Assure 360

What to do when you find asbestos contamination on site

Written by Nick Garland on 28/03/2018
 

Finding asbestos contamination on a site or building project can feel paralysing. But there’s no need to panic. Here’s a simple guide to help.

The words ‘asbestos’ and ‘contamination’ are probably two of the things you least want to hear. Whether you’re involved in commissioning or designing a construction project or just occupying a building, asbestos can lead to worry, cost and delays.

Outside of the nuclear industry, the management and safe removal of asbestos is the most regulated process you can be involved in. And regulation invariably means expense – particularly if there’s regulatory infringement.

Why is there so much asbestos in the built environment?

What is asbestos? As far as day to day practicality is concerned – ‘asbestos’ refers to the actual product that has been installed into a building. Because the ‘benefits’ of asbestos were so far reaching and its production relatively cheap – the type of products it was used in were virtually unlimited.

Asbestos can be found in:

  • Insulating panels
  • Cement corrugated sheeting, guttering and downpipes
  • Pipe insulation
  • Plastic floor tiles
  • Gaskets and electrical insulators

And many other materials and structural elements.

Tony Rich, a respected asbestos consultant in the US, has taken and collated a vast collection of photographs of examples of materials and locations where asbestos has be found from roofing to cigarette filters

With the number of different products so extensive it’s no wonder that properties constructed before the early 1980s almost certainly contain asbestos. As the ban only came into force in 2000, even those built as late as 1999 could have some.

How does asbestos get into the ground?

As we increasingly look for asbestos in soils we are finding more and more. Even if we ignore fly tipping and re-burying on site, there are several reasons why the ground we stand on can become contaminated.

Alas for many years we were not very good at finding asbestos in buildings. In defence of the surveyor, the proliferation of asbestos is huge (especially in the UK) and progressive refurbishments can cover over and conceal it. But the approach to intrusive pre-demolition surveys used to be quite weak.

The guidance on what you needed to do with asbestos once found in buildings about to be demolished was not always in concert with the hazardous waste rules. For example, it was widely accepted that Textured Coating had low asbestos content, was bonded to the surface it was painted on, and when demolished, did not constitute hazardous waste.

Buildings could be demolished without even looking for asbestos, either intentionally (we don’t want to know) or as an incompetent oversight.

Whatever the reason, if a building is demolished with asbestos still in it, that asbestos will find its way into the ground. The site itself could become contaminated and / or the subsequent rubble could be converted into secondary aggregate for other sites.

What to do if you find asbestos

Whether you find asbestos in a building, or find it contaminating land you’re going to be building on, I’ve created a simple acronym to help remember the useful steps to take:

R – Respond calmly

2 – Two important questions to assess risk

D – Decide what you’re going to do next

2 – Two trade organisations who can help you find a licensed asbestos professional to help

Respond calmly

If you discover asbestos, in the first instance – do not panic. As the HSE’s Martin Gibson has said – in the UK we have a long history and genuine expertise in managing the risk from asbestos. This does not always mean remove it.

Two simple risk assessment questions

With the proviso that you shouldn’t touch or disturb asbestos – the best rule of thumb when assessing the risk of asbestos in a building is to ask these simple questions:

  1. ‘How hard or soft is it?’
  2. ‘Is it protected / out of reach?’

For example, if the asbestos material is a corrugated garage roof: this is out of reach (or at least not easy to knock into) and clearly quite hard. So the risk is low.

If it is low level pipe insulation, it’s easy to touch and relatively soft. The risk is high. Simple.

You need to have as much knowledge as possible to answer these questions. And when it comes to asbestos that means a survey. This will tell you where any asbestos is and what the risks are.

The challenges of ground contamination

The very nature of ground contamination makes the ‘problem’ an entirely different beast.

By being in the ground the material is buried and therefore hard to find. It degrades – breaking down and dispersing the asbestos fibres. Surveys have to follow a different pattern and are detailed in the HSE’s asbestos analyst guide (read my recent summary for more information). On the positive side, (especially in the UK) the ground is damp – important as wet asbestos does not get into the air too easily.

The risk assessment for ground contamination though remains essentially the same. Ask yourself two questions:

  • How near to the surface is the material?
  • How degraded is the material?

Loose insulation at the surface is high risk. Buried cement is low risk.

Decide what you’re going to do

The next step is decide what you are going to do about it.

For asbestos in a building, providing that the material is in good condition there are plenty of options that do not include costly removal. In fact this is the HSE’s primary recommendation. If you can avoid touching, damaging or in any way disturbing the asbestos – then it is safer to manage it in situ. Even this is relatively straightforward – it involves a periodic check to make sure that its condition has not deteriorated.

If you do leave asbestos in the building – anyone who could come into contact with it should know it is there. If they could damage it through their work, they should have Asbestos Awareness training. These courses are so widely available that it is almost certain that there is a company near you that provides them. Check out the IATP or UKATA website to find a provider.

If however the asbestos is in poor condition, or it is in such a position that it could get damaged in the future, action may need to be taken. This still doesn’t necessarily mean removal but it does mean that you will need professional assistance. Options other than removal could be to protect the asbestos – help ensure it doesn’t get damaged. This can range from covering it up, painting it or to simply close and lock the door.

Again with ground contamination, we are faced with different challenges. We often only know of the existence or the contamination because digging is planned. But it could be something as simple as buried broken cement coming to the surface on a walkway. In either case some form of action is usually required. Just like asbestos in buildings though, that action could be ‘close the door’. In this case it would be to install a capping layer above the problem to seal it off. If however digging is unavoidable then some form of controlled removal will be required.

The rules on where this material goes is simple, but has huge implications:

  • Does the ground comprise >0.1% asbestos by weight?
  • Are there any visible fragments, that in of themselves are >0.1% asbestos by weight?

If either of these are the case, then the material is ‘hazardous waste’ and therefore expensive to dispose of. If not at these levels, but still present, it is not ‘hazardous’, but must be disposed of at a landfill site that has an ‘asbestos cell’. Significantly less expensive, but still onerous.

Therefore a single fragment of visible asbestos can render a whole load contaminated. Careful early planning, screening and segregation becomes critical.

Two trade organisations who can help you get licensed help

I have always recommended that a licensed contractor is used for any work on asbestos. This is (strictly speaking) not always legally required, as some low risk asbestos (the cement sheeting I mentioned earlier) does not need a licence. It does however need special equipment, training, medical supervision and insurance. In my experience you are much more likely to get it done right first time with a licensed contractor.

There are two main trade organisations: my one: ACAD, and ARCA. Both can offer lists of members that have passed their audit scheme. However, I would counsel that you would need more than this. Any company that operates an internal competence scheme like Assure360 gets a gold star in my opinion. Beyond that – personal recommendation (if your procurement will allow) is always the surest way to a happy outcome.

Land remediation is a specialist, complex skill that most (even licensed) contractors don’t have. The approach does not normally include enclosures, but could in the most serious of cases. Careful selection is therefore vitally important.

How to become an educated client

The final piece of advice I always offer is to become an educated client. Asbestos removal is expensive, complex and scary. Going ignorant into a contractual relationship in those circumstances is brave indeed. What’s more, CDM15 no longer allows clients to say ‘I didn’t realise’, or ‘that’s not my area’.

So, either get someone in your organisation that understands the subject (e.g. the BOHS course P405), or appoint a consultant independent of any of the asbestos project team who can be your expert advocate.

There is even help in selecting the right person: FAAM is the new faculty for asbestos professionals and commits its members to a level of expertise and an ethical code of conduct. Ask are they full members of FAAM (MFAAM)?

Expertise in asbestos land remediation is unfortunately less widespread. Whilst asbestos in the ground is a problem that has been with us for nearly as long as asbestos has, it’s been somewhat under the radar for most professionals.The introduction of the comprehensive document CAR-Soil has allowed training course to be developed often by CL:AIRE. CL:AIRE also publish a list of their members, but I don’t believe there is a formal auditing or vetting process.

The importance of safety auditing

Either your in-house expert or the external advocate would then be able to directly check that the project is being run safely according to the plan. In other words audit. Assure360has been specifically designed to help clients like the Royal Mail to monitor asbestos projects whether in the built environment or in the ground (no apologies for the shameless plug).

Whilst asbestos is a scary word – the Brits are world leaders in managing the risk. Get the right people around you and don’t panic.

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