Background
The Occupational Health and Safety Regulations 2017 requires a person who manages or controls a workplace (PMC) where asbestos has been identified to maintain an asbestos register and an employer who has management or control of asbestos to maintain an employer’s asbestos register.
The asbestos registers must contain the location of the asbestos, the likely source of asbestos that is not fixed or installed, the type and condition of any asbestos containing material (ACM), whether ACM is friable or non-friable, whether ACM is likely to sustain damage or deteriorate, and any activities carried out in the workplace that are likely to damage or disturb the asbestos.
The register must also detail any inaccessible areas that are likely to contain asbestos. Before demolition or refurbishment work occurs at the workplace, the PMC and employer must review their asbestos registers with regards to the proposed works. The PMC and employer must ensure their asbestos registers have adequate information to allow the person performing the work to effectively manage the risks from asbestos in the building or structure. If it does not, the register must be revised. Note: If asbestos is likely to be disturbed by demolition work, it must, so far as is reasonably practicable, be removed before the work commences. If asbestos is likely to be disturbed by refurbishment work, it must, so far as is reasonably practicable, be removed.
Reviewing the asbestos register
Ideally, an asbestos register should be reviewed after the areas to be demolished or refurbished are vacated. This will allow a person with the requisite knowledge, skills and experience to undertake a thorough investigation of the building or structure to identify areas where asbestos is present. If the review is conducted while some areas are inaccessible, such as areas still occupied by staff or locked, the PMC or employer should have the person return and investigate those areas once they are accessible
When reviewing or revising the register ensure all information is presented in a clear and suitable manner so that it can be easily understood. This allows the person undertaking the demolition or refurbishment work to develop appropriate systems of work for the particular building or structure and, if necessary, arrange for any known asbestos that is likely to be disturbed to be removed before the works commence.
Avoid confusion by ensuring the register:
- clearly states any assumptions made in the preparation of the register, and any limitations the register may have
- clearly identifies any areas of the building or structure which could not be accessed or assessed for the presence of asbestos
- provides detailed and consistent descriptions when specifying areas or locations (consider using photos, diagrams or building plans to assist in accurate position identification)
- uses language suitable for the audience
- is up to date and reflects the current condition of the building or structure
Handover of the asbestos register
When handing over the asbestos register to the person undertaking the demolition or refurbishment works the PMC or employer should consider, especially for complex works, having the person who reviewed the register provide a briefing on its contents. This briefing may include a tour of the building or structure to identify the known asbestos locations, as well as any inaccessible areas that may contain asbestos.
If the person undertaking the work is not satisfied with the suitability of the register for the proposed works, they should raise their specific concerns with the PMC or employer.
The most efficient and cost effective way to maintain an accurate asbestos register is to implement a software solution such Lupin’s AuditPRO asbestos Management. For further information on AuditPRO contact Kristy Titus on 0460 775 591