Locating hidden asbestos during ‘intrusive’ surveys. By James Dodgson
It is a legal requirement under the Control of Asbestos Regulations (CAR) 2012 to prevent the uncontrolled disturbance of asbestos-containing materials (ACMs) prior to any major refurbishment or demolition work taking place on any given structure that was built/refurbished before the year 2000. In order for all ACMs on the premises to be located and identified as far as is reasonably practicable, refurbishment or demolition surveys are required, with intrusive techniques implemented in order to determine whether asbestos is located in hidden and/or inaccessible locations.
However, challenges are posed when duty holders place limitations on the scope of intrusive work conducted during refurbishment or demolition surveys, and this has an impact on surveyors in the event of any ‘unknown’ or ‘missed’ materials being discovered further down the line.
Why are refurbishment and demolition surveys considered intrusive?
During refurbishment or demolition surveys, surveyors will gain access to all of the areas where the works are planned to take place, checking for any asbestos that may be hidden from the naked eye and/or is difficult to reach. In order to access areas that are difficult to gain entry to, surveyors are required to carry out the necessary level of damage using specialist equipment to determine which materials the building has been constructed with and whether or not they contain asbestos. In order to do this, the survey areas must be unoccupied, with the surveyed areas being proven as fit for reoccupation upon completion and before inhabitants are allowed entry.
Aggressive inspection techniques enable surveyors to access hard to reach structural areas between walls, floors and underground services, and can include the lifting up of carpets and tiles, breaking through walls, ceilings, cladding and partitions and opening up floors. When carrying out these intrusive works, appropriate control measures should be put in place to ensure that the level of damage does not make the building structurally unsound, while also preventing the spread of debris. This is why it is so important to ensure that the areas are completely unoccupied prior to these surveys taking place.
What kinds of challenges are posed when undertaking intrusive surveys?
As a general rule of thumb, there should be no restrictions on the level of access permitted during a refurbishment or demolition survey unless the site in question is ruled unsafe or if access is physically impractical. However, prior to these surveys taking place, both the surveyor and the duty holder will need to discuss access arrangements and the extent of the damage required as part of the planning stage of the contract. Where access is not possible, surveyors must clearly locate these areas on plans and within the survey report itself to ensure that all parties are fully aware of any areas of concern and whether further action is required.
Despite intrusive surveys only causing damage to the areas where the proposed refurbishment or demolition is due to take place, duty holders often request that surveyors locate and identify all hidden ACMs without causing any significant damage to the building. By placing restrictions on the scope of the intrusive works required, the surveyor is unable to accurately locate and identify all ACMs on the premises that fall within the remit of the survey, increasing the risk of hazardous materials remaining undetected. This has the potential to impact the accuracy of the refurbishment or demolition project that the survey has been commissioned for, particularly if ACMs are identified and require subsequent removal further down the line (with a 14-day notification issued to the HSE beforehand). In addition, there is a risk to the workforce unknowingly disturbing and exposing themselves and others around them to the concealed ACM.
Why is it important to document any limitations on the scope of intrusive works agreed by the duty holder?
The extent of intrusion required within a refurbishment or demolition survey will vary from premise to premise, with factors that affect the extent of the intrusion required including the type of building, its accessibility and the nature of the construction work being carried out. Surveyors will relay the scope of the investigative work required to the duty holder, who will then state whether or not they are happy for this level of intrusion to take place. Any restrictions on the survey should be discussed between the duty holder and surveyor prior to the commencement of the works, with evidence of this agreement clearly documented. In situations where an area is being reoccupied following the survey and prior to the project works, building custodians can be rightly nervous about decorative damage and the unsightly condition that can follow an intrusive survey. In these cases, it may be that an attendance from third parties is required to ‘reinstate’ the building condition.
If any area cannot be accessed by the surveyor for any reason once the survey is underway, it is imperative that the duty holder is informed as soon as possible, with arrangements made for additional access where required. However, if further access is physically impossible, the survey report should flag up these areas to ensure that there is a full understanding of remaining ‘risk areas’. With this information, the duty holder must then ensure that they have the appropriate management and emergency procedures in place to safely deal with any suspicious or unknown materials if they are uncovered.
James Dodgson is commercial director, Asbestos, at SOCOTEC UK. In the UK, SOCOTEC is the leading provider of testing, inspection and compliance services, offering comprehensive solutions for the Infrastructure & Waste and Environment & Safety sectors. The company, which employs more than 1700 people, delivers in excess of seven million tests a year to over 5000 customers.
For more information, please see www.socotec.co.uk