ASBESTOS MANAGEMENT SURVEYS
So what is a Management Survey?
A management survey is the standard survey. Its purpose is to locate, as far as reasonably practicable, the presence and extent of any suspect 'Asbestos Containing Materials' (ACM's) in the building which could be damaged or disturbed during normal occupancy, including foreseeable maintenance and installation, and to assess their condition.
Management surveys will often involve minor intrusive work and some disturbance.
The extent of intrusion will vary between premises and depend on what is reasonably practicable for individual properties, i.e it will depend on factors such as the type of building, the nature of construction, accessibility etc.
A management survey should include an assessment of the condition of the various ACM's and their ability to release fibres into the air if they are disturbed in some way. This ‘material assessment’ give a good initial guide to the priority for managing ACM's as it will identify the materials which will most readily release airborne fibres if they are disturbed.
The survey will usually involve sampling and analysis to confirm the presence or absence of ACM's. However, a management survey can also involve presuming the presence or absence of asbestos. A management survey can be completed using a combination of sampling ACM's and presuming ACM's or, indeed, just presuming.
Any materials presumed to contain asbestos must also have their condition assessed.
By presuming the presence of asbestos, the need for sampling and analysis can be deferred until a later time (e.g before any work is carried out). However, this approach has implications for the management arrangements.
The dutyholder bears potential additional costs of management for some non-ACM's. Any work
carried out on ‘presumed’ materials would need to involve appropriate contractors and work methods in compliance with CAR 2012 irrespective of whether the material was actually an ACM or not.
Alternatively, before any work starts, sampling and analysis can be undertaken to confirm or refute the presence of asbestos.
The results will determine the work methods and contractors to be used. The ‘presumption’ approach has several disadvantages: it is less rigorous, it can lead to constant obstructions and delays before work can start, and it is more difficult to control. ‘Default’ presumptions may also lead to unnecessary removal of non-ACM's and their disposal as asbestos waste.
Default presumptions may be suitable in some instances, e.g ‘small’ or simple premises, as part of a client’s management arrangements.
Remember in the absence of sampling to check for asbestos regulation 5 of CAR 2012 places a mandatory duty on states:-
(1) An employer must not undertake work in demolition, maintenance, or any other work which exposes or is liable to expose employees of that employer to asbestos in respect of any premises unless either—
(a) that employer has carried out a suitable and sufficient assessment as to whether asbestos, what type of asbestos, contained in what material and in what condition is present or is liable to be present in those premises; or
(b) if there is doubt as to whether asbestos is present in those premises that employer—
(i) assumes that asbestos is present, and that it is not chrysotile alone, and
(ii) observes the applicable provisions of these Regulations.