The Importance of Asbestos Management in Modern Construction

Manufacturers widely used asbestos in over 3,000 various commercial products, and it continues to pose potential health issues 20 years after Australia banned it at the end of 2003. Development throughout Australia has left a dangerous legacy of asbestos-containing materials (ACM), and now is the time to plan for its eradication in all development/refurbishment projects, thus eliminating the risk of future generations being exposed to asbestos and related diseases. Actively knowing where asbestos is, or assuming its presence at your workplace and managing it, is key to preventing unexpected discoveries and the potential for unnecessary asbestos exposure.

Asbestos Registers

The person(s) with management and/or control of the workplace bear the responsibility for identifying and managing asbestos. They primarily accomplish this through the creation and maintenance of a register that indicates the presence and status of asbestos and asbestos-containing materials. Australian regulatory jurisdictions uniformly require the creation of a register to highlight the presence of asbestos and asbestos-containing materials within a workplace. Workplaces must review their asbestos register or asbestos management plan (AMP) at least once every five years if asbestos has been identified or is assumed to be present. Asbestos registers are categorised into two types: Compliance and Intrusive (known in Victoria as Division 5 and Division 6 Assessments, respectively).

Division 5 Asbestos Registers

Compliance (Division 5) asbestos registers typically involve a walkthrough assessment with minimal disturbance and sampling, and are generally not suitable for identifying asbestos before demolition or refurbishment works. The purpose of the Compliance (Division 5) register is to identify the presence and locations of asbestos and asbestos-containing materials that are likely to be encountered during normal and proposed occupation of the workplace, including regular and minor maintenance works and small refurbishments.

Division 6 Asbestos Registers

Intrusive (Division 6) registers are designed to reflect the proposed scope of works for non-occupational works, such as large-scale refurbishments and/or demolition. The level of access and intrusiveness should directly relate to the proposed scope of works and minimise the number of inaccessible areas and those assumed to contain asbestos. Intrusive (Division 6) assessments limit their scope to areas most likely affected by the proposed works, excluding areas outside this scope. Undertaking an Intrusive (Division 6) assessment effectively reduces areas of uncertainty, such as no access areas or items assumed to contain asbestos. Workers should not start work until they have read and understood the site’s asbestos register and its implications for their work. Addressing any audit gaps is essential before commencing work that might disturb these areas or materials.

Ensuring a Compliant Asbestos Register

The employer, person with management or control, or the Person Conducting a Business or Undertaking (PCBU) is responsible for ensuring a compliant asbestos register has been reviewed before starting demolition or refurbishment work. The review aims to highlight and, as far as reasonably practicable, reduce or eliminate any uncertainties within the asbestos register and determine if the proposed works are likely to disturb asbestos-containing materials. The duty of reviewing and updating the asbestos register might also be a contractual task for a Principal Contractor on larger projects or the landlord for smaller projects.

For domestic projects, the builder engaged to undertake the proposed works is responsible, although this may vary from site to site and project to project.

Moreover, after establishing an asbestos register at a workplace, the presence of asbestos needs to be indicated. Labelling items identified as, or assumed to contain, asbestos with asbestos warning labels to assist in identifying the locations of asbestos-containing materials assists in complying with this part of the regulations.

Sampling and Identifying Suspected Asbestos-Containing Materials

If uncertainty exists about whether an item or building material contains asbestos, one must assume the item or material contains asbestos until a laboratory with the relevant National Association of Testing Authorities (NATA) Australia accreditation samples and analyses it. One should treat an item or material assumed to contain asbestos as an asbestos-containing material until sampling and analysis prove otherwise.

Other Hazards

One can also identify other hazardous building and construction materials on site, such as polychlorinated biphenyls (PCB), synthetic mineral fibres (SMF), ozone-depleting substances (ODS), and lead and lead-containing paintwork. Often, one can include these in the site’s asbestos register to assist in their on-site management.

Importing Goods from Overseas

Asbestos continues to enter Australia through construction materials and on sites. Importers and exporters have the responsibility to ensure they do not import or export prohibited goods, such as asbestos. The Australian Border Force (ABF) needs assurance that goods containing asbestos are not unlawfully crossing the border. Examples of asbestos in construction include brakes, gaskets, and natural stone gaskets. You can find more information on the ABF website: ABF Asbestos Information.

Importers must proactively manage the risk in their supply chain and be ready to present documentary evidence proving their goods are asbestos-free. Employers, persons with management or control, or Persons Conducting a Business or Undertaking (PCBU) should implement a system to ensure their suppliers and subcontractors do not import materials containing asbestos. It is too late once authorities have identified the goods on site, and the relevant WorkSafe/SafeWork/Comcare regulator must be notified.

Training

Workers who direct others or may encounter or remove asbestos from time to time should undergo asbestos awareness training. This training should cover topics such as identifying asbestos materials, understanding regulatory requirements, handling and disposal, health effects, and the use of personal protective equipment (PPE) and respiratory protective equipment (RPE). Additionally, the training should teach how to access and understand the asbestos register.

Our trainers, with up to 35 years of experience in identifying and managing asbestos and hazardous building materials, offer customised and memorable training. For more information, please contact us.

Asbestos Removal and Clearance

OHS/WHS regulations mandate the removal of asbestos under the following conditions:
– Asbestos-containing materials or asbestos-contaminated items present an exposure risk to occupants within a workplace; and/or
– An asbestos-containing material is, or is likely to be, disturbed or damaged.

An appropriately licensed asbestos removal contractor must lawfully remove any nominated asbestos-containing material or asbestos-contaminated item. Regulatory authorities require asbestos removal contractors to hold a license for the area where they conduct work. For a list of registered licensed asbestos removal contractors, please refer to your local regulatory authority’s website.

The asbestos removal contractor has regulatory responsibilities to isolate the nominated asbestos work area from other site works and the public. When setting up the exclusion zone, the contractor must clearly indicate that asbestos removal works are in progress. Additionally, the removalist must implement necessary controls to prevent the release of asbestos fibers during their work practices.

Licensed Asbestos Assessors

In Australia, all regulations require Airborne Asbestos Fibre Monitoring (air monitoring) during Class A (friable) asbestos removal works by a Licensed Asbestos Assessor (LAA) or Independent Competent Person (ICP) in Victoria. However, experts highly recommend conducting air monitoring for all asbestos removal and remediation works, especially those near public areas. Note that South Australia requires air monitoring for all licensed asbestos removal works.

After completing the asbestos removal works, the person(s) who commissioned the works must hire an independent LAA/ICP to perform a visual clearance inspection of the area. This is to confirm the removal of all asbestos, including any associated dust and debris. Typically, the LAA/ICP conducting the air monitoring also performs the clearance inspection.

Following a satisfactory visual clearance inspection, the LAA/ICP must issue a clearance certificate confirming that the area, including the immediate surroundings, is free from visible asbestos contamination and that all air monitoring results were below the detection limit of 0.01 fibres per milliliter (f/mL) of air sampled. Moreover, an employer/PCBU must ensure that air monitoring results are readily accessible to affected employees, such as designated work groups and health and safety representatives.

Without complete demolition, it’s impossible to guarantee the total removal of asbestos.

For more information or to book one of our experienced asbestos or hazardous auditors in Melbourne or Adelaide please contact Helia EHS here. Helia can conduct an asbestos or hazardous materials audit, asbestos sampling, airborne asbestos fibre monitoring, asbestos clearance inspections, or asbestos management plans.

 

[1]  OHS – Occupational health and Safety Regulation 2017 (Victoria); WHS – Work Health and Safety Regulations.

[1] Independent Licensed Asbestos Assessor (WHS Regulation 489); or a Competent Person (Victoria) 

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