Asbestos Policy For Asbestos Management
Last Updated on 12 March 2024
Is your organisation’s asbestos management policy & plan fit for purpose?
If asbestos is present in any property you control, there is a legal requirement to have in place an asbestos management plan. This is the basis for protecting individuals who work in those buildings, visit those buildings and those who will occasionally come to undertake work in those buildings such as contractors.
Control of Asbestos Regulations 2012
The legal framework for the asbestos management plan starts with the Control of Asbestos Regulations 2012. Regulation 4, in general summary contains an explicit duty on the owners and occupiers of non-domestic premises, who have maintenance and repair responsibilities, to assess and manage the risks from the presence of asbestos.
What is important to remember here, is that the ‘duty to manage asbestos‘ requirements of regulation 4 of CAR 2012 do not normally apply to domestic premises, but they will apply to none domestic spaces or ‘common areas’ within properties where there are multiple residential spaces. In simple terms, in a block of flats, the duty will still apply to the stairwells, lift shafts, lobbies, bin stores, lounge areas etc.
Larger organisations or sites where there are lots of staff often have an asbestos policy and a management plan. Whilst the plan describes in detail how you meet the requirements of Regulation 4, the asbestos policy is more a statement of intent. It is a shorter high level document that is adopted by those in charge of governance who hold the duty in relation to asbestos. This would generally sit above the asbestos management plan.
Councils, NHS, Universities, Housing Associations, Military and large employers will generally take this approach. It’s important that both documents are clear concise, contain the names of individuals who hold the duty and those who will perhaps oversee the delivery of that duty for the ‘Duty Holder’.
In simple terms, the CEO may be the ‘duty holder’ and the head of health and safety may deliver that duty on their behalf.
Typical Problems With Asbestos Policy And Management Plan
Our organisation, has, for several years, assisted these organisations and individuals to ensure their asbestos policy and plan are fit for purpose. Typical problems we see include the following:-
The policy and plan were written by a third party, outside the organisation
Many organisations will not have the relevant training and experience to write their own plans and policies. They use outside assistance which is perfectly normal. However, that individual should not only understand the organisation, but be on hand to assist and advise as required on an ongoing basis. If the policy or plan is a standard template then this should be a warning flag.
The Asbestos policy and plan are overcomplicated
Write more words and charge more money? Beware of policies and plans that are overcomplicated. We have seen documents that run into almost a 100 pages that are not as effective as some at around 7/8 pages. Try not to be seduced by large glossy documents you do not bother to read.
It is vitally important that you do what you say. We regularly audit these types of plans and policies. Our simple approach is this. We pick each item in turn and ask the question. Item 1: Do you do this? Please show me the evidence. It’s as simple as ‘say what you do’ ‘do what you say’ and keep the evidence..
The policy and plan were written from the top down and not the bottom upwards
The temptation when writing plans and policies is to start at the top of the organisation and work downwards to the ‘shop floor’. This is a mistake in most circumstances, as understanding the day to day functions of the site is key. We suggest starting by looking at how everything works on a daily basis on the site and build upwards from there. This method allows you to identify any procedural gaps, weaknesses and training requirements.
The Asbestos policy hasn’t been updated annually
We see policies and plans specifically that have not been updated or reviewed for years. It is important these are reviewed at least every twelve months or following any significant event changes such as individuals with designated duties leaving and/or arriving.
Named individuals have changed
In the same vein as the item above. If the CEO and head of Health and Safety leave the organisation and the policy/ plan are not updated, then it is not as relevant as it should be.
Training doesn’t match the relevant responsibility
If the organisation has personnel in key roles and they don’t have the appropriate training to assist them in their duty, then the asbestos policy/management plan isn’t fit for purpose. Training is never proof of competence. However, ongoing and appropriate training for specific roles will go some way to ensuring robustness.
Need professional advice on creating an asbestos policy?
We hope you find this information useful when you review your own organisations asbestos policies and plans. If you need any help or advice at all then we’ll be very happy to assist you. Give us a call and our experts will give you some advice and guidance on whatever if is you’re concerned about.
Please contact us on 0800 141 2676, email us at info@rbasbestos.co.uk or fill in the form below.
Our professional surveyors conduct inspections and surveys every day across the UK on all types of properties, both residential and commercial, for private home owners and commercial property Managers and owners. So when it comes to managing ACMs in your property, you’re in very safe hands with RB!!
