Asbestos Management

Purpose and Scope

The purpose of this procedure is to ensure that asbestos that is present in the workplace is managed in such a way that workers and others are not exposed to asbestos.  It applies to all asbestos and asbestos containing material (ACM) including:

• Friable asbestos (e.g. pipe lagging, sprayed insulation etc.)
• Non-friable asbestos (e.g. asbestos cement sheet, vinyl floor tiles etc.)
• Asbestos contaminated dust or debris (ACD) (e.g. dust left from past asbestos removal)
• Contaminated sites (e.g. contaminated soil)
• Naturally occurring asbestos (NOA)

Responsibilities

HY Project Team

• Ensure existing Asbestos Registers and reports are obtained for the premises prior to work commencing on site
• Ensure a hygienist report is obtained to confirm whether ACM is present if asbestos is suspected or may potentially be located on impacted areas of site
• Ensure the State WHS regulator is notified of Asbestos Removal activities where required
• Ensure an Asbestos Management Plan is in place for the Project if Asbestos/ACM has been identified onsite
• Ensure an Asbestos Removal Control Plan has been developed by the Subcontractor for the Project
• Ensure applicable Work Permits are implemented prior to commencing work
• Ensure only trained and competent persons perform work on site
• Ensure worker competencies and qualifications are verified prior to commencing work
• Ensure that SWMS are provided for any work that involves, or is likely to involve, the disturbance of asbestos

Hazard Identification, Risk Assessment, Control, and Effectiveness (HIRACE)

The HYer Standard sets out the minimum controls for managing asbestos. Any additional hazards and controls identified during Proactive Planning Meetings, Workers Tools, or other discussions, need to be recorded in the project risk register. When planning work involving asbestos, consideration should be given to:

• Unidentified asbestos
• Accidental disturbance of asbestos
• Removal of asbestos
• Transport and disposal of asbestos waste

When planning asbestos-related activities, consideration must be given to whether there is a risk to health from asbestos.  Consider whether the asbestos or ACM is:

• In poor condition
• Likely to be further damaged or to deteriorate
• Likely to be disturbed due to work practices carried out in the workplace (e.g. demolition, restoration, earthworks, civil works, roadworks, temporary works)
• In an area where workers are exposed to the material

The effectiveness of controls is checked using High Risk Work Check-Ins within the Inspections module in HammerTech.

Identification Of Asbestos & Acm

HY will ensure, so far as is reasonably practicable, that all asbestos or ACM at a project site is identified prior to work commencing.  In the first instance, HY will review available information that may include:

• Design risk assessment
• Building plans
• Hazardous materials survey
• Client Asbestos Register

If once reviewing the available information:

• if it has been confirmed that asbestos or ACM is present, or
• if there are reasonable grounds to believe that asbestos is not present

then a competent person does not need to be engaged to make this decision.  Otherwise, a Certified Occupational Hygienist (COH) will be engaged to confirm the presence/classification of Asbestos.

HY will assume that:

• Material is asbestos or ACM if it cannot be identified but a competent person reasonably believes it is asbestos or ACM
• Asbestos is present if part of the workplace is inaccessible (that is, cannot be accessed during normal daily activities or routine maintenance) and it is likely to contain asbestos or ACM

Once the presence and location of asbestos has been assumed:

• All requirements for managing asbestos will be followed until the material is removed or testing has confirmed that it is not or does not contain asbestos
• The workplace asbestos register is to include all the presumptions made about materials in the workplace with a simple, generic statement such as, ‘Roof sheeting is presumed to contain asbestos’ or ‘All underground conduits are presumed to contain asbestos.’

If suspected asbestos or ACM is identified once work has commenced, the work must cease immediately.  The area must be isolated and made safe.  This includes the use of barricading and signage.  HY must be notified immediately who will arrange for the material to be identified by an occupational hygienist.

Site Induction

The possibility of unidentified asbestos being found on site is highlighted in the site induction process. This is to make workers aware of the possibility that asbestos could still be found in cavities for example, even if areas have been previously cleaned.  It is also to make workers aware of the process for responding to suspected/previously unidentified asbestos finds.

Indicating Presence Of Asbestos & Acm

Where asbestos is identified, its presence/location should be clearly indicated using visual representations.  If reasonably practicable, the presence and location of the asbestos or ACM is to be indicated by a label.  However, it may be more appropriate to use signs.  It should be noted that whilst desirable, it is not always practicable (or permitted by the client) in some workplaces such as public areas of working hospitals to visually indicate the presence of asbestos.

Labels

When considering the number and position of labels, they must clearly identify the presence and location of asbestos or ACM.  The location of labels should be consistent with the location listed in the asbestos register.  If a risk assessment suggests asbestos may be disturbed or people are likely to be exposed and it is not reasonably practicable to label asbestos directly, a prominent warning sign should be posted in its immediate vicinity.  For example, if floor tiles have been identified as containing asbestos, an appropriate warning sign may be displayed on an adjacent wall.

Warning Signs

Any areas of a workplace that contain asbestos, including plant, equipment and components, should be signposted with warning signs to ensure the asbestos is not disturbed without the correct precautions being taken.  Signs should be placed at all the main entrances to the work areas where asbestos is present.

Other Methods

Where it is not reasonably practicable to use labels or warning signs to indicate the presence and location of asbestos or ACM, a process of informing workers about the presence and location of asbestos before they commence work must be implemented.

The presence and location of the asbestos should also be entered on site plans and the asbestos register and be accessible to all workers to ensure they are aware of the presence of asbestos.

Asbestos Register

An Asbestos Register must be prepared, maintained and made available to HY for the workplace if asbestos or ACM has been identified or is suspected of being present.  The current asbestos register (e.g. provided by the client) will be reviewed by HY and be updated, if required, prior to making it available to other stakeholders.

Asbestos records are to be entered into the Registers Module within HammerTech. Entries into this module will form the “Asbestos Register”.  These records include:

• A record of any asbestos or ACM that has been identified at the site
• Date the asbestos was identified
• Location, type and condition of the identified asbestos
• Photos where applicable

Asbestos Records are to be reviewed if:

• The asbestos management plan is reviewed
• Further asbestos or ACM is identified at the workplace
• Asbestos is removed from or disturbed, sealed or enclosed at the workplace
• Refurbishment or demolition work is to be undertaken

The Asbestos Register is to be kept at the workplace in such a way that it is readily accessible to:

• Workers who carry out work at the site and their health and safety representatives
• Subcontractors and any other businesses that carry out work at the site
• The client and any other company that requires work to be carried out at the site

The Asbestos Register is to also be provided to:

• Subcontractors whose work involves a risk of exposure to airborne asbestos (e.g. demolition, refurbishment)
• The Client at the completion of the project for ongoing asbestos management

Asbestos Management Plan

A HY Asbestos Management Plan may be prepared and maintained for a workplace if asbestos or ACM has been identified or assumed present. The HY Asbestos Management Plan is to include information about:

• Identified asbestos and/or ACM at the project e.g. link to the asbestos register, locations identified on site plan etc.
• Processes in place for the management of asbestos e.g. safe work procedures and control measures
• Procedures for managing incidents or emergencies involving asbestos at the workplace
• Workers carrying out work involving asbestos e.g. consultation, information and training responsibilities

The HY Asbestos Management Plan is to be kept at the workplace in such a way that it is readily accessible to:

• Workers who carry out work at the site and their health and safety representatives
• Subcontractors and any other businesses that carry out work at the site
• The client and any other company that requires work to be carried out at the site

Contaminated Sites

Sites may be contaminated with asbestos and/or ACM due to previous activities such as illegal dumping of waste and previous demolition works.  Site remediation may be required (i.e. the removal of the asbestos and ACM from the site).  Specialists may need to be engaged, who may include licensed asbestos removalists, depending on the type and quantity of asbestos, ACM or asbestos contaminated dust or debris (ACD) identified at the site.

If during excavation works, previously unidentified asbestos or ACM is uncovered, the work must cease immediately and emergency response initiated.

Demolition and Refurbishment Work

Prior to any demolition or refurbishment work, HY will:

• Review the asbestos register to ensure that it is comprehensive and adequate for the proposed demolition or refurbishment work
• Provide a copy of the asbestos register to the subcontractor(s) carrying out the demolition or refurbishment work, and
• Ensure asbestos or ACM that is likely to be disturbed is identified and, so far as is reasonably practicable, removed before the demolition or refurbishment commences
• If asbestos or ACM cannot be removed then it must be effectively encapsulated and clearly labelled

A ‘demolition or refurbishment survey’ may be required, including extensive sampling and testing of materials for asbestos, because parts of buildings or plant, including those which might normally be inaccessible, are likely to be disturbed by the demolition or refurbishment work.  Inaccessible areas are to be treated as likely to contain asbestos if existing sampling returns positive results of ACM. During demolition these areas must be monitored for unexpected finds.

Asbestos Removal & Asbestos-Related Work

Asbestos-related work is work involving asbestos that can occur as defined by legislation.  It includes:

• Sampling and identification in accordance with the WHS Regulations
• The transport and disposal of asbestos and asbestos waste in accordance with jurisdictional legislation
• Managing in situ asbestos, fixed or installed before 31 December 2003, in accordance with the WHS Regulations
• Work involving ‘asbestos contaminated’ soil that a competent person has determined:
  • does not contain any visible ACM or friable asbestos
  • if friable asbestos is present, does not contain more than trace levels of asbestos determined in accordance with AS 4964–2004: Method for the qualitative identification of asbestos in bulk samples.

Asbestos removal involves the removal of asbestos and ACM from the workplace.  There are extra responsibilities associated with asbestos removal.

Air Monitoring

Air monitoring will be carried out if there is uncertainty as to whether the exposure standard for airborne asbestos is likely to be exceeded at the workplace.  Air monitoring is also carried out for certain work associated with asbestos removal, including:

• control monitoring – for ensuring that an enclosure or other controls used during asbestos removal are effective at preventing fibres from being found outside the work area
• clearance monitoring – to ensure that the work area is free of asbestos fibres prior to being certified for reoccupation

Air monitoring should be carried out as per Hygienist’s recommendations in their remediation procedure.

Control monitoring is mandatory for all friable asbestos removal.  This includes prior to dismantling an enclosure and for the purposes of the clearance inspection.  Air monitoring should be considered where the asbestos removal work is being undertaken in or next to a public location.

In South Australia, air monitoring is required for the removal of both friable and non-friable asbestos.

Air monitoring must be carried out by a competent person who is independent of the removal process.  A competent person may include:

• A licensed asbestos assessor or a person who has undertaken the endorsed unit of competency for licensed asbestos assessors
• An occupational hygienist who has experience in asbestos exposure monitoring

Air monitoring results are to be communicated to workers, i.e., posted on the site notice board.

Where exposure monitoring is carried out, the organisation carrying out the air monitoring (HY or Subcontractor) must keep records of the results for 30 years and must ensure that the results of air monitoring are readily accessible to persons at the workplace (and their HSRs) who may be exposed to asbestos.

Refer to Health Surveillance and Workplace Monitoring procedure for more information.

Health Monitoring

Health monitoring must be provided to workers if they are at risk of exposure to asbestos when carrying out:

• Licensed asbestos removal work
• Other ongoing (unlicensed) asbestos removal work, or
• Asbestos-related work

Subcontractors that conduct asbestos removal and/or asbestos-related work are responsible for ensuring health monitoring of their workers is in place and carried out by medical practitioners. HY will verify that Subcontractors involved with asbestos removal and/or asbestos-related work undertake health monitoring of their workers as per legislative requirements. Refer to Health Surveillance and Workplace Monitoring procedure.

Workers that conduct asbestos removal and/or asbestos-related work must be provided with the appropriate respiratory protective equipment (RPE). The type of respiratory protection depends on the work to be conducted and is to be determined by a competent person.

A fit test is to be performed to ensure the RPE fits the individual and provides a good face seal between the worker’s skin and the face piece.  Fit tests are to be repeated when changing from different model of RPE or a different sized face piece.

Training & Certification

Workers that are involved in asbestos removal work and/or carrying out asbestos-related work must be trained in the identification, safe handling and suitable control measures for asbestos and ACM.

Workers that carry out licensed asbestos removal work (including asbestos removal supervisors) must also be:

• Trained in carrying out licensed asbestos removal work at the workplace to ensure that the work is carried out in accordance with the specific asbestos removal control plan
• Hold certification for the class of licensed asbestos removal work that they will be carrying out

Asbestos Removal

Prior to engaging a Subcontractor to carry out asbestos removal works, HY will ensure that they are appropriately licenced for the type and amount of asbestos or ACM to be removed.

Note: In Victoria, to remove non-friable asbestos <10m without a licence, workers must not perform more than one hour of asbestos removal work total during a seven-day period.

Asbestos Removalist Supervisor

An Asbestos Removalist Supervisor must oversee licenced asbestos removal as follows:

If the asbestos removal work requires a Class A licence (i.e. removing friable asbestos) then a named asbestos removal supervisor must be present at the asbestos removal area whenever the work is being carried out

If the asbestos removal work requires only a Class B licence (i.e. removing non-friable asbestos that is more than 10 m²) then a named asbestos removal supervisor must be readily available to a worker whenever they are carrying out the work (e.g. contactable by phone and able to arrive at the workplace within 20 minutes)

Notification

HY will inform workers and any other people at the site, as well as the client, of planned asbestos removal work and when the work is to commence.  HY will also take all reasonable steps to inform any other PCBUs at or in the vicinity of the workplace and anyone occupying premises in the immediate vicinity of the site of planned asbestos removal work and when the work is to commence.

Asbestos Removal Control Plan

Prior to commencing any asbestos removal, the Subcontractor responsible for the asbestos removal must provide HY with an Asbestos Removal Control Plan.  It must include details of:

• How the asbestos removal will be carried out, including the method, tools, equipment and PPE to be used
• The asbestos to be removed, including the location, type and condition of the asbestos
• Notification requirements to regulator and any jurisdictional authorities

The Subcontractor must communicate the plan to any parties who may be affected by the removal and keep a copy of the Asbestos Removal Control Plan at site, in such a way that it is readily accessible, until the completion of the asbestos removal work.

Limiting Access

Controls must be implemented to limit access to the area where asbestos removal and/or asbestos-related work is being carried out.  Access must be limited to:

• Workers who are engaged in the removal work
• Other people who are associated with the removal work, and
• People who are allowed under the WHS Regulations or another law to be in the asbestos removal area (e.g. inspectors, emergency service workers)

Signs and barricades must be used to clearly indicate the area where asbestos removal work is being performed.  Warning signs must be:

• Placed to inform all people nearby that asbestos removal work is taking place in the area
• Placed at all the main entry points to the asbestos removal work area where asbestos is present

Enclosures

The work area when removing friable asbestos must, so far as is reasonably practicable, be enclosed (sometimes referred to as the ‘bubble’) to eliminate or minimise the release of airborne asbestos fibres.  When large-scale friable asbestos removal work is being undertaken, the asbestos removal work area must be enclosed and under ‘negative pressure’ with the use of negative air pressure units.  A smoke test of the enclosure must be conducted prior to work commencing.

A risk assessment must be undertaken to determine if enclosures should be used for non-friable asbestos removal.  Factors such as proximity to other work areas, weather conditions if outdoors, and the amount of material to be removed should be considered.

Consideration must also be given to the size and type of enclosure to ensure that it can “accept” or has sufficient access to allow emergency response personnel (e.g. paramedics or firefighters carrying a stretcher and fire hose).  A trial drill may need to be conducted prior to use.

Prohibited Tools & Equipment

High-pressure water sprays or compressed air must not be used on asbestos or ACM.  Other tools and equipment that generate dust such as high-speed abrasive power and pneumatic tools (e.g. angle grinders, sanders, saws and high speed drills) and brooms and brushes (unless brushes are used for sealing) must also not be used on asbestos, unless the use of the equipment is controlled.  This means the equipment is enclosed when used, or the equipment is designed or used in a way that captures or suppresses airborne asbestos fibres.

Decontamination and Waste Containment

Decontamination processes, including access to facilities are to be documented in the subcontractor’s Asbestos Removal Control Plan. Facilities are to be available to decontaminate the asbestos removal work area, any plant used in that area, workers carrying out the asbestos removal work, and other persons who have access to the asbestos removal area because they are associated with the asbestos removal work.

Items removed from the asbestos work area which are likely to be contaminated must be decontaminated before they are removed or sealed in containers with the exterior of the containers decontaminated.

Asbestos waste must be contained and labelled in accordance with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) before it is removed from the asbestos removal area.

Clearance Inspection

HY will ensure that once the licensed asbestos removal work has been completed:

• a clearance inspection is carried out, and
• a clearance certificate in writing is issued before the workplace can be re-occupied

Clearance inspections must be carried out and clearance certificates issued by:

• An independent licensed asbestos assessor, for work that must be carried out by a Class A licensed asbestos removalist (i.e. removal work involving friable asbestos), or
• An independent competent person, for asbestos work that is not required to be carried out by a Class A licensed asbestos removalist (i.e. removal work involving more than 10 m2 of non-friable asbestos)

Transport and Disposal Of Asbestos and Asbestos Waste

Disposal bags and/or sheeting must be made of heavy-duty plastic (200 µm polyethylene, also known as polythene).  Disposal bags must be marked with the label ‘Danger Asbestos – Do not open or damage bag. Do not inhale dust’.  Each bag should be sealed with adhesive (cloth or duct) tape separately prior to placing it in a second plastic asbestos disposal bag.

Once the waste has been removed from the asbestos removal work area, it should either be:

• Stored in closed containers (for example 60 or 200 litre steel drums with removable lids, which should be lined with heavy duty plastic, or a sealed skip), or
• Immediately removed from the site by the relevant EPA approved/licensed carrier for disposal

All containers containing a hazardous chemical such as asbestos must conform to the labelling elements of the GHS.

Asbestos waste must be transported and disposed of in accordance with the relevant state or territory Environment Protection Authority (EPA) requirements. This includes ensuring waste tracking (e.g. issuing of waste transport certificates) is undertaken.  Asbestos waste can only be disposed of at a site licensed by the EPA and it must never be disposed of in the general waste system.  Waste reports must be provided to HY.

Emergency Procedures

Where asbestos removal and/or asbestos related work is being undertaken at a site, the procedures for the response to an emergency related to asbestos must be included in the Emergency Response Plan,  Environmental Management Plan and relevant SWMS.

Where there is a potential for asbestos to be accidentally disturbed, or it could become airborne, HY will act to minimise exposure of workers and the wider public to airborne asbestos.

If accidental disturbance of asbestos occurs:

• Cease work immediately in the area where asbestos has been disturbed
• Inform the site manager or other HY representative immediately
• Inform necessary workers
• Restrict access to the area and ensure only appropriately trained workers attend the site – i.e. Licenced Asbestos removalists, Occupational Hygienists, Emergency Services
• Provide briefing of situation and suitable personal protective equipment (if required) to appropriately trained workers who will respond to the incident
• If safe to do so, wet down asbestos ASAP and kept wet while waiting for further advice
• Contact relevant State WHS/OHS regulatory body to report the disturbance
• Contact an Occupational Hygienist to implement an air monitoring program to assess asbestos exposure levels and specific risk control measures
• Seek guidance from an Occupational Hygienist on process for removal and disposal of the asbestos

In the event that during asbestos removal or asbestos-related work, personnel become accidentally exposed to asbestos, they are to be advised to:

• Complete the online National Asbestos Exposure Register
• If concerned that they have contracted an asbestos related disease, to see their GP
• If in NSW, make a request to the Dust Diseases Board (DDB) for a respiratory medical examination to find out if they have a dust disease

Definitions and Abbreviations

ACD – Asbestos Contaminated Dust or Debris

ACM – Asbestos Containing Material

NOA – Naturally Occurring Asbestos

RPE – Respiratory Protective Equipment

Friable asbestos – asbestos that when dry, or as the result of a work process, may be crumbled, pulverised or reduced to a powder by hand pressure

Non-Friable asbestos – asbestos that when dry may not be crumbled, pulverised or reduced to powder by hand pressure (for example materials containing asbestos that have been mixed with cement or other hard bonding materials)

EPA – Environmental Protection Authority

GHS – Globally Harmonized System of Classification and Labelling of Chemicals

References

• Work Health & Safety Regulation 2011 (QLD), 2012 (SA/TAS) and 2017 (NSW) – Chapter 8 Asbestos
• Occupational Health and Safety Regulations 2017 (Victoria) – Part 4.4 Asbestos
• How to Manage & Control Asbestos in the Workplace (Model Code of Practice)
• How to Safely Remove Asbestos (Model Code of Practice)
• Federal Safety Commission (FSC) Audit Criteria – H4 Asbestos

Associated Documents

• HYer Standard – Asbestos Management
• Health Surveillance and Workplace Monitoring procedure
• Quick Guide – Personal Protective Equipment
• Quick Guide – Silica Management
• Quick Guide – Work Zones
• HY Asbestos Management Plan