Excerpts from an example Type 2 Asbestos Report and asbestos registerClick to enlarge Cover Index Site Assessment Material Assessment Material Assessment Overview No Access & Restrictions Assessment Information Asbestos Data Sheet Asbestos Data Sheet Asbestos Data Sheet Asbestos Data Sheet Asbestos Data Sheet Asbestos Data Sheet Asbestos Data Sheet Asbestos Data Sheet Asbestos Data Sheet Asbestos Data Sheet Asbestos Data Sheet Asbestos Survey Information Asbestos Register Front Sheet Asbestos Register Sheet Asbestos Register Sheet Asbestos Register Sheet Asbestos Register Signatory Page
This page is
currently being updated and will be replaced shortly to include any
changes imposed by the new surveying guidance: HSG264 Asbestos: The
Survey Guide, which was introduced Jan 29th 2010
information with regards to the new guidance visit our
asbestos survey section.
Asbestos Survey Reports & Asbestos Registers
Introduction to Asbestos Survey Reports / Asbestos RegistersOnce your asbestos survey has been undertaken, understanding the survey results is essential in the application of any additional requirements for compliance with the Control of Asbestos Regulations (2006), Regulation 4 'The Duty to Manage'. Dependant upon the results of the survey, it may be that no further action is required, i.e. if your survey has returned results of 'no asbestos detected'. However it must be pointed out that should this be the case, unless you have had a full Type 3 pre demolition or destructive asbestos survey, with no 'non accessed areas or restrictions' then you will still require some form of asbestos management plan or policy for full compliance and asbestos management. This will be to cover the eventuality of disturbing areas which have not been accessed and as such not surveyed during the Type 2 or Type 3 asbestos surveys. These no access areas should be highlighted within the asbestos survey report or asbestos register. Any such areas must be presumed to contain asbestos bearing materials, unless proven otherwise. Your management plan, asbestos policy and asbestos procedures must reflect this. We have based this help section on Type 2 Sampling asbestos surveys for the following reasons, however all survey reports and registers are similar in layout and design; With Type 1 asbestos surveys, it is normally the case that all or most areas are presumed to contain asbestos bearing materials unless proven otherwise. It is for this reason that this type of survey is not a popular choice for ongoing asbestos management. With a Type 1 asbestos survey, long term ongoing costs of everyday management during normal activities can be high. This is due to the general all round assumptions that are made which require further surveys or sampling prior to the disturbance of any materials not specifically excluded from being presumed to contain asbestos. This disturbance can be as minor as every day maintenance tasks or minor building upgrades such as changing light fittings, installing shelves or even hanging pictures. In practice any such activities would require some further form of survey or sampling procedure to ensure asbestos containing materials are not disturbed. As you can imagine having to survey or sample prior to the smallest task is not only very difficult to manage but will very soon become an expensive way to manage. asbestos removal specification followed by a tender process, a removal project and ultimately certification of asbestos removal and clearance, prior to starting any planned works. Type 2 asbestos surveys are the most commonly utilised for the purposes of asbestos management. As such we have concentrated on this survey type for our help section on understanding asbestos survey reports and registers. As mentioned it is generally accepted that the the main purpose of a type 2 asbestos sampling survey is to enable the client to manage asbestos containing materials within their property and aid them in compliance with Regulation 4 - ' The Duty to manage '. All to often the client receives an asbestos survey report and register and does not take any further action. This is mainly due to a misconception that a Type 2 asbestos survey report constitutes compliance with ' The Duty to Manage ', it does not! In the following section we hope to shed some light on understanding how an asbestos survey report is structured and what steps are required following the inspection. It is generally accepted that all asbestos surveys and subsequent reports and registers should comply with MDHS 100 (Methods for the Determination of Hazardous Substances) and HSG 248 Health and Safety Guidance: "Asbestos: The analysts' guide for sampling, analysis and clearance procedures". MDHS 100 sets out the requirements of the actual survey and the way in which the information collected must be presented. As such a large majority of asbestos survey reports and asbestos registers are similar in appearance. However it must be noted that not all surveying company's fully comply with the set requirements. If you are thinking of having a survey undertaken or have already commissioned one, then it is recommended that you take some time to inspect the requirements of MDHS 100 to ensure that you are aware of what to expect and that the company you have employed are delivering the service you need and require in accordance with current regulations and guidance. To understand an asbestos survey report it is essential to understand the main points that such a report is intended to highlight. Generally as an overview a Type 2 asbestos survey report should contain the following information:
In some cases such as Oracle Solutions UK ltd, the surveying company will assign a risk assessment to the entire building or site which has been surveyed. This is intended to give the client an initial visual overview of the findings. The site assessment score will be based on the highest risk asbestos element which has been identified during the survey. In the following example the site has been assessed as having a risk score of medium. This means that somewhere on the site there are asbestos containing materials which were identified and have been assessed as having a ' medium potential to release asbestos fibres '.
The risk categories detailed within the table are part of the material assessment algorithm as detailed within MDHS 100. The site score is based on the highest material risk rating at the site. Materials with assessment scores of 10 or more are regarded as having a high potential to release fibres, if disturbed. Scores of between 7 and 9 are regarded as having a medium potential, and between 5 and 6 a low potential. Scores of 4 or less have a very low potential to release fibres. Non asbestos materials are not scored.
The assessment score is coloured which is replicated throughout the report and register for ease of understanding and remains the same for specific item assessment as well as overall site assessment. Following on from the table is a brief paragraph which shows the client in essence what risk score their site would be if all asbestos containing materials at the site were in a safe and manageable condition.For example the site below has been assessed as a medium risk site with a ' medium potential to release asbestos fibre '. The paragraph following the table has assessed that should the minimum works required be completed (in accordance with The Control of Asbestos Regulations 2006), then the sites risk assessment would be reduced to a ' low potential to release asbestos fibre '. So in brief this page gives the client a general overview that their site is currently not fully compliant and some type of asbestos remedial works are required.
To better understand the site assessment the client needs to know how the assessment of individual asbestos containing materials is carried out. Within MDHS 100 is an algorithm which can be utilised to score each asbestos containing material identified during the survey. The following table shows the scores for each element which is sampled and identified as containing asbestos.The table contains examples of scores which are added together to calculate a total score of between 2 and 12. This total score forms the material assessment score. There are obviously many asbestos containing materials which are not listed and this is then (if not detailed within MDHS 100) left to the experience of the surveyor / consultant to determine which score category to assign.
| The material assessment is worked out as follows:|
Product Type + Damage Extent + Surface Treatment + Asbestos Type = Material Assessment
Therefore if an unsealed asbestos cement flue pipe, in good condition, is identified during the survey and a sample analysed at a laboratory identifies the pipe to contain Chrysotile (White) asbestos, then the algorithm would be:
Therefore the material assessment for this product is a 3, or as previously detailed a 'very low potential to release fibre'. and coloured accordingly.
As a general standard, recommendations for this material will be based on the minimum requirement to place asbestos containing products into a safe and manageable condition, and as such it would be recommended that this product not be disturbed, be left in situ, and managed. Recommendations are further explained later in this section.Now that the general basis of site and material assessment has been covered we will look at each asbestos containing material to see how this information is relayed in report format. Not all surveying companies utilise this format as it is time consuming and requires significant information to be entered into the report. At Oracle Solutions UK Ltd we believe that the client should be furnished with as much information as possible to ensure a greater report detail and allow for corrective actions and management to be undertaken effectively. However as previously discussed it is generally accepted that this information should be included within all asbestos survey reports in order to comply with MDHS 100. Each survey report should contain specific information for each and every material that the surveyor / consultant suspected as containing asbestos during the survey. A sample would have then been collected and on completion of the sample analysis the surveyor / report writer would be able to complete the following data sheets inputting the laboratory results. The following shows an example data sheet for a recent survey, there are more examples to the left of the page:
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It is important to note that there is a separate data sheet for each item located, and presumed to contain asbestos, during the asbestos survey. Each sheet contains specific data and includes, client details, site details, survey date, building and specific location of the material in question.
Further to this there is a description of the material, a measurement (or extent) and all of the previously discussed information required to undertake the material assessment. A photograph is included for ease of visual location and the product material assessment is listed. Additional information is contained within the comments section, this can be any information which the surveyor collected on site and feels is pertinent to the identified material.
The last section is recommendations. Recommendations are based on all of the collected data and where asbestos is confirmed, normally reflects the minimum required actions to place the asbestos containing material into a safe and manageable condition. Where asbestos is not identified (i.e. the laboratory reported 'no asbestos detected') then no further action would be required and as such there would be no recommendation.
We have now covered the basic report structure which includes the overall site assessment and specific asbestos containing material assessments. Depending upon your particular site and report the number of asbestos containing materials, their location and extent will vary.
Each separate asbestos bearing material may have a specific recommendation. As previously mentioned on the basis that the Type 2 asbestos survey has been undertaken for the purposes of complying with the duty to manage, then each recommendation will generally be designed in such a way as to aid you in complying with those regulatory duty's. As such each recommendation will give you required works which as a minimum will place all asbestos containing materials into a safe condition and enable their management on an ongoing basis.
Recommendations may suggest additional steps which can be considered dependant upon your asbestos management plan, policy and procedures. If your policy and procedures are already in place prior to the survey these should be discussed with the surveyor so that they can better recommend actions which comply with them.
For example the regulations stipulate that all reasonable steps are undertaken to prevent the spread of asbestos. In order to achieve this, accidental damage to asbestos containing materials must be reduced and controlled. To reduce and control accidental damage all those who are likely to come into contact with asbestos containing materials at your site, must be made aware of the risks. This should form part of your management plan. Managing this duty can be aided by applying asbestos warning labels to all asbestos containing products. Therefore if this is included within your asbestos management plan the surveyor can recommend such actions within the asbestos survey report. However labelling of asbestos products is not the best course of action for all premises. As such other measures must be considered and implemented.
Although recommendations will be based on the overall goal of placing all asbestos containing materials into a safe and manageable condition, it may not (dependant upon the amount of asbestos materials identified and their condition) be practicable to undertake all works immediately. This is why Under ‘Regulation 4’ (The duty to manage), of ‘The Control of Asbestos Regulations 2006’, the duty holder is required to carry out additional assessments using the report together with their detailed knowledge of additional factors such as, i) use to which the location is put, ii) the occupancy of the area, iii) the activities carried on in the area; and iiii) the likelihood / frequency with which maintenance activities are likely to take place. This additional assessment will form the basis of the required asbestos management plan.
No access areas were briefly mentioned earlier in this section. It is worthy of note that no access areas and restrictions within survey reports are as important as the areas which were accessed. It is generally taken for granted that when a survey has been undertaken that all areas were surveyed and all asbestos materials at the site were identified. This is rarely the case.
Asbestos bearing materials were readily used within the main construction of many buildings and as such can be hidden within constructed areas which are not reasonably accessible during a survey. Examples of this are cement sheets used as concrete shuttering beneath floors and in structural casings, asbestos packers beneath steel structures and concrete slabs. Even with a fully destructive type 3 survey it is often the case that hidden asbestos containing materials are not uncovered until major demolition of the building has taken place.
It is therefore commonplace for asbestos survey reports to contain two section which cover such eventualities, these are: 1) Restrictions, and 2) No Access Areas.
It is usual for both sections to be included within a single section of an asbestos survey report.
These are normally areas or items excluded from all surveys of the same type, and although they change depending on the type (as each survey type is distinctly different in the type of access required) most company's utilise the same restrictions within each report. All survey company's will use certain restrictions which are commonly found such as previously discussed.
However the client should take note of such restrictions to ensure that they are not compromising the validity of the report. For example it is not unusual to see restrictions included which should be easily accessible for any good surveyor and should be an integral part of an asbestos survey. An example of such a restriction is where suspended ceiling voids are excluded. By excluding such an easily accessible area without good cause almost makes the survey worthless. It would mean that no maintenance works or access could be undertaken within this area without presuming it to contain asbestos. This would severely restrict general maintenance activity's. As the purpose of a Type 2 asbestos survey is to aid in the management of asbestos within in a building during normal maintenance, such restrictions should not be imposed.By paying close attention to these restrictions a client is able to quickly identify the value of their survey and the competency and thoroughness of the surveying company. The following page contains general restrictions during a type 2 survey which are considered to be acceptable.
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It should be noted that included are restrictions based on health and safety factors, such as electrical installations, confined space, access, and damage to presumed asbestos materials. All of which are self explanatory. Further to this there are restrictions on items within the building such as machinery, installations and equipment, basically any item not considered part of the building itself. However in this instance where asbestos products are obvious or within an item that the surveyor, from experience, knows will usually contain asbestos, these are generally noted within the report. However this will be in accordance with the surveyors skills. Lastly you will see restrictions based on damage. These are to minimise damage to the property being surveyed and will usually not be included within a fully destructive Type 3 survey report, for obvious reasons.
Although a good surveyor will make all reasonable efforts to access all areas of a building the client should make arrangements to have keys and access available at the time of the survey. Further to this if any of the restrictions discussed are required as part of the survey for whatever reason, the client should make the surveying company aware at the time of quotation, as there are additional required costs for accessing these types of accepted restrictions.
'No Access Areas' are generally considered to be areas or items which would normally be included within the asbestos survey, but due to circumstance beyond the surveyors control were not available for inspection. An example of this is where a room or area is locked and at the time of the survey their were no keys available at the site. As such this type of area would be recorded as a no access or not surveyed area.Further to this there may be certain areas which the surveyor cannot survey or reach and are included within the main descriptions of 'restrictions'. However good surveyors will provide further detail of items which experience shows are likely to contain asbestos. An example of this is a 'fire proof safe'. A good surveyor will know that safes of this type generally contain asbestos bearing materials and even though they are not considered to be part of the building structure, locked and inaccessible, will want to bring it to the attention of the client. Including this as a no access area will highlight such an item.
As can be seen from this webpage the main asbestos report can be both long and complicated. An asbestos register is a much reduced version of the report and is a tool to be utilised in the effective management of asbestos containing materials at a site. Not all surveying company's include a register with the survey report as information within a register is duplicated from the main survey. However Oracle Solutions (UK) Ltd believe that the asbestos register should be included with the report to aid effective asbestos management.
The asbestos register is normally designed to remove information which would be considered to be non essential for general maintenance requirements. As such an asbestos register should contain the basics: Asbestos containing materials identified during the survey, photographs of the product, product and asbestos type, condition, and extent. Asbestos registers normally contain a location plan and detail any restrictions and no access areas.
The register should be designed in such a way as to be easily understood. Anyone working at the site, who is likely to be be undertaking works which could potentially disturb asbestos containing materials should be instructed to read the asbestos register, make themselves familiar with any asbestos containing materials at the site and be aware of any areas which must be presumed to contain asbestos. This will enable them to make an assessment as to whether the works they are proposing to undertake are safe to do so.
The register will normally have a signatory page for each maintenance operative or contractor to confirm their awareness of the register, any associated risks therein and are able to make an assessment of the risk. Obviously anyone working within such a position should have appropriate training in order to make an assessment of this type.
The register will also contain details of the next due re-inspection date and will also have areas where change in condition to identified materials can be recorded. This will include any asbestos remediation works, accidental damage or a change in condition noted by anyone with access to the register.In instances where more complicated tasks other than general maintenance are required the whole asbestos survey report should be available for further details and assessment of risk.
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It is worthy of note that even where a survey has returned results which have not identified asbestos containing materials at a site, that as long as there are survey restrictions or no access areas, an asbestos register is required. This is to ensure that anyone entering non surveyed areas are aware that they have not been surveyed and as such must be presumed to contain asbestos bearing materials until proven otherwise.
The register can also be utilised to include and aid any company asbestos management policy and procedures.