Asbestos Reinspections – How often should you reinspect asbestos materials.
In this episode Neil and Ian discuss asbestos reinspection intervals. When should asbestos reinspections be undertaken, who should undertake them and what should they include.
Transcript:
Ian: Welcome to the Asbestos Knowledge Empire. I’m Ian Stone.
Neil: I’m Neil Munro.
Ian: So today we are talking about Asbestos re-inspections.
Neil: Yes, what is that asbestos re-inspection? Different from a survey.
Ian: Well… Exactly that, that’s what I was going to start with.
Neil: So… and usually that follow on from sort of a survey etcetera, so using base information, so you should really have an existing asbestos register.
Ian: Usually that’s from a management survey.
Neil: Yeah, could have survey information added to it. So it is basically taking the existing asbestos information.
Ian: So you know what it is, where it is, the condition that’s in and then it is re-inspecting that so a visual check, go into the location that it’s in, and looking at the material and comparing it to what data you’ve got, what the photo previously looked like making sure there is no deterioration, there is no cracks, there is no signs of deterioration. You are checking for water leaks, all sorts of stuff. Basically anything that could affect that material in its location.
Neil: And it is part of that process you’d be updating the material risk assessment. So the material risk assessment looks at how easily or how readily that asbestos material will release asbestos fiber should it be damaged. And it looks at the product type so what asbestos product it is. It looks at the condition so whether it is in a good condition or whether it is damaged. It will also look at the surface treatment so whether it is sealed, or unsealed, or it could self sealed. And It will also look at taking to account what asbestos fiber has been identified in them too. So that’s probably the most important is updating that information, that assessment because then that falls in and follows in with your priority risk assessment and then your overall risk on how you manage that material.
Ian: If you are going to re-inspect and last year the asbestos insulating board ceiling was in a lovely condition. It was all painted and it was all fine. This year you have re-inspection undertaken and for some reason, I don’t know, weathering or water leak because the paint is now flaking off.
Neil: Chipped it, damaged it.
Ian: Yeah, exactly, anything that could affect it then that is kind of the first call of the material has changed. So the risk assessment has changed so it might go from a medium risk up into the high risk category. But also with that like you say, it is the priority risk assessment. That’s a very important one to check when you are doing the re-inspection because you could have something that’s low risk, or say medium or high risk but it is in a very low risk area. However, in the course of the last 12 months that use of that area has changed. I’ve seen that before in school halls where you got a store covered and they store hockey sticks in there, so the hockey sticks come out once a year for one week and that’s the only time they play hockey. However, in the last 12 months they’ve cleared all that out, put it somewhere else and now that is the caretaker store, and they are in there at all day every day. Or they are in there that now becomes their material store so the risk of damaging stuff when they are dragging equipment and getting it out, it’s kind of increases the risk of any asbestos being damaged in that area.
Neil: Yeah. So the golden question and the question we get asked quite a lot, and it is a bit of a gray area when it comes to putting some specific down. So that is when and how often should these re-inspections be undertaken?
Ian: Yeah, and from an industry standpoint it is kind of always been 12 months.
Neil: Yeah, which I think is probably the benchmark.
Ian: A good minimum.
Neil: Yeah, the benchmark for if you are going to do something set in 12 monthly inspections is a good place to start.
Ian: Yeah, I mean if you think about a year it is a hell of a short period of time. The older I get the quicker my life is flashing through my eyes. Twelve months is going by and that’s Christmas comes quicker every year, summers get shorter.
Neil: I think that comes down from previous guidance, documents, the proof card practice, you kind of stated re-inspections or inspection of materials should be done annually. However, when the new proof card practice was put up in whenever it was, 2012, it kind of sort of…
Ian: It reworded that section.
Neil: Yeah, reworded that element.
Ian: This section, have you got it?
Neil: Yes, so it kind of just pointed towards any identifiable suspect, ACM, must be inspected and its condition assessed periodically so no actual [unclear – 5:12] specific in there. It is not the whole has been damaged. The frequency of inspection would depend on the location, the ACMs, and other factors which old affect their condition for example the activities in building, non-occupancy, etc. There will also be events or changes for example maintenance work, new tenants or employees should also attribute the review of the plan. So it doesn’t actually put a timeframe on it however what I believe the interpretation of that is really you’ve got asbestos materials which are in high volume, high traffic, high occupancy areas, I think you would need to increase the time of inspection rather than decrease it.
Ian: Definitely. I think that’s a very key point because I think a lot of people look to maximize the time between re-inspections because obviously it costs a lot of money. However, just looking at the word periodically it means from time to time or occasionally, but it also means at regular occurring intervals so even the word itself means both.
Neil: Yeah, so if you will then try to do re-inspection every two years it is not kind of regular. Is it?
Ian: No.
Neil: And lots of people trying to sort of push towards that I think. Now, don’t get me wrong, if you’ve got a mastic pad in a sink within a pumping station that somebody probably goes to once a year then re-inspecting that every year may not be reasonably practical. You could maybe extend that to every two years if you had the evidence to back that up. Now, what I mean by that is if you’ve got a risk assessment that you’ve carried out re-inspections for a period of time that may be annually for the last two, three, four years and no change has happened to that material, then yes, you’d have the evidence to say, actually I’m now going to change the frequency of that because I’ve got the evidence to that over the last 4-5 years the material hasn’t changed. It hasn’t been disturbed.
Ian: Yeah. I think that is the key point there. It’s you take the asbestos information but then you churn that through another type of risk assessment to then determine how often you should be doing it because periodically it is different for different things. Again, if you had a mastic pad to a sink in a staff room and for the last four years you have re-inspected it and there’s been no change. Yeah, you could make that judgment and go, you know what, it hasn’t been affected so I am going to bump it to every other year no or whatever. I personally wouldn’t that because the staff room is being used day in and day out and the risk of that material changing is increased because there is more people in and around itself.
Neil: And if you got one mastic pad in a school you probably more likely to have other asbestos materials in there which would maybe fall into a higher re-inspecting regime.
Ian: Yeah, again, I think it probably make sense you go to the highest category for the re-inspection rather than doing like split shift on what you are going to re-inspect because then it can get complicated.
Neil: So to give you an increase, I know you kind of touch on earlier, so if you’ve got an asbestos material in a school corridor, maybe an asbestos panel on a fire door, re-inspecting that every 1-2 years is not really practical I don’t think.
Ian: 100% not. Even a school, or even a business like an office or anything like that.
Neil: Yeah, yeah, where you got high traffic areas. You’ve got an asbestos product whether it will be low risk, medium risk, high risk, whatever, if you got it in that location you’ve got high risk of human exposure because of the occupancy, the activities, the amount of people that are in there. So therefore, really, in that situation you probably looking at daily if not weekly inspections on that material.
Ian: 100%, definitely. It is a very good one, right? So if you look at a panel on a back of the door in a business corridor, like I said offices, the likelihood of that getting disturbed would be less because as adults normally we open…
Neil: Don’t kick doors.
Ian: We open doors properly. We don’t play football inside. We don’t write “Neil loves Eleanor” on the back of a door and scribe it in with a pen knife.
Neil: In my doors.
Ian: But if you compare that to a school, well, I mean that’s the difference. So an office corridor is going to be used normally usually…
Neil: As adults.
Ian: As adults. Whereas kids at school they are absolutely horrendous at times. Like you say, kick doors.
Neil: Well, if you say to a child don’t kick that door. It is like, you know, [unclear – 9:52] Isn’t it?
Ian: If somebody says to me don’t do something, now, I’m still likely going to do it. I’m like a big child. Yeah, so exactly that and it is like. So if you take those two scenarios the arrow being in the corridor you might go, do you know what it is a high risk material in a high risk area we are going to re-inspect that once every three months, once every six months. But like you said about the school you’re going to be one who’s look at that daily or at least weekly I would say because of the likelihood. It goes up through the roof because of the occupants in the area. So it is kind of the blanket industry thing that everybody has taken on over the years are going, yeah once year, once a year, once a year. It is [unclear – 10:29] It is literally [unclear – 10:31] and it all should be risk assessment based on all of those elements really.
Neil: Yeah. But equally to that because of these kind of change, not change, but like loosening in the wording. Some people have taken that as to, you don’t have to do that every year anymore. They have taken it the wrong way.
Ian: Yeah, and it is the wrong way.
Neil: It’s not a loser, it should be tighter.
Ian: Yeah, and that is the way you can read that because before it said annually, so now it doesn’t said annually so people have gone, does it say yearly I can go 10 years.
Neil: Yeah, it should be risked assessed wise.
Ian: Yeah, 100%. So one thing when inspections. Who should carry them out?
Neil: That is a very very good question because we do get asked this quite often. Don’t we?
Ian: Yeah.
Neil: And I’ve got an opinion but should we just describe the actual guidance on that?
Ian: So HSE. It should be somebody who is competent.
Neil: Yes, competent.
Ian: Yeah, competence. What is competence? HSE determines competence who’s got knowledge training, experience and other qualities. Never understood what the other qualities mean. I don’t know whether that means they are really good and they can remember jokes.
Neil: No. It is blue eyes, black eyes, big muscles.
Ian: Is it?
Neil: Because that’s what used to be good qualities as... could be a decent wine collection.
Ian: Yeah, other qualities. I don’t know what they are but.
Neil: We’ll pass on that.
Ian: We’ll skip on that one.
Neil: If we take the qualifications, what qualifications can you have? Now, this isn’t any actual set qualifications to you can go and do a re-inspection.
Ian: No, the closest one that comes to it is a surveyor’s qualification.
Neil: But I don’t think you have to go that because you’re not actually surveying for asbestos. You are actually just looking at the material that has already been identified to be to you. But you do need to have some experience of what is asbestos and do you actually know what it is. Do you know what it looks like? Do you know what the materials look like when they change, when they deteriorate, when they start to peel, when there’s damage, when the material start to provide a risk.
Ian: And if you change the word from a qualification to training and I think that’s a key point of you can be trained to do re-inspection without having the formal qualification. And what I mean by training, it could be a competence, somebody who always deemed competent. So one of our asbestos consultants could come to your site and walk it with the property manager or the caretaker and give that kind of toolbox talk, that one to one training on look this is the asbestos that you’ve got on site. These are the kind of risks to look out for. This is what it looks like now if this happens. So like you say, if it peels, if it cracks, if it chips, if a corner comes off. That kind of training because some people you might say, well, going to have to look at that panel, and they look at the panel, and they are going to go well looks like a photo but it might have a big crack in the middle and the corner missing. He’s like, it is not really damaged. It’s only a bit. It’s not properly damaged. Do you know what I mean? That’s what somebody might look at it as and in reality that’s not good enough because it has deteriorated.
Neil: Yeah, and that kind of comes with experience as well. So for instance you may want to body on your site so you may want to pay asbestos consultants to come and do re-inspection with you a couple of times. So you can gain that experience or you may want to do it and then have it audited by an asbestos consultant to ensure that you are gaining the relevant experience and doing it right basically.
Ian: Yeah, that is who should carry them out. However, all of that said, you can get somebody you deemed competent who can be trained and then gets the experience to do it. The kickery is on that. You’ve got to update all that information. It is not just the case of I’d rather look and it is fine. And that’s the difference I find between professional consultants just like us doing it and people on the DIY approach is when we carry out a re-inspection we re-photograph, re-update, we re-issue the report with all that new information, whereas, on the DIY approach it can be done but lots of several another podcast, if you work enough paper…
Neil: Yeah, you’ll never get that full update so.
Ian: No.
Neil: You get the picture. What it’s actually look at now?
Ian: Exactly that.
Neil: It was painted orange, it is now painted red. And this is kind of that’s when things kind of start to go wrong…
Ian: Starts getting confused.
Neil: When somebody comes to check your asbestos register they are looking for an orange panel and the asbestos is now red, that’s when mistakes can kind of start happening.
Ian: Oh, well, it is not here anymore. It must have been removed.
Neil: Exactly.
Ian: So again, somebody might go, gosh it’s removed; delete it, rip the page out and then all of a sudden you’ve got a bit of asbestos that’s not even being managed because it has been removed from your register without appropriate.
Neil: Definitely a possibility. The other thing that I wanted to highlight is if you are doing them yourselves or you are employing somebody outside of the industry you are taking the liability as well for that.
Ian: Oh yes.
Neil: So, you know, it’s then on your PI and you are the competent person all of a sudden.
Ian: That is a very, very good point.
Neil: Whereas, if you’re hiring in a professional to give you that advice and provide you that information, you’ve got their liability as well to rely on.
Ian: Definitely. That’s a really good point because, again, nobody is ensured to do work with asbestos whether that’s physical work or a re-inspection unless you’ve got to actually add it into your insurance, right? The insurance industry, they always remove asbestos. That’s one of the things I remove from everything they do because when asbestos goes wrong it cost a hell lot of money so that is always something that’s excluded out of every policy. And it’s only the likes of surveying companies, removal companies, that kind of thing that have it added in because that’s what they do for a living.
Neil: I know, I’m giving another example of schools because I think schools is a very particular risk when we are talking about asbestos, so lots of schools rely on their site managers or caretakers to do re-inspections and if you actually step back and think about that. Now, in my experience school caretakers they haven’t got asbestos knowledge in line with a competent asbestos surveyor/consultant.
Ian: No. They have literally been given the task.
Neil: They’ve been given the task so they’ve got to go around and do this.
Ian: They’ve been shafted.
Neil: Yeah, pretty much. Now, if you actually think about that what’s the liability on the school if that person, he/she, gets that wrong?
Ian: It is unthinkable. Some of the high schools, 2000 kids in, if it goes wrong and the amount of kids gets exposed from kind of misinterpretation it’s next level is ridiculous.
Neil: Yes. So why would you? You know, re-inspections are not expensive.
Ian: No they are not.
Neil: And for your peace of mind. You are not only taking the liability off your hands. That alone should be enough. Two, you get any information, that data used before, it is all new. It is fresh data. It is easy to use and if you got an asbestos database it is all updated accordingly. It’s not piece of paper, printed off, signed on and crossed out.
Ian: Can’t read someone’s writing.
Neil: Can’t read someone’s writing. Yeah, it is kind of a no brainer. No brainer at all.
Ian: Yeah. But that said, I think the biggest take away about what you spoken about is re-inspection they should be risk assessment based. Don’t rely on the fact of industry says and it’s used to say annually.
Neil: I think annually is definitely a benchmark and if you are not doing it manually you need to have…
Ian: That’s a benchmark minimum.
Neil: I was going to say you need to have a word and say, “Well, are we actually complying here?” If you are not doing that as a minimum like as we’ve discussed here that going to more increase not decrease doing inspection regimes.
Ian: Exactly that.
Neil: So I hope you found that useful. Remember if you’ve got any questions please come and join us on the Facebook group in the Asbestos Knowledge Empire.
Ian: Just go to Facebook, search in the search bar for Asbestos Knowledge Empire and it will come up.
Neil: Yup, we’ve placed quite a few bits and pieces in there so you can download and stuff like that.
Ian: Yes, there’s downloads, there are forms, there is extra information, the stuff that we spoke about in another podcast, the links to stuff, that’s all in there.
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