Do you need an Asbestos Survey or an Asbestos Register?
The simple answer is they are both required and go hand in hand, so why is the ‘Register’ element so often overlooked?
Regulation 4 Duty to Manage Asbestos in Non Domestic Premises is quite clear in stating the requirements of the dutyholder:
‘The dutyholder must manage the risk from asbestos on the premises.
The main dutyholder is required to ensure that a written plan is prepared that shows where the ACM is located and how it will be managed to prevent exposure to asbestos, including to contractors and other workers who may carry out work on the fabric of the building that could disturb the ACM. This plan then needs to be put into action and communicated to those affected. The dutyholder needs to ensure the plan is reviewed regularly and updated as circumstances change, in consultation with all those who may be affected. ‘
HSG264 – Asbestos: The Survey Guides, again reinforces this process for the dutholder and surveyors:
The purpose of an asbestos survey (Dutyholder)
- To help manage asbestos in your premises.
- To provide accurate information on the location, amount and condition of asbestos-containing materials (ACMs).
- To assess the level of damage or deterioration in the ACMs and whether remedial action is required.
- To use the survey information to prepare a record of the location of any asbestos, commonly called an asbestos register*, and an asbestos plan of the building(s).
- To help identify all the ACMs to be removed before refurbishment work or demolition.
*Note: the information in the register should be used to inform the risk assessment (eg consider who could disturb asbestos on your premises), and to establish the management plan to prevent such a disturbance.
Survey key points (Surveyors)
- Be aware that the survey is essential for the client/dutyholder to successfully manage asbestos.
- All asbestos should be located as far as reasonably practicable within the survey type.
- Ensure that the appropriate survey is undertaken for the client’s needs.
- Avoid caveats.
- Ensure the survey is reported in a format that can be used to prepare an asbestos register and building plan.
- Inform the client that the survey is not the end point in managing asbestos.
From my experience most of the industry focus is on the production of survey reports, which will provide information on the location and condition of ACM’s but are generally not in a format that will lend themselves for future additions, amendments, updates.
In the lifetime of a building (up to its final demolition), multiple surveys, inspections, sampling, removal may be required to continually manage the risks and prevent the spread of and exposure to asbestos.
Therefore, the focus, and priority should be the ‘Asbestos Register’, the format it is held in needs to be able to be updated when additional activities are carried out, of which surveys are a vital part.
- Are my ‘Asbestos Registers’ easily accessible by staff, contractors etc?
- Do they clearly identify which areas of the building have been inspected or NOT inspected?
- Do they clearly identify where asbestos containing materials have been identified?
- Is the ‘Asbestos Management Plan’ linked to the ‘Asbestos Register’ information?
- Can the register be updated?
- Following additional surveying
- As part of a condition inspection (re-inspection)
- Following removal works or remedial works
And don’t forget the floor plans, they play an integral part of understanding where asbestos has been located and need to be maintained in conjunction with the register data.
If you feel you are failing in any of the above, it may be time to consider consolidating all your existing data into one usable system.
Sounds costly, well think how much money is wasted replicating survey information or reproducing when information is lost.
Or the implications if asbestos is disturbed by staff, contractors or the public.
Properly managed ‘Asbestos Registers’ can save you time and money and provide a safe working environment for everyone!
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