Long term asbestos risk management
October 1st 2004 Alan Hambidge is a director of Controls Assurance, an indoor environment risk management consultancy. Here he examines how a systematic approach to asbestos risk management can bring considerable benefits to those with large property portfolios, including housing and local authorities.
Developing an Asbestos Management System Health and Safety Law in the UK is developing further and further towards the need for a systematic risk management system. This is seen clearly in the Control of Asbestos at Work, Regulations, 2002, where Regulation 4 requires us to Manage the Risk through such a management system. As most asbestos is still insitu, we have no choice but to manage the risks, including those from accidental and incidental exposure. There is not a legal duty to conduct an asbestos survey, but there is a legal duty under Regulation 4 of the Control of Asbestos at Work Regulations, 2002 to do a suitable and sufficient assessment of risk (which will entail some surveying).
Many organisations waste vast amounts of money on unnecessary activity. So, how do you establish what you need to do? An initial compliance audit will confirm an organisation’s level of compliance with legal requirements. The audit will also produce an asbestos management plan, that will identify the elements necessary for a successful asbestos management system.
The approach necessary for proper management of the risks from issues such as asbestos requires a degree of confidence in the system that has developed. A proper management system will be required, based on priorities that have their origin in risk score, giving consideration to practicalities, cost and difficulty. The system should be cradle-to-grave in its nature (i.e.
from what was wrong all the way to what was done, and where the evidence is kept). The system should be flexible and live and the information contained within it readily retrievable by those that may require it.
As stated, it will be necessary to overview the status of the organisation using an initial audit exercise. This is a pre-requisite of all good Management Systems (if an organisation is unaware of its current level of compliance, it will not be possible to set objectives and targets for improvement of the risk issues). Once this initial audit has been conducted, and the level of compliance is known, a programme for all noncompliances or opportunities for improvement should be established. An asbestos risk management group should be convened to manage the risks identified by the audit and develop a programme for the management system. Representation on these groups will typically include The Responsible Person (Asbestos), the Deputy Responsible Person (Asbestos), any Nominated Person(s) and the Retained Specialist Consultant. It is recommended that such a group meets every twomonths initially, using the key headings of the asbestos risk management audit as its agenda items. The risk management programme developed should extend for 3 to 5 years, and should include:
• The number and frequency of risk assessment/surveys to be conducted each year. It is not necessary to assess all asbestos risks at once, and it may be undesirable to do so. A multiple-year programme of surveys based on site priority is far better. So how do we establish what should be surveyed? A desk-based “Risk Screen exercise will be required to assign priority to sites, and therefore when and to what level they are surveyed. This exercise is very valuable for organisations with large property portfolios, and can bring considerable cost savings • The number and frequency of any re-assessments required each year • Development of suitable and sufficient policies and procedures for the management of the relevant risk issues. A training programme based on training needs analysis should then be developed and delivered • An audit programme (with audit criteria, frequency, etc). Independent consultants are recommended for audits and initial risk-assessments. However, it might be in the interest of the organisation to work closely with the consultants and obtain the necessary training to conduct some elements of monitoring and re-inspection. This will vary from one organisation to the next • Establishment of the asbestos risk management group. Regular review meetings using the audit headings as an agenda • Development of a risk management system. This system should be cradle-to-grave in nature. A good vehicle for such a system is Microsoft Access. This is readily available, thus reducing potentially very expensive licensing issues to a minimum
Once all of these steps have been carefully considered and an adequate risk management programme has been laid down, the organisation will have a Management System approach to Risk. | 
