The introduction of an additional category of “Notifiable Non-Licensable Work” (NNLW) in the updated Control of Asbestos Regulations 2012, issued on 6th April, is intended to bring an extra layer of health and safety procedure to the renovation, demolition and disposal of waste building material at a property where any exposure to asbestos is to be prevented.
While reinforcing asbestos awareness with building contractors and premises owners can only be a positive move, the problem of avoiding confusion as to which category the asbestos work falls under and the level of risk involved, will still remain.
Consequently, a proper and authorised survey and risk assessment must be carried out before any works are begun. The procedure should eradicate negligent practices where the dismantling and disposal of building material is quickly dispatched, along with any asbestos subsequently uncovered during the demolition work.
Once asbestos has been discovered, it must be determined whether further work in dealing with the material is deemed either licensable, NNLW or non-licensed in each and every case. This is dependent on the asbestos type, condition and material form, and the nature of the work planned.
From the mid 1980s onwards and until its import was banned at the end of the 1990s, most asbestos used in the building industry to create insulating wallboard, surface and sprayed coatings, pipe insulation and cement products tended to be made from white chrysotile fibres. Any asbestos found in a poor condition due to moisture or wear is liable to easily release fibres into the atmosphere.
A long gestation period of between 15 to 50 years is known to elapse before the first asbestosis symptoms appear, by which time, the disease may have spread to adjacent tissues or organs. A patient’s survival rate after a conformed diagnosis can be less than 6 months.
Assessment of asbestos containing materials (ACMs) encountered and the decision over whether the work is NNLW or non-licensed work is the responsibility of the person in charge of the job.
Undoubtedly, there will be specific circumstances, where only very minor repairs or maintenance are to be carried out and where exposure is deemed to be infrequent, of low intensity and will fall well below and not exceed the control limits for exposure of 0.1 fibres per cubic centimetre of air (0.1 f/cm3).
According to HSE estimates there are still around four million properties in the UK containing hidden asbestos material. As a result it is expected that several million notifications for NNLW work will be legally required annually, affecting some 730,000 workers in the building industry.