health & safety
Information, Instruction, Training & Supervision and Asbestos Removal The I, I, T & S requirement of HASAWA has been around for over 45 years and is clearly established. It is also very relevant and crucial, for asbestos removal work as it is a very high risk and heavily regulated industry. Origins of I, I, T & S The Health and Safety at Work etc Act 1974 (sometimes referred to as HASAWA, the HSW Act, the 1974 Act or HSWA) is the primary piece of legislation covering occupational health and safety in Great Britain. The Health and Safety Executive (HSE) and local authorities are responsible for enforcing this Act, together with the regulations made under the Act. These regulations cover a wide range of subjects, including asbestos, through the Control of Asbestos Regulations 2012 (CAR 2012), as well as non-asbestos topics such as working at height, manual handling, vibration and noise. Within section 2 of HASAWA, all employers have a legal duty to provide such Information, Instruction, Training and Supervision (often abbreviated as I, I, T & S) as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of employees.
Information Requirements in CAR 2012 Regulation 5 of CAR 2012 requires employers to identify the presence of asbestos and its type and condition (e.g. from an asbestos survey) before any building, maintenance, demolition or other work, liable to disturb asbestos, begins. It also sets out the requirement to arrange a survey if existing information on the presence of asbestos in the premises is incomplete or appears unreliable. Employers will also need to assess the accuracy of information in surveys and plans provided to
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arca & atac news · summer 2022
them, and their relevance to the location and type of work to be done in the building. When a Licensed Asbestos Removal Contractor (LARC) visits a site to price up potential asbestos removal works, this is essentially an information gathering exercise. Not only will the LARC be assessing the accuracy of the survey (extent of the asbestos containing material, it’s condition, the way it is fixed to the substrate, the quantity of material etc.) but will also be assessing practical elements of the removal process itself, including: w Location of the decontamination unit(s) and waste skip(s), and their proximity to the working enclosure(s) w Enclosure dimensions, potential voids, adjacent areas, and extent of the air monitoring requirements w Location of negative pressure units and airlock/baglock systems, and how these will facilitate suitable air management w Power and water supplies, drainage suitable for wastewater from decontamination w Any other special characteristics of the site and its vicinity. Many LARC’s have developed comprehensive checklists to capture all the required information during the visit, with the end results resembling a completed questionnaire. Regulation 6 of CAR 2012 requires employers to carry out a risk assessment to identify the
risks of exposure to asbestos. It sets out the requirement to record any significant findings and identify steps to prevent, or reduce, exposure to employees. General non-asbestos risks should be considered too, as required by regulation 3 of the Management of Health and Safety at Work Regulations 1999. All this vital information needs to be gathered and considered collectively to plan how the work will be undertaken.
Converting Information into Instruction
This is a crucial stage of the whole process. Following the information gathering exercise, the next step for a LARC, to effectively plan a job, is to convert the information into a set of detailed and specific instructions for site teams to follow. It is not sufficient to merely reproduce the gathered information and expect this to lead to exemplary site standards and practices. The finished document needs to be a practical and useful document of instructions, and takes considerable time and skill to compile. The resulting Plan of Work, describing the safe working method to be followed, should be drawn up by a suitably competent person (as required by regulation 7 of CAR 2012). The Plan of Work is the record of how senior managers/directors want the job to be done and should include the appropriate actions to control risk and prevent harm. Its main purpose is to guide site work, and it is a
