New asbestos surveying guidance HSG 264

After two years of discussion between the Health and Safety Executive and interested parties, including RICS, BIFM, asbestos consultancies, removal contractors, demolition contractors and the Environment Agency, new guidance has now been published (January 2010) to move asbestos surveying guidance in line with the Control of Asbestos Regulations 2006.

This new set of guidance, called HSG 264 “Asbestos, the Survey Guide”, replaces MDHS 100, which first came out prior to the Control of Asbestos at Work Regulations in 2002, and therefore solves a number of inconsistencies in the regulations. A full set of the changes is detailed below:

1. The guidance details expectations of asbestos management plans and their content to tie in with Control of Asbestos Regulations 2006 (CAR) and duties under the Construction (Design and Management) Regulations 2007

2. Revision of Types of survey from Type1 (Presumptive), 2 (Sampling), 3 (Intrusive) to Management (replaces Types 1, 2) and Refurbishment / Demolition (replaces Type 3).

3. Asbestos Management Surveys are undertaken to ensure building managers can address risks of building in normal occupancy

4. Asbestos Refurbishment / Demolition Surveys are undertaken to identify asbestos where use of building fabric (or fixed plant) changes / will be disturbed

5. Explicit duty on Surveying practices to undertake method statements, risk assessments for the work, particularly for Refurbishment / Demolition surveys and to ensure adequate liaison with customer for hazards encountered

6. Recognition that some previous surveys missed possible asbestos / did not inspect rigorously enough and so a duty on customers and surveyors to reduce as far as possible caveated areas (including areas impossible / inaccessible to survey). Caveats must be agreed between the stakeholders in advance of any survey, and detailed fully in correspondence between such parties.

7. Asbestos Management surveys may require limited opening up to ensure that normal use of the building will not identify unforeseen asbestos locations (e.g. for telecoms / data cabling that would be installed in normal conditions)

8. Asbestos Refurbishment / Demolition surveys are expected to have suitable and adequate precautions provided to undertake the survey without providing any additional risks from hazards encountered during that survey. This includes creating working areas similar to asbestos remedial work areas when opening up suspected locations, provision of PPE / RPE and decontamination equipment, and isolation of the area from all services. Prior to any work in such areas the space intended for inspection should be vacant and prior to re-occupation reassurance air monitoring is recommended where significant opening up has occurred.

9. Management surveys can be extrapolated in homogenous areas (such as tower block common parts) where homogeneity is expected. All parts of a building should still be visually inspected however.

10. Where Management surveys are used to provide information for Refurbishment / Demolition surveys, assumptions can be made for the management plan, however it is still expected that asbestos training is provided to contractors undertaking work.

11. The new Guidance provides details of what the customer should expect within the survey report, and places explicit duty on the customer to check information provided is accurate (e.g. room name / number)

12. Surveyors are expected to enquire of customers a range of information at tender / enquiry stage to provide a full and detailed quotation and risk assessment, and to ensure that suitable and sufficient awareness is made of hazards to be encountered to allow precautions to be utilised.

13. In addition, surveyors are expected to attend walk through surveys to consolidate information gained from written / verbal communication; however it is appreciated this is not possible / feasible in all occasions.

14. Surveys are expected to be undertaken by teams of 2 surveyors where practicable

15. The guidance details levels of accreditation and quality necessary to ensure a quality service and expert advice, namely use of UKAS accredited laboratories who can demonstrate quality. Surveying personnel should hold suitable training / and be regularly audited for competence either through UKAS / ABICS and hold BOHS qualifications.

16. The guidance provides detail on difficult to access areas and expectations for examination in those areas.

17. The guidance is more explicit on the requirements for initial and continual training to tie in with the additional demands stated within CAR for surveyors but more importantly for customers as part of their management plan.

For further independent information on the impact of this guidance on how you should manage asbestos in your buildings, please contact GBNS Partnership on 01371 810700 or click here.

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