9.1.1 Removal Work by HT Personnel.............................................................. 6
9.1.2 Removal of Asbestos by Licensed Contractor ......................................... 6
9.2.2 Air Monitoring to Determine Exposure Levels........................................ 7
Title: Asbestos Management Procedure Version: 3
Document Owner: OH&S Management Team
Approver: Mick Cuppari
Date Created: 09 December 2009
Date Approved: October 2011
Date Effective: 2011
Health, Safety & Environment - HSEP0924 – Asbestos management procedure
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Assessment
ASBESTOS MANAGEMENT FLOWCHART
Monitoring
Leased property
Owner to have management plan
No Action required
NO
Hydro owned
Asset?
YES
Risk Assess for
Asbestos by competent person
NO
Could material contain Asbestos?
YES
Asset Manager to
Action assessment and create/update
Asbestos Register
Condition
Assessment
3 yearly by competent person
Has condition deteriorated?
Condition
Assessment
Review Audits and
Register 6 yearly
- Asset Manager
- Building Manager
- OHS consultant
YES
YES
Asset Manager to
Build Job and budget in FMMS
Has condition deteriorated?
NO
Can high risk items be added to Capex for removal
Revision 3
Print Date: 12/04/2020
NO
NO
Update Register and close out
FMMS
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WORKING WITH ASBESTOS FLOWCHART
Working with
Asbestos
Competent person to do
JHA / ATW
Dispose using
ESMS
Guidelines
NO
Less than
10m
2
Competent person to supervise work
Is there a
SWI?
YES
Conduct Take
5 and follow
SWI
Dispose using
ESMS
Guidelines
Greater than
10m
2
Licenced removalist
Competent
Person to
Review SMP and issue
ATW
Dispose using
ESMS
Guidelines
Revision 3
Print Date: 12/04/2020
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The Tasmanian Workplace Health & Safety Regulations 1998, Division 9 sets out the specific legal obligations for the management of Asbestos in workplaces.
The broad legal obligations are to:
Ensure no person is exposed to Asbestos fibres above the national exposure standard;
Undertake a risk assessment of the potential exposure to airborne respirable Asbestos fibres;
Take all reasonably practicable steps to identify the presence of Asbestos containing materials
(asbestos);
Inform parties of the location of asbestos and precautions to minimise risk;
Prepare and maintain an Asbestos Register;
Regularly inspect the asbestos and record findings;
Make the register available and inform potentially affected parties;
Fix signs or labels to asbestos where regular maintenance of repair work is likely to be carried out;
Provide information, instruction and training to any person who may be exposed to airborne asbestos fibres; and
Ensure any asbestos removal work is undertaken in accordance with the Code of Practice for the Safe
Removal of Asbestos 2nd Edition [NOHSC: 2002(2005)].
The Tasmanian Workplace Health & Safety Regulations 1998 require hazards to be controlled as far as is reasonably practicable and the control hierarchy to be progressively applied. Hydro Tasmania will apply the control hierarchy to minimise employee, contractor and public risk from exposure to airborne respirable
Asbestos fibres.
This Asbestos procedure applies to all buildings, structures, plant and equipment owned by Hydro
Tasmania. It applies to employees, contractors and sub contractors of Hydro Tasmania, to occupants of
Hydro Tasmania buildings, and to external organisations that may come into contact with or disturb asbestos in Hydro Tasmania premises. This procedure will apply to Hydro Tasmania employees and its subcontractors undertaking work for external clients as a minimum where the Principal does not have existing procedures.
The procedure applies to all work during which an employee or contractor may be exposed to asbestos, the ongoing maintenance and control of asbestos as well as work undertaken to repair or remove asbestos.
Asbestos Registers have been prepared for all existing Hydro Tasmania assets and work sites containing asbestos including the type, locations and risk of all asbestos.
Where new assets are acquired or projects identify the risk of Asbestos, a survey shall be undertaken by competent personnel. The surveys shall include an assessment of the Asbestos condition, disturbance potential and risk rating.
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Hydro Tasmania’s Asbestos Register enables the business to show that it:
1.
Undertakes regular Asbestos condition inspections, as determined by a risk assessment but no greater than: o 3 years by a competent person; o 6 yearly by asset/building manager, OHS Consultant
2.
Effectively programs work activities for maintenance, repair or replacement of components and equipment containing asbestos;
3.
Prioritise and program removal of damaged asbestos; and
4.
Be in a position to advise employees and contractors of the presence of asbestos prior to maintenance, construction or demolition works commencing.
Controlled copies of the asbestos registers are to be available on the Hydro Tasmania intranet.
Asbestos Registers will be made available to all parties who could potentially be exposed to, disturb or come into contact with asbestos.
The Asbestos Registers shall contain the following information:
The date the inspection / identification was made and details of the competent person(s) who carried out the inspection / identification;
Type of asbestos-containing material (sheeting, insulation etc);
The location of the material or description of the plant/equipment;
The quantity / percentage of Asbestos present;
The asbestos condition;
Asbestos disturbance potential;
A risk assessment of the asbestos;
Details of any air monitoring conducted;
Recommended actions; and
Any maintenance or service work on asbestos, including details of the competent companies or personnel involved, the date and scope of the work undertaken, Asbestos removal control plans,
Workplace Standards Tasmania (WST) notification and copies of any clearance certificates.
Following the re-inspection, removal or maintenance activity of asbestos, the site Asbestos Register shall be updated with links to any associated documents (as above).
Risk assessments will be undertaken by competent personnel on all buildings and plant suspected of containing asbestos and will take into consideration:
Age of building or plant;
Old or existing reports;
Registers;
The type of asbestos;
The nature of the asbestos;
The asbestos condition (Friable or Non-Friable);
The asbestos disturbance potential; and
Personnel exposure.
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Where there is uncertainty about suspected asbestos containing material it will be validated by an industrial hygienist.
If asbestos is confirmed, control monitoring will be considered based on risk to ensure that exposure to airborne asbestos fibres is maintained below the Control Level of 0.1 fibres/ per mL and a risk assessment completed to determine if the asbestos will need to be removed.
Asbestos that is identified and is to remain in place, shall be added to the Hydro Tasmania Asbestos
Register and have an ongoing management plan in place to monitor its condition as per this procedure.
Non-Friable Asbestos
Over 97% of the products in Australia were non-friable material in which the Asbestos fibres were bonded by cement, vinyl, resin or other similar material.
If accidentally damaged or broken these asbestos products may release a few fibres initially but will not continue to do so…
Friable Asbestos
The hazardous friable asbestos is material which can be crumbled, pulverised, or reduced to powder by hand pressure. This may also include previously non-friable material which becomes broken or damaged by mechanical force.
As a general rule - If the Asbestos containing material can be easily disturbed and become air borne - by the effect of a breeze or simply creating a breeze by walking past it - it is in a friable state.
As Asbestos products were very versatile they could be easily moulded, shaped, cut drilled or painted.
There is no conclusive on-site testing for the presence of asbestos. Asbestos products can only conclusively be determined through laboratory testing following sampling.
As a general rule, if you think the material is asbestos - treat it as if it is asbestos until proven through laboratory testing.
All tasks involving the disturbance of asbestos shall only be conducted after an appropriate risk assessment and control procedure has been identified and implemented.
A competent person shall be available to supervise work during all activities involving asbestos.
Whenever maintenance or service work is carried out on asbestos the following shall be recorded in maintenance management system or project documentation and linked back to the Asbestos register if applicable.
The name of the competent person(s) who performed the work
The date the work was undertaken;
The scope of the work undertaken;
The job hazard analysis (JHA) for the work or standard work instruction (SWI) applied; and
Any clearance and disposal certificates.
During all engineering, maintenance and construction projects with the potential to disturb asbestos, the risk of exposure to airborne asbestos fibres shall be assessed by a competent person and included in the safety & environmental management plan (SEMP) and control strategies implemented.
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The potential for asbestos disturbance will be considered during the preparation stage of all maintenance, demolition and refurbishment work. Where it is identified that there is a risk of exposure, work activities and / or projects shall include asbestos notification and control procedures as a component of the permit to work, SEMP and/or Project Plan.
Removal is not always the best action. The decision to remove Asbestos Containing Material (ACM ) should be made on the basis of a risk assessment. The Code of Practice for the Management and Control of
Asbestos in Workplaces [NOHSC:2018 (2005)] provides guidance on when the removal of Asbestos
Containing Material is required or recommended.
Removal of asbestos can be carried out by Hydro Tasmania personnel only if:
The person has undertaken competency training or the job is being supervised by a person who has undertaken competency training
The asbestos to be removed is bonded non-friable material of less than 10 square metres (<10m2). in total;
Removal of asbestos samples for analysis or other testing
Work is carried out in accordance with a Standard Work Instruction or approved procedure.
A licensed asbestos removalist will be engaged to undertake any removal of asbestos over 10 square metres (>10m2), or any other work that the competent person believes should be undertaken by a licensed removalist. The friability of the asbestos will dictate the type of removal required. Asbestos removal will not commence unless written acknowledgement of the Asbestos Removal Start Work Notification (AR1) and Asbestos Removal Control Plan (AR2) has been received by Workplace Standards Tasmania. Whenever a licensed Asbestos removalist is engaged to undertake work on asbestos, a JHA shall be completed and approved by the Manager responsible for organising the work and in conjunction with a Safety, Quality and
Environment advisor. For all asbestos work a Hydro Tasmania “Waste Management Disposal/ recycling form” (EF1604) shall be completed and kept with the project documentation as well as sending a copy to a
Hydro Tasmania Environmental Advisor for Sustainability reporting. This form can be found in the Hydro
Tasmania Environmental and Sustainability Management System (ESMS).
A competent person (usually the Licensed Contractor or Industrial Hygienist), shall conduct a visual clearance inspection of the asbestos work area prior to the removal of the access restrictions. A Visual
Clearance Certificate (AR4) must be issued by this a competent person prior to the re-occupation of the area for normal use. Note: This should be done independently of the licensed asbestos removalist and, although this can be arranged by the removalist, this person should be employed directly by Hydro
Tasmania to avoid any conflict of interest in assessing the cleanliness of the site
For all asbestos removal projects appropriate project documentation must be retained and recorded with the project and maintenance files along with a reference to these files being updated in the Hydro
Tasmania Asbestos Register against the asset or area. A link to this register can be found in Hydrosafe!
Information and forms regarding asbestos removal requirements and licensing for asbestos removalists can be found on the Workplace Standards Tasmania web site along with Start Work Notification (AR1), Visual
Clearance Certificate (AR4) and Asbestos Removal Control Plan (AR2) and associated documentation and links to the national code of practice. www.wst.tas.gov.au/safety_comply/asbestos
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Workplace airborne respirable fibre monitoring will be conducted where the Asbestos Removal Control
Plan requires air clearance monitoring to be conducted. All air monitoring shall be conducted by an independent competent person in accordance with the Guidance Note on the Membrane Filter Method for
Estimating Airborne Asbestos Fibres [NOHSC: 3003 (2005)].
Where air clearance monitoring is required the independent competent person must issue an Air Clearance
Certificate. Air Clearance Certificate(s) must be issued and received prior to the removal of barriers, signs and the re-occupation of the area.
Adopted National Exposure Standards For Atmospheric Contaminants In The Occupational Environment
[NOHSC: 1003 (1995)]] has set the following exposure standards which state the maximum airborne asbestos fibre levels that workers can be exposed to:
Types of Asbestos
Crocidolite (blue asbestos)
Amosite (brown asbestos)
Chrysotile (white asbestos)
Other forms
Any mixtures of these or where the composition is unknown
TWA (Time-weighted Average
Values) fibres per mL of air
0.1
0.1
0.1
0.1
0.1
The exposure standards represent airborne concentrations which, according to current knowledge, should neither impair the health of nor cause undue discomfort to nearly all workers. However it should be noted that the exposure standards do not represent `no-effect' levels which guarantee protection to every worker. The above TWA exposure standards apply to long-term exposure to a substance over an eight-hour day, for a five-day working week.
Asbestos monitoring must be done by a qualified occupational hygienist and follow the procedures under the Membrane Filter Method for Estimating Airborne Asbestos Dust (NOHSC 1988). Testing for the number of asbestos fibres in a sample must be done by a laboratory accredited by the National Association of
Testing Authorities (NATA) for asbestos counting.
There are two types of sampling: Occupational Sampling and Environmental Sampling.
1.
Occupational sampling
A sample of air is collected from the worker's breathing zone and the numbers of fibres in a set volume of air are counted under a microscope to determine exposure levels. The results are compared against the current occupational exposure standard for airborne asbestos fibres
2.
Environmental sampling
Air sampling is done to assess the effectiveness of controls within the working area and outside the operations. These samples from the area measure background levels of asbestos and should be taken extensively during asbestos removal operations. An adequate number of samples must be
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Where it is found that workers have been exposed above the TWA of asbestos >0.1per mL, medical surveillance for the employees is required.
Where it is determined that an employee is exposed to airborne respirable Asbestos fibres, Hydro Tasmania may be required to implement a health surveillance program. Health surveillance will only be provided where the exposure assessment indicates that it is warranted.
Asbestos is listed in the Workplace Health & Safety Regulations 1998 Schedule 4, which provides guidance on specific hazardous substances that may require health surveillance.
Where health surveillance is conducted records will be kept for 72 years from date-of-birth and 30 years from the time the health surveillance, which ever is longer.
Asbestos must be removed from site and Hydro Tasmania will ensure that clean-up is properly completed and that there is no contamination of asbestos left at a site.
Asbestos must be disposed of in a manner that satisfies the requirements detailed in the Environmental
Management Pollution and Control Act 1994 (Controlled Waste Regulations).
Disposal can only be done after approval is given to dispose of asbestos at an approved site and or the disposal activity is contracted to an approved licensed waste disposal contractor.
Asbestos waste can be disposed at local council waste facilities if licensed. (Contact your local Council for information on approved dump sites in your area). As this is classed the same as all Hydro Tasmania waste it must be recorded for sustainability purposes. A Hydro Tasmania “Waste Management Disposal/ recycling form” (EF1604) must be filled out and kept with project documentation and a copy forwarded to an environmental advisor for record keeping. This form can be located in the Hydro Tasmania Environmental and Sustainability Management System (ESMS).
Appropriate Standard Work Instructions and Checklists including the use of personal protective equipment must be implemented wherever there is the potential to disturb asbestos.
Standard Work Instructions and Checklists complemented with Job Hazard Analyses (JHA) will be developed for all routine tasks involving work on asbestos. Instructions shall include disposal procedures.
Checklists at Hydro Tasmania are available for:
Asbestos- Gasket and packing removal “CL-11-01”
Asbestos- Sheeting removal less than 10 square metres. “CL-11-02”
Asbestos- Drilling into bonded material; “CL-11-03”
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Training will be delivered to employees and contractors who may be exposed to asbestos on Hydro
Tasmania work sites.
Hydro Tasmania has two Training levels for employees and contractors undertaking work with Asbestos less than 10m2 or that is exempt depending on the type of work eg: drilling of panel, gasket removal and removal of small non friable material.
1.
Supervised low risk work for employees (i.e. bonded Asbestos containing material – not friable asbestos).
Employee training course shall include the following points:
What is asbestos
Types of asbestos
Uses of asbestos in Australia & in Hydro locations
What are exposure risk factors
Asbestos related disease
Exposure standards, control levels & control measures to prevent exposure
Overview of the regulatory requirements – registers, labels, removal
Managing risk during low risk work – principles, PPE, safe operating procedures
Review of safe work procedures
Final questions
Plus an assessment
This format equips authorised staff to conduct low risk work including small scale removal, maintenance and inspections (updating the Register, etc).
2.
Training for Supervisors and Managers: This is a high level training course on the management of asbestos. Persons who oversee or manage facilities that have asbestos containing material should have this qualification. All persons undertaking asbestos work for Hydro Tasmania shall be supervised by a person with this qualification.
3.
The Supervisor Manager training course shall include the following points:
Identify primary legislative requirements and sources of information
Identify the requirements for the management of asbestos in your workplace
Select the appropriate management and control options for asbestos in your workplace
Select and supervise removal contractors
Course Contents
Legislative overview
Relevance of [NOHSC: 2018 (2005)] to Tasmanian Legislation
Health aspects of exposure to Asbestos, health surveillance and monitoring requirements
Owner & Management responsibilities
Development of an asbestos management plan
Identification of asbestos in the workplace
Control measures for asbestos containing materials
Control measures for asbestos containing materials
Maintenance and access and isolation requirements
Asbestos Register requirements
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Regular inspection and condition assessment
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The Tasmanian Workplace Health & Safety Regulations 1998.
Code of Practice for the Safe Removal of Asbestos 2nd Edition [NOHSC: 2002(2005)].
Code of Practice for the Management and Control of Asbestos in Workplaces [NOHSC: 2018(2005)].
Environmental Management Pollution and Control Act 1994 (Controlled Waste Regulations)
Controlled Waste Transport Regulations (EMPCA)
Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres [NOHSC: 3003
(2005)].
Worksafe Victoria – Worksafe Asbestos Bulletin No2 – Limited removal of fixed or installed asbestos permitted without a licence
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Competent Person
Non-Friable Asbestos
Friable Asbestos
Asbestos –likely sources
Revision 3
Print Date: 12/04/2020
Means a person possessing adequate qualifications, such as suitable training and sufficient knowledge, experience and skill, for the safe performance of the specific work. (Attending an approved Asbestos identification and removal course is considered by the Director the minimum training requirement to carry out the visual inspections). Additional knowledge, experience and skills would be required by the competent person performing air monitoring (e.g. occupational hygienist).
Over 97% of the products in Australia were non-friable material in which the
Asbestos fibres were bonded by cement, vinyl, resin or other similar material.
If accidentally damaged or broken these asbestos products may release a few fibres initially but will not continue to do so.
The hazardous friable asbestos is material which can be crumbled, pulverised, or reduced to powder by hand pressure. This may also include previously non-friable material which becomes broken or damaged by mechanical force.
As a general rule - If the Asbestos containing material can be easily disturbed and become air borne - by the effect of a breeze or simply creating a breeze by walking past it - it is in a friable state.
External cladding (corrugated sheet, galbestos, hardieplank)
Internal cladding (flat sheet, can look like hardieflex, villaboard, versilux fibre cement sheets)
Floor tiles (vinyl)
Floor Compressed Sheeting (Hardiepanel compressed sheeting)
Ceiling panels
Control room panels and noise insulated panels
Electrical cabinets (zelemite sheet)
Cable trays (flat sheet)
Busbar duct panels (flat sheet)
Fuse linings (woven tape)
External & internal cladding
Floor tiles
Spares e.g. gaskets, arc shields
Fuse switches (arc shield)
Resistor banks
Brakes
Drum controllers (millboard)
Internal walls or panels
Pipe flange gaskets
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Insulated pipework (possibly oil, water, air)
Piping flange gaskets
Bearing cooler flanges
Bearing /bearing housing (e.g. shell type turbine bearings)
Pump gland packing
Brake pads
Insulated pipework containing hot material (possibly oil, water, air)
Field switch (arc shield)
Heater mounting blocks (fibre cement)
Circuit breakers (arc shield)
CFS units (arc shields and rope seals)
Alternator winding cover gaskets
Wrapping/ Tape on old Alternator coils & end windings
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Revision
Number
0
1
2
Reason for
Revision
Detailed Revision Description Reviewer
Original
Critical Procedure
Review Update
New Format
Review Update
Original document created
Legislation, training and checklist/ safe work instructions.
Mick Cuppari
Charles Woolen
Bruce Hill
3 Review update Section 9.1.1 Removal of use of gloved bags by employees
Bruce Hill
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