Earlier in the year the Health & Safety Executive launched a new asbestos guidance document that includes important regulatory changes for the way asbestos surveys are planned and delivered.

The publication, entitled ‘Asbestos: The Survey Guide (HSG 264)’ replaces and expands on the surveying industry standard – ‘MDHS100: Surveying, sampling and the assessment of asbestos containing materials’.

The new guidance directly affects organizations who undertake asbestos surveys, as well as providing advice for those who are required to implement and manage asbestos under Regulation 4 of the Control of Asbestos Regulations (CAR 2006) in non-domestic premises (i.e. Clients/Duty Holders).

Summary of Changes

Survey Name Changes

New survey names now introduced to assist the Client/Duty Holder in understanding the purpose of the survey and to help them select the most appropriate survey for their needs. The name changes are also designed to promote the management of asbestos.

• Type 2 = Management Survey
• Type 3 = Refurbishment or Demolition Survey

Improving Survey Planning

Better liaison between the surveyor and duty holder before the survey goes ahead to ensure accurate and useable pre-survey information.

Changes to Survey Scope

Management Survey (was a Type 2 survey)

• Management Survey is to be more comprehensive and better planned
• Suitable for continual use/occupation of building
• Should survey all accessible areas (Inside risers, service ducts, above suspended ceilings/ voids, walls, ceilings, pipe work, boilers, lift shafts etc.)
• Any areas not inspected must be presumed to contain asbestos
• Not sufficient for renovation or refurbishment of building areas
• Used to facilitate ongoing management of asbestos containing materials (ACM’s).

Refurbishment or Demolition Survey (was a Type 3 survey)

• Necessary in areas where refurbishment is due to be carried out (a Management Survey alone is not sufficient)
• Can be small (localized areas only) or large scale
• Used to locate all ACMs in all areas (wall cavities, structural locations, ducts, risers, tunnels, under floor tiles)
• Likely to involve destructive means of access

Presumptions Not Exclusions

All areas in a Management Survey (that it is reasonably practicable to inspect) should be accessed and if not, no access must be pre-determined by client. Any such areas will be presumed to contain asbestos and should be managed as ACMs.

Strengthened Advice to Duty Holders On Assessing Surveyor Competence

The Client/Duty Holder should be satisfied that a surveyor is technically competent to carry out the work required and has appropriate qualifications, expertise and track record. Guidance includes:

• UKAS accreditation of organizations
• Individual surveyor competence (P402/5, ABICS, Minimum 6 months experience)
• Track record and experience logs
• If none of the above then look at an organizations Quality Control and Assurance

Avoiding & Reducing Survey Caveats

Survey caveats are a burden to asbestos management and by better planning can be significantly reduced or eliminated all together. This will improve survey accuracy and quality.

• Can be avoided by proper liaison with the Client/Duty Holder
• Problems regarding access should be reported to the Client/Duty Holder and should be minimized where ever possible
• If necessary caveats should be fully justified and agreed between the Client/Duty Holder and the surveyor
• Any caveats must be detailed clearly in the survey reports