It's always recommended, but very rarely implemented. 'Label as asbestos containing material'......or something similar. I always wonder why so many clients opt not to label ACMs at their site? Labelling is a task that requires very little additional cost and effort (with the exception of remote locations of course). However, if you have a good quality existing register there is very minimal additional cost to include labelling of ACMs in your next reinspection.
Let's be frank. It doesn't matter how good you think the format of your asbestos register is, someone (and I guarantee it's more than one) will struggle to interpret the thing. It's the nature of the beast. Or, you may provide the register to the project manager who then doesn't pass it on to the contractors doing the work. Labels provide a visual cue to the contractors on the ground who are actually completing the work and even if it only avoids one contractor inadvertently disturbing asbestos, it's a win right?
Would you also believe that some building owners, property managers and facility managers don't know where all the asbestos exists in their buildings? Labels can help managers and staff at the site to immediately identify ACMs that may become damaged or require repair.
Do I Really Have To?
The NSW Code of Practice: How To Manage & Control Asbestos In The Workplace states that:
"If reasonably practicable, the presence and location of the asbestos or ACM must be indicated by a label".
Clause 424 of the WHS Regulation states that:
A person with management or control of a workplace must ensure that—
(a) the presence and location of asbestos or ACM identified at the workplace under clause 422 is clearly indicated, and
(b) if it is reasonably practicable to do so, indicate the presence and location of the asbestos or ACM by a label.
(a) in the case of an individual—70 penalty units, or
(b) in the case of a body corporate—345 penalty units.
Well that's about as clear as mud! I hate the term reasonably practicable. Is it not reasonably practicable to provide further control measures to prevent asbestos disturbance for minimal cost included with a service you already require? I would be handing out penalty units all over the place.
Why Isn't It Already Included?
So why don't all companies include the cost of labelling if the regulator recommends it? Short answer, many clients don't want them up. If I had a dollar for every time a client had requested me to complete a building survey without mentioning the 'A word' to anyone.... well I'd probably only have $50, but that's still a lot of times. Even with larger clients that request labelling as part of a survey, some will request that you only label in back of house areas, or label in discreet locations.
If you've commissioned an asbestos survey, then it is reasonably practicable to include labelling, so just make it mandatory. Signage should be placed at building entrances, sign in areas, electrical boxes etc. and labels should be applied to all ACMs.