A management survey is the standard survey and it is used for the purposes of managing asbestos within properties. Its purpose is to locate, as far as reasonably practicable, the presence and extent of any suspect ‘asbestos-containing materials’ (ACM’s) in the building, which could be damaged or disturbed during normal occupancy, including foreseeable maintenance and installation, and to assess their condition. Management surveys will often involve minor intrusive work and some disturbance. The extent of intrusion will vary and will depend on what is reasonably practicable for individual properties (i.e. it will depend on factors such as the type of building, the nature of construction, accessibility etc). The survey can be based on presuming the presence or absence of asbestos. However, it will usually (but not always) involve sampling and analysis to confirm the presence or absence of ACMs. A management survey should include an assessment of the condition of the various ACMs and their ability to release fibres into the air if they are disturbed in some way. This ‘material assessment’ will give a good initial guide to the priority for managing ACMs as it will identify the materials which will most readily release airborne fibres if they are disturbed. A management survey can be completed using a combination of sampling ACMs and presuming ACMs or, indeed, just presuming. Any materials presumed to contain asbestos must also have their condition assessed (ie a material assessment).
By presuming the presence of asbestos, the need for sampling and analysis can be deferred until a later time. However this approach has implications for the management arrangements. The duty holder bears potential additional costs of management for some non-ACMs. Any work carried out on ‘presumed’ materials would need to involve appropriate contractors and work methods in compliance with CAR 2006 irrespective of whether the material was actually an ACM or not. Alternatively, before any work starts, sampling and analysis can be undertaken to confirm or refute the presence of asbestos. The results will determine the work methods and contractors to be used.
The ‘presumption’ approach has several disadvantages: it is less rigorous, it can lead to constant obstructions and delays before work can start, and it is more difficult to control. ‘Default’ presumptions may also lead to unnecessary removal of non-ACMs and their disposal as asbestos waste. Default presumptions may be suitable in some instances, e.g. ‘small’ or simple premises, as part of a client’s management arrangements.
Surveyors should always endeavour to positively identify ACMs. A sufficient number of samples should be taken to confirm the location and extent of ACMs. It is legitimate to reduce sample numbers where materials can be strongly presumed to be ACMs. However the default presumption option should be avoided where possible, as it can make managing asbestos more difficult for the duty holder. Default presumption should only be used in circumstances where it is requested by the client and/or where access genuinely cannot be obtained.
When sampling is carried out as part of a management survey, samples from each type of suspect ACM should be collected and analysed. If the material sampled is found to contain asbestos, other similar materials used in the same way in the building can be strongly presumed to contain asbestos. The sample number should be sufficient to establish whether asbestos is present or not in the particular material. Sampling may take place simultaneously with the survey, or as in the case of some larger surveys, can be carried out later as a separate exercise.
All areas should be accessed and inspected as far as is reasonably practicable. Surveying may also involve some minor intrusive work, such as accessing behind fascia and panels and other surfaces or superficial materials. The extent of intrusion will depend on the degree of disturbance that is or will be necessary for foreseeable maintenance and related activities, including the installation of new equipment/cabling. Management surveys are only likely to involve the use of simple tools such as
screwdrivers and chisels. Any areas not accessed must be presumed to contain asbestos. The areas not accessed and presumed to contain asbestos must be clearly stated in the survey report and will have to be managed on this basis ie maintenance or other disturbance work should not be carried out in these areas until further checks are made.
Management surveys should cover routine and simple maintenance work. However it has to be recognised that where ‘more extensive’ maintenance or repair work is involved, there may not be sufficient information in the management survey and a localised refurbishment survey will be needed. A refurbishment survey will be required for all work which disturbs the fabric of the building in areas where the management survey has not been intrusive. The decision on the need for a refurbishment survey should be made by the duty holder.
A refurbishment and demolition survey is needed before any refurbishment or demolition work is carried out. This type of survey is used to locate and describe, as far as reasonably practicable, all ACMs in the area where the refurbishment work will take place or in the whole building if demolition is planned. The survey will be fully intrusive and involve destructive inspection, as necessary, to gain access to all areas, including those that may be difficult to reach. A refurbishment and demolition survey may also be required in other circumstances, e.g. when more intrusive maintenance and repair work will be carried out or for plant removal or dismantling.
There is a specific requirement in CAR 2006 (regulation 7) for all ACMs to be removed as far as reasonably practicable before major refurbishment or final demolition. Removing ACMs is also appropriate in other smaller refurbishment situations which involve structural or layout changes to buildings (e.g. removal of partitions, walls, units etc). Under CDM, the survey information should be used to help in the tendering process for removal of ACMs from the building before work starts. The survey report should be supplied by the client to designers and contractors who may be bidding for the work, so that the asbestos risks can be addressed. In this type of survey, where the asbestos is identified so that it can be removed (rather than to ‘manage’ it), the survey does not normally assess the condition of the asbestos, other than to indicate areas of damage or where additional asbestos debris may be present. However, where the asbestos removal may not take place for some time, the ACMs’ condition will need to be assessed and the materials managed.
Refurbishment and demolition surveys are intended to locate all the asbestos in the building (or the relevant part), as far as reasonably practicable. It is a disruptive and fully intrusive survey which may need to penetrate all parts of the building structure. Aggressive inspection techniques will be needed to lift carpets and tiles, break through walls, ceilings, cladding and partitions, and open up floors. In these
situations, controls should be put in place to prevent the spread of debris, which may include asbestos. Refurbishment and demolition surveys should only be conducted in unoccupied areas to minimise risks to the public or employees on the premises. Ideally, the building should not be in service and all furnishings removed. For minor refurbishment, this would only apply to the room involved or even part of the room where the work is small and the room large. In these situations, there should be effective isolation of the survey area (e.g. full floor to ceiling partition), and furnishings should be removed as far as possible or protected using sheeting. The ‘surveyed’ area must be shown to be fit for reoccupation before people move back in. This will require a thorough visual inspection and, if appropriate (e.g. where there has been significant destruction), reassurance air sampling with disturbance. Under no circumstances should staff remain in rooms or areas of buildings when intrusive sampling is performed.
There may be some circumstances where the building is still ‘occupied’ (ie in use) at the time a ‘demolition’ survey is carried out. For example in the educational sector, refurbishment/demolition surveys may be conducted in schools or colleges during one closure period (e.g. holidays) and the work not undertaken until the next holiday period. Also, a demolition survey maybe conducted to establish the economic future or viability of a building(s). The survey results would determine the outcome. In such situations, the ‘survey’ will need extremely careful managing with personnel and equipment/furnishings being decanted and protected (as necessary), while the survey progresses through the building. Again, there should be effective isolation of the survey areas and the ‘surveyed’ area must be shown to be fit for reoccupation before personnel reoccupy.
The value and usefulness of the survey can be seriously undermined where either the client or the surveyor imposes restrictions on the survey scope or on the techniques/method used by the surveyor. Information on the location of all ACMs, as far as reasonably practicable, is crucial to the risk assessment and development of the management plan. Any restrictions placed on the survey scope will reduce the extent to which ACMs are located and identified, incur delays and consequently make managing asbestos more complex, expensive and potentially less effective.
In management surveys, surveyors should be properly prepared for accessing all reasonably practicable areas in all parts of the building. Potentially difficult to enter areas (including locked rooms etc) should be identified in the planning stage with the dutyholder and arrangements made for access. In situations where there is no entry on the day of the survey, a revisit should be made when access will be possible. Where there are health and safety risks associated with some activities (eg height, confined spaces), these should be adequately assessed and arrangements made to control them. Any area not accessed (and where no other information exists) must be presumed to contain asbestos and be managed on that basis.
In refurbishment surveys, the area and scope of the work will need to be agreed between the dutyholder and the surveyor. In these surveys and in demolition surveys there should be no restrictions on access unless the site is unsafe (eg fire-damaged premises) or access is physically impractical. The level of intrusion will be significantly greater than with management surveys. It will include accessing structural areas, between floors and walls and underground services. Some areas may be difficult to gain entry to and/or may need specialist assistance or equipment. Access arrangements need to be fully discussed in the planning stage and form part of the contract, particularly where assistance has to be engaged. Where access has not been possible during refurbishment and demolition surveys, these areas must be clearly located on plans and in the text of the report to allow the refurbishment and demolition processes to be progressive in those areas. Any ACMs must be identified and removed at this time. It is now recognised that even with ‘complete’ access demolition surveys, all ACMs may not be identified and this only becomes apparent during demolition itself. Surveyors need to be competent to do all the relevant work and tasks in this class of surveys. They will need some knowledge of construction, be able to carry out the work safely and without risk to health, have the correct equipment to do the work and have the appropriate insurance.
If any restrictions have to be imposed on the scope or extent of the survey, these items must be agreed by both parties and clearly documented. They should be agreed before work starts and are likely to form part of the contract. If during the survey, the surveyor is unable to access any location or area for any reason, the dutyholder must be informed as soon as possible and arrangements made for later access. If access is not possible, then the survey report should clearly identify these areas not accessed. Limitations should be kept to an absolute minimum by ensuring that staff are adequately trained, insured and have the appropriate equipment and tools.