This is the second of our blogs discussing new technical guidance from The National Organisation of Asbestos Consultants (NORAC). This time we are looking at the guidance on re-inspection surveys and reports.
Known asbestos items should be re-inspected periodically, and it is the Duty Holder’s responsibility, under The Control of Asbestos Regulations 2012, to determine the frequency of survey, and ensure it is carried out.
The guidance gives examples of bitumen sink pads and vinyl floor tiles, which, under normal circumstance, are unlikely to release fibres. It could be acceptable therefore to have ‘inspection periods’ of between three and five years. But various high-risk materials could require inspection more than once annually.
It is our view however, that the Control of Asbestos Regulations could be read in such a way as to mandate survey annually, where any asbestos is known to be present. The reason is that it is unlikely that you can properly update your asbestos management plan otherwise.
The key point is that the decision should be justified, and this detailed in the management plan. We would suggest that it therefore needs to be a reasonable decision, as determined by any investigation that may subsequently be required.
The purpose of re-inspection is to assess any changes in the material, for evaluation of risk. Since the extent of damage to material is typically noted as ‘low’, ‘medium’, or ‘high’, it is of course therefore subjective. Two ways to reduce the risk of inaccuracy here are consistency, and detail in the report, so that the previous condition of the material can be fully understood as a starting point.
NORAC also notes that survey reports should be done in accordance with HSG264 Asbestos: The Survey Guide – as is done by Environmental Inspection.
NORAC also favours a detailed executive summary, which should tell Duty Holders exactly what asbestos was found, its condition, and suggested actions. This applies to all types of asbestos survey (management, refurbishment, demolition), except re-inspections, where this information is already known. Instead, for a re-inspection, the summary should focus on the extent of deterioration of the ACM in specific locations, what action should be taken, and in what order of priority.
The main section of the report should include technical detail on all ACMs, and the nature of any changes.
It should be remembered that a re-inspection should not only result in a survey report – but also in the updating of the Asbestos Register, as discussed in that guidance and in our previous blog.