Proposed Control Of Asbestos Regulations Changes
Proposals to change certain aspects of the Control of Asbestos Regulations 2006 (CAR06) are currently being considered by the HSE to bring the UK’s regulations in line with other European countries.
On the face of it, very little will change, but one aspect could have implications on certain asbestos roofing projects.
At present, asbestos roofing works are exempt from the licensing requirements, because asbestos cement products are considered low risk, given that fibre release from such products is unlikely, as the asbestos is contained within a cement matrix.
The HSE appears to be keen not to extend the requirements to licence certain types of work, it is working to separately define what types of work are licensed.
At the moment, there are two classifications, licensed or non-licensed.
The proposal, which is likely to be accepted in some form, is to introduce a new classification, namely, “Notifiable, Non-Licensed Work” or NNLW.
Judging by the consultation document, it would appear that all asbestos roof encapsulation (coatings and over-cladding) would fall into this new category. Minor repair works would not and neither would asbestos roof replacement, since asbestos cement sheets, even when weathered, would not be considered to be “degraded”.
The consequence of this new classification will be that prior to starting such works, the HSE will have to be notified on a 14 day notice.
Additionally, it seems to be that contractors will have to maintain medical examination records of each worker who is exposed to asbestos. Medical examinations will be required every three years and records kept for 40 years. (Under the proposals, a three year transition period is likely before the medical examination requirement comes into force).
There also seems to be a new requirement for NNLW work to comply with risk assessment, control of exposure and training requirements.
Conclusion
If the proposals to change are implemented, it will be more important than ever to engage only competent contractors to carry out your asbestos roof works.
As chartered building surveyors and asbestos surveyors, we can advise on all aspects of roofing works and can manage the entire process on your behalf.
The requirement to notify the HSE will inevitably mean that medium to large scale roofing works will attract their attention, meaning that it is far more likely that they will visit the site not only for compliance checks in relation to CAR06, but also more general health and safety matters.
Our project management service includes CDM Coordinator duties, to help ensure that your contractors and the site comply with all health and safety legislation.
Fines for non-compliance are commonplace and in certain cases of breach, can result in immediate suspension of projects and further action against the contractor and the client.
Why take the risk?
Even today, before the implementation of revised regulations, it is possible to fall foul of the various H & S legislative requirements.
Our services and expertise with asbestos roofing means that your roofing project will run smoothly and in accordance with all current regulations.
If you are a roofing contractor or asbestos coating specialist, we recommend that you engage an independent chartered building surveyor to conduct a roof survey to ensure that the roof is suitable for the proposed solution.
For more information, or to arrange an initial survey, please call David Carter on 0121 711 7110.