Health and safety law is increasingly pointing the way towards systematic risk management systems for property containing asbestos. For example, the new UK 'Control of Asbestos at Work, Regulations, 2002' require such a management system. And, as most asbestos is still in situ, organisations have no choice but to manage the risks, including those from accidental and incidental exposure.
There is no legal duty in the UK to conduct an asbestos survey, but there is a legal duty under regulation 4 of the regulations to do a 'suitable and sufficient' assessment of risk (which will entail some surveying).
However, many organisations waste vast amounts of money on unnecessary activity. So, how do you establish what you need to do?
An initial compliance audit will confirm an organisation's level of compliance with legal requirements. The audit will also produce a top level asbestos management plan, which will identify the elements necessary for a successful asbestos management system.
The approach necessary for proper management of the risks from issues such as asbestos requires a degree of confidence in the system that an organisation has developed. A proper management system will be required, based on priorities which have their origin in risk score, giving consideration to practicalities, cost and difficulty. The system should be 'cradle-to-grave' in its nature (ie starting with what was wrong extending all the way through to what was done, and where the evidence is kept). The system also needs to be flexible and live, with the information it contains readily retrievable by all those that may require it.
As stated, it will be necessary to overview the status of the organisation using an initial audit exercise. This is a prerequisite of all good management systems. If an organisation is unaware of its current level of compliance, it will not be possible to set objectives and targets for improvement.
Once this initial audit has been conducted, and the level of compliance is known, a programme for all non-compliances or 'opportunities for improvement' should be established. Convening an asbestos risk management group will enable management of the risks identified by the audit and development of a programme for the management system.
Such a group will typically include:
- the responsible person (asbestos)
- the deputy responsible person (asbestos)
- nominated person(s)
- the retained specialist consultant.
Ideally, such a group should meet every two months initially, with the key headings of the asbestos risk management audit forming its agenda.
The risk management programme developed should extend for three to five years. It should include the following.
- The number and frequency of risk assessments/surveys to be conducted each year. It is not necessary to assess all asbestos risks at once, and it may be undesirable to do so. A multi-year programme of surveys based on site priority is far better. Establishing what should be surveyed generally necessitates a desk-based risk screen exercise which will assign priority to sites, and therefore when and to what level they are surveyed. This exercise is very valuable for organisations with large property portfolios, and can bring considerable cost savings.
- The number and frequency of any reassessments required each year.
- Development of suitable and sufficient policies and procedures for the management of the relevant risk issues. A training programme based on training needs analysis can then be developed and delivered.
- An audit programme (with audit criteria, frequency, etc). Although independent consultants may provide audits and initial risk assessments, it is often in the interests of an organisation to work closely with these consultants and obtain the necessary training to conduct some elements of monitoring and re-inspection. The appropriateness of this will vary from one organisation to the next.
- Establishment of the asbestos risk management group, with regular review meetings using the audit headings as an agenda.
- Development of a 'cradle-to-grave' risk management system.A good vehicle for such a system is Microsoft Access, as it is readily available, reducing potentially very expensive licensing issues to a minimum.
Once all of these steps have been carefully considered and an adequate risk management programme has been established, the organisation will have achieved the management system approach to risk required by the regulations.
However, beyond regulatory compliance, it will also gain the benefits of a proactive approach to a problem which is likely to remain for many years to come.
- Alan Hambidge is a director of specialist indoor environment risk management consultancy controls-assurance.co.uk, Tel: 01993 706581.
