Asbestos is the name for a group of naturally occurring silicate minerals that can be separated into fibres. The fibres are strong, durable, resistant to heat and fire. They are also long, thin and flexible, so that they can even be woven into cloth.
There are three main types of asbestos, all of which are potentially dangerous:
- Brown / Grey - Amosite
- Blue - Crocidolite
- White - Chrysotile
Asbestos represents a safety risk when fibres are released into the atmosphere and are inhaled. The fibres can cause asbestosis, lung cancer or mesothelioma (a cancer of the chest wall).
Fibres can be released when asbestos products deteriorate or when the products are worked on during repair or maintenance activities e.g. sawing, drilling, etc.
This will require an inspection/ survey of the building to identify if asbestos has been used in its construction. If asbestos has been identified then the location and condition of this must be noted.
Contractors who are carrying out work on the premises must be informed of the location of any asbestos prior to starting work.
Where asbestos is in a poor condition a competent contractor should be consulted about making it safe.
Regulation 4 of the Control of Asbestos at Work Regulations requires the duty holder to "Manage Asbestos" - which basically means they have to establish whether asbestos is present, in any form, in the buildings, whilst ensuring that it does not and will not present any risks to anybody. For some workplaces, this may prove to be a simple exercise but for others it almost certainly will not.
Who is the duty holder?
Those holding duties to manage asbestos in non-domestic premises could be the owner, the occupier, a managing agent or anyone else with responsibilities in the property. The legal definition of duty holder, from the regulations, is:
- every person who has, by virtue of a contract or tenancy, an obligation of any extent in relation to the maintenance or repair of non-domestic premises or any means of access thereto or egress therefrom; or
- in relation to any part of non-domestic premises where there is no such contract or tenancy, every person who has, to any extent, control of that part of those non-domestic premises or any means of access there to or egress therefrom.
Where there is more than one duty holder, responsibility will be shared, based on their relative duties for maintenance and repair.
Where is asbestos found in buildings?
Some Asbestos Containing Materials (ACMs) are more vulnerable to damage and more likely to give off fibres than others. In general, the materials which contain a high percentage of asbestos are more easily damaged. The list below is roughly in order of ease of fibre release (with the highest potential fibre release first). Sprayed coatings, lagging and insulating board are more likely to contain blue or brown asbestos (the most hazardous types). Asbestos insulation and lagging can contain up to 85% asbestos, thus making them more likely to give off fibres. Work with asbestos insulating board can result in equally high fibre release if power tools are used. On the other hand, asbestos cement contains only 10%-15% asbestos. The asbestos is tightly bound into the cement and the material will only give off fibres if it is badly damaged or broken.
You are most likely to come across asbestos in these materials:
- Sprayed asbestos and asbestos loose packing - generally used as fire breaks in ceiling voids.
- Moulded or preformed lagging - generally used in thermal insulation of pipes and boilers.
- Sprayed asbestos - generally used as fire protection in ducts, firebreaks, panels, partitions, soffit boards, ceiling panels and around structural steel work.
- Insulating boards used for fire protection, thermal insulation, partitioning and ducts.
- Some ceiling tiles.
- Millboard, paper and paper products used for insulation of electrical equipment. Asbestos paper has also been used as a fire-proof facing on wood fibreboard.
- Asbestos cement products, which can be fully or semi-compressed into flat or corrugated sheets, which are largely used as roofing and wall cladding. Other asbestos cement products include gutters, rainwater pipes and water tanks.
- Certain textured coatings.
- Bitumen roofing material.
- Vinyl or thermoplastic floor tiles.
You should always presume any material contains asbestos unless there is strong evidence to suggest it does not.
- Carry out a desktop study to check out what you already know about your buildings, e.g. look at building plans and other documents.
- Contact anyone else who may already have useful information about the building, e.g. a surveyor, architect or contractor who knows the building.
- Carry out an inspection of the building. You can do this in house, especially if you simply assume materials contain asbestos. Or use an independent expert if samples have to be analysed.
- Record the results of the inspection, identifying the parts of the building where asbestos may be located.
- Assess the type and condition of any ACMs, how likely they are to be damaged or disturbed, and the risk of asbestos fibres being released into the air - Is the surface of the material damaged, frayed or scratched? Are the surface sealants peeling or breaking off? Is the material becoming detached from its base? (This is a problem with pipe or boiler lagging and sprayed coatings) - Are protective coverings, designed to protect the material, missing or damaged? Is there asbestos dust or debris from damage near the material?
- Draw up a management plan. State which areas, if any, need asbestos to be sealed, encapsulated or as a last resort, removed. The key part of the plan is to warn people coming to work on the building, to prevent accidental exposure.
- Build in regular checks to make sure the condition of materials has not deteriorated. Concentrate on areas of high risk, where materials are more likely to get damaged.
- Keep the management plan up to date to show any changes that could affect the risk.
- Remember, the new legal duty is about managing any asbestos in a building, not about removing all asbestos! Asbestos that is in good condition and not likely to be disturbed should not be removed. Asbestos is only dangerous when disturbed. If it is safely managed and contained it does not present a health hazard. Removing it can be more dangerous than simply containing it.
- Do not treat all asbestos materials the same. You only need to use a licensed contractor to work on high risk materials, such as pipe insulation or asbestos insulating panels – not on asbestos cement which is much less dangerous.
- Do not forget that the regulation is all about protecting maintenance workers and others from asbestos fibres, so concentrate on practical steps to achieve this.
Finally, a statement from the HSE's website on this issue:
"The regulation is not a duty to survey. Any survey will only be a step towards managing any asbestos, and poor or inappropriate survey could prove to be worse than no survey at all".
The Main requirements are:
- Establish if there are any Asbestos Containing Materials (ACMs) within the premises, confirm its location and the condition it is in.
- Creating a record/log of the location and condition of confirmed or presumed ACMs within the premises (e.g. asbestos register).
- Make an assessment of the risk from the material (e.g. asbestos survey).
- Prepare a plan that sets out precisely how the business is going to manage the risk from the materials (e.g. monitor, removal, etc).
- Carrying out the necessary steps needed to put your established plan into action.
- Review and monitor your plan and the arrangements put in place.
- Creation of a system for providing information on the location and condition of the materials to any person who is liable to work on or disturb it.
Questions to Consider
- Has an asbestos survey been completed?
- Are there any asbestos materials within the premises?
- What is the condition of the confirmed or suspected asbestos materials?
- Are the areas being monitored for signs of deterioration?
- Are all staff aware of the location and condition of the ACMs within the premises?
- Has sufficient information been given to all persons potentially affected by the materials?
- Are all confirmed asbestos containing materials clearly identified e.g. labelling?
The above guidance provides an introduction on the main requirements needed to adequately manage this health and safety topic. If you require further guidance, risk assessments or template documentation on this subject please consult your relevant full guidance health and safety website (BIGGA, England Golf, Scottish Golf, Wales Golf). If you do not hold the log in details for this website, for your club, please speak to your golf club management team to identify who the account administrator is and request the details.