HSG 264 – Asbestos: The Survey Guide
On 29th January 2010 the HSE released HSG 264 Asbestos: The Survey Guide. This document expands on and replaces MDHS 100. The document is aimed at those conducting Surveys, those who commission surveys and those with specific responsibilities for managing asbestos in accordance with Control of Asbestos Regulations (CAR) 2006. Some of the key areas of HSG 264 are:-
- UKAS Accreditation demonstrates Technical Competence for undertaking surveys
- Type 1 & 2 Surveys are now termed Management Surveys and Type 3 Surveys are now termed Refurbishment and Demolition Surveys
- A Survey Strategy has been detailed for both non-domestic and domestic properties
- Further emphasis and importance has been placed on the Survey Planning Phase of a survey.
- Survey Report and Asbestos Register complexity and format has been detailed
- The approach a Dutyholder should take to check a survey in respect to accuracy, suitability and adequacy is more clearly defined
- The survey planning phase should aim to reduce any caveats and areas of no access as far as is reasonably practicable.
HSG 264 is heavily illustrated and is broken down into a number of key sections as follows:-
- Introduction – Detailing Legal Requirements, Who the Document is aimed at, management of asbestos in domestic properties, construction work, appointed person and health and safety Issues.
- Competence and Quality Assurance Procedures – This section determines the level of training and experience required by each surveyor and the competency of the surveying organisation and the surveyor. Also referenced is the Quality Management System that should be in place. Key within this section is that the HSE strongly recommends the use of certified or accredited surveyors or organisations and determines that UKAS Accreditation demonstrates technical competence and will ensure that surveys are carried out by competent people.
- Asbestos Surveys – This section details the purpose of the survey and presumption and identification of ACM’s, the types of surveys, survey restrictions and caveats, survey strategy for both non-domestic and domestic properties. Under purpose of the survey it re-iterates information within CAR 2006 that an asbestos survey should be conducted for all properties (type determined by requirement) which is used to create an asbestos register, a risk assessment and a management plan to manage the risks of asbestos. One of the main changes from MDHS 100 is the types of surveys and terminology. Under HSG 264 there are two types of survey instead of three. Type 1 and Type 2 surveys have now been combined together into Management Surveys and Type 3 Surveys are now termed Refurbishment and Demolition Surveys. A Management Survey is a standard survey and will be used for the purposes of managing asbestos within properties. The survey will often involve minor intrusive work and some disturbance to facilitate foreseeable maintenance and related activities and can involve a combination of sampling to confirm asbestos is present or presuming asbestos to be present. An assessment of the condition and ability to release fibres into the air if they are disturbed in some way should also be undertaken for each ACM. Refurbishment Surveys are required for all works which disturb the fabric of the building in areas where the management survey has not been intrusive. A demolition survey should be conducted in the whole building if demolition is planned. A refurbishment and demolition survey is also required when more intrusive maintenance and repair work will be carried out or for plant removal or dismantling. The manner in which caveats and survey restrictions are discussed and agreed is detailed.
Under Survey Strategy for non-domestic properties it states that there is an expectation that every building will be surveyed on an individual basis to identify the presence and condition of asbestos. It also details a survey strategy for domestic properties within this section specifically targeted at Local Authorities and Housing Associations managing large numbers of domestic properties. This process involves a desktop study to establish probable asbestos status of groups of properties and details when management surveys and when refurbishment surveys should be conducted in these properties.
- Survey Planning – This section details Dutyholder planning and Surveyor planning procedures. Information to be collected at the planning stage of the survey is fully listed. Explanation is given to the 4 steps in the survey planning process which are:-
- Step 1 – Collect all the relevant information to plan the survey
- Step 2 – Consider the Information (desk-top study)
- Step 3 – Prepare a survey plan (including how data will be recorded)
- Step 4 – Conduct a risk assessment for the survey
The purpose here is to limit the use of caveats and reduce areas not accessed as part of the survey as far as is reasonably practicable.
- Carrying out the survey (surveying) – Within this section there is information on a systematic survey inspection, what and how to assess and record and where additional precautions and care need to be undertaken. Bulk Sampling Strategy is addressed and a list of asbestos containing products and the size and frequency of samples is included. Bulk Sampling procedures describe safe systems of work and how samples should be extracted. Material Assessments should be undertaken in all Management Surveys and also in those refurbishment or demolition surveys where the period between the survey and event is significant (more than 3 months). Priority Assessments should be prepared in close liaison with the client to ensure detailed knowledge of all factors affecting this assessment.
- Survey Report – The survey report should be comprehensible and useable by the client and information should be easy to extract and use to prepare an asbestos register. The report should contain:-
- Executive Summary
- Introduction covering the scope of work
- General site and survey information
- Survey results (including material assessment results)
- Conclusions and actions
- Bulk analysis results
Within this section it details which information should be contained in each section and provides an example asbestos register and sample asbestos building plan.
- Dutyholder’s use of survey information – This section details how the client should check the survey has been adequate and that the report is suitable and accurate. It states that the survey reports will in most cases not be the asbestos register which will be a simpler document containing much less information. Regular updating of the asbestos register is also addressed briefly stating that it should be updated where asbestos is removed, new areas are sampled / surveyed and changes to the condition of ACM’s.
Six Appendices are also included as follows:-
- Appendix 1 – Refurbishment and demolition surveys – This appendix details which areas should be included within a refurbishment and demolition survey and the level of access required.
- Appendix 2 – ACM’s in buildings listed in order of ease of fibre release
- Appendix 3 – What ACM’s look like and where to find them
- Appendix 4 – Material assessment algorithm
- Appendix 5 – Example of a survey and sampling equipment checklist
- Appendix 6 – Quality Assurance and quality control – This appendix outlines the essential components of a quality management system which are Quality Assurance for Site Work; Audit of Completed Surveys; Survey Reports.
Article Written By Kieran Moon – Redhills ( www.redhills.co.uk )
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