This is the first of three blogs we have produced discussing key technical guidance from The National Organisation of Asbestos Consultants (NORAC). In this article we discuss the importance of the Asbestos Register.
The guidance confirms that the Asbestos Register is intended to be a live document, mapping out all of the Asbestos Containing Materials (ACMs) present on a site, and their current condition. It should be supported with background information, such as previous surveys. Importantly though, the register is more than just the survey report, or collection of reports.
The register is important because previous surveys may be deemed by potential users as out of date, or not relevant to their circumstances e.g. a survey produced for previous refurbishment work that has either been completed, or postponed. But such a survey may have uncovered something new and useful. So, by adding such information to the register, the register is comprehensive, is never out of date, and it guides future re-inspections.
Different surveys serve different purposes, so the accumulated knowledge contained within the register is unique.
For non-domestic premises therefore, the register is fundamental to the successful management of asbestos.
There are various people throughout any organisation who may need access to the asbestos register from time to time (or various roles, if a small organisation). We understand these to include facilities managers, building managers, Duty Holders as defined in the asbestos legislation, and anyone who may be responsible for commissioning or carrying out refurbishment work. It’s important to ensure that such people have knowledge of, and physical access to the register.
The guidance emphasises the importance of photographic evidence – both for identification purposes, and for the visual recognition of changes over time. Repairs, treatments and removals should also be noted.
NORAC also gives suggestions on what else might be contained within an asbestos survey, to be of most use to the client: Materials that don’t contain asbestos, but look similar to those that do – thus avoiding unnecessary additional inspections.
It then advises against using a single photograph to represent several different applications of the same material; to avoid invalid assumptions about the condition of the other materials.
So, a competent asbestos surveyor will not just hand you a survey document – they will update your asbestos register – a key part of your asbestos management plan.