When asbestos materials are disturbed or damaged in the workplace we are often quick to point the finger at the particular tradesperson or company that was undertaking the work. The company may not have trained the staff members properly, they may have signed and/or reviewed asbestos registers and to be fair often should have been more aware. However, a lot of the time this is just part of the problem.
From my experience, many site owners and managers (the PCBUs) are not employing the proper management of asbestos and other hazardous materials in their workplaces. Registers and management plans may be outdated or non-existent, high priority items may not have been actioned and when it comes to paying for services, our industry suffers from the selection of the cheapest possible option.
So I ask, if a PCBU doesn’t value proper management of hazardous materials in the workplace, how can they blame someone else when things go wrong?
Does your site take asbestos management seriously?
We are in 2022 people, if your building is old enough to require an asbestos register then you should have one, and it should have been reviewed AT LEAST TWICE! Asbestos registers are a critical first step in asbestos management. Registers identify where asbestos is in the workplace, provide a condition assessment of the materials and identify areas of concern or materials that require further action or removal.
Sites must be re-surveyed every 5 years as a minimum, note that this is minimum compliance and not the recommended! I would recommend yearly reviews, particularly if friable materials are present, as these can degrade quicker and result in the spread of asbestos contamination.
If you don’t have a register, or it is outdated, you need a new one!
Management Plans are separate from the asbestos register. Management plans should be site specific and should detail the appropriate processes and procedures for working in and around asbestos materials at a specific site. This document will also outline legal requirements, licensing requirements, processes for contractors etc.
So you have a register and management plan, tick. But can you produce them? Don’t just file away these documents never to see the light of day. Everyone should know where these are kept, have access to them and be able to produce these documents when requested. Sites must also implement systems of work for all staff and contractors to review registers prior to undertaking their work and identify areas where asbestos may be impacted by the task.
LABELLING (OR NOT)
This is one that is often overlooked by PCBU’s. However, labelling can be a crucial step in avoiding unexpected asbestos disturbance. Labelling provides a visual indicator and can help contractors identify ACMs when locations on the register may be a little confusing. Labelling is a cheap step in the process, and I can’t understand why it is not more common.
Examples of stickers and signage.
THE CHEAP OTIONS
Why do they always pick the cheapest option? Like all risk management, asbestos follows the hierarchy of control where administrative options and PPE are at the bottom of the list. We see it all the time where a high risk material is identified and the client chooses to put up some signage, restrict access to authorised persons and request that they utilise PPE to enter the area. This is then usually followed up by no action. These types of controls should only ever be used in the interim while arranging remedial action.
Another way of valuing the cheap options is within the resurvey process. We encounter many instances where requests for re-surveys specifically state that only previously identified materials are to be reassessed. This is not necessarily the smaller operators, but can be large organisations too. In other words, it is a condition assessment update, not a survey. An update of the asbestos register should include a full re-survey of the site. You never know what was previously missed.