Asbestos Management Procedure
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Background
NSW Department of Education manages a diverse asset portfolio including schools, childcare centres, and housing and community use facilities across the state. The NSW Department of Education is committed to managing ACM in NSW Department of Education workplaces in accordance with legislation, and in a manner that eliminates or minimises the risk to people.
ACM is defined as any material that, as part of its design, contains asbestos. The removal or repair of ACM can cause concerns for students, workers and the wider community, due to the potential exposure risk of asbestos fibres that may be released during disturbances of ACM.
Note that this document refers to asbestos-related work and non asbestos-related work. Asbestos-related work is any work in which disturbance of asbestos is planned. Where an asbestos disturbance occurs during any activity that is not planned asbestos-related work, this would constitute an accidental disturbance and must be managed in accordance with the Asbestos Incident Management Procedure.
Purpose and Scope
This Asbestos Management Procedure supports the Asbestos Management Plan (AMP) and provides detailed guidance on how asbestos and ACM that is identified at NSW Department of Education workplaces will be managed.
The NSW Department of Education is committed to managing asbestos and ACM in accordance with work health and safety legislation and thereby eliminating or minimising the risk to health and safety. This commitment is achieved through a number of measures outlined in this document, including embedding asbestos identification and management into all stages of project management, and ensuring asbestos-related information and training is readily available.
This Asbestos Management Procedure is intended to be read by any person involved in the management of asbestos at NSW Department of Education facilities.
Legislation
The management of asbestos and ACM within NSW Department of Education facilities, including identification, removal, encapsulation, transport, disposal, or potential disturbance of ACM, must be carried out in accordance with current versions of all relevant State and Commonwealth legislation, regulations, and SafeWork NSW Codes of Practice including, but not limited to, the following:
Definitions
Term
Meaning
Accidental disturbance
Any disturbance of asbestos or ACM except during planned asbestos-related work.
Air monitoring
Air monitoring involves sampling airborne asbestos fibres to assist in assessing exposure to asbestos and the effectiveness of implemented control measures. It must be conducted in accordance with the Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Dust, 2nd Edition [NOHSC: 3003 (2005)]. It is a DoE requirement that air monitoring is performed when any form of asbestos disturbance works is undertaken.
Airborne asbestos
Any fibres of asbestos small enough to be made airborne. For the purposes of monitoring airborne asbestos fibres, only respirable fibres are counted.
ARCP
Asbestos Removal Control Plan. A document that identifies the specific control measures that will be used to ensure that workers and other people are not at risk when asbestos removal work is being undertaken.
Asbestos
The asbestiform varieties of mineral silicates belonging to the serpentine or amphibole groups of rock-forming minerals, including actinolite asbestos, grunerite (or amosite) asbestos (brown), anthophyllite asbestos, chrysotile asbestos (white), crocidolite asbestos (blue) and tremolite asbestos, or a mixture that contains one or more of these.
Asbestos containing dust (ACD)
Dust or debris that has settled within a workplace and is, or is assumed to be, contaminated with asbestos.
Asbestos containing material (ACM)
Any material or thing that, as part of its design, contains asbestos.
Asbestos-related work
For the purpose of this procedure, asbestos-related work is any work involving the planned disturbance of asbestos including asbestos removals.
Asbestos waste
Any waste that contains asbestos. This includes removed material and disposable items used during asbestos removal work including plastic sheeting, disposable tools and personal protective equipment.
Asset Services Officer
School Infrastructure staff who perform a range of asset services including the delivery of capital works projects and all aspects of facilities management.
Competent person
A competent person is someone who has acquired knowledge and skills to carry out the task through training, a qualification or experience.
In relation to identifying asbestos, a competent person is:
- trained to handle and take asbestos samples, have the knowledge and experience to identify suspected asbestos and be able to determine risk and control measures
- familiar with building and construction practices to determine where asbestos is likely to be present, and/or
- able to determine that material may be friable or non-friable asbestos and evaluate its condition.
In relation to carrying out clearance inspections under WHS Regulation clause 473, a person who has acquired through training or experience the knowledge and skills of relevant asbestos removal industry practice and holds:
- a certification in relation to the specified VET course for asbestos assessor work, or
- A tertiary qualification in occupational health and safety, occupational hygiene, science, building, construction or environmental health.
The department engages competent persons from the Hygienist Services Panel (SINSW1340-20) for the purpose of identifying asbestos or carrying out clearance inspections.
Contaminant
Any substance that may be harmful to health or safety.
Contamination of land
The presence in, on or under the land of a substance at a concentration above the concentration at which the substance is normally present in, on or under (respectively) land in the same locality, being a presence that presents a risk of harm to human health or any other aspect of the environment.
Control measure
In relation to a risk to health and safety, means a measure to eliminate or minimise the risk.
Demolition work
Work to demolish or dismantle a structure, or part of a structure that is loadbearing or otherwise related to the physical integrity of the structure, but does not include:
a. the dismantling of formwork, falsework, or other structures designed or used to provide support, access or containment during construction work, or
b. the removal of power, light or telecommunication poles.
Duty holder
Any person who owes a work health and safety duty under the WHS Act including a person conducting a business or undertaking, a designer, manufacturer, importer, supplier, installer of products or plant used at (upstream), officer or a worker.
Exposure standard
For asbestos is a respirable fibre level of 0.1 fibres/mL of air measured in a person’s breathing zone and expressed as a time-weighted average fibre concentration calculated over an eight-hour working day and measured over a minimum period of four hours in accordance with the Membrane Filter Method or a method determined by the relevant regulator.
Friable asbestos
Material that is in a powder form or that can be crumbled, pulverised or reduced to a powder by hand pressure when dry, and contains asbestos.
GHS
Globally Harmonized System of Classification and Labelling of Chemicals.
Hazard
A situation or thing that has the potential to harm a person. Hazards at work may include asbestos, noisy machinery, a moving forklift, chemicals, electricity, working at heights, a repetitive job, bullying and violence at the workplace.
Health and Safety Representative (HSR)
Means worker/s who are elected to represent the health and safety interests of workers.
Hygienist
For the purposes of this plan, the hygienist will also be a competent person/licensed asbestos assessor.
In situ asbestos
Asbestos or ACM fixed or installed in a structure, equipment or plant but does not include naturally occurring asbestos.
Incident
An unplanned event that could result in an injury to a person or a to loss of, or disruption to, an organisation's operations, services or functions.
Independent
In relation to clearance inspections and air monitoring means:
a. not involved in the removal of the asbestos
b. not involved in a business or undertaking involved in the removal of the asbestos, in relation to which the inspection or monitoring is conducted.
Licensed asbestos assessor
A person who holds an asbestos assessor license through SafeWork NSW (or similar) under the WHS Regulations to perform air monitoring and clearance inspections relating to class A asbestos removal work.
Licensed asbestos removalist
A person conducting a business or undertaking who is SafeWork NSW licensed under the WHS Regulations to carry out class A or class B asbestos removal work.
NATA-accredited laboratory
A testing laboratory accredited by the National Association of Testing Authorities (NATA), Australia, or recognised by NATA either solely or with someone else.
Naturally occurring asbestos (NOA)
The natural geological occurrence of asbestos minerals found in association with geological deposits including rock, sediment or soil.
Non asbestos-related work
For the purpose of this procedure, work which does not include planned disturbance of ACM (including work adjacent to ACM).
Non-friable asbestos
Material containing asbestos that is not friable asbestos, including material containing asbestos fibres reinforced with a bonding compound.
Person conducting a business or undertaking (PCBU)
A person conducting a business or undertaking to the extent that the business or undertaking involves the management or control, in whole or in part, of the workplace.
The NSW Department of Education is a PCBU and therefore has primary duty of care.
PPE
Personal protective equipment
P&C
Parents & Citizens Association
Respirable asbestos fibre
An asbestos fibre that:
- is less than 3 microns (µm) wide, and
- is more than 5 microns (µm) long, and
- has a length to width ratio of more than 3:1.
Structure
Anything that is constructed, whether fixed or moveable, temporary or permanent, and includes:
a. buildings, masts, towers, framework, pipelines, transport infrastructure and underground works (shafts or tunnels)
b. any component of a structure
c. part of a structure.
SAMP
School Asbestos Management Plan
SWMS
Safe Work Method Statements
Unexpected find
The identification of an asbestos hazard (or suspected asbestos hazard) which is not listed in the relevant asbestos register. Note that an asbestos find as part of hazard identification activities (such as an intrusive asbestos survey in preparation for a project) is not an unexpected find.
Volunteer
A person who is acting on a voluntary basis (irrespective of whether the person receives out-of-pocket expenses).
WHS Act
Work Health and Safety Act 2011 (NSW)
WHS Regulations
Work Health and Safety Regulation 2017 (NSW)
Worker
A person who performs paid work in any capacity for an employer, business or organisation (including but not limited to employees, apprentices, contractors and subcontractors) or who is unpaid (including but not limited to volunteers).
Works
For the purpose of this document, works means any planned activity performed by a worker, which involves the disturbance of building materials or ground surfaces.
Health Risks of Asbestos
Asbestos is the term given to a group of naturally occurring mineral silicates which are prevalent in the earth’s crust and are composed of fibres that do not readily break down within the human body.
Inhaling asbestos fibres may lead to asbestos related diseases such as asbestosis, lung cancer or mesothelioma. The risk of developing an asbestos-related disease depends on a number of factors including but not limited to how many fibres have been breathed in and for how long and the type of asbestos.
Roles and Responsibilities
Under the WHS Regulation, the NSW Department of Education must eliminate risks relating to asbestos, or if that is not reasonably practicable, minimise the risks so far as is reasonably practicable.
All staff, students, contractors, volunteers and visitors have a responsibility to:
- Take reasonable care for their own health and safety,
- Not adversely affect the health and safety of other persons, and
- Comply with reasonable direction relating to health and safety, including following the directions of this procedure for any asbestos-related matters.
This Asbestos Management Procedure identifies responsibilities below for the following parties:
- all employees;
- person responsible for works;
- School Infrastructure;
- school principal and workplace manager;
- school staff;
- Health, Safety and Staff Wellbeing Directorate; and
- facilities maintenance contractors and other contractors/service providers.
All Employees
All employees of the NSW Department of Education should:
- participate in asbestos training where required. For more information on training see 'Training';
- not disturb material suspected to be ACM; and
- report all issues with the condition of ACM, asbestos registers and asbestos warning signage at any NSW Department of Education facilities.
Person Responsible for Works
The person responsible for works may be a School Infrastructure Asset Management staff member, School Principal, workplace manager or other person. Regardless of the work, the person responsible shall:
- adhere to NSW Department of Education policies and procedures for the management of ACM;
- not engage any service providers for work, however minor, without the explicit approval of the appropriate Asset Management Unit;
- not undertake any work on assumed or confirmed ACM without engaging appropriately licensed contractors (see section 'Procuring Asbestos-Related Works' );
- review asbestos registers for the workplace prior to commencement of any works;
- ensure the contractor (if relevant) is inducted and provided a copy of the asbestos register which is contained within the School Asbestos Management Plan;
- ensure submission of the HAZMAT Community Notification Request Form in accordance with the HAZMAT Community Notification Request Form - How to Guide (where relevant);
- ensure that a SWMS is received from the contractor before work starts for any asbestos-related work, and that work is carried out in accordance with the SWMS;
- ensure that asbestos or ACM that is likely to be disturbed is identified and so far as is reasonably practicable, removed prior to demolition or refurbishment commencing;
- ensuring asbestos removal work is carried out by a licensed asbestos removalist who is adequately licensed to carry out the work;
- ensure that air monitoring is carried out (where required) and a clearance certificate (where required) issued for asbestos removal work;
- ensure that the results of air monitoring (where required) are communicated to relevant stakeholders; and
- inform the school principal or workplace manager of any disturbance or concerns with any building materials.
Note: All other delivery partners and external PCBUs must also adhere to the responsibilities listed in this section.
School Infrastructure
The responsibilities of School Infrastructure include:
- developing policies and procedures in relation to the management of asbestos and ACM in NSW Department of Education facilities;
- establishing and maintaining asbestos register data (excluding the input of reports/documents) for NSW Department of Education facilities;
- ensuring the general Asbestos Management Plan and SAMPs are updated as required;
- engaging pre-qualified hygienists to manage and update school asbestos registers and SAMPs;
- reviewing school-organised work applications;
- liaising with the principal and/or workplace managers about asbestos-related activity such as incidents and/or remediation to manage risks to students, staff, and visitors;
- providing support and assistance for any asbestos or ACM incident, including investigation and implementation of preventative and corrective actions; and
- managing and overseeing ground inspections at frequencies specified in the SAMP.
School Principal and Workplace Manager
A school principal is defined as a person that has executive authority for a NSW Department of Education facility. The responsibilities of the school principal or workplace manager include:
- reporting incidents to the Incident Response and Support Hotline.
- adhering to NSW Department of Education policies and procedures for the management of asbestos and ACM.
- ensuring that staff do not undertake works at schools without receiving approval from their Asset Management Unit (where required).
- for school organised work, facilitating contractors’ induction upon entry to the school, including ensuring asbestos registers are accessed for any work disturbing building materials or surface soils.
- inspecting for signs of damage to buildings, fixtures and grounds following severe weather events (including but not limited to heavy rain, flooding and hail) and reporting them to Asset Management Unit immediately, including through FMWeb2.0.
School Staff
School staff have a responsibility to:
- adhere to NSW Department of Education policies and procedures for the management of asbestos and ACM; and
- inform the School Principal of any incident involving the disturbance of asbestos or ACM or concerns with any building materials.
Heath Safety and Staff Wellbeing Directorate
The responsibilities of the Health, Safety and Staff Wellbeing Directorate includes:
- acting as the liaison point with Safe Work NSW, including supporting schools with inspector visits as required;
- arranging support for impacted workers including arranging the Employee Assistance Program;
- reporting notifiable incidents relating to asbestos or ACM to Safe Work NSW immediately;
- communicating with School Infrastructure in relation to ACM or asbestos-related incidents; and
- record keeping and department reporting of asbestos or ACM incidents.
The department continues to maintain resources to support the management of psychosocial hazards and risks in schools and workplaces, via the psychosocial hazards intranet page.
Facilities Maintenance Contractors and Other Contractors / Service Providers
The responsibilities of a contractor engaged in asset-related works at schools include:
- implementing and adhering to safe work practices;
- reviewing the school’s asbestos register and SAMP prior to performing works which disturb building materials or include any excavation work;
- receiving, reviewing and signing any Asbestos Work Authorisation as required; and
- if asbestos containing material is found or suspected of being found, isolate and restrict access to the area and inform the principal or workplace manager.
Asbestos Risk Management
A systematic process for managing any work health and safety risk, including asbestos, is:
- Identify hazards.
- Assess risks.
- Eliminate risks so far as is reasonably practicable (ie. asbestos removal).
- Controlling risks (such as with an enclosure, encapsulation or sealing).
- Review control measures to ensure they are working as planned.
Open and constructive consultation, communication, and cooperation between duty holders, principals and other workplace managers, workers and other stakeholders is essential to the work health and safety risk management process and must occur at every stage. Consultation on health and safety risks arising from work involving asbestos or ACM needs to comply with the NSW Department of Education’s WHS consultation arrangements.
Refer to the WHS consultation and issue resolution policy for further detail.
Managing the risk of asbestos exposure in NSW Department of Education workplaces involves the following key components:
- maintaining up to date asbestos registers;
- managing in-situ asbestos;
- managing works which disturb building materials or grounds surfaces;
- ensuring asbestos works including asbestos removals are performed safely;
- ensuring all relevant staff are trained; and
- monitoring the effectiveness of asbestos management procedures and continual improvement.
Identifying In-Situ Asbestos
ACM can be safely managed in-situ by ensuring that ACM are not damaged or deteriorated to such an extent that NSW Department of Education facility staff, students, contractors, or visitors are exposed to airborne asbestos fibres. Proactive and effective management of in-situ asbestos is important to demonstrate to the school community that asbestos is being managed in line with WHS legislation.
Identifying ACM is the first step in managing the risk of exposure to asbestos in NSW Department of Education facilities.
The NSW Department of Education ensures, so far as is reasonably practicable, that all asbestos and ACM at NSW Department of Education facilities is identified by a competent person. This includes conducting a thorough inspection of all areas of the facility including but not limited to buildings, structures, ceiling spaces, storage areas, and facility grounds. These inspections may be conducted during school hours, provided they are not disrupting school activities.
Material that cannot be identified, but a competent person reasonably believes is asbestos, must be assumed to be asbestos or ACM unless sample analysis indicates otherwise.
If there is uncertainty as to whether asbestos is present in any part of a NSW Department of Education facility, it can either be assumed to contain asbestos and treated with appropriate caution based on the level of risk, or be inspected by a competent person.
When the presence and location of asbestos has been assumed all requirements for managing asbestos must be followed until the material is removed, contained, or testing has confirmed that it does not contain asbestos.
If there are inaccessible areas in a NSW Department of Education facility, that a competent person has identified as likely to have asbestos or ACM, it must be assumed they contain asbestos or ACM until they are accessed, and the competent person determines if asbestos is present or not. If materials cannot be visually assessed or sampled without damaging the item,
the competent person will include the item on the asbestos register if asbestos is suspected.
Asbestos Register
An asbestos register is a document that lists all identified (or assumed) asbestos or ACM in a workplace. It is intended to inform workers and others in the workplace to prevent accidental disturbance of ACM.
NSW Department of Education has asbestos registers for facilities under their control unless:
- the facility is a building constructed after 31 December 2003; and
- no asbestos has been identified at the facility; and
- no asbestos is likely to be present at the facility from time to time.
The asbestos register records the date on which the asbestos or ACM was identified (or assumed) at the facility, as well as the location, type and condition of the asbestos.
The risk associated with the asbestos, or each ACM item is assessed by the hygienist and included in the asbestos register.
Online Asbestos Review Tool (OART)
OART is managed by the department’s School Infrastructure division and is hosted in the Asset Management System. It is an online database and reporting tool which allows the competent person / licensed asbestos assessor selected from the Hygienist Services Panel (SINSW01340-20) to produce asbestos registers for NSW Department of Education facilities.
OART assists with the overall management, amalgamation, and digitised access of asbestos information within NSW Department of Education facilities.
School Asbestos Management Plan (SAMP)
Asbestos or ACM that has been identified in NSW Department of Education facilities is detailed in the SAMP.
The SAMP details the management of asbestos by documenting procedures designed to minimise the risk of exposure to all personnel on that site. It must be read in conjunction with the department’s AMP.
Accessing an Asbestos Register and School Asbestos Management Plan
Each school’s asbestos registers are contained within the SAMP and are readily accessible to workers and health and safety representatives, as well as PCBUs who carry out, or intend to carry out, work at NSW Department of Education facilities, and the public here.
Signage, Notices, and Labelling
The requirements meet the responsibilities outlined in the SafeWork NSW Code of Practice: How to manage and control asbestos in the workplace.
Warning signage
All warning signs are compliant with AS 1319-1994: Safety signs for the occupational environment.
The NSW Department of Education will ensure a workplace that contain asbestos, is signposted with warning signs so that the asbestos is not disturbed without the correct precautions being taken.
Labelling
Labelling is the practice of using stickers or other notices to identify the location of asbestos or ACM in a workplace. The NSW Department of Education has determined that the labelling of all facility ACMs is not reasonably practicable and has in place alternative controls to manage risk.
Reviewing and Revising an Asbestos Register and School Asbestos Management Plan
To ensure the information is maintained and up to date, the asbestos registers and SAMP are reviewed and updated every 5 years or whenever:
- further asbestos containing material is identified at a facility;
- the SAMP is no longer adequate for managing asbestos or ACM at a facility;
- there is a review of the asbestos register or a control measure;
- a health and safety representative requests a review;
- asbestos is removed from or disturbed, sealed or enclosed at a facility, or refurbishment or demolition work is to be undertaken.
Asbestos register and SAMP reviews should be performed by an occupational hygienist from the Hygienist Services Panel (SINSW01340-20).
Managing Work
Works which disturb building materials or ground surfaces, including minor works, must not occur without the authorisation of Asset Management Unit.
Any find or disturbance of asbestos ACM or suspected ACM must be reported in accordance with the Asbestos Incident Management Procedure.
Overview and Stages
Overview
In accordance with WHS legislation, all risks must be identified and eliminated where reasonably practicable to do so. Where the risk cannot be eliminated, it must be minimised so far as is reasonably practicable in line with the hierarchy of controls. Note that the following relates to the risk of asbestos exposure, however other risks on the same project, such as confined spaces, falls, heat stress and electric shock must also be managed in the same way.
The hierarchy of controls, in order of most to least protective and reliable, is:
- Elimination: eliminate the risk, for example by removing the ACM.
- Minimisation: minimise the risk through substitution (replace the hazard), isolation (isolate the hazard), engineering controls. Examples include barriers, enclosures, distance, restricting access.
- Administrative controls: such as procedures, information and training.
- PPE: for example, respiratory protection.
A combination of these controls may be required in order to adequately manage and control risks associated with asbestos and ACM. Administrative controls and PPE are the least effective at minimising risk because they do not control the risk at the source and rely on human behaviour and supervision. These control measures should only be used:
- to supplement higher level controls;
- as short-term interim measures until a more effective way of controlling the risk can be used, or
- when there are no other practical control measures available.
Note: The most suitable control measure should be selected in consultation with the competent person / licensed asbestos assessor.
Stages
The following represents a non-exhaustive list of considerations for any person arranging works.
Planning Works
Roles and responsibilities
The NSW Department of Education requires any person planning works which disturb building materials or ground surfaces to consider the presence of asbestos and potential for disturbance during project and maintenance planning, regardless of the project size. Note that this requirement includes School Infrastructure, GAs and school P&Cs.
Review of Asbestos Registers
As part of planning works on a NSW Department of Education facility, including plant, constructed or installed before 31 December 2003, the Project Manager must review the asbestos register and SAMP (see documentation here: Schools asbestos register (nsw.gov.au)) and determine whether the asbestos documentation adequately covers the area to be disturbed. If the project will disturb an area listed as inaccessible on the register, or that could not reasonably be presumed to have been accessed, further intrusive sampling may be required.
Note that this will include areas within wall cavities, behind fixed ceilings and subfloor areas where suitable access is not provided without damaging building materials, as well as sub-surface soils.
Pre-Project Investigation
Pre-project investigations should be procured through the Hygienist Services Panel (SINSW01340-20). Further information regarding engaging a hygienist can be found here: Hygienist Schedule of Rate Contract.
Where required because the current asbestos register does not adequately cover the area to be disturbed, a competent person (such as an occupational hygienist) should be engaged to perform a destructive asbestos survey, also known as a demolition or refurbishment survey, which will involve destruction of targeted building materials. A demolition or refurbishment survey can help ensure that accidental asbestos disturbance, and subsequent disruption to the project timeline and budget implications are minimised.
Where asbestos ACM has previously been found in soils, it should be presumed that any project which will disturb the soil surface will encounter asbestos or ACM. The Project Manager should engage a competent person to perform an assessment of the soil (see panel here: Hygienist Schedule of Rates Contract., or proceed with the assumption that the soil contains asbestos and plan works accordingly (for example engage a licensed asbestos removal contractor to perform the works).
An asbestos in soils assessment will likely address:
- the extent of asbestos or ACM contamination in soils where proposed works are to occur.
- the friable or non-friable nature of the ACM (if present).
- recommended controls for the management of identified contamination, such as removal, capping or redesign of works.
- recommended ongoing management post project.
- license types required for any recommended removal of contamination.
- whether the contamination is likely to meet the threshold for notification to the NSW EPA. Note that non-friable asbestos-cement sheeting debris in soils does not require notification to the EPA.
The competent person from the hygienist panel will be able to update the asbestos register with the findings from the demolition or refurbishment asbestos survey or asbestos in soils assessment. If the investigation was completed by a competent person that is not on the hygienist panel (not recommended), all resultant reports must be shared with the Compliance and Environment team (schoolinfrastructure@det.nsw.edu.au) for the asbestos register to be updated.
Project Planning
Works should be planned to either avoid disturbing asbestos or remove the asbestos prior to works commencing. The procedure for arranging an asbestos removal is outlined in Section 'Procuring Asbestos-Related Works'. Where it is not reasonably practicable to remove the asbestos or ACM, other controls will be required to ensure that the works do not pose a risk to health and safety from exposure to asbestos fibres. Controls must be considered in accordance with the hierarchy of controls. The following methods may be used for preventing the accidental disturbance of known asbestos or ACM:
- if it is possible remove the asbestos or ACM during the first stage of the project.
- if possible, place hoarding or other physical barrier around known asbestos or ACM.
- where there is not already signage, place signage on known asbestos or ACM for the duration of the project.
- plan the works to not involve the disturbance of known asbestos or ACM.
- include the presence of asbestos or ACM in contractor induction and pre-start documentation.
Note that staff are not permitted to perform asbestos-related work.
So far as is reasonably practicable, asbestos removal should be performed after school hours (including when there is no occupancy of after-school care) to minimise the number of people in the area. Approval must be obtained from the relevant Executive Director (for example Executive Director – Asset Management or Executive Director – Infrastructure Delivery) for asbestos removal to be performed during school hours. Staff may be on NSW Department of Education-owned
facilities while an asbestos removal is occurring elsewhere, providing that the asbestos work area is suitably restricted. The Project Manager must give due consideration to the means of communicating to all relevant staff that an asbestos removal is occurring.
Certain equipment can generate airborne asbestos fibres and must not be used on asbestos or ACM. The WHS Regulation prohibits the use of the following equipment on asbestos or ACM:
- high-pressure water spray (unless used for firefighting or fire protection purposes); and
- compressed air.
Any equipment which may release airborne asbestos (such as power tools and abrasive hand tools) must not be used on ACM unless controls have been implemented in consultation with a competent person / licensed asbestos assessor. The following maintenance activities must not be conducted without approved safe work practices being implemented in consultation with a competent person / licensed asbestos assessor:
- drilling of ACM;
- sealing, painting, coating and cleaning of asbestos-cement products (under no circumstances should asbestos cement products be water blasted or dry sanded in preparation for these activities);
- cleaning leaf litter from gutters of asbestos cement roofs;
- replacing cabling in asbestos cement conduits or boxes;
- working on electrical mounting boards (switchboards) containing asbestos; or
- inspection of asbestos friction materials.
As a priority, the practicality of removing the asbestos or ACM must be considered when planning for maintenance of asbestos or ACM at the workplace, in accordance with the hierarchy of controls.
Note: Works requiring disturbance to asbestos or ACM must not be conducted without consultation with a competent person / licensed asbestos assessor and implementation of an approved safe work practice.
Procuring Works
Procuring Non Asbestos-Related Works
Service providers are to be given key asbestos management related documents (including the asbestos register) before they price work to ensure that service providers have information about asbestos risks associated with the work. This enables service providers to:
- consider the tools and work methods to be applied for the work.
- consider the legislative prohibitions or restrictions on the use of certain plant on ACM; and
- prepare any necessary safe work method statements for the works and ensure their workers are trained in the safe work method statements before commencing the works.
Service providers with relevant training, expertise, experience and safety performance history should be preferenced during selection activities.
Procuring Asbestos-Related Works
Asbestos Removal Contractors
The licensing requirement will depend on the type of ACM involved in the works. The requirements for licensing are provided in the table below. While an unlicensed removalist is acceptable in our legislative framework for removals of less than 10 m2 of non-friable asbestos, the NSW Department of Education requires a licensed asbestos removal contractor to be engaged for all asbestos work. Project Managers may choose to engage a more qualified asbestos removal contractor than is strictly required, as a precautionary measure, for example engaging a Class A asbestos removalist for a non-friable removal.
Asbestos Removal License | What asbestos can be removed? |
---|---|
Class A |
Any amount of ACM |
Class B |
Any amount of non-friable ACM and the dust associated with its removal |
Occupational Hygienist
The requirement for a hygienist in legislation also depends on the nature of the works. Air monitoring is to be performed during all asbestos removal works which requires a Class A asbestos removal licence, where required for friable removals, or where otherwise required by the WHS Regulation.
The person responsible for organising the works must ensure that, when removal work is completed, a clearance inspection is carried out and a clearance certificate is issued by:
- if the asbestos removal work must be carried out by the holder of a Class A asbestos removal licence - an independent licensed asbestos assessor; or
- in any other case - an independent competent person.
The NSW Department of Education may engage a licensed asbestos assessor to perform clearance inspections even when removal work does not require a Class A asbestos removal licence, as a conservative measure.
Note: The competent person / licensed asbestos assessor must be selected from consultants on the Hygienist Services Panel (SINSW01340-20) detailed on the intranet.
Pre-works
It is the responsibility of the person responsible for planning works to:
- Communicate, where relevant, any school community impact information associated with the works. If works are to involve asbestos-related work, where practicable, the school community must be told that asbestos work is to be carried out and the date it is to commence. Potentially affected parties may include:
- staff.
- out of hours school providers.
- community organisations using the facilities.
- P&C association members.
- Provide a copy of the asbestos register to the PCBU carrying out the works. The contractor must acknowledge that they have read and understood the asbestos register as part of the induction process.
- Ensure that contractors have developed SWMS where required. Asbestos-related works are designated as high-risk, therefore SWMS must be developed for any asbestos related works. Works that do not plan to disturb asbestos; but are to be conducted in the vicinity of asbestos or ACM, should include the presence of asbestos and the recommended controls to ensure that it is not disturbed in documentation and pre-start meetings.
For any removal of friable asbestos or removal of greater than 10m2 of non-friable asbestos, the licensed asbestos removal contractor must do the additional following:
- Prepare an Asbestos Removal Control Plan (ARCP) before removal work commences. An ARCP documents the specific control measures that will be used to minimise the risk of asbestos exposure during removal works, including the work method, tools, equipment and PPE to be used. It also documents the details of the asbestos to be removed, including the location, type and condition of the asbestos. A copy of the ARCP must be present at the workplace while the removal is occurring. If a notifiable incident occurs in connection with the asbestos removal work, the licensed asbestos removalist must keep the ARCP for at least two years after the incident occurs.
- Notify the regulator in writing at least 5 days before the removal work commences. Note this is distinct from notifiable incidents, which are discussed in Section 'Incidents and Emergencies'. In limited circumstances asbestos removals can commence immediately, following notification to the regulator by phone and writing within 24 hours after notice is given, where there is a risk of exposing people to respirable asbestos fibres or a breakdown of essential services. This must be assessed on a case-by-case basis with guidance from SafeWork NSW.
The person responsible for the works should confirm with the licensed asbestos removal contractor that the above items have been completed before works commence.
During Works
Non Asbestos-Related Works
If asbestos or ACM or suspected asbestos or ACM is discovered or disturbed during non asbestos-related works, the Asbestos Incident Management Procedure must be followed. In the first instance, the worker/s must:
- Stop work.
- Isolate the area.
- Notify the Principal or Workplace Manager.
Asbestos-Related Works
Departmental employees must not carry out works on assumed or confirmed ACM.
As discussed above, so far as is reasonably practicable, asbestos removal should be performed after school hours (including when there is no occupancy of after-school care) to minimise risk to students and staff.
Approval must be obtained from the relevant Executive Director (for example Executive Director – Asset Management or Executive Director – Infrastructure Delivery) for asbestos removal to be performed during school hours. Staff may be on NSW Department of Education-owned facilities while an asbestos removal is occurring elsewhere, providing that the asbestos work area is suitably restricted. The Project Manager must give due consideration to the means of communicating to all relevant staff that an asbestos removal is occurring.
Control Measures
The following control measures represent the minimum requirements that a contractor should follow when performing asbestos-related work:
- A nominated asbestos removal supervisor must be present during friable removals, or readily available during non-friable removals (for example contactable by phone and able to arrive at the workplace within 20 minutes).
- Delineate the asbestos work area with barricades to restrict access. The nature of the barricade will depend on the risk level, for example temporary fencing may be appropriate for a friable asbestos removal while barrier tape may be adequate for removal of non-friable debris from an outdoor area.
- Display signage indicating the asbestos removal area.
- Use wet methods where reasonably practicable.
- Use suitable tools and equipment including H-Class industrial vacuum cleaners, hand tools, and equipment designed to capture or supress dust.
- Use correct and appropriate PPE at all times in the asbestos removal work area. At a minimum, asbestos removal contractors would be expected to wear fit-tested respiratory protection, coveralls, gloves and safety footwear.
- Provide suitable decontamination facilities.
- Contain and label asbestos waste and dispose of it as soon as reasonably practicable at a site licensed to accept asbestos waste.
- Separate PPE and equipment contaminated with asbestos and handle it appropriately.
The following additional control methods are expected for friable asbestos removals:
- The asbestos removal area is enclosed to prevent the release of asbestos fibres (for example with a “bubble” constructed of plastic sheeting).
- The enclosure has been tested for leaks, typically the licensed asbestos assessor will perform a “smoke test” to achieve this.
- Negative pressure is used (Note: negative pressure is not required if a glove bag is used).
- Wet methods are used.
Further information regarding safe removal of asbestos can be found in the NSW Code of Practice How to safely remove asbestos.
Clearance Inspection and Clearance Certificates
Clearance inspections must be carried out and clearance certificates issued by:
- an independent licensed asbestos assessor for friable asbestos-related work; or
- an independent competent person or licensed asbestos assessor for non-friable asbestos-related work.
The licensed asbestos assessor or competent person must not issue a clearance certificate unless they are satisfied that the asbestos removal area and the area immediately surrounding it are free from visible asbestos contamination in the form of dust and debris. The asbestos work area cannot be reoccupied for normal use or other work activities until the clearance certificate is received. This means that access must be restricted to everyone who is not involved in the asbestos removal work, and barriers and signage must remain in place, until the clearance certificate is received.
The clearance certificate must be in writing and must state that:
- the licensed asbestos assessor or competent person found no visible asbestos residue from asbestos removal work in the area, or in the vicinity of the area, where the work was carried out; and
- if air monitoring was carried out by the licensed asbestos assessor or competent person as part of the clearance inspection - the airborne asbestos fibre level was less than 0.01 fibres/mL.
Air Monitoring
Control air monitoring is asbestos fibre air monitoring performed at the boundaries of the asbestos removal area to ensure that the control measures are effectively preventing asbestos fibre escape outside of the asbestos removal area.
For friable asbestos removals, it is a legislative requirement that clearance air monitoring be completed as part of asbestos removal works. The licensed asbestos assessor cannot issue a clearance certificate, and therefore the work area cannot be reoccupied, until asbestos fibre air monitoring results are below 0.01 fibres/mL.
Where control air monitoring is performed it must be conducted before and during relevant asbestos-related works and all air monitoring must be performed in accordance with the Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres, 2nd Edition [NOHSC: 3003 (2005)]. The following action levels will apply for any control air monitoring results.
Action level | Action |
---|---|
Less than 0.01 fibres/mL |
Air monitoring report to be issued to Project Manager on a daily basis; Continue with control measures. |
Greater than or equal to 0.01 fibres/mL, less than or equal to 0.02 fibres/mL |
Air monitoring report to be issued to Project Manager on a daily basis; Contractor to inform Project Manager of elevated result; Project Manager to log result with the Incident Response and Support Hotline; Project Manager and hygienist to review control measures; Project Manager and hygienist to investigate the cause; Implement controls to eliminate or minimise exposure and prevent further release. |
Greater than 0.02 fibres/mL | Stop removal work; Contractor to notify Project Manager; Contractor to notify Safe Work NSW by phone followed by a written statement including the results of the air monitoring and that work has ceased; Project Manager to notify HSSW through the Incident Response and Support Hotline (1800 811 523); Investigate the cause in consultation with all workers involved with the removal work; Implement controls to eliminate exposure and prevent further release; Do not recommence removal work until further air monitoring is conducted and fibre levels are at or below 0.01 fibres/mL. |
Communicating Air Monitoring Results
For friable asbestos-related work, it is a requirement for air monitoring results to be given to the following people:
- workers at the workplace;
- health and safety representatives for the workplace;
- PCBUs at the workplace, for example if there are trades working at the workplace; and
- other people at the workplace.
Project Managers are to request communications through School Infrastructure, ensuring that all air monitoring reports are supplied to the communications team for this purpose.
For non-friable asbestos-related work, if air monitoring is conducted, results must be readily accessible to people who were in the work area during the time. While asbestos-related work will be performed during low occupancy times as far as is reasonably practicable, this can be achieved by posting the printed air monitoring report at the entrance to the asbestos removal work area.
Waste Disposal
All asbestos removed must be transported and disposed of as asbestos waste according to the WHS Regulation, the NSW Environment Protection Authority Waste Classification Guidelines, and the requirements of the local licensed waste disposal facility. Asbestos waste can only be disposed of at a site licensed by the NSW Environment Protection Authority, and it must never
be disposed of in the general waste stream. Where removal of asbestos-contaminated soil is required, the same requirements will apply.
The asbestos waste must be contained and labelled in accordance with the GHS before the waste is removed from an asbestos-related work area and disposed of as soon as practicable at a site authorised to accept asbestos waste.
PPE used in asbestos-related work and contaminated with asbestos must be:
- sealed in a container, and the exterior of the container is decontaminated and labelled in accordance with the GHS to indicate the presence of asbestos before being removed; and
- so far as is reasonably practicable, disposed of on the completion of the asbestos-related work at a site authorised to accept asbestos waste; and
- if it is not reasonably practicable to dispose of the PPE that is clothing—
- laundered at a laundry equipped to launder asbestos-contaminated clothing; or
- if it is not practicable to launder the clothing, kept in the sealed container until it is re-used for the purposes of asbestos-related work; and
- if it is not reasonably practicable to dispose of the PPE that is not clothing—
- decontaminated before it is removed from the asbestos removal area; or
- if it is not practicable to decontaminate the equipment in the asbestos removal area, kept in the sealed container until it is re-used for the purposes of asbestos-related work.
Post Works
Asbestos removal areas are not to be reoccupied until a clearance certificate has been received from the licensed asbestos assessor or competent person. The hygienist must update the asbestos register to indicate any asbestos or ACM that has been removed, as well as any areas in the clearance certificate where asbestos or ACM must be assumed to remain. The person responsible for the works should check that this process has been completed as part of project close-out.
Responsible Party | Action |
---|---|
Person responsible for the works |
Receipt of asbestos clearance certificate from the occupational hygienist. |
Receipt of waste docket from asbestos removalist (as required). |
|
Ensure asbestos register is updated (as required). |
|
If the school community had not been notified of the asbestos works prior to works commencing, communication advising of the works must be distributed as part of project close-out. |
Training
NSW Department of Education has initiated various training measures to ensure staff are aware of the risks involved with respect to asbestos or ACM in the workplace.
Training regarding asbestos management is available through MyPL. Departmental staff should ensure that this training is completed at the recommended interval.
Asbestos Awareness Training for Asset Management Staff
NSW Department of Education has asbestos awareness training for workers who may be involved in asbestos related work. The training is administered by School Infrastructure and covers the identification, safe handling and suitable control measures for asbestos and asbestos containing material in relation to asbestos management in department facilities.
Management and Control Asbestos in the NSW Schools
NSW Department of Education has a training course to help workers understand the process for controlling and managing asbestos in the workplace, including how to access the department's Asbestos Management Plan (AMP), and SAMP. The training covers incident reporting protocols when asbestos is unexpectedly found, disturbed, or suspected of being found or disturbed. This course is mandatory for principals, public schools PSSE, asset services officers and work health and safety advisors.
Incidents and Emergencies
Notifiable Incidents
Serious work-related health and safety incidents are notifiable to SafeWork NSW.
As such the scene must be preserved pending further direction from the regulator. With regards to asbestos, an incident in a workplace which exposes any person to a serious risk resulting from immediate or imminent exposure to an uncontrolled escape, spillage or leakage of asbestos may require notification to Safe Work NSW.
The process for notifiable incidents relating to unplanned asbestos works (accidental disturbance and/or unexpected finds including relating to vandalism and illegal dumping) is set out in the Asbestos Incident Management Procedure.
In the event of a notifiable incident relating to planned asbestos-related work:
- Stop work.
- Isolate the area and preserve the scene. Note: the scene of a notifiable incident must be preserved unless Safe Work NSW gives permission for the scene to be disturbed, except any action needed to assist an injured person, make a site safe or facilitate a police investigation.
- Call the Incident Response and Support Hotline (1800 811 523)
The Health, Safety and Staff Wellbeing Directorate must report notifiable incidents to Safe Work NSW as soon as possible. If a notifiable incident occurs during asbestos removal work, the licensed asbestos removalist must keep the ARCP for at least two years after the incident occurs.
Emergencies
An emergency can occur if a building, structure, or plant is structurally unsound or the collapse of a building, structure or plant is imminent.
If an emergency occurs and requires demolition, a procedure must be developed in consultation with a competent person / licensed asbestos assessor that will, as far as reasonably practicable, reduce the exposure to asbestos of workers and persons in the vicinity of the demolition site to a level below the exposure standard before the demolition work starts. The regulator must also be provided with written notice of the emergency immediately after they become aware of the emergency and before the demolition starts.