Management Guide

Creating an Effective Asbestos Management Plan

December 5, 2023

9 min read

Management

Legal Requirement

Under the Control of Asbestos Regulations 2012, duty holders for non-domestic premises are legally required to manage asbestos risks, which includes creating and maintaining an asbestos management plan. Failure to comply can result in prosecution, fines, and reputational damage.

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Legal Requirements and Responsibilities

Before diving into the components of an asbestos management plan, it's important to understand the legal framework surrounding asbestos management in the UK:

The Duty Holder

The "duty holder" is the person responsible for managing asbestos risks in non-domestic premises. This is typically:

The building owner
The person responsible for maintenance (e.g., facilities manager)
A tenant with responsibility for building maintenance under a lease agreement
In some cases, multiple parties may share duty holder responsibilities

Key Legal Obligations

Under the Control of Asbestos Regulations 2012, duty holders must:

Take reasonable steps to identify the location and condition of ACMs
Document and maintain an asbestos register
Assess the risk of exposure from ACMs
Prepare and implement an asbestos management plan
Regularly review and update the plan
Provide information about ACMs to anyone who might disturb them

Non-Compliance Consequences

Failure to comply with asbestos regulations can result in:

Enforcement notices from the Health and Safety Executive (HSE)
Prosecution and significant fines
Reputational damage
Civil claims from those exposed to asbestos due to negligence
In severe cases, imprisonment for responsible individuals

The Essential Components of an Asbestos Management Plan

An effective asbestos management plan should contain the following key components:

1. Asbestos Policy Statement

Begin with a clear policy statement that outlines your organization's commitment to managing asbestos risks. This should include your overall approach to asbestos management, key objectives, and responsible personnel. For larger organizations, this may reference your broader health and safety policy.

2. Roles and Responsibilities

Clearly define who is responsible for different aspects of asbestos management within your organization. This should include:

The duty holder(s)
Asbestos coordinator/manager
Health and safety personnel
Maintenance staff
External consultants and contractors
Building users and tenants

For each role, specify their responsibilities and the level of authority they have in implementing the plan.

3. Asbestos Register

The asbestos register is a critical document that records all known or presumed ACMs in the building. It should include:

Date of the asbestos survey
Precise locations of ACMs (floor plans are highly recommended)
Types of asbestos identified (chrysotile, amosite, crocidolite, etc.)
Product type (insulation, ceiling tiles, floor tiles, etc.)
Extent/quantity of material
Condition assessment
Accessibility/vulnerability to damage
Surface treatment (if any)
Risk assessment rating

The register should be kept up-to-date and readily accessible. Digital registers with searchable databases are increasingly common for larger properties or portfolios.

4. Risk Assessment

Each identified ACM should be assessed for its risk potential. The risk assessment typically considers:

Material assessment: The type and condition of the ACM itself
Priority assessment: The likelihood of disturbance based on factors like location, occupancy, and activity

From these assessments, you can categorize ACMs into risk levels (e.g., high, medium, low) that will determine appropriate management actions.

5. Management Actions and Control Measures

Based on the risk assessment, specify how each ACM will be managed. Options typically include:

Leave in place and manage

For materials in good condition and unlikely to be disturbed. Regular monitoring required.

Repair or seal

For slightly damaged materials that can be effectively repaired.

Enclose

Placing a physical barrier around the ACM to prevent disturbance.

Remove

For high-risk materials or where refurbishment/demolition is planned.

Detail the specific control measures for each management option, including:

Monitoring schedules and procedures
Inspection requirements
Access restrictions
Labeling requirements
Permit-to-work systems

6. Emergency Procedures

Include clear procedures for dealing with:

Accidental damage to ACMs
Suspected ACM discovery during works
Air monitoring requirements following incidents
Decontamination procedures
Reporting requirements (internal and to authorities)

These procedures should be easily accessible to all staff and contractors, with clear contact information for responsible persons.

7. Communication Plan

Outline how information about asbestos will be communicated to:

Employees
Contractors and maintenance workers
Tenants
Visitors
Emergency services

This should include training requirements, information provision methods, and how the asbestos register will be made available to those who need it.

8. Review and Update Procedures

Specify how and when the management plan will be reviewed and updated. This should include:

Regular review schedule (at least annually)
Triggers for additional reviews (e.g., after incidents, changes in regulations, building modifications)
Procedures for updating the asbestos register
Document control procedures

Implementing Your Asbestos Management Plan

Having created your asbestos management plan, effective implementation is crucial. Follow these steps:

Step 1: Conduct an Asbestos Survey

If not already done, commission an appropriate asbestos survey from a competent surveyor. For most buildings, a management survey is required, while refurbishment or demolition surveys are needed before such work is undertaken.

Step 2: Develop the Initial Management Plan

Based on survey findings, create your management plan incorporating all the components described above. Ensure it's specific to your building and circumstances.

Step 3: Communicate and Train

Ensure all relevant parties are aware of the plan and understand their responsibilities. Provide appropriate training based on their level of involvement with ACMs.

Step 4: Implement Control Measures

Put in place all specified control measures, such as labeling, access restrictions, permit systems, and any necessary remediation work by licensed contractors.

Step 5: Regular Monitoring and Review

Conduct regular inspections of ACMs according to your plan schedule. Document all findings and update the register as needed. Review the effectiveness of your plan at least annually.

Step 6: Maintain Records

Keep comprehensive records of all asbestos-related activities, including surveys, inspections, air monitoring, work performed on ACMs, training provided, and plan reviews.

Common Challenges and Practical Solutions

Challenge: Incomplete Historical Information

Many buildings, especially older ones, lack complete records of materials used in construction and modifications.

Solution: Where information is incomplete, the precautionary principle should apply—presume materials contain asbestos until proven otherwise. Prioritize sampling of materials in high-risk or frequently accessed areas.

Challenge: Coordinating Multiple Contractors

Buildings often have various contractors working on different systems (electrical, plumbing, HVAC), making asbestos information coordination challenging.

Solution: Implement a robust permit-to-work system where all contractors must review asbestos information and sign off before beginning work. Consider contractor induction sessions specific to your building.

Challenge: Resource Constraints

Smaller organizations may struggle with the resources needed for comprehensive asbestos management.

Solution: Prioritize actions based on risk levels. Consider phased implementation of control measures, addressing highest-risk materials first. Explore shared resources with similar organizations or outsourcing certain aspects.

Challenge: Maintaining Awareness Over Time

Asbestos awareness can diminish over time, especially in buildings where ACMs are well-managed and incidents are rare.

Solution: Schedule regular refresher training, include asbestos information in induction procedures for new staff, and use periodic awareness campaigns. Consider asbestos management software with automated reminders for inspections and reviews.

Conclusion: Beyond Compliance to Best Practice

An effective asbestos management plan is not just about meeting legal requirements—it's about protecting people's health and creating a safe environment. While developing a comprehensive plan may require significant initial effort, the systematic approach it provides simplifies ongoing management and reduces the risk of costly incidents.

Remember that asbestos management is an ongoing process, not a one-time task. Regular reviews, updates, and communication are essential to maintaining an effective plan that continues to protect building occupants and workers over time.

Key takeaways for asbestos management plan success:

Base your plan on a thorough professional asbestos survey
Clearly define roles and responsibilities
Implement proportionate control measures based on risk assessment
Communicate effectively with all stakeholders
Document everything and maintain comprehensive records
Review and update regularly
Seek professional advice when needed

By following these principles, you'll create an asbestos management plan that not only meets regulatory requirements but also provides genuine protection for everyone who uses your building.

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Free Asbestos Management Plan Template

Download our comprehensive template to help you create your own asbestos management plan. Includes sections for all required components and practical examples.