BBC
BBC Organisation and Arrangements for the Management of Asbestos
July 2011
|Date |Change |Authors |
|May 2011 |Revision and replacement of original April 2010 document |Richard Perry – BBC Safety |
| | |Matthew Griggs – Redhills |
| | |Tim Baugh - Redhills |
|July 2011 |Minor typographical changes |Tim Baugh |
1. Introduction and Guidance 5
1.1. Policy 5
1.2. What is asbestos? 5
1.3. Regulations and Guidance 6
1.4. The Duty to Manage 6
1.5. BBC Standards 7
2. Organisation & Arrangements 7
2.1. Organisation chart 7
2.2. Roles and Responsibilities 8
3. Information, Instruction and Training 12
3.1. General 12
3.2. Induction Training and information 12
4. Accidents, Incidents and Emergencies 13
4.1. Emergency procedure 13
5. Documents 14
5.1. The Asbestos Register 14
5.2. Risk Assessment 15
5.3. Asbestos Management Plans 15
5.4. Provision of Information 16
6. Guidance notes for Asbestos Consultant activities specific to the BBC 17
6.1. Air Sampling 17
6.2. Removal Work and Work in Controlled areas 18
6.3. Surveys and Inspections 20
7. General Site Guidance Specific to the BBC 22
7.1. Guidance for Productions on location 22
7.2. Guidance for Overseas Bureaux 23
7.3. Demolition of adjacent premises 24
Appendix 1 - Asbestos Survey Request Form 25
Appendix 2 - Internal Notification of Asbestos Works 27
Appendix 3 - Contact Names and Numbers for 28
Appointed Persons Asbestos (Nations & Regions) 28
Appendix 4 - Details of the Duty Holder (Johnson Controls) 29
and the Asbestos Consultant (Redhills). 29
Guide to use of this document
This document has been compiled to identify the Organisation and Arrangements in respect of asbestos management within BBC owned or leased premises. It sets out the key roles and responsibilities in order to ensure compliance with the Control of Asbestos Regulations 2006.
The document will outline the expected standards required in order to meet current HSE Legislation guidance and considered best practice in respect of asbestos management removal and analytical works. Notwithstanding compliance with any other specific contract particulars that may be in place between the BBC and their stakeholders.
Glossary of terms
The following are definitions of abbreviations and terms that are used within this document:
|BBC |- |British Broadcasting Company |
|Facilities Manager |- |The BBC appointed manager of the property portfolio |
|Asbestos Consultant |- |Appointed Asbestos/Analytical Consultant |
|ACM |- |Asbestos Containing Material |
|Competent Person |- |Someone with the requisite skill, qualification, experience and training to carry |
| | |out a task. |
|HSE |- |Health & Safety Executive |
|UKAS |- |United Kingdom Accreditation Service |
|LARC |- |Licensed Asbestos Removal Contractor |
|CAR |- |Control of Asbestos Regulations |
|HSG |- |Health and Safety Guidance, issued by the HSE e.g. HSG 227 |
Introduction and Guidance
1 Policy
It is the policy of the BBC to comply with all relevant legal requirements and obligations regarding asbestos at work and in premises for which we have direct responsibility, or where we have the majority of control.
1 The BBC will:
• Appoint competent persons/consultants to carry out preventative and protective measures, provide information and consult with our employees about asbestos matters.
• Ensure any work and maintenance carried out on our premises in relation to asbestos is carried out by competent persons and to keep existing ACM in good repair.
• Inform and co-operate with contractors, tenants, shared owners, other employers of people working in our premises to ensure our policy is achieved.
• Provide information, instruction and training to our employees and those affected so far as is reasonably practicable.
• Ensure our employees co-operate with us in ensuring our premises are safe and do not place themselves or others at risk.
• Establish the relevant forums to discuss, monitor and review all matters relating to asbestos.
• Monitor and review our policy and those documents associated with it.
2 What is asbestos?
Asbestos is the name given to a group of naturally occurring fibrous silicate minerals, whose varied properties such as resistance to heat, mean that it was used within the formulation of many building materials. The prime usage of asbestos within construction and other uses was approximately from the 1950’s and up to 1999.
Use of asbestos was banned in the UK in 1999 with the exception of some highly specialist applications, therefore for any construction post 1999 it can be reasonably assumed that it does not contain asbestos within its fabric.
Asbestos has been classified as a class 1 carcinogen, that is it “should be regarded as carcinogenic to man”. In order for asbestos to be hazardous to health it must be of a condition that will give rise to airborne respirable fibres. Notably an asbestos containing material’s condition and treatment must be in a state whereby fibres can be released, alternatively physical or natural disturbance of an asbestos containing material must be undertaken.
Asbestos containing materials are not hazardous where they are effectively managed and maintained in a good state of repair.
Owing to the widespread use of asbestos materials within buildings, it is accepted that there is now a naturally occurring element of asbestos within the environment.
3 Regulations and Guidance
The below gives an outline of the Regulations, Legislation and Guidance within the United Kingdom, that directly relate to asbestos. The BBC pays due note and attention to the below in respect of our procedures, policies and working methods.
➢ The Health & Safety at Work Act 1974
➢ L143 – The Control of Asbestos Regulations 2006
➢ L127 – Regulation 4 The Management of Asbestos in non domestic premises
➢ HSG247 – The Licensed Contractors Guide
➢ HSG248 – The Analysts Guide
➢ HSG264 – The Surveyors Guide
➢ HSG227 – A comprehensive guide to managing asbestos in non domestic premises
Further to the above and those where the BBC may have duties indirectly relating to asbestos may include:
➢ L144 – The Construction Design and Management Regulations
➢ L21 – The Management of Health & Safety at Work Regulations
The above lists should not be considered exhaustive and the BBC shall adopt a considered best practice approach where reasonably practicable.
4 The Duty to Manage
Under Regulation 4 “The Duty to Manage” of the Control of Asbestos Regulations (CAR) 2006, the BBC recognises their responsibilities as a dutyholder to:
a) Take reasonable steps to find materials in premises likely to contain asbestos and to check their condition;
b) Presume that materials contain asbestos unless there is strong evidence to suppose they do not;
c) Make a written record of the location and condition of asbestos and presumed asbestos-containing materials (ACMs) and keep the record up to date;
d) Assess the risk of the likelihood of anyone being exposed to these materials; and
e) Prepare a plan to manage that risk and put it into effect to ensure that;
i) Any material known or presumed to contain asbestos is kept in a good state of repair:
ii) Any material that contains or is presumed to contain asbestos is, because of the risks associated with its location or condition, repaired or if necessary removed; and
iii) Information on the location and condition of the material is given to anyone potentially at risk
The BBC fulfill their role as dutyholder by appointing competent persons to undertake the safe management of asbestos within their premises, for which they maintain responsibility. This document outlines the organisational responsibilities, procedures and standards in order to achieve this.
5 BBC Standards
The BBC have their own internal standards in respect of any works with asbestos, most notably no BBC employee is permitted to undertake any works with asbestos or works that could be construed as working with asbestos, such as sampling or investigating. Investigations, surveys, consultancy and any removal or remediation works are to be undertaken in accordance with this document and those listed in Section 1.3.
No members of BBC staff, or those carrying out work on behalf of the BBC, are expected to work or reside in areas where ambient asbestos fibre levels are in excess of the current clearance indicator, i.e. > 0.010 fibres per millilitres of air. The exception to this will be those Contractors and Consultants employed specifically to carry out asbestos remediation works.
Organisation & Arrangements
1 Organisation chart
The following organisation chart provides a pictorial view of the asbestos management within the BBC:
2 Roles and Responsibilities
Overall accountability is held by the Director General and the BBC delegates some responsibility to others by virtue of their appointments and contracts, this overall accountability cannot be delegated.
1 BBC
BBC workplace is responsible for managing asbestos in all BBC Buildings they appoint the facilities management company.
BBC Workplace:
▪ With the appointed asbestos consultant they shall write and maintain this document;
▪ They have appointed the facilities management company to assist the BBC in their role as the duty holder within the meaning of UK legislation. In turn the facilities management company shall appoint the specialist asbestos consultant commonly referred to as the Asbestos Management Team.
BBC People are responsible for ensuring that if any person is suspected of having been exposed to asbestos dust then a record of this is kept on their personnel file for 40 years.
BBC Safety is responsible for providing general advice regarding Health & Safety together with providing relevant input and discussion with the appointed asbestos consultant.
Appointed Persons Asbestos (APA’s) have a defined responsibility for:
• Keeping local records of ACM where there is no permanent FM presence;
• Providing that information to any person who has the potential to disturb asbestos within their premises.
Other divisions within the BBC must:
Appoint a senior manager with responsibility for Health and Safety who will ensure a management system is in place for the effective communication and compliance with these organisational arrangements. Notwithstanding any resulting codes of practice, guidance or other BBC Standards provided within this document. The Senior Manager shall be assumed to be the divisional representative on the BBC Safety Committee, unless otherwise specified.
BBC Managers, BBC Staff, Service Partners, and Contractors, must:
▪ Consider the potential of exposure to asbestos when working on BBC Sites.;
▪ Make the necessary arrangements to satisfy themselves as to the safety of undertaking their work by not contaminating the environment of staff and others, or put them at risk;
▪ Ensure that those whom it is reasonable to expect might encounter ACM during their work, have received training in simple recognition of such hazards and the appropriate remedial actions /notifications they must take should it be discovered;
▪ Outside of BBC premises find out from landlords or building owners information about asbestos containing materials which might affect our staff;
▪ Ensure that their staff have read and understood the BBC’s guidance and that in particular they:
▪ Must not disturb any known asbestos materials;
▪ Must not undertake work on buildings without ensuring that there is no asbestos which could be disturbed;
▪ Report any incident when they suspect that asbestos dust has been released.
All occupiers and users of BBC buildings are responsible for obeying the BBC rules and in particular:
▪ Not disturbing known asbestos;
▪ Not interfering with the fabric of buildings ;
▪ Reporting suspected ACM;
▪ Reporting incidents.
2 Facilities Management
The Facilities Management Company is appointed to assist the BBC in their duties under Regulation 4 (the Duty to Manage) and in doing so they shall:
• Ensure that there is a source of specialist advice for all other activities and will on request provide assistance with dealing with incidents and accidents resulting from the disturbance of asbestos;
• Vet, appoint, and monitor the Asbestos Environmental Consultants and otherwise known as the Asbestos Management Team;
• In the event that information is not available from the landlord, the facilities manager shall instruct the asbestos consultant to undertake those services required to meet the requirements described under Regulation 4.
They shall provide to the BBC suitable and timely reports on:
• Routine asbestos inspections, reviews of risk assessments, provision and implementation of action plans;
• Accidents / incidents to: include date; location; brief summary of accident / incidents; action taken or further action required;
• Details on any air monitoring tests undertaken by the asbestos consultant that are recorded to be above the prescribed level;
• Training and assessments of competency to include; awareness training for staff, specialist training of APA; competency assessments of APA, the Service Provider and contractors;
• Routine review of the Asbestos Register and Asbestos Management Plan, highlighting and significant modifications / revisions and updates.
And shall:
• Provide relevant information to Trade Union safety representatives;
• Facilitate visits by enforcing authorities in respect of asbestos and ensure that they are provided with the information that they require.
3 Asbestos Consultant
The asbestos consultant is appointed to undertake the necessary services relating to asbestos in order to aid the client in their management of asbestos, they shall:
▪ Effectively manage the risk from asbestos by undertaking the relevant investigations, inspections and monitoring;
▪ Ensure records are kept of locations of Asbestos Containing Materials (ACM) (the Asbestos Register);
▪ Appoint contractors for the safe abatement and removal of asbestos where a material poses a significant risk;
▪ Provide training to Appointed Persons Asbestos;
▪ Prepare an Asbestos Management Plan for each premises to manage that risk and put it into effect and monitor its effectiveness;
▪ Provide information on the location and condition of material to anyone potentially at risk;
▪ Provide the Facilities Manager with relevant information and reporting where required;
▪ Assist the client in developing their policy, procedures and strategy;
▪ Provide the Facilities Management with the relevant information to allow their reporting to the client.
4 English Regions, Wales, Scotland and Northern Ireland
The regions are managed by BBC workplace and they appoint the facilities manager to assist them in their duties under Regulation 4 (the Duty to Manage). Workplace ensures that they have appointed suitably competent persons “Appointed Persons Asbestos” (APA’s) within each region.
5 Divisions - Nominated Persons and APA’s
Divisions with any responsibility for managing premises will appoint a lead manager (a nominated person) to ensure that these arrangements are implemented. The main duty of the nominated person will be to appoint a person for each building (Appointed Person Asbestos) who will in turn ensure that these arrangements are implemented in that building:
The nominated person will:
• Take responsibility for those aspects of Asbestos Management which are not undertaken by Workplace or their appointed facilities manager and consultant
• Appoint in writing APA’s for asbestos management for all premises
• Appoint in writing a deputy APA , to deputise for the APA at all times and when the APA is unavailable
• Ensure that APA’s, and their deputies have adequate resources, and management authority to discharge their duties.
• Arrange for APA’s to be assessed for competence by the facilities manager in matters relating to Asbestos Safety.
• Inform the facilities manager of the appointment of APAs
• Ensure that they have access to a source of asbestos safety advice.
• Ensure that these arrangements are routinely reviewed, typically bi-annually
Appointed Persons Asbestos (APA)
• APA’s assist the Duty Holder in managing asbestos across the BBC Property Portfolio. In London and Scotland the APA role is taken by the Asbestos Consultant. Elsewhere, APA’s are appointed by the lead managers from amongst their own staff.
• APA’s need to have knowledge of the premises for which they are appointed to be able to perform their duties, and they must be suitably trained.
• One APA can be responsible for more than one building such as satellite stations and minor buildings that may only be occupied on special occasions.
APA’s must:
• Consult the Asbestos Management Team on all issues relating to Asbestos Management.
• Ensure that they are in receipt of the necessary Risk Assessment in respect of ACM for all premises in the areas that the APA is required to manage.
• Ensure that a copy of the Asbestos Register is held at all the premises to which it refers and that it is available for viewing to those who have the potential to disturb asbestos.
• Ensure that a copy of the Asbestos Management Plan is held at the premise. Ensure that all Contractors are made aware, prior to any works being carried out, of the BBC arrangements and Guidelines relating to asbestos for each BBC site.
6 Landlords
Within a small number of buildings the BBC have staff located within landlord owned, and landlord managed Buildings.
In these premises, the landlord or his representative under the terms of Regulation 4 must ensure that anyone potentially at risk within his building/s receives information on the location and condition of ACM’s.
Workplace will liaise with landlords to ensure that information is provided to the BBC by landlords and to Landlords by the BBC where applicable.
7 Productions other than in BBC premises
The Producer is responsible for implementing this guidance on productions for which they are responsible; they must:
• Ensure that they contact the facilities manager, who shall in turn contact the Asbestos Consultant for advice and assistance.
• Act upon any advice and assistance that they are given.
• Ensure staff are made aware of any risk assessment or advice which has been given.
• In the event of an emergency or any potential disturbance of asbestos, ensure that they contact the Facilities Manager.
Please refer to section 7 of this document for further guidance, particularly if the site is owned by others or is a public area.
Information, Instruction and Training
1 General
As a minimum, asbestos awareness training is required to be given to employees whose work could potentially expose them to asbestos. Such training shall be undertaken by organisations certified by the United Kingdom Asbestos Training Association (UKATA).
Appropriate refresher training shall be provided every year or sooner where there may be a significant change in regulatory standards, guidance or approved codes of practice.
Other groups including APA’s, Facilities Management staff and asbestos consultant staff shall require training appropriate to the roles in which they undertake.
2 Induction Training and information
Information for all BBC staff and for those with specific responsibilities is published on myRisks. Training can be arranged by the Facilities Manager.
All Persons engaged to work at BBC Premises shall attend as a minimum the induction training. This training will include an overview of the BBC organisational arrangements for the Management of Asbestos and any emergency procedures or reporting.
Accidents, Incidents and Emergencies
In the event that there is a suspected or potential disturbance of an ACM then the following outline procedure should be followed by any member of staff or contractor.
1 Emergency procedure
1 Actions resulting from an emergency
The Asbestos Consultant, Facilities Manager and BBC Safety shall review all findings resulting from an emergency and provide appropriate remedial measures and further controls as required.
The Facilities Manager shall:
• Co-ordinate the relevant parties in respect of the management and assessment of the incident.
• Have the authority to prevent any serious or imminent danger.
• Instruct the Asbestos Consultant to undertake relevant inspections and investigations.
• Provide the relevant reports to the BBC.
The Asbestos Consultant shall:
• Determine any inspections/investigations or monitoring required as a result of the incident.
• Scope any remedial works required.
• Instruct an approved Licensed Asbestos Removal Contractor to undertake works.
• Provide certification/written documentation allowing the re-occupation of areas.
• Assist the BBC.
The relevant BBC department responsibilities are:
• Managers in affected areas shall determine the actions required to enable any BBC activity to be rescheduled or re-located.
• BBC Safety shall decide on the correct level of escalation of communications and keep records of actions taken.
• BBC Personnel dept. (BBC People) will ensure records are held on personnel files of any affected BBC employee.
• BBC safety will be responsible for ensuring that a record is kept of all incidents/accidents for a minimum of 40 years.
• BBC Safety shall report under RIDDOR any incident that meets the criteria of current HSE Legislation and Guidance.
• BBC safety will inform the Chief Medical Officer (CMO) regarding any possible health implications.
• BBC safety will ensure that a record of the incident has been entered onto the myRisks database.
Documents
The following documents are deemed relevant in respect of the management of asbestos within BBC owned or leased premises .
1 The Asbestos Register
The Asbestos register contains information obtained from surveys, inspections, incident reports and any other source relating to the presence of asbestos in BBC Premises.
All data relating to ACM’s collected from sites surveys and re-inspections across the BBC Property Portfolio is managed by the Asbestos Consultant on behalf of the Facilities Manager, however the BBC has right of access to this information at all times. The Asbestos Consultant must keep the information up to date and accessible to anyone who needs it, including building users and the emergency services. The Facilities Manager shall be responsible for aiding the Asbestos Consultant with the relevant support.
In order to satisfactorily manage ACM within BBC premises, all maintenance and building work is controlled by a permit to work system. As part of that system, the Asbestos Register must be consulted before building works are undertaken.
Information relating to ACM’s is currently held either in an Electronic Database, or in hard copy format, or both. The key function of the Authorised Person Asbestos (APA) is to hold a copy of relevant (local) parts of the asbestos register.
In buildings outside London and Scotland, a hard copy of the register is kept at the building by the APA.
Key information contained within the asbestos database can be obtained from the Facilities Manager and / or the Asbestos Consultant.
Where information is inconclusive, the arrangement of an ACM inspection/survey will be required to be undertaken.
All registers currently include Risk Assessments for ACM identified in that building (see 5.2 below).
2 Risk Assessment
The Facilities Manager must monitor the undertaking of regular risk assessments of known ACM within premises in the BBC UK estate. The risk assessments for any particular building are an essential element of the management plan for that building. The risk assessment process is the same throughout the BBC and is described in this section.
The risk assessments for asbestos materials at the BBC are undertaken by the Asbestos Consultant and calculated in accordance with HSG264 and HSG227. And comprise a material assessment and a priority assessment.
The material assessment establishes the condition of the ACM, or the presumed ACM. The algorithm considers the following 4 parameters:
• product type;
• extent of damage;
• surface treatment;
• asbestos type.
Each of the above parameters is scored.
The priority assessment will look at the likelihood of someone disturbing the ACM. The factors taken into the account here are:
• maintenance activity.
• occupant activity.
• likelihood of disturbance- accessibility.
• human exposure potential- frequency of use.
Scores from the material assessment and the priority assessment will be added together to give the overall risk assessment score. That score will also form the basis for an asbestos action plan.
Currently all Registers contain Risk Assessment information for the building it refers to.
3 Asbestos Management Plans
1 General
Every building should have an individual asbestos management plan. The Asbestos Management Plan is a regulated requirement that defines the BBC arrangements, procedures and process for controlling the hazard of asbestos in individual premises under its ownership or management control.
The Facilities Manager is responsible for the Asbestos Management Plans and must ensure that all persons, including contractors, are aware of the Asbestos Management Plan and Asbestos Site Registers, and comply with the procedures therein. The Asbestos Management plans are produced by the Asbestos Consultant.
To ensure compliance with legislation, the Asbestos Management Plan will include key information relating to:
• The definition of The “Duty Holder”
• Asbestos Site Registers – including drawings and plans.
• Roles and responsibility of an APA.
• APA contact numbers.
• Emergency procedures.
• Dissemination of information.
• Training requirements.
2 Review of Asbestos Management Plans
Asbestos management plans must be reviewed to ensure that they remain up to date. In particular consideration should be given to:
• Any safe systems of work, permit to work, or other management procedures that refer to, or are referred to by the plan.
• Communication of the plan – and specifically that contact details and names are correct.
• Tenders and contract documents and specifications that may be referred to by the plan.
• Emergency plans.
• Personnel or organisational changes.
• Changes in building use and occupancy.
• Incidents or failure of the procedures.
APAs are responsible for reviewing the plan for the buildings for which they have responsibility. Any proposed changes must be communicated to the Facilities Manager who shall in turn assess and implement as required.
4 Provision of Information
With respect to construction work, JCI (London and Scotland) and the APA (elsewhere) will ensure that all relevant information such as surveys, risk assessments, location drawings, reports, etc. will be made available to any CDM Co-ordinator at the earliest opportunity for inclusion in the pre-construction health and safety plan. If work is not CDM then they will provide it to an appropriate person such as the project manager.
There is a specific requirement within Regulation 4 (9) to ensure that information regarding ACM is made available to the emergency services. This is to be done by the Facilities Manager or the APA in buildings where one is appointed.
A hard copy register accompanied by CAD Drawings must be kept on each site in a position where it is easily located and obtained without entering the main body of the building.
Guidance notes for Asbestos Consultant activities specific to the BBC
1 Air Sampling
1 General
Air sampling will be undertaken:
• Prior to the commencement of asbestos works, to establish background airborne concentrations.
• As leak testing, to support the initial smoke test and visual inspection of the enclosure.
• At the termination of any work on ACM before the enclosure is removed.
• When ACM have been transported through a building outside of any enclosure.
• When there has been disturbance of ACM or suspected release of fibres.
The Asbestos Consultant is responsible for planning and undertaking the works including all types of air sampling. The Facilities Manager will inform BBC managers as to the nature of the risk and the Facilities Manager or BBC Safety, will undertake business continuity planning, to cover the eventuality of an elevated test result.
In deciding whether an “asbestos area” is safe for return to normal use, the air test must show levels that are not above the clearance indicator. The clearance indicator level is set by the HSE and published in HSG 248 ‘The Analysts’ Guide’, the current value is ................
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