
The Asbestos Register records the locations of all materials at a site which we know or suspect contain
asbestos. It is one of the main parts of the written plan. To make sure our records are complete, the register
includes details of where samples of suspect materials were taken, and where analysis has shown that these
do not contain asbestos. Each site keeps a local register to help manage ACMs within its own area. The
Industrial Hygienist is responsible for maintaining the Asbestos Register.

The register requires an ongoing sampling program to be maintained, as it does not support the support
assumption that suspect material contains no asbestos. For guidance on taking samples, refer to Appendix
6. Before taking a sample, presume that the material contain ACMs and take appropriate precautions,
especially if the materials are friable (could release fibres into the air).

Information from the Asbestos Register is used as part of the asbestos-management programme and
designed to make sure that:-

 Everyone working on a site, including staff and contractors, know the location of all ACMs or
suspected ACMs
 Inspection and records of the condition of the materials are taken at intervals appropriate to their
location and condition, so that remedial action is taken as soon as it becomes necessary
 The risks associated with work carried out on, or near ACMs are accurately assessed by the person
carrying out the work or the team leader
 To prioritise any work involving ACMs and carry it out systematically

The Asbestos Register contains information on:-

 The precise location and extent of the ACMs, together with the points from which samples are taken
with details marked on a site plan
 The type of product the material is in and what it is used for, for example, sprayed coating for joist
insulation
 The approximate quantity of ACMs, for example, the dimensions of boarding, the length of the pipe
run and so on
 The condition of the material, for example, whether it is in good condition, friable (could release
fibres into the air), dusty, damaged or likely to be damaged easily (digital photographs are taken to
record the condition)
 The type of asbestos fibre

From this information, a priority risk assessment is completed after carrying out a material risk assessment
and an exposure risk assessment.

High material risks might not present any exposure risk if the area is not being used. On the other hand, low
material risks are much more likely to cause problems if they are in areas that are used often or where they
are likely to be disturbed.

Exposure risk information is collected and included in the asbestos register as part of an overall priority risk
assessment. It is only from this priority risk assessment that the appropriate action to take is decided. This
action includes:-

 Removing the ACMs

 Totally enclosing the material
 Leaving the ACMs where they are and managing them in place (unless maintenance or demolition
work is carried out)

This information is summarised in an overall management plan. For every asbestos area or product the
management plan includes:-

 The target date for completing any necessary work to deal with the material and, the name of the
person or people responsible for the work

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 Details and dates on which the work is carried out, and the names of the people who carried out the
work
 For asbestos left in place, how often the area must be inspected, and the results of the inspections

All ACMs must be labelled appropriately and clearly. If it is decided to leave asbestos where it is, but
knowing it might be disturbed during maintenance work, the asbestos should be recorded in the Asbestos
Register, and procedures established to make sure the work is carried out in an authorised way.

The register is reviewed regularly to make sure that all the information it contains is up to date, and that it
includes the dates when inspections are carried out, and the identity of the inspectors. The inspectors
responsible for recording these details in the register must receive appropriate training.

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Appendix 4 - Procedure for removing CAF gaskets
CAF (Contains Asbestos Fibre)

Prepare: Consider:

1. Look at the job 1. Access from above, not below

2. Plan the task (including emergency 2. Simultaneous operations
actions) 3. GA, isolation and deluge, wind,
3. Assess the risk, get help if needed weather

Minimum permit conditions:

1. Trained within 12 months to ASBESTOS AWARENESS

STANDARD
2. FFP3 + Tyvek overalls with hood worn + Kevlar gloves
3. No power tools, no improvised tools
4. Use water sprayer to minimise asbestos dust
5. Use chemicsl gel softners to dissolve bonding agents which
allow gaskets to be scraped off
6. Use drop sheets to catch waste and damp rags for clean up
7. Double bag waste and seal prior to disposal by material
controller

Erect barriers:

1. PPE on, ensuring good RPE fit

2. Place and secure drop sheet
3. Dampen all visible ACMs, leave for a minute to soak
4. Loosen fixings/fastenings, dampen material as it is
exposed
5. Ease gasket from face using a putty knife
6. Bag waste as it is produced
7. Clean dampened mating faces with scraper

Clean up:

1. Visually inspect area, collect debris, wipe clean with damp rags
2. Take off overalls by turning inside out
3. Seal waste sack after venting excess air away from your face
4. Bag RPE, remove barriers and tannoy end of job

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Appendix 5 - Specialist contractor audit checklist
Planning

There is a good reason to do the work and this reason will improve overall site safety
The contractor holds the necessary competencies for work with Asbestos
Note : May be required for scaffolding.
None of the work will put site users in danger or prevent normal or emergency work on the site.
Work will not be on or next to hot plant or equipment (includes direct sunlight)
Worker heat stress issues have been addressed
There is secure temporary storage close to the job and complete waste disposal route is in place
Any necessary arrangements are made for electrical equipment (example electrical hygiene
shower) used in Classified areas which are not certified for use
The contractor has considered and defined safe systems of work to prevent or reduce exposure
and prevent or reduce spread to as low as reasonably practicable

Pre-start

All training is appropriate to the task and valid throughout the task.
Training is valid for 12 months and includes scaffolder, operator and supervisor level
You have walked around the area and reviewed the control measures, especially area
segregation; designation, marking, entry control, ventilation and hygiene facilities
Independent, competent air monitoring is in place
All staff at site are aware of the risks, control measures and emergency arrangements
The Emergency Response Team is familiar with the habitat, safe access and exit, and
emergency plans
Negative pressure unit is compliant on all recent equipment

Ongoing

Viewing panels are used and accessible, no dust can be seen in air or on glass
Power tools are not used
Waste sacks are wiped down in the bag lock before being double bagged (clear over red)
Waste sacks are clearly labelled and are not overfilled and sharp objects will not tear the bags
Waste is in marked, secure containers, not in the habitat, entrance lock or hygiene facility

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Appendix 6 – Selection of specialised asbestos contractor

Is major 1. Request Industrial

demolition involved or Hygienist to survey or
are invasive structural review justification
alterations YES
required 2. Update Register

NO

Check
register

Could Unacceptable
unbounded materials such NO Assess risk Get advice from
as asbestos insulating board the asbestos risk (condition, Industrial
(AIB), coating or insulation extent, location) Hygienist
be disturbed?

Acceptable
YES risk

Is work that Not sure Get help from the

High is not carried out regularly or
Industrial
low intensity work on bonded
risk!
High Risk! material?
Hygienist

YES

Prepare PTW. Get

Has a NO Get help from the
PTW been Industrial
prepared? Hygienist
Hygienistif
needed
1. Carry out work using
specialist contractor
YES
2. File all clearance
certificates on
completion Carry out basic
NO awareness
Are workers
trained? training. Contact
Industrial
Hygienist

YES

3. Ensure responsible
disposal of waste Proceed with
4. Update register and work
remove any signs
NO

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Appendix 7 - Sampling procedure asbestos containing material

Prepare: Consider:

1. Look at the job 1. Have you checked the asbestos register?

2. Plan the task (including emergency 2. Will taking samples make any difference – can
actions) you assume it is asbestos and treat
3. Assess the risk, get help if needed accordingly?

Minimum WCC conditions:

1. Mask FFP3, Tyvek overalls and Kevlar gloves

2. Sharp knife but no power tools and no improvised tools
3. Use water sprayer to reduce the amount of asbestos dust
4. Use drop sheets to catch any waste and damp rags to clean
up
5. Double-bag waste and seal bags before a material
controller disposes of them.

Isolate the area:

1. Put PPE on, make sure RPE fits well

2. Identify exactly each material you want to take a sample
of.
3. If possible choose a sample from loose material or
debris
4. Dampen the sample area, leave for a minute for the
water to soak in but not dry
5. Collect a sample about the size of a thumbnail. Take a
larger one if this will avoid the need for cutting – never
hack at the area.

Clean up:

1. Inspect the area, collect debris, wipe clean with damp rags
2. Take off overalls by turning them inside out and put them
in a waste sack
3. Seal the waste sack after venting excess air away from
your face

Transport:
1. Send the sample to a suitable local provider
Package the sample to prevent any damage (check with the industrial hygienist if you
while it is being moved are not sure)
2. Be sure to log the certificate of the analysis
For example double-bag the sample and put the
and update the asbestos register
bags in a screw-top container and padded
envelope

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Appendix 8 – Asbestos emergency action flowchart
Suspect unplanned asbestos
1. Stop working immediately
exposure

1. Remove contaminated
clothing and bag it (do
not put it in the bin) YES Is dust on you
2. Shower or wash or your
thoroughly clothing?
3. Leave the facility clean
condition
NO

1. Report the problem to the control

room and follow their instructions
2. CRO to presume it is asbestos and
NO arrange to evacuate the area safely
3. Check the asbestos register or
arrange to take samples if
necessary
4. Make Industrial Hygienist aware of
the situation

Does the
sample contain
asbestos?

YES

1. Industrial hygienist to assess

asbestos risk
2. Identify, inform and support all
affected staff

Is there
NO Is asbestos NO more than a slight
awareness training complete
risk to the health of the
and appropreate?
ERT?

YES YES

Carry out clean-up 1. Isolate the area and employ a

work following PTW specialist contractor
Carry out asbestos-
and make sure waste
awareness training 2. File clearance certificates when the
is disposed of
work is finished
responsibly
3. Take all reasonable steps to prevent
further exposure
4. Health Manager will record in your
personal file an estimate of your
exposure to asbestos.
Update

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