Alan Hambidge, director and principal consultant at controls-assurance.co.uk puts the case for risk management of asbestos
It’s an issue from the 80’s isn’t it? After all we’ve spent thousands removing it in the last 20 years, there can’t be much left.” While this is an all too common view of the status of asbestos in the UK, the situation is actually the exact opposite, with the bulk remaining in situ.
However, we must remember that while asbestos is always a hazard, it is not always a risk. As a result, all organisations have a duty to manage asbestos. This is the main focus of the Control of Asbestos at Work Regulations, 2002 under Regulation 4 – The Duty to Manage.
Weak audit trails
Despite the existence of many management systems, such as ISO 9000 and ISO 14000 series, health and safety management systems are not as common as they should be. Most asbestos audits show management systems and audit trails to be weak. Far too commonly, asbestos surveys are only negative asset registers and fail to identify a prioritised action plan for the management of all asbestos risks based on ‘risk’, ‘cost’ and ‘difficulty’. The systems lack a cradle-to-grave approach, from asbestos risk identified through to evidence of actions taken.
So what should you do? This is quite straightforward. The first step is an asbestos risk management audit. All good management systems start with the question: “What is our current position?” If this is not known it will be impossible to develop a suitable action plan. Once the audit is complete, and the necessary actions have been identified, you will need to develop a policy and procedures which will identify how your organisation will ensure the safe management of asbestos. Remember, it is likely that a great deal of asbestos will be retained, and thus you need to manage deliberate, accidental and incidental exposure to these materials.
Training in procedures
Once the policy and procedures has been developed relevant staff need to be trained in the use of these procedures. It will then be necessary to establish which parts of a site should be subject to a (Type) 2 asbestos survey. It is important to be aware that the legal duty is to conduct a suitable and sufficient assessment, and not to do a survey. However, for the assessment to be suitable and sufficient (as defined in the Management of Health and Safety at Work Regulations), it will be necessary to complete some surveys.
Desk-based ‘risk screen’ exercises are employed to identify and justify the sites for survey, type of survey and number of samples to be taken. This is a very valuable exercise, as it identifies and justifies resource assignment.
Once the sites for survey have been established, a detailed specification let, and a competent consultancy appointed, the risk assessments can be completed. It is important at this stage that a full management system is prepared, as this will allow an audit trail to be demonstrated, budget needs to be identified by priority and the remedial works necessary to be implemented.
In conclusion, asbestos is one of the most obvious candidates for a management system approach. It is critical that companies are confident of their position, and as such an audit of status should be conducted on an annual basis by an independent, competent individual.
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