HSG264 Asbestos

HSG264 Asbestos: The Survey Guide – A Summary

On 29th January 2010 the HSE released HSG 264 Asbestos: The Survey Guide. This document expands on and replaces MDHS 100. This document is aimed at those conducting Surveys, those who commission surveys and those with specific responsibilities for managing asbestos in accordance with Control of Asbestos Regulations (CAR) 2006.

Main new features:

Types of Asbestos Survey

The management survey (akin to the Type 2 survey) is designed to locate, as far as reasonably practicable, the presence and extent of asbestos containing materials (ACM’s), so that the Duty holder can prepare a plan for the management of asbestos.

Standard type of survey
Types 1 and 2 no longer applicable
Normal occupancy / activities
Associated routine and simple maintenance / installations work
Involve minor intrusive work e.g. accessing behind fascia and panels or superficial materials.
Combination of sampling and presuming ACM's present
Default presumption should be avoided, more difficult to manage e.g. lead to unnecessary removal of non-ACM's

The refurbishment/demolition survey (akin to the Type 3 survey) is a much more intrusive survey, designed to locate all the ACM’s so they can be removed before the refurbishment (whether small scale or a large project) or demolition takes place.

Includes minor refurbishment which involve structural or layout changes e.g. removal of partitions, walls etc.
Needed for home improvement programmes e.g. new kitchens, bathrooms, electrics, plumbing, windows, roof etc.
Does not need to assess condition of ACM's other than to indicate areas of damage or areas debris may be present apart from where removal may not take place for more than 3 months – need to assess condition of ACM's
No access areas from previous survey must be accessed
Textured coating: survey should identify the nature of the substrate and whether textured coating removal will be required
Provides details of specific areas which should be inspected: Suspended ceiling, partition walls, cavity walls, apertures, floors, ducts, cladding, debris in boiler room, roof voids, DPC etc.
Surveyed area must be fit for reoccupation – requires thorough visual inspection and reassurance air sampling with disturbance (areas with significant destruction)

Planning Stage

Purpose of survey?
Should not accept restrictions on the surveyor's ability to access such areas. Under the new HSE guidance, the duty holder cannot simply take advantage of the small print, for example excusing the surveyor from accessing areas above a certain height, to relieve him of his obligation to locate and manage asbestos.

The duty holder should provide:

clear information on the number of buildings to be inspected
plans and relevant reports or surveys on the building design, structure and construction
information as to the use of the buildings and any known hazards details of access arrangements to all relevant areas
Avoidance of standard form of disclaimers/caveats, ineffectiveness to protect a negligent surveyor.
Should not seek to escape liability for incompetent performance by reliance on standard form and widely drawn caveats.
Should be adequately prepared for accessing areas such as ceiling voids, lofts, lift shafts, basements or high ceilings
Any caveat MUST be agreed between the duty holder and the surveyor before commencement and documented in the survey report.

The surveyor should provide: asbestos

details of any caveats (see below)
confirmation of any areas not accessed
insurance details
references from previous work
names of surveyors
timetable of work

Carrying Out the Survey

Detailed instructions to the surveyor and largely reproduces in expanded form the contents of MDHS 100 and the same applies in relation to the presentation of results
New sections on survey strategy for domestic sector
Clearer definition for Strong presumption and presumed (default situation)
Product ‘location & use’ section updated
Greater detail on conducting refurbishment/demolition surveys
Should check for AIB off-cuts
For cement products - if bulk analysis is inconclusive (e.g. Chrysotile & Amosite are detected) then water absorption test should be carried out to determine if AIB or AC
Contract monitoring by duty holder e.g. to check accuracy of survey report and against the original tender; plans are clear and accurate; all rooms and areas have been accessed, sufficient samples taken; any obvious discrepancies and inconsistencies.

Clarity of Report

Two more sections on reporting requirements:

Executive summary - describe the scope, type and extent of survey and include the summary of identified/presumed ACM’s, no access areas, ACM’s with high material assessment scores, clear notes on any actions (and priorities)
Conclusions and actions – summarise the rooms/products/items which contain ACM’s and material (or the priority assessment) to indicate their urgency

Quality Assurance & Quality Control

New requirement for non-accredited organisations/surveyors – Should implement an effective quality management system (ISO 9001 as a minimum)
5% of all surveys are re-inspected
Audit of completed surveys
Survey reports should be checked by an authorised person before issuing to client

Editorial contributed by Mr M Lopacki

NATAS (National Asbestos Training and Accreditation Scheme)

www.natas.co.uk

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