Some asbestos removal may be nonlicensed, HSE notifiable or not

Posted on | By Thornton Kay
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Kent, UK
In a 1998 SalvoNEWS story we reported that asbestos found in buildings is not always easy to identify (sn159 Asbestos Dust – The Hidden Killer 10feb1998). The most common uses found in buildings were spray coatings on steelwork, concrete walls and ceilings; insulation lagging on pipework and ducts; insulating boards such as Asbestolux and Marinite; fire doors and ceiling tiles; asbestos cement products such as sheeting on walls and roofs, asbestos tiles and slates, cold water tanks, gutter, downpipe; some decorative plaster finishes such as Artex, and household items such as a 1940s moulded toilet cistern.
 
Last month the UK Health & Safety Executive (HSE) updated their asbestos guidance. The dangers outlined were that inhalation of asbestos fibres can lead to dangerous lung conditions including mesothelioma, asbestosis, and lung cancer. The most dangerous types are amosite (brown asbestos) and crocidolite (blue asbestos) used in products until the early 1980s often as an insulating 'wool' or flexible rope seal, all of which can only be removed by a licensed contractor. See the HSE general asbestos safety link below.
 
The less dangerous form of asbestos is chrysotile (white asbestos) cement sheet, pipe and ducting which was legally sold, and found reclaimed in UK and Irish salvage yards, until 2000. In 1997 it was estimated that 70% of UK commercial buildings contained asbestos, and the Environment Agency confirmed to Salvo that reclaimed asbestos cement sheeting could be legally sold by UK salvage yards with no special precautions. In April 1998, SalvoNEWS reported that the UK ban on white asbestos was delayed following a deal by the Blair government with Canada, one of the world’s biggest asbestos producers, where Canada agreed to lobby the world’s beef buying community to buy British beef in exchange for the Government dropping the proposed ban on white asbestos, despite its the ban in most European countries. In 2000, SalvoNEWS reported that the sale by reclamation yards of reclaimed asbestos cement sheet had been banned.
 
In 2023, in the UK some work is non-licensed, of which some is notifiable to HSE.
 
To be exempt from needing a licence the work must be:
- Sporadic and of low intensity - to be considered sporadic and of low intensity the concentration of asbestos in the air should not exceed 0.6f/ cm3 measured over 10 minutes
- Carried out in such a way that the exposure of workers to asbestos will not exceed the legal control limit of 0.1 asbestos fibres per cubic centimetre of air (0.1 f/cm3) (averaged over a four hour period)
- Meet at least one of the four following conditions:
- 1. It is a short non-continuous maintenance task, with only non-friable materials (friability describes how likely an asbestos containing material, ACM, is to release asbestos fibres when worked on, so non-friable materials will only release a small number of fibres during work);
- or
- 2. It is a removal task, where the ACMs are in reasonable condition and are not being deliberately broken up, and the asbestos fibres are firmly contained within a matrix, eg the asbestos is coated, covered or contained within another material, such as cement, paint or plastic;
- or
- 3. It is a task where the ACMs are in good condition and are being sealed or encapsulated to ensure they are not easily damaged in the future;
- or
- 4. It is an air monitoring and control task to check fibre concentrations in the air, or it's the collection and analysis of asbestos samples to confirm the presence of asbestos in a material.
 
Examples of non-licensed non-notifiable work with asbestos
- - - - -
 
▪ Cleaning up small quantities of loose/ fine debris containing ACM dust (where the work is sporadic and of low intensity, the control limit will not be exceeded and it is short duration work)
▪ Drilling of textured decorative coatings for installation of fixtures or fittings
▪ Encapsulation and sealing-in work on ACMs that are in good condition
 
Maintenance work involving:
▪ asbestos cement products (eg on roof sheeting, tiles and rainwater goods)
▪ asbestos in ropes, yarns and woven cloth
▪ asbestos gaskets or asbestos rope cords (including removal as part of repair and upkeep of equipment) if this can be done without substantial breakage
▪ asbestos-containing thermoplastic and vinyl floor tiles, bitumen roof felt, shingles, damp-proofing coatings, and mastics
▪ asbestos-containing felt and paper
▪ plastic paint coatings, PVC floors, panels and sealing compounds
▪ asbestos-containing conveyor belts/drive belts, bonded rubber, electric cables
▪ resin-based ACMs such as friction products (eg brake linings)
▪ Painting/repainting AIB that is in good condition
 
Removal of:
- asbestos cement products, (eg roof sheeting and rainwater goods) provided the material is carefully handled/removed without breaking up;
- this includes work with asbestos cement which is weathered but not otherwise substantially damaged
- small areas of textured decorative coatings using suitable dust- reducing methods, to support other activities such as installation/ replacement of smoke alarms and light fittings
- textured decorative coatings provided that this can be done without deterioration of the material, (eg if the backing board is carefully cut around to achieve virtually intact removal)
- loosely fixed (eg screwed) asbestos insulating board (AIB) panels in order to gain access to areas for other maintenance activities (eg under a bath to carry out pipework maintenance, or for access to a ceiling void for repair of lighting). This also includes re-attaching the panels after the work is done
▪ an AIB door with asbestos fire proofing
 
Short duration work:
▪ to repair minor damage to AIB
▪ involving drilling holes in AIB (eg when installing shelving)
 
Examples of notifiable non-licensed work (NNLW) with asbestos
- - - - -
 
Removal of:
- asbestos cement products (eg roof sheeting) where the material will be substantially damaged or broken up (eg as a result of fire or flood damage)
- asbestos cement products (eg roof sheeting) where the material will be substantially broken up, creating significant quantities of dust and debris (eg 'dropping' an asbestos cement roof)
- asbestos paper and cardboard products if not firmly bonded in a matrix
 
Short duration work:
- to remove asbestos insulating board as part of a refurbishment project involving asbestos insulation eg repairing minor damage to a small section of pipe insulation where the exterior coating has been broken or damaged
 
Other work on:
- large-scale removal of textured decorative coatings using steaming or gelling methods (eg beyond that required for maintenance activities such as installation/replacement of smoke alarms and fittings)
 
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HSE states that risk assessments are required
All non-licensed and notifiable non-licensed work with asbestos needs a risk assessment and must be carried out with the appropriate controls in place, and those carrying out the work must have had the correct level of information, instruction and training, to protect themselves (and others in the area) from the risks to health that exposure to asbestos causes. See more on HSE website about risk assessments.
HSE guidance on nonlicensed work involving asbestos
HSE general asbestos safety

Story Type: News