CODE OF PRACTICE – MANAGING PUBLIC HEALTH RISKS FROM ASBESTOS – 10 April 2015 USER GUIDE – MANDATORY PROVISIONS 3 1. PURPOSE 5 2. APPLICATION OF THIS CODE 6 3. DEFINITIONS OF KEY TERMS 6 4. ASBESTOS HEALTH RISK 7 5. PROHIBITED ACTIVITIES 8 6. PERMITTED ACTIVITIES 8 7. ASBESTOS-RELATED WORK 9 7.1 ACM Identification and Assessment 9 7.2 ACM Maintenance and Repair 10 7.3 ACM Removal 11 7.3.1 General Control Measures 12 7.3.2 Temporary Removal and Reinstatement of non-friable ACM 13 7.3.3 Removal of 10 m2 or less of non-friable ACM 13 7.3.4 Removal of more than 10 m2 of non-friable ACM 14 7.3.5 Removal of friable ACM 15 7.3.6 Other Worker Removals 15 7.4 ACM Disposal 15 7.5 Soil and Built Environment ACM Contamination 16 7.6 Building Refurbishment or Demolition 17 7.7 Natural Disaster ACM Contamination 18 7.8 ACM in Remote Areas 18 8. ACTIONS OF AN AUTHORIZED PERSON 18 9. PRINCIPAL LEGISLATION 19 10. OTHER RELEVANT GUIDANCE 19 1 11. CONTACT INFORMATION 19 12. LIST OF ABBREVIATIONS 20 APPENDICES APPENDIX A – ASBESTOS SAMPLING PROCESS 21 APPENDIX B – SAFE WORK PRACTICE 2 – SEALING, PAINTING, COATING AND CLEANING OF ASBESTOS-CEMENT PRODUCTS 22 APPENDIX C - SAFE WORK PRACTICE 3 – CLEANING LEAF LITTER FROM GUTTERS OF 24 ASBESTOS-CEMENT ROOFS APPENDIX D – EXAMPLES ASBESTOS REMOVAL WORK 26 APPENDIX E - EXAMPLES OF ASBESTOS WARNING LABELS AND SIGNS 29 APPENDIX F - COMPONENTS OF THE ASBESTOS REMOVAL CONTROL PLAN 30 2 USER GUIDE – MANDATORY PROVISIONS This Code was developed to provide holistic guidance across a broad range of asbestos management issues relevant to protecting public health, including asbestos-related activities and special situations, such as disaster management. It includes a mixture of mandatory, recommended and advisory provisions. The mandatory provisions which are listed below in summary form are the most important because they closely relate to legislative requirements and to the proper handling higher risk scenarios. They are also placed in boxes in the relevant Sections. The mandatory provisions that relate to OHS legislation will normally be enforced by WorkSafe inspectors but can also be assessed/enforced by persons Authorized under the HAR. To assist an Authorized Person to apply the HAR and this Code, refer to the Guidance Note on the Enforcement of the Health (Asbestos) Regulations 2016. Prohibited Activities (Section 5, page 8 ) A summary of the main prohibitions (and exceptions to them), are as follows; Sale or supply of ACM, except for the purpose of correct disposal; Disturbing or removing of ACM except as permitted activities under Section 7; Disposal of ACM except as outlined at Section 7.4; The moving of ACM premises or structures except as provided for at Section 7.3; Re-use of ACM except as provided for under Section 7.3.2 Use of high pressure water or air to clean ACM; and Any unsafe work practices that cause the release of airborne asbestos fibres. Permitted Activities (Section 6, page 8) As indicated below, some asbestos-related work or activities (ARW) are only permitted if undertaken in specific ways. ACM in Poor Condition (Section 7.1, page 9) When ACM is in a poor condition a Department of Health or Local Government Authorized Person may require action to be taken by the owner or responsible person to manage the risk it presents. Asbestos Removal (Section 7.3, page 11) General Control Measures (Section 7.3.1, page 12) These apply to all persons undertaking asbestos removals. Isolating the work area with barriers and warning signage suited to the job; Using principally wet methods to eliminate or minimise the generation of asbestos fibres; Using appropriate tools and equipment; Using personal protective equipment (PPE); Decontaminating the area, involved personnel, PPE and equipment; and Properly containing and disposing of waste. 3 Temporary Removal and Reinstatement of ACM (Section 7.3.2, page 13) Any removed ACM which is greater than 6 m2 in total area must not be reinstated. Removal of 10 m2 or less of ACM (Section 7.3.3, page 13) Personal removal of 10 m2 or less of non-friable ACM for disposal by members of the public must be notified in writing to the Local Government Authorized Person. Removal of more than 10 m2 of ACM (Section 7.3.4, page 14) Removal of more than 10 m2 of non-friable ACM must be undertaken by an asbestos removalist, unless an exemption is approved by an Authorized Person. OSH legislative requirements (and Code requirements) for asbestos removal include: Asbestos removalist supervisor is present at the site or readily available; Asbestos removal workers are trained appropriately and training records are kept; Removalist to notify relevant parties of the asbestos removal, including the commencement date; Removalist prepares an asbestos removal control plan which outlines how the work will be safely managed; Removalist ensures the site is visually clear of ACM at the end of the job in the case of non-friable removal; Air monitoring for asbestos fibre is required during removal of friable ACM.; and Other actions as listed under General Control Measures. Removal of friable ACM (Section 7.3.5, page 15) The removal of friable ACM is only permitted by an asbestos removalist with an unrestricted license issued by WorkSafe. Other Worker Removals (Section 7.3.6, page 15) A non-licensed worker carrying out asbestos removal work (10m2 or less of non-friable ACM) must be trained in the identification and safe handling of asbestos and observe safe practices. ACM Disposal (Section 7.4, page15) Any disposal of ACM must be in accordance with Division 6, Regulations 42 to 47 of the Environment Protection (Controlled Waste) Regulations 2004, including that: It is an offence to dispose of ACM except as provided for in the CWR; ACM must be separated from non-asbestos material, double wrapped and labeled in accordance with the CWR; The person (disposer) who takes ACM to an approved ACM disposal facility must notify the operator that the load contains ACM; 4 The disposer must keep the asbestos disposal receipts from the facility; and The operator of an approved ACM disposal facility must dispose of the ACM in accordance with the CWR 2004. This Code also requires the disposer to retain the disposal receipts for one year and to make them available to an Authorized Officer if requested t o do so. Soil and Built Environment ACM Contamination (Section 7.5, page16) Soil contamination must be managed as follows: The area of contamination must be clearly delineated, taking a cautionary approach in situations of uncertainty, i.e. expanded boundary; Visible ACM should be removed by handpicking and properly contained and disposed of, while taking note of the locations of greatest concentration; and If the contamination may include asbestos-contaminated dust it should be removed from hard surfaces by wet wiping and from soft or natural surfaces by use of an asbestos vacuum cleaner. Building Refurbishment or Demolition (Section 7.6, page 17) An ACM survey must first be undertaken by a competent person before the demolition or part-demolition of a pre1990 building or structure, and a report prepared; The ACM survey report must be provided (by the premises owner) to Local Government or any entity which is to undertake or approve that demolition or partial demolition; Any demolition or partial demolition of a building or structure in which ACM has been identified, or if its presence cannot be discounted, must be subject to an ACM asbestos removal control plan developed for the particular activity and site; and After the demolition of any pre-1990 building, the debris must be inspected by the demolition contractor for presence of ACM and any suspect material properly collected and disposed of. 1. PURPOSE The objective of the Code of Practice (Code) is to prevent the public from developing asbestos-related diseases. This Code provides information on legal requirements and practical guidance for managing asbestos-containing materials (ACM) in the public domain, and is to be used in support of the Health (Asbestos) Regulations 2015 (HAR), which are administered by the Department of Health (WA Health). The Code is intended to be used by a range of users. Users include: members of the public who may be involved in asbestos-related activities; Local Government Environmental Health Officers who will be enforcing the Code and the 5 HAR; and licensed asbestos removalists or other workers who may be disturbing ACM in residential or other buildings, or situations where asbestos-related work may affect the public. 2. APPLICATION OF THIS CODE This Code applies to any person undertaking asbestos-related work (ARW), but particularly in the public domain. It relates to all aspects of ACM, including prohibited activities as well permitted ones subject to proper management, ranging from minor ACM activities, such as repair and maintenance, to larger scale ACM removal work. In this Code, managing ACM in the public domain means preventing situations in which ACM may pose a risk to the public by direct disturbance, degradation, or an emergency situation, for instance a building affected by fire or storm. The ‘public domain’ is taken to include people who are not participating in a workplace activity at the time of a potential exposure, such as workers during out-of-hours accommodation on a mining site. Although workplace situations (which can include a home), are not excluded from the scope of the HAR and Code, the expectation is that such situations will be best dealt with by WorkSafe (and in certain situations the Department of Mines and Petroleum) under OSH legislation. WorkSafe remains the primary regulatory agency for asbestos management in workplaces. A ‘workplace’ includes any situation where a person or people are engaged for a reward or payment to remove ACM or carry out ARW. However, if a workplace is the source of a potential ACM risk to the public, this Code and the HAR may be applied, sometimes in conjunction with WorkSafe’s regulatory controls. To facilitate this process a Memorandum of Understanding on ACM regulatory operational matters was signed between WorkSafe and WA Health on xxxx 2015. Risk to the public includes potential future risk as a result of reasonable management measures not being taken, such as by not removing piles of dumped asbestos cement sheets or remediating asbestos cement sheet fragments which are mixed into the soil. The Code draws upon and references where necessary, the following documents which are applied under OSH legislation: Code of Practice – How to Safely Remove Asbestos – 2011 – Safe Work Australia Code of Practice – How to Manage and Control Asbestos in the Workplace – 2011 – Safe Work Australia This Code is supplemented with a number of Guidance Notes designed to provide practical advice on particular ARW activities, many referenced in the Code. The latest set of supporting Guidance Notes is at: http://www.public.health.wa.gov.au/3/1143/2/asbestos_in_the_home.pm 3. DEFINITIONS OF KEY TERMS Asbestos means the asbestiform variety of any mineral silicate belonging to the serpentine or amphibole group of rockforming minerals that include the following: (a) actinolite; (b) grunerite or amosite (known as brown asbestos); 6 (c) anthophyllite; (d) chrysotile (known as white asbestos); (e) crocidolite (known as blue asbestos); (f) tremolite asbestos; or (g) any mixture containing one or more of the mineral silicates referred to in paragraph (a) to (f); Asbestos-containing material (ACM) means any material, thing, that, as part of its design, contains asbestos. Asbestos-related work means work involving asbestos or ACM, including asbestos removals, permitted under the HAR; Authorized Person means an environmental health officer or a person authorized under regulation X of the Health (Asbestos) Regulations 2015; Competent person (2011 Code) means a person who has acquired through training, qualification or experience, the knowledge and skills to carry out the task; Friable asbestos-containing material means any ACM which when dry(a) is in a crumbled, pulverised or powder form; or (b) can be crumbled, pulverised or reduced to powder by hand pressure; Licence means an unrestricted or restricted asbestos licence; Non-friable asbestos-containing material means ACM that is not friable asbestos and includes material containing asbestos fibres reinforced with a bonding compound; OSH 1984 means the Occupational Safety and Health Act 1984; OSH 1996 means the Occupational Safety and Health Regulations 1996; Reasonable belief means a belief that a material is ACM, based on the experience of the Authorized Person and having regard to the age, appearance, purpose and location of the suspect material; Restricted licence means a restricted asbestos licence granted under regulation 5.45B of OSH 1996; Unrestricted licence means an unrestricted asbestos licence granted under regulation 5.45A of OSH 1996; WHS means Work Health and Safety; Workplace means a place where work is carried out for a business or undertaking and includes any place where a worker goes, or is likely to be, while at work. Note that if a paid worker is doing the work (including work at a residence), the location of the work is, at that time, a workplace. 7 4. ASBESTOS HEALTH RISK The primary risk from asbestos is the inhalation of tiny fibres (respirable) that can penetrate deep into the lungs and trigger asbestos disease processes including asbestosis, lung cancer and mesothelioma. Although there is no known safe level of exposure to these respirable fibres, the likelihood of disease is very low at background exposure levels, and increases with the duration and level of exposure. Other determinants of risk include the type of asbestos, normally considered to increase in the following sequence: chrysotile (white) < amosite (brown) < crocidolite (blue), although all types of asbestos are dangerous. Mesothelioma is the most sensitive and serious result of asbestos exposure and its prevention is often the basis for asbestos management programs in general. Some high risk activities (such as angle grinding asbestos) can release high numbers of fibres over a short time. It is possible to have a short term but high level exposure. There is evidence that renovators of asbestos-containing homes have an increasing incidence of mesothelioma. However, the majority of cases of asbestos-related disease occur from repeated exposures in occupational situations. In any case, it is very important to keep the release of and public exposure to respirable asbestos fibres as low as possible, with a view to achieving environmental background levels. In doing so, it is important to achieve at least worker levels of protection, and preferably substantially better. This is because among other adverse risk factors, the public may have longer periods of exposure, such as if asbestos contaminates their backyard, and are less likely to have any control over or awareness of such exposures. 5. PROHIBITED ACTIVITIES Most significant activities associated with ACM are either prohibited, or strictly controlled. The main exception is the use of ACM in structures and equipment that were installed prior to the 2003 national ban on the import and use of asbestos. The main prohibitions relating to public health are outlined in the HAR, in particular, Regulations Y and Z. The Code is primarily concerned with permitted activities and how they need to be undertaken. A summary of the main prohibitions (and exceptions to them), are as follows; Sale or supply of ACM, except for the purpose of correct disposal; Disturbing or removing of ACM except as permitted activities under Section 7; Disposal of ACM except as outlined at Section 7.4; The moving of ACM premises or structures except as provided for at Section 7.3; Re-use of ACM except as provided for under Section 7.3.2 Use of high pressure water or air to clean ACM; and Any unsafe work practices that cause the release of airborne asbestos fibres. 6. PERMITTED ACTIVITIES Permitted activities involving ACM are mainly to achieve the safe management of ACM. They are deemed “asbestosrelated work” (ARW) when conducted in accordance with the HAR and this Code. Permitted activities include the following: 8 ACM identification and assessment (Section 7.1); Maintenance and repair of ACM in situ (Section 7.2); Temporary removal (then reinstatement) of limited amounts of ACM by a person who is not a worker (Section 7.3.2); Removal of up to and including 10m2 of non-friable ACM (not subject to licensed removal) when notified to the Local Government Authorized Person (Section 7.3.3); Removal of >10m2 of non-friable ACM by a person who holds an asbestos removal license issued by WorkSafe (or has been engaged by such a person), or in the case of a non-workplace situation a person who has been granted an exemption by the Local Government Authorized Person (Section 7.3.4); Removal of any amount of friable ACM carried out only by a person who holds an unrestricted asbestos license issued by WorkSafe (or has been engaged by such a person) (Section 7.3.5); Transport of ACM for the purposes of disposal (Section 7.4); Disposal of ACM (Section 7.4); and ACM activities associated with research, education or management that have been approved by the WorkSafe Commissioner (for workplaces) or the CEO of the Department of Health (for non-workplaces). 7. ASBESTOS-RELATED WORK Any person who carries out ARW is legally required to take all reasonable measures to prevent or minimise the release of airborne asbestos fibres. In many cases ACM in residential situations, which most commonly is asbestos cement, will not require any active management other than avoiding disturbance. This will be particularly the case with painted ACM house walls and eaves as they will be subject to very little natural deterioration with time. ACM fences and especially roofs are more likely to become weathered and damaged and so pose a greater potential risk. The following Sections outline ARW and its requirements which may apply to ACM in the home or in other specific situations such as contaminated soil, building demolitions, and natural disasters. 7.1 ACM Identification and Assessment Initial identification and assessment of suspected or known ACM may be necessary for a number of reasons including planning for maintenance or removal, or checking for soil or aggregate contamination. Identification of asbestos in a product can be difficult even for an asbestos professional and normally needs laboratory analysis to be certain. The recommended sampling procedure for the purposes of laboratory analysis is outlined in Appendix A. If a suspect material is part of a pre-1990 structure and is a product that commonly used asbestos, such as flat or corrugated cement sheeting, then it should be treated as ACM unless testing has confirmed otherwise. 9 Any suspected or known ACM should be monitored in regard to its condition and circumstances to ensure that deterioration and/or disturbance will not cause the release of respirable asbestos fibres. ACM in poor condition may pose a risk to occupants of a property and sometimes to neighbours or visitors. When ACM is in a poor condition a Department of Health or Local Government Authorized Person may require action to be taken by the owner or responsible person to manage the risk it presents. In general, if ACM is non-friable and in good condition then it would be deemed a negligible risk unless subject to significant physical damage or disturbance. This also applies to asbestos cement fragments. Non-bonded or friable ACM may pose a higher risk, depending on the circumstances. As ACM has been used so extensively in buildings and structures, it often occurs as contamination of soil as a result of dumping or poor demolition practices, and sometimes in recycled material. The nature and level of contamination then needs to be assessed for management purposes. More guidance on this issue is provided in section 7.5. More detailed information on the issue is provided in the Guidance Note on the Identification and Assessment of Asbestos-Containing Material. 7.2 ACM Maintenance and Repair in situ This section refers to ‘minor works’ associated with maintenance or repair of ACM (in situ) without any removal occurring. Maintenance can include cleaning, painting, repair (sealing of cracks), as well as scraping, sanding and drilling if done correctly. Such work should only apply to asbestos cement sheeting or other non-friable products and must be carried out in a manner that does not cause the release of airborne asbestos fibres. As indicated in Section 7.1, an Authorized Person may direct that maintenance, repair or even removal for disposal must take place. Cleaning and painting can prolong the life of an ACM product and make it less likely to release respirable asbestos fibres. Appendix B provides guidance on cleaning, painting and sealing ACM safely. Where there is minor incidental damage to asbestos cement sheeting (cracks, holes) and it is not practical to replace the whole sheet or panel with non-asbestos material, broken edges can be sealed with paint or PVA glue or the area covered over with a non-ACM product. Where possible it is preferable to replace the damaged material or structure with a nonACM alternative or the opportunity be taken to replace the whole ACM structure. Any heavily weathered or friable ACM that needs maintenance should be removed, and this must be by a licensed asbestos removalist. In some cases, enclosure and signage of potential friable material may be appropriate as a shortterm measure pending removal (e.g. following an ACM building fire). Old asbestos cement roofs in particular may be become brittle and prone to release respirable asbestos fibres into the drainage system and at low levels into the air. If such roofs are in a poor condition they should be replaced rather than repaired. Safe procedures should be used when cleaning the gutters of ACM roofs due to the potential for fine fibres in the gutter debris. Appendix C provides guidance on gutter cleaning. The use of high pressure water or air for cleaning ACM is prohibited because it can release large quantities of asbestos fibres, especially from old roofs, and the resulting asbestos contamination can also spread onto adjacent properties. 10 More detailed information on management of ACM in situ is contained in the Guidance Note on the Maintenance and Repair of Asbestos-Containing Materials. 7.3 ACM Removal Unsafe removal of ACM may release high levels of respirable asbestos fibres, presenting a health risk. This Section outlines the general requirements of the removal process and then provides more detailed guidance for specific scenarios. The aim is to have asbestos removalists undertake most of the work, especially for higher risk tasks. The accompanying ACM Removal Decision Tree graphic indicates which scenario may apply. Appendix D also provides examples of how some of the more common removal tasks can be undertaken and additional detailed guidance is provided in the Guidance Note on the Removal of Asbestos-Containing Materials. The removal of a building or structure containing ACM is prohibited unless intended for proper disposal or unless approved by the CEO of the Department of Health in exceptional circumstances, such as relocating a historical home. ACM REMOVAL DECISION TREE PROPOSED ACM REMOVAL Not Sure IS ACM FRIABLE No Yes IS ACM AMOUNT >10 M2? No Yes LICENSED REMOVALIST RECOMMENDED. WILL YOU USE ONE? No REMOVAL NOTIFICATION TO LG REQUIRED FOR DIY WORK Yes GET EXPERT ADVICE OR ASSUME FRIABLE – SEE 7.1 REMOVALIST WITH UNRESTRICTED LICENSE REQUIRED REMOVALIST WITH AT LEAST RESTRICTED LICENSE REQUIRED UNLESS DIY EXEMPTION APPROVED Possibly apply for Exemption LOCAL GOVERNMENT Notification LOCAL GOVERNMENT REMOVAL UNDERTAKEN 11 For protection of the public and consistency with WorkSafe and national OSH legislation, the HAR require the removal of more than 10m2 of non-friable ACM to be undertaken by an asbestos removalist who holds a restricted or unrestricted license with WorkSafe. The requirement for licensed asbestos removal >10m2 is based on the total area of the asbestos removal job, regardless of the pattern of work. It is further required that any amount of friable ACM removal must be undertaken by an asbestos removalist who holds an unrestricted license with WorkSafe. If friability is uncertain, such as due to its unfamiliar form or poor condition, then the ACM should be treated as friable. Any ACM removed whether temporarily or with a view to disposal should be only be stored on site for up to 14 days, and that material must be properly packaged, labelled and protected from damage. 7.3.1 General Control Measures for ACM Removal Any asbestos removal is subject to a range of mandatory general control measures as well as activity specific management procedures. The main general controls, applying to removal of any quantity of ACM, are as follows; Isolating the work area with barriers and warning signage suited to the job. The larger the removal or greater the potential for fibre release, the more robust these control measures will need to be. There also may be some urgency for action in some situations, such as fire damaged buildings. Appendix E provides examples of warning signs and labels. Work should normally not occur while there are non involved people in the vicinity; Using principally wet methods to eliminate or minimise the generation of asbestos fibres. This must be regular application of a fine water spray (possibly with a wetting agent) to the whole area being removed. An acceptable alternative would be to spray with PVA solution. Care should be taken to avoid wetting any electrical wires or equipment; Using appropriate tools and equipment. These can include asbestos vacuum cleaners (never use domestic vacuum cleaners), manually operated hand tools, and other tools designed to capture or suppress respirable dust. Prohibited are: high speed abrasive power tools, brooms and brushes (except for paint/sealer application) and high pressure water or air cleaners. Using personal protective equipment (PPE). PPE must be used by all people entering the asbestos removal area. PPE includes coveralls, gloves and safety footwear, and respiratory protective equipment (RPE). The RPE must at least be a properly fitted dust mask or half face respirator with a P1 or P2 filter rating. Coveralls should be disposable and footwear should be easy to clean (eg laceless boots). PPE selection and procedures will depend on the scale and risk of the removal task. Further information is available from AS/NZS 1716-2003 Respiratory Protective Devices and AS/NZ 1715-1994 Selection, Use and Maintenance of Respiratory Protective Devices (or as updated); Figure 1: Disposable, half-face particulate respirator. Figure 2: Re-usable half-face, particulate filter (cartridge) respirator. 12 Decontaminating the area, involved personnel, PPE and equipment. During the work potentially contaminated tools and PPE should be left in the isolated area so as not to contaminate other areas. A person leaving the area should wipe or vacuum the PPE before removing, leaving the RPE removal to last. If the PPE is to be reused it should be protected from further contamination while in the work area by covering. Personal hygiene and careful washing are essential, with an emphasis on hands, fingernails, face and head. At the end of the job, tools and PPE should be vacuumed or wet wiped or disposed of with the asbestos waste. The work area should be cleaned by vacuuming or wet wiping. Only industrial asbestos vacuum cleaners should be used. Containing and disposing of waste. All ACM waste must be wetted down and double bagged or wrapped in two layers of at 200µm thick plastic. Alternatively, ACM waste may be placed in a sealed container such as a drum. It must be labeled as asbestos waste using labels such as those in Appendix E. It must also be removed from the work site as soon as practical, but within 14 days. During any storage period prior to disposal, the waste ACM must be protected from damage. For transport and disposal see section 7.4. The exact nature of and degree to which general and specific control measures will apply will depend on the circumstances of the removal. This is outlined in greater detail in subsequent specific removal scenarios. 7.3.2 Temporary Removal and Reinstatement of Non-friable ACM Non-friable ACM may be removed temporarily and then reinstated under certain conditions, except in workplaces. The purpose of temporary removal is often to provide essential access to utilities such as plumbing or rear property access through an ACM cement fence. The use in another place of temporarily removed non-friable ACM is prohibited. If such a removal is warranted, then it is recommended that the opportunity be taken to have at least that component and preferably the whole of the ACM structure, removed and disposed of in a proper manner, especially if it is has significant damage or deterioration. Any removed ACM which is greater than 6 m2 must not be reinstated and must be properly contained for transport and disposed of at a suitable facility. Any person undertaking temporary ACM removal must do this in a safe manner and in accordance with this Code and any associated task specific guidance material. For some temporary removals the full range and degree of Code requirements may not always need to apply in low risk situations, such as a short-term removal of 0.5 m2 ACM cement panel to aid access to electricity cables. Here, double bagging of the ACM and erecting warning signage would not be necessary. OSH legislation does not permit reinstatement of removed ACM in workplaces. If a paid worker is doing the work (including at a residence), the location of the work is, at that time, a workplace. 7.3.3 Removal of 10 m2 or less of Non-friable ACM Personal removal of 10 m2 or less of non-friable ACM for disposal by members of the public is permitted, but is still subject to a number of controls. These controls include: The proposed removal for disposal must be notified in writing (letter or email) to the Local Government Authorized Person; and The removal must be undertaken in accordance with the requirements of this Code. The purpose of the notification is for the Local Government Authorized Person to provide advice and relevant guidance material and on a random basis check the cleanliness of the site after the removal. 13 7.3.4 Removal of more than 10 m2 of non-friable ACM Removal of more than 10 m2 of non-friable ACM must be undertaken by an asbestos removalist with at least a restricted license, unless the work is done by a member of the public (not a worker) and the homeowner has an exemption from the Local Government Authorized Person. In approving an exemption request and issuing an exemption certificate the Authorized Person will need to be satisfied If desired, an exemption must be applied for and approved by the corresponding Local Government Authorized that: Person using the ACM Removal Exemption Form. The work will not be done by paid workers; The nature of the work can be managed by non-licensed persons; and The work will be undertaken in accordance with this Code. The Authorized Person may also impose conditions associated with the exemption, including variation of the requirements which would apply (see box below) if a licensed asbestos removalist was undertaking the task. The main risk factors to be considered for an exemption to be granted include: the low risk nature of the activity in terms of situation and quantity of ACM, the competency and/or knowledge of the person undertaking the work; the remoteness of the location where the work is being undertaken; and access to licensed removalists. Competency may partially be demonstrated by proof of completion of the Cancer Council/DOH eLearning course on renovation and asbestos at: xxxx In most cases the work will be undertaken by a licensed asbestos removalist as required by the HAR and this Code. This work will need to be undertaken in accordance with WA OSH legislation and with any additional requirements of the Code. If the work requirements of the OSH legislation are met, this will at the same time to a large extent satisfy the requirements of this Code. OSH legislative requirements for asbestos removal include: Asbestos removalist supervisor is present or readily available; Asbestos removal workers are trained appropriately and training records are kept; Removalist to notify relevant parties of the removal, including the commencement date. These parties include the person commissioning the work, the owner and occupiers of the premises, and immediate neighbours; Removalist prepares an asbestos removal control plan which outlines how the work will be safely managed. In preparing the control plan the licensed removalist should consult with the employer, the owner and occupier (if not the same person). A copy of the plan must be given to the person who commissioned the work, be accessible on site to the occupiers, and be available for inspection by WorkSafe. Appendix F includes key elements that should be included in an asbestos removal control plan; Removalist ensures the site is visually clear of ACM at the end of the job, in the case of non-friable removal. For friable removal, a formal independent clearance (visual inspection and air monitoring) is conducted and a clearance certificate issued when results are satisfactory. Air monitoring is conducted, where appropriate. Air monitoring for asbestos fibre is required during removal of friable ACM. However, air monitoring can be undertaken on other occasions where appropriate, such as sites where there is potential for public exposure. Any monitoring should be conducted in accordance with the Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres 2nd Edition [NOHSC: 3003 (2005)]. For public or domestic exposure the threshold level for management action is 0.01 fibre per ml of air. 14 The Removalist also has mandatory duties in regard to: displaying warning signs in and limiting access to the asbestos work area; supplying PPE; ensuring appropriate decontamination facilities are in place; and ensuring waste containment and disposal procedures are in place. Guidance on these measures is available above under General Control Measures. Detailed guidance in regard to all these duties is contained in Section 3 of the Code of Practice – How to Safely Remove Asbestos – 2011 – Safe Work Australia. 7.3.5 Removal of friable ACM Friable ACM is uncommon in the domestic built environment in WA. However, some old vinyl flooring may have a soft, friable asbestos backing; and after a severe fire asbestos cement material may become friable. The removal of friable ACM is only permitted by an asbestos removalist with an unrestricted license issued by WorkSafe. Such work must be undertaken in accordance with OSH legislation. Detailed guidance in regard to this type of removal is contained in the Code of Practice – How to Safely Remove Asbestos – 2011 – Safe Work Australia. 7.3.6 Other Worker Removals In accordance with OSH legislation, a worker (including a self-employed person conducting a business) without an asbestos removal license can undertake a removal of 10m2 or less of non-friable ACM. This allows a person (for example, a plumber) to remove small amounts of non-friable asbestos and replace it with nonasbestos alternatives if they come across it during renovations, refurbishments, or service and maintenance work. However, this person must be trained and use safe work methods to ensure the work does not create a risk to the health and safety of people at the workplace. Under OSH legislation the duties of these workers also include applying the general control measures listed under 7.3.1 above. 7.4 ACM Transport and Disposal In addition to the guidance in section 7.3.1, any disposal of ACM must be in accordance with Division 6, Regulations 42 to 47 of the Environment Protection (Controlled Waste) Regulations 2004 (CWR). The legislation is administered by the Department of Environment Regulation (DER) and includes the following provisions: It is an offence to dispose of ACM except as provided for in the CWR; ACM must be separated from non-asbestos material, double wrapped and labeled in accordance with the CWR; The person (disposer) who takes ACM to an approved ACM disposal facility must notify the operator that the load contains ACM; The disposer must keep the asbestos disposal receipts from the facility; and The operator of an approved ACM disposal facility must dispose of the ACM in accordance with the CWR 2004. This Code also requires the disposer to retain the disposal receipts for one year and to make them available to an Authorized Officer if requested t o do so. 15 The Department of Health (DOH) and DER make provision for the disposal of ACM contaminated soil in containment cells under the Contaminated Sites Act 2003 if suitably constructed and managed. DOH should be contacted in this regard. 7.5 Soil and Built Environment ACM Contamination ACM is a frequent contaminant of soil and sometimes of other fill material such as aggregate. This may be the result of improper ACM removal or building demolition involving ACM, illegal dumping, ACM breakage or weathering, historic contamination and use of ACM contaminated fill. Some of these contaminating activities may also impact the built environment as well. The most common problem is ACM as asbestos cement fragments sitting on the surface and sometimes intermixed with soil. Any sort of ACM soil or built environment contamination needs to be assessed and remediated because of the possibility over time of the ACM degrading or further damaged so that it releases respirable asbestos fibres. If the contamination is the result of inadvertent or negligent damage from an asbestos removal or building demolition involving ACM, then it should managed at that time in suitable manner as part of the clean up process. In these situations OSH legislation should apply, and also this Code in the case of a public place or residential area. The relevant OHS legislation is the Code of Practice – How to Safely Remove Asbestos – 2011 – Safe Work Australia, which requires asbestos removal areas at workplaces to be left visually clear of ACM. Soil contamination must be managed as follows: The area of contamination must be clearly delineated, taking a cautionary approach in situations of uncertainty i.e. expanded boundary; Visible ACM should be removed by handpicking and properly contained and disposed of, while taking note of the locations of greatest concentration; and If the contamination may include asbestos-contaminated dust it should be removed from hard surfaces by wet wiping and from soft or natural surfaces by use of an asbestos vacuum cleaner. In some cases of soil contamination such as if it has penetrated below the surface or become buried as a result of a soil disturbing demolition then a surface soil skim may be necessary or a professional assessment and management of the contamination as is outlined below. If the contamination is historical or from other causes such as breakage of dumped ACM then this Code is likely to be the main regulatory guidance. Detailed advice is provided in the following documents: Guidance Note on the Management of Small-Scale, Low-Risk Soil Contamination – May 2009 ; and Guidance Note on the Identification, Assessment and Management of Asbestos Contamination in Regional Public Parks – May 2011. 16 In cases of complicated, large scale and/or subsurface ACM contamination, then environmental consultants may need to be involved and manage the site in accordance with the Contaminated Sites Act 2003 (administered by DER) and the Department of Health Guidelines for the Assessment, Remediation and Management of Asbestos-Contaminated Sites in Western Australia – May 2009. Certain ACM contamination situations require more specialized guidance because of the greater potential presence of respirable asbestos fibre, they cross regulatory boundaries, and they are atypical. These situations include ACM contamination as a result of a fire, mining activities, and high pressure cleaner use. The corresponding guidance is listed below: Guidance Note on the Management of Fire Damaged Asbestos – October 2014; Guidance Note on Public Health Risk Management of Asbestiform Minerals associated with Mining – July 2013; and Guidance Note - Managing Contamination from Pressure Cleaning of Asbestos Cement Roofs– March 2010. For any types and causes of ACM contamination of soil or built environment, it is important that when it is discovered that measures be implemented immediately to prevent further spread and damage and the potential for people to be exposed to respirable asbestos fibres. These measures are detailed in the above publications and include actions such as wetting or covering the material and erecting barriers and warning signs. An Authorized Person may direct that certain actions be taken to prevent exposure to airborne fibres. 7.6 Building Refurbishment or Demolition When any type of building is to be or substantially renovated or demolished it should be first investigated for the presence of hazardous materials, including asbestos for pre-1990 buildings or structures. If ACM is not looked for or is inadvertently missed then the subsequent demolition can break it up and distribute it. This can pose a risk to workers and nearby public at the time and result in contamination of the site and the debris which may be destined for recycling. For any proposed demolition or part-demolition of a pre-1990 building or structure, a survey must first be undertaken by a competent person to determine the presence of ACM and the findings be presented in a report. This is supported by the OSH regulations. The ACM survey report must be provided (by the premises owner) to Local Government or any entity which is to undertake or approve that demolition or partial demolition and that entity should not undertake or authorize the work until such a report is provided. Any demolition or partial demolition of a building or structure in which ACM has been identified or if its presence cannot be discounted, must be subject to an ACM management plan developed for the particular activity, including details of the ACM removal. An asbestos management plan is to be provided on request, to the Local Government Authorized Person with a copy kept on site at all times during the demolition. After the demolition of any pre-1990 building, the debris must be inspected by the demolition contractor for presence of ACM and any suspect material properly collected and disposed of. 17 This should occur before the building waste is taken off site so that if it is contaminated it can be disposed of properly and not end up in a recycling facility. To help prevent the contamination of recycled material DER has published the Guidelines for Managing Asbestos and Construction and Demolition Waste Recycle Facilities – 2013. After the demolition debris has been removed there should be another walkover looking for signs of ACM contamination of the site. If such contamination is identified it should be managed as indicated under Section 7.5, and the building debris which has already been removed be sent for proper disposal. 7.7 Natural Disaster ACM Contamination Asbestos contamination as a result of natural disasters creates special management issues because they can be large scale and associated with traumatized and displaced populations as well as degraded capacity to respond on asbestos and on the disruption in general. The Guidance Note on the Management of Fire Damaged Asbestos – October 2014 provides information on how to manage asbestos associated with large scale fires, such as major bushfires, and also some guidance on other natural disaster situations. In these situations there is a great need to have good communication and consultation arrangements with the affected public and to be flexible and creative in managing any ACM problem. In emergency situations the CEO of the DOH may provide power to LG Authorized Persons to vary the requirements of this Code as indicated under Section 8. Ideally the asbestos and other public health issues should be handled in a consistent and coordinated way to adequate standards suited to the circumstances. The involvement of the Western Australian Natural Disaster Relief and Recovery Arrangements can greatly facilitate proper management. 7.8 ACM in Remote Areas ACM in remote locations can create different management challenges due to the lack of resources to manage ACM problems, such as asbestos professionals, specialist equipment and disposal facilities. In such situations, the Local Government Authorized Person may wish to be to take more responsibility in supervising asbestos management activities and adopt a more situation specific and flexible response in this regard. Particularly for these areas, advice can be sought from the Department of Health to resolve problems in a practical manner. The Department of Health will continue to take account of and in some cases provide specific remote area guidance in its asbestos management publications. 8. ACTIONS OF AN AUTHORIZED PERSON An authorized Person under the HAR is empowered to enforce the HAR and its associated Code. Usually these officers are Environmental Health Officers of Local Governments or appropriately qualified and experience DOH officers. However other people can be authorized as the CEO of DOH sees fit. When dealing with ACM issues, an Authorized Person may not be certain at a particular time that ACM is definitely involved. If an ACM situation requires immediate or fast action and the Authorized Person has a reasonable belief that ACM is involved then the action should be directed to occur. For the purposes of this Code, a reasonable belief is a belief that a material is ACM based on the experience of the Authorized Person as well as the age, appearance, purpose and 18 location of the suspect material. Authorized Officers may issue a written or verbal direction if circumstances warrant an immediate management action. In parallel or subsequently to any direction given based on a reasonable belief, the identification of the suspect material should be determined by laboratory analysis and management arrangements be reviewed based on the outcome. The CEO of DOH has the power to authorize Local Governments to use means other than those specified in the HAR to deal with asbestos contamination in cases of emergencies and natural disasters. This might include: not having to individually separate and wrap ACM materials (after a natural disaster such as a bushfire), or establish a temporary disposal site if the existing sites cannot handle the volume of wastes. Instructions in regard to the application of the Code are provided in the Guidance Note on the Enforcement of the Health (Asbestos) Regulations. 9. PRINCIPAL LEGISLATION Health Act 1911 Public Health Bill 2015 Health (Asbestos) Regulations 2015 OSH Act and Regulations: Code of Practice – How to Safely Remove Asbestos – 2011 – Safe Work Australia Code of Practice – How to Manage and Control Asbestos in the Workplace – 2011 – Safe Work Australia Environment Protection (Controlled Waste) Regulations 2004 10. OTHER RELEVANT GUIDANCE Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres 2nd Edition [NOHSC: 3003 (2005)] DER Guidelines for Managing Asbestos and Construction and Demolition Waste Recycle Facilities – 2013. DOH Guidelines for the Assessment, Remediation and Management of Asbestos-Contaminated Sites in Western Australia – May 2009. 11. CONTACT INFORMATION More information on the Health (Asbestos) Regulations 2015 and associated Code of Practice and Guidance Notes is available from the Environmental Health Directorate – 08 93884999 or mailto:ehinfo@health.wa.gov.au and at: Website - http://www.public.health.wa.gov.au/3/1143/2/asbestos_and_public_health.pm For enquiries about asbestos at workplaces, contact WorkSafe on 1300 307 877 or www.commerce.wa.gov.au . 19 LIST OF ABBREVIATIONS ABBREVIATIONS FULL TEXT ACM Asbestos-containing material ARW Asbestos-related work Code (this) Code of Practice – Managing Public Health Risks from Asbestos CWR Environment Protection (Controlled Waste) Regulations 2004 HAR Health (Asbestos) Regulations 1992 OSH 1984 Occupational Safety and Health Act 1984 OSH 1996 Occupational Safety and Health Regulations 1996 20 Appendix A ASBESTOS SAMPLING PROCESS (Adapted from Appendix A, Code of Practice – How to Manage and Control Asbestos in the Workplace – 2011 – Safe Work Australia) The following steps should be taken to carry out sampling, preferably by a competent person: Step 1 – Preparation Make sure no one else is in the vicinity when sampling is done. Shut down any heating or cooling systems to minimize the spread of any released fibres. Turn off any fans if you’re inside. If outside, then sample on a non windy day. Do not disturb the material any more than is needed to take a small sample. Collect the equipment you will need for sampling, including: o pliers, resealable plastic bags, disposable coveralls, waterproof sealant, plastic drop sheet, water spray bottle o P2 respirator, rubber gloves. Step 2 – Taking the sample Wear disposable gloves. Put on respiratory protective equipment (RPE). Wear a pair of disposable coveralls. Lay down a plastic drop sheet to catch any loose material that may fall off while sampling. Wet the material using a fine mist of water containing a few drops of detergent before taking the sample. The water/detergent mist will reduce the release of asbestos fibres. Carefully cut a thumb nail piece from the entire depth of the material using the pliers. For fibre cement sheeting, take the sample from a corner edge or along an existing hole or crack. Place the small piece into the resealable plastic bag. Double bag the sample, include the date and location and an asbestos caution warning. Tightly seal the container after the sample is in it. Send the sample to a NATA-accredited laboratory. Step 3 – Cleaning up Use a damp paper towel or rag to clean up any material on the outside of the container or around the area sampled. Seal the edges with waterproof sealant where the sample was taken. Carefully wrap up the plastic drop sheet with tape and then put this into another plastic rubbish bag. Wipe down the tools and equipment with a dampened rag. Place disposable gloves and coveralls into a rubbish bag, along with the damp rag. Seal plastic bag. Wash hands. Keep RPE on until clean-up is completed. Follow a decontamination procedure (personal washing) upon completion of the task. Dispose of asbestos materials with reference to Section 7.4 above. 21 Appendix B From Appendix F, Code of Practice – How to Manage and Control Asbestos in the Workplace – 2011 – Safe Work Australia SAFE WORK PRACTICE 2 – SEALING, PAINTING, COATING AND CLEANING OF ASBESTOS-CEMENT PRODUCTS These tasks should only to be carried out on asbestos that are in good condition. For this reason, the ACM should be thoroughly inspected before starting the work. There is a risk to health if the surface of asbestos cement sheeting is disturbed (e.g. from hail storms and cyclones) or if it has deteriorated as a result of aggressive environmental factors such as pollution. If it is so weathered that its surface is cracked or broken, the asbestos cement matrix may be eroded, increasing the likelihood that asbestos fibres will be released. If treatment is considered essential, a method that does not disturb the matrix should be used. Under no circumstances should asbestos cement products be water blasted or dry sanded in preparation for painting, coating or sealing. Equipment that may be required prior to starting work (in addition to what is needed for the task) Disposable cleaning rags A bucket of water, or more as appropriate, and/or a misting spray bottle Sealant Spare PPE A suitable asbestos waste container Warning signs and/or barrier tape. PPE Protective clothing and RPE (see AS1715, AS 1716). It is likely that a class P1 or P2 half face respirator will be adequate for this task, provided the recommended safe work procedure is followed. Where paint is to be applied, appropriate respiratory protection to control the paint vapours/mist must also be considered. Preparing the asbestos work area If work is being carried out at heights, precautions must be taken to prevent falls. Before starting, assess the asbestos cement for damage. Ensure appropriately marked asbestos waste disposal bags are available. Carry out the work with as few people present as possible. Segregate the asbestos work area to ensure unauthorised personnel are restricted from entry (e.g. close door and/or use warning signs and/or barrier tape at all entry points). The distance for segregation should be determined by a risk assessment. If working at a height, segregate the area below. If possible, use plastic sheeting secured with duct tape to cover any floor surface within the asbestos work area which could become contaminated. This will help to contain any runoff from wet sanding methods. Ensure there is adequate lighting. If using a bucket of water, do not resoak used rags in the bucket, as this will contaminate the water. Instead, either fold the rag so a clean surface is exposed or use another rag. Never use high-pressure water cleaning methods. Never prepare surfaces using dry sanding methods. Where sanding is required, you should consider removing the asbestos and replacing it with a non-asbestos product. Wet sanding methods may be used to prepare the asbestos, provided precautions are taken to ensure all the runoff is captured and filtered, where possible. Wipe dusty surfaces with a damp cloth. When using a spray gun, never use a high-pressure spray to apply the paint. Painting and sealing 22 When using a roller, use it lightly to avoid abrasion or other damage. Use damp rags to clean the equipment. If required, use damp rags and/or an asbestos (HEPA) vacuum cleaner to clean the asbestos work area. Place debris, used rags, plastic sheeting and other waste in the asbestos waste bags/container. Wet wipe the external surfaces of the asbestos waste bags/container to remove any adhering dust before they are removed from the asbestos work area. Personal decontaminati on should be carried out in a designated area If disposable coveralls are worn, clean the coveralls while still wearing RPE using a HEPA vacuum, damp rag or fine-water spray. RPE can be cleaned with a wet rag or cloth. While still wearing RPE, remove coveralls, turning them inside-out to entrap any remaining contamination and then place them into a labelled asbestos waste bag. Clearance procedure Decontaminati ng the asbestos work area and equipment Remove RPE. If non-disposable, inspect it to ensure it is free from visible contamination, clean it with a wet rag and store in a clean container. If disposable, cleaning is not required but RPE should be placed in a labelled asbestos waste bag or waste container. Refer to the Code of Practice: How to Safely Remove Asbestos for more information. Visually inspect the asbestos work area to make sure it has been properly cleaned. Dispose of all waste as asbestos waste. Refer to the Safe Work Australia Code of Practice: How to Safely Remove Asbestos for more information. 23 Appendix C From Appendix F, Code of Practice – How to Manage and Control Asbestos in the Workplace – 2011 – Safe Work Australia SAFE WORK PRACTICE 3 – CLEANING LEAF LITTER FROM GUTTERS OF ASBESTOS CEMENT ROOFS Equipment that may be required prior to starting work (in addition to what is needed for the task) A bucket of water, or more as appropriate, and detergent A watering can or garden spray A hand trowel or scoop Disposable cleaning rags A suitable asbestos waste container Warning signs and/or barrier tape An asbestos vacuum cleaner. PPE Protective clothing and RPE (see AS1715, AS 1716). It is likely that a class P1 or P2 half face respirator will be adequate for this task, provided the recommended safe work procedure is followed. Preparing the asbestos work area Since the work is to be carried out at a height, appropriate precautions must be taken to prevent the risk of falls. Ensure appropriately marked asbestos waste disposal containers are available. Segregate the asbestos work area to ensure unauthorised personnel are restricted from entry (e.g. use warning signs and/or barrier tape at all entry points). The distance for segregation should be determined by a risk assessment. Segregate the area below. Avoid working in windy environments where asbestos fibres can be redistributed. If using a bucket of water, do not resoak used rags in the bucket as this will contaminate the water. Instead, either fold the rag so a clean surface is exposed or use another rag. Disconnect or re-route the downpipes to prevent any entry of contaminated water into the waste water system and ensure there is a suitable container to collect contaminated runoff. Contaminated water must be disposed of as asbestos waste. Mix the water and detergent. Using the watering can or garden spray, pour the water and detergent mixture into the gutter but avoid over-wetting as this will create a slurry. Remove the debris using a scoop or trowel. Do not allow debris or slurry to enter the water system. Wet the debris again if dry material is uncovered. Place the removed debris straight into the asbestos waste container. Use damp rags to wipe down all equipment used. Use damp rags to wipe down the guttering. Where practicable, and if necessary, use an asbestos vacuum cleaner to vacuum the area below. Place debris, used rags and other waste in the asbestos waste container. Wet wipe the external surfaces of the asbestos waste container to remove any adhering dust before it is removed from the asbestos work area. Gutter cleaning Decontaminatin g the asbestos work area and equipment 24 Personal decontaminatio n should be carried out in a designated area If disposable coveralls are worn, clean the coveralls while still wearing RPE using a HEPA vacuum, damp rag or fine-water spray. RPE can be cleaned with a wet rag or cloth. While still wearing RPE, remove coveralls, turning them inside-out to entrap any remaining contamination and then place them into a labelled asbestos waste bag. Clearance procedure Visually inspect the asbestos work area to make sure it has been properly cleaned. Clearance air monitoring is not normally required for this task. Remove RPE. If non-disposable, inspect it to ensure it is free from contamination, clean it with a wet rag and store in a clean container. If disposable, cleaning is not required but RPE should be placed in a labelled asbestos waste bag or waste container. Refer to the Code of Practice: How to Safely Remove Asbestos for more information. Dispose of all waste as asbestos waste. Refer to the Code of Practice: How to Safely Remove Asbestos for more information. 25 Appendix D From Appendix D of the Code of Practice – How to Safely Remove Asbestos – 2011 – Safe Work Australia EXAMPLES OF ASBESTOS REMOVAL WORK This appendix does not address other hazards that may be present at a workplace, for example falls from heights or electrical hazards. These hazards must also be identified and the associated risks controlled. This appendix provides guidance on how to perform a specific task associated with asbestos removal work. With all tasks, some general requirements include the following: Obtain the asbestos register prior to commencing asbestos removal work. Depending on the type of asbestos removal work, follow the requirements outlined in Chapters 2–4 of this Code (original reference)(for example, laying plastic sheeting, isolating the work areas, signs and barricades, PPE, cleaning up site decontamination). Asbestos cement products Asbestos cement products consist of approximately 15 per cent asbestos fibres by weight. A wide range of products have been commonly found—including roofing, shingles, exterior cladding on industrial, public and some domestic premises, corrugated/profile sheets as well as flat sheets—that have been used for exterior flexible building boards. If possible, you should remove the asbestos cement products whole. If some sections have been damaged prior to removal, these may be strengthened by applying duct tape. Identify the method in which the asbestos cement product is held in place, then use a method that would minimise airborne dust generation in removing the product. For example: fasteners: dampen then carefully remove using a chisel bolts: dampen then use bolt cutters (or an oxy torch) – do not use an angle grinder screws: dampen then carefully unscrew with a screwdriver nails: dampen then carefully lever the panel or punch through if absolutely necessary. Avoid breaking the asbestos cement products. If breakage is absolutely necessary to remove/dislodge the product, dampen the material and minimise breakage. Remove the asbestos cement product wet/damp by applying a fine water spray, unless this creates an electrical risk. Once removed from its position, spray the back of the product with a fine water spray. Frequent application of a fine water spray may be required depending on the circumstances (for example, a very hot day) but be careful not to create a slip hazard. Personal decontamination must be carried out in accordance with the WHS Regulations and this Code. 26 Asbestos cement roof sheeting Asbestos cement can become brittle with age, so any removal work on roofs should address the risk of fall hazards. If lichen is encountered on roof sheeting, caution should be exercised in the use of water and the choice of workers’ footwear because lichen can be slippery, especially when it is wet. The removal of asbestos cement roofing must be performed in accordance with the WHS Regulations. Angle grinders should not be used because of the potential for damage to the asbestos cement and subsequent fibre release. Anchoring screws/bolts should be removed from the roofing sheets using an oxy torch or another suitable device that will not significantly damage the sheet. If the system of removal involves walking directly on the roof to remove roof sheeting (this should be the last option when choosing a method to remove roof sheeting), spray the asbestos cement roof sheeting with a PVA solution prior to removal. Ensure the PVA is dry before removing it so as to avoid a slip hazard. Once removed, spray the back (underside) of the asbestos cement with either a fine water spray or the PVA solution. Where the asbestos cement product requires lowering to the ground, ensure this is done in a manner that will minimise the generation of respirable dust. Do not use chutes, ramps or similar gravity dependent devices. Examples of appropriate lowering methods for roof sheeting include: by hand, over short distances loading the wrapped sheets on to a cradle for support using scissor lifts or similar devices using scaffolds. You should follow the cleaning, decontamination, waste removal and disposal procedures in this Code once the asbestos sheeting has been removed. Where the area to be removed is greater than the size of an average domestic house or where considerable dust will be generated, you should use a full decontamination unit. Ensure that clearance of the area has been completed and a clearance certificate has been issued prior to reoccupation of the area. Personal decontamination must be carried out in accordance with the WHS Regulations and this Code. Removal of floor tiles Flooring products such as Polyvinyl chloride (PVC or vinyl) tiles often contain a few per cent (5–7 per cent) of very fine chrysotile. Black and brown thermoplastic tiles containing larger amounts and often visible clumps of chrysotile were also produced. Sheet floor coverings were sometimes backed with a thin layer of chrysotile paper. Some underfelts, such as hessian underlays for carpets and linoleum, were also manufactured containing asbestos. The mastics which were used to bond the floor covering to the surface could also contain asbestos. Some hard-wearing composite floors (for example, magnesium oxychloride) also contain about 2 per cent of mineral fibres, which could be asbestos. 27 Place a tool (such as a scraper or wide blade) between the tiles and lift the tile away from the floor, being careful to minimise breakage. A hammer or mallet can be used to tap the tool under firmly-adhered tiles to assist separating the tiles from the floor. Minimise dust by spraying fine water mist under tiles as they are lifted. Place the tiles into a 200 µm plastic waste bag or suitable alternate waste container dedicated for asbestos waste that is clearly labelled with an appropriate warning sign indicating asbestos waste. Use the scraper to remove any adhesive that is left adhered to the floor after each tile has been removed and place this waste into the asbestos waste bag or suitable waste container. The vinyl can be cut into strips prior to its removal to facilitate bagging, or it can be rolled into one roll and wrapped securely with plastic, making sure it is totally sealed. If a heat source is used to soften the adhesive beneath a vinyl tile, care should be taken not to scorch or burn the tile. Burning or scorching vinyl tiles can result in the release of toxic decomposition products and generate a fire hazard. In some cases, the adhesive may contain asbestos. Follow the cleaning, decontamination, waste removal and disposal procedures once the tiles have been removed. Ensure that clearance of the area has been completed prior to reoccupation of the area. Personal decontamination must be carried out in accordance with the WHS Regulations and this Code. Removal of ceiling tiles False ceiling tiles or suspended ceilings sometimes need to be removed so maintenance work can be performed. If asbestos has been used on structural materials above a false ceiling there could be contamination on the upper surface of the tiles. The minimum RPE suitable for this operation is a P1 or P2 filter with a half-face piece respirator. If considerable amounts of asbestos dust or debris are likely to be involved, full-face air-purifying positive pressure respirators should be worn. Any surface below the tiles that might be contaminated should be covered with plastic sheeting. The first tile should be lifted carefully to minimise the disturbance of any asbestos fibres. The top of each tile should be thoroughly vacuumed and wet wiped, where possible, prior to removing subsequent tiles. Where non-asbestos ceiling tiles are to be reused, they should be covered with plastic as they are removed from the ceiling to prevent further dust settling on them. Wrap the asbestos ceiling tiles in a double layer of heavy-duty, 200 μm thick plastic sheeting. Waste containment, disposal and clearance must be carried out in accordance with the WHS Regulations and this Code. Personal decontamination must be carried out in accordance with the WHS Regulations and this Code. 28 Appendix E From Appendix B, Code of Practice – How to Manage and Control Asbestos in the Workplace – 2011 – Safe Work Australia 29 Appendix F From Appendix A of the Code of Practice – How to Safely Remove Asbestos – 2011 – Safe Work Australia 30 31 32 COMMENT FORM DRAFT CODE OF PRACTICE FOR PUBLIC HEALTH ASBESTOS MANAGEMENT INTRODUCTION This form provides a format for comments on issues that the Environmental Health Directorate considers important. However, the responder can also address other relevant matters, preferably of substance. Although major comments are encouraged here, tracked comments may be included in the body of the Code next to the related provision. All comments will be reviewed for action, but the feedback to contributors may be of a generalised nature. Identified contentious issues will be included in a planned Workshop depending on timing, and/or be subject to input from an Expert Advisory Group or issue specific consultation. GENERAL ISSUES Regulatory Approach Adequacy of the regulatory package consisting of HAR, Code, series of Guidance Note and EHO and public tools. Also value of integrating closely with WorkSafe in regard to operations and regulatory standards. Development Approach Adequacy of HAR package development process The desirability of introducing a regulatory package possibly before WorkSafe has promulgated its revised approach to asbestos management. Usability It is important the Code is accessible and usable, including through the use of additional guidance mentioned below. An important usability issue that has been flagged is for there to be better delineation of and access to the mandatory parts of the Code and guidance package. 33 Implementation Support Are a regulatory package, training & operational tools adequate to assist implementation and form should they take? Appendices Are these appropriate and sufficient? Additional Guidance Most parts of the Code will be supported eventually by issue specific Guidance with priority given to removals and enforcement guidance. Are the following additional ones adequate? ACM: identification; condition assessment; risk evaluation; maintenance; soil contamination; high pressure cleaning prohibition and management; and fire. Other issues Responder’s choice. 34 TECHNICAL REGULATORY ISSUES Regulation of <10m2 Removals See Explanatory text for this provision in the body of the Code – Section 7.3.3 page 13. In summary, for ACM removals of <10m2 which of the following is preferred: general regulatory arrangements e.g. education and reasonable measures, or specific regulatory provisions e.g. a notification system or a permit system? Demolition requirements Although the these requirements are consistent with the OSH Code 2011, are we being too ambitious in including them in our Code and HAR? Asbestos in Remote Situations Are current proposed HAR package components adequate to address rural needs: an exemption system for >10m2 ACM removal requirements and associated EHD support measures. See Explanatory text in the Code – Section 7.8 page 18. Other Responder’s choice. 35 OTHER COMMENT CONTACT DETAILS Name Position Email Land line/Mobile 36