MANAGEMENT ASBESTOS SURVEYS
A management survey is the standard survey. Its purpose is to locate, as far as reasonably practicable, the presence and extent of any suspect ACMs 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, ie 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 ACMs and their ability to release fibres into the air if they are disturbed in some way. This ‘material assessment’ will give a good initial guide to the priority for managing ACMs 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 ACMs. 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 ACMs and presuming ACMs or, indeed, just presuming. Any materials presumed to contain asbestos must also have their condition assessed (ie a material assessment).
By presuming the presence of asbestos, the need for sampling and analysis can be deferred until a later time (eg 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-ACMs. 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-ACMs and their disposal as asbestos waste. Default presumptions may be suitable in some instances, eg ‘small’ or simple premises, as part of a client’s management arrangements.
Surveyors should always endeavour to positively identify ACMs. A sufficient number of samples should be taken to confirm the location and extent of ACMs. It is legitimate to reduce sample numbers where materials can be strongly presumed to be ACMs. However, the default presumption option should be avoided where possible, as it can make managing asbestos more difficult for the dutyholder. Default presumption should only be used in circumstances where it is requested by the client and/or where access genuinely cannot be obtained.
When sampling is carried out as part of a management survey, samples from each type of suspect ACM should be collected and analysed. If the material sampled is found to contain asbestos, other similar materials used in the same way in the building can be strongly presumed to contain asbestos. Less homogeneous materials (eg different surfaces/coating, evidence of repair etc) will require a greater number of samples. The sample number should be sufficient to establish whether asbestos is present or not in the particular material. Sampling may take place Asbestos: The survey guide Page 20 of 73 Health and Safety Executive simultaneously with the survey, or as in the case of some larger surveys, can be carried out later as a separate exercise.
All areas should be accessed and inspected as far as is reasonably practicable. Areas should include underfloor coverings, above false ceilings, and inside risers, service ducts, lift shafts etc (see Box 4). Surveying may also involve some minor intrusive work, such as accessing behind fascia and panels and other surfaces or superficial materials. The extent of intrusion will depend on the degree of disturbance that is or will be necessary for foreseeable maintenance and related activities, including the installation of new equipment/cabling. Surveyors should come prepared to access such areas (ie with the correct equipment etc). Management surveys are only likely to involve the use of simple tools such as screwdrivers and chisels. Any areas not accessed must be presumed to contain asbestos. The areas not accessed and presumed to contain asbestos must be clearly stated in the survey report and will have to be managed on this basis ie maintenance or other disturbance work should not be carried out in these areas until further checks are made.
Box 4: Areas to be inspected as part of a management survey
All ACMs should be identified as far as is reasonably practicable. The areas inspected should include: underfloor coverings, above false ceilings (ceiling voids), lofts, inside risers, service ducts and lift shafts, basements, cellars, underground rooms, undercrofts (this list is not exhaustive).
Management surveys should cover routine and simple maintenance work. However, it has to be recognised that where ‘more extensive’ maintenance or repair work is involved, there may not be sufficient information in the management survey and a localised refurbishment survey will be needed. A refurbishment survey will be required for all work which disturbs the fabric of the building in areas where the management survey has not been intrusive. The decision on the need for a refurbishment survey should be made by the dutyholder (probably with help from others).
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“The HSE strongly recommends the use of accredited or certificated surveyors
for asbestos surveys. The duty holder should not appoint or instruct an independent
surveyor to carry out a survey unless the surveyor is competent.”
HSG264 Asbestos: The Survey Guide