The management of asbestos within an organisation responsible for a large and diverse property portfolio may seem daunting. This is often compounded by limited resources and large geographical spread of the properties. However, this need not be the case. The appropriate use of two critical and over-looked techniques, namely 'audit' and 'screening' permits organisations to identify the correct approach to the management of asbestos through risk assessment, survey, and the development of adequate procedures supported by training.
Let us start by clarifying some definitions in the context of this article, for example 'risk assessment' as a function with regard to asbestos hazards. The primary function of risk assessment is to permit an organisation to identify the best use of available resources in the reduction of risks to the health and safety of individuals. Risk assessment acknowledges that resources are finite, so we are looking for the biggest return in risk management for each £1 of spend.
Where we have a large property portfolio with many premises of the same type with very limited exposure to potential asbestos containing materials (ACMs), and where the cost of full Type 2 surveys of all sites would be too great, we would not be able to justify Type 2 surveys of all premises. This is clearly not the best use of available resources. We need to remember at this stage, that the requirement under the Control of Asbestos at Work (2002) Regulations is for a 'suitable and sufficient' risk assessment (as defined in the Management of Health and Safety at Work Regulations) to be conducted, but not necessarily a survey.
In such an instance we need to identify a tool which would permit us to develop and justify a programme of representative Type 2 and supporting Type 1 surveys to allow cloning out of the data to all sites of the same archetype. Such cloning exercises must be carefully managed through policy, procedures, training and awareness. All relevant individuals must understand the limitation of cloning, and the meaning of the data in context.
The tool employed to identify the representative sites for survey to permit cloning is 'risk screening'. A risk screen is a predominately desk-based assessment of the potential risk offered by all of an organisation's premises. The tool scores the sites on a number of factors, including build type, size, maintenance work, occupant type, age, and so on.
The screen can be used first, in conjunction with interviews with staff and site visits to identify the different archetypes of the properties. Each property archetype is then assessed using the screen criteria and a score assigned. Depending on this score, a number of representative sites in each archetype will be identified for Type 1 and Type 2 surveys to permit the cloning exercise. If refined sufficiently, the screen will also indicate the number of samples estimated as needed from each site.
The result of the exercise will be a defensible robust programme for the required surveys, typically taking place over three to five years. And the benefits of the technique are great. Not only does it produce the programme of surveys required by the Control of Asbestos at Work 2002 Regulations, but it provides justification. As discussed above, this exercise also identifies the biggest return in survey data per £1 of survey spend. Risk screens can return considerable cost savings in the survey programme in comparison with the approach of conducting Type 2 surveys of all premises.
Regulation 4 of the Control of Asbestos at Work, 2002 Regulations requires the development of an asbestos risk 'management system'. If we turn to recognised management systems models, such as ISO 9001 (quality standard) and ISO 14001 (environmental management standard), we see that a 'status audit' is seen as a critical pre-cursor to the development of an adequate management system.
Audits are a top-level review of an organisation to ensure that all the required elements of the Control of Asbestos at Work 2002 Regulations are in place and functioning properly. An asbestos risk management audit should be conducted by an individual who is independent of the asbestos management group in the organisation.
The audit is typically performed in three main parts:
1. review of all relevant records, existing audits (if present), policy, procedures, work methods, risk assessments, surveys, evidence of training, evidence of remedial works completed etc
2. interviews with all relevant staff, in particular testing compliance with regulations and policy and procedures
3. brief site walk-over to test (1) and (2).
The audit results in the essential framework on which will hang the entire management system. Without an audit like this, the structure may be ineffective and poorly resourced.
Both audits and screens should be subject to annual review and updating to ensure that adequate progress is being made. It is also wise to employ the core headings of the audit as the agenda items in the asbestos risk management group meeting minutes, to ensure that all issues are adequately covered.
Benefits of this approach
The benefits are illustrated by the summary findings of asbestos risk management audits in 10 different organisations, each with a property stock in excess of 1,000 separate premises. The organisations were subject to asbestos audits in the last 18 months by my own firm. This was the first time that any of the organisations had conducted an audit and screen exercise, and in all cases it has resulted in cost savings, sometimes considerable ones. The organisations comprise two local authorities and eight housing associations.
Figure 1 summarises the findings of some of the principal questions in the asbestos status audit for the sample. The figure also demonstrates the cost saving achieved through completion of the risk screen and removal of unnecessary asbestos surveys. It is worth noting that local authorities are, on the whole, ahead of housing associations in terms of compliance, and stand to make less potential saving. Even so, the cost saving potential from the screens of the 10 organisations, was 15% for local authorities and 68% for housing associations.
The audit questions show that, as a rule, top-level issues are not given sufficient consideration by many organisations with large portfolios. Organisations still tend to implement risk assessments before the responsible persons are appointed, policies and procedures completed and awareness and training campaigns implemented. This is a peculiar approach when you consider that most asbestos is likely to be retained and managed by the organisation. The initial action should always be an audit of the approach and development of the required policies and procedures.
Audit and screen are valuable tools in the management of asbestos risks. They should be given proper attention, and should be reviewed annually. The benefits are too great to be overlooked.
- Alan Hambidge is director and principal consultant of controls-assurance.co.uk, Tel: 01993 706581. Website: www.controls-assurance.co.uk