HSG 264 – Asbestos: The Survey Guide

On 29th January 2010 the HSE released HSG 264 Asbestos: The Survey Guide. This document expands on and replaces MDHS 100. The document is aimed at those conducting Surveys, those who commission surveys and those with specific responsibilities for managing asbestos in accordance with Control of Asbestos Regulations (CAR) 2006. HSG 264 is heavily illustrated and is broken down into a number of key sections as follows:-

1. Introduction– Details the legal requirements, who the document is aimed at, management of asbestos in domestic properties, construction work, appointed person and health and safety issues.

2. Competence and Quality Assurance Procedures– the level of training and experience required by each surveyor and the competency of the surveying organisation and the surveyor is specified. Quality Management System that should be in place are also referenced. The HSE strongly recommends the use of certified or accredited surveyors or organisations and advises that UKAS Accreditation demonstrates technical competence and will ensure that surveys are carried out by competent people.

3. Asbestos Surveys– This section details the purpose of the survey and presumption and identification of ACM’s, the types of surveys, survey restrictions and caveats, survey strategy for both non-domestic and domestic properties. Under purpose of the survey it re-iterates information within CAR 2006 that an asbestos survey should be conducted for all properties (type determined by requirement) which is used to create an asbestos register, a risk assessment and a management plan to manage the risks of asbestos.

One of the main changes from MDHS 100 is the types of surveys and terminology. Under HSG 264 there are two types of survey instead of three. Type 1 and Type 2 surveys have now been combined together into Management Surveys and Type 3 Surveys are now termed Refurbishment and Demolition Surveys.

A Management Survey is a standard survey and will be used for the purposes of managing asbestos within properties. The survey will often involve minor intrusive work and some disturbance to facilitate foreseeable maintenance and related activities and can involve a combination of sampling to confirm asbestos is present or presuming asbestos to be present. An assessment of the condition and ability to release fibres into the air if they are disturbed in some way should also be undertaken for each ACM.

Refurbishment Surveys are required for all works which disturb the fabric of the building in areas where the management survey has not been intrusive.

A demolition survey should be conducted in the whole building if demolition is planned. A refurbishment and demolition survey is also required when more intrusive maintenance and repair work will be carried out or for plant removal or dismantling. The manner in which caveats and survey restrictions are discussed and agreed is detailed.

Under Survey Strategy for non-domestic properties, the guide states that there is an expectation that every building will be surveyed on an individual basis to identify the presence and condition of asbestos. It also details a survey strategy for domestic properties specifically targeted at Local Authorities and Housing Associations managing large numbers of domestic properties. This process involves a desktop study to establish probable asbestos status of groups of properties and details when management surveys and when refurbishment surveys should be conducted in these properties.

4. Survey Planning –Dutyholder planning and Surveyor planning procedures are explained. Information to be collected at the planning stage of the survey is fully listed. Explanation is given to the 4 steps in the survey planning process which are:-

5. Carrying out the survey (surveying) – Within this section there is information on a systematic survey inspection, what and how to assess and record and where additional precautions and care need to be undertaken. Bulk Sampling Strategy is addressed and a list of asbestos containing products and the size and frequency of samples is included. Bulk Sampling procedures describe safe systems of work and how samples should be extracted. Material Assessments should be undertaken in all Management Surveys and also in those refurbishment or demolition surveys where the period between the survey and event is significant (more than 3 months). Priority Assessments should be prepared in close liaison with the client to ensure detailed knowledge of all factors affecting this assessment.

6. Survey Report– The survey report should be comprehensible and useable by the client and information should be easy to extract and use to prepare an asbestos register. The report should contain:-

Within this section it details which information should be contained in each section and provides an example asbestos register and sample asbestos building plan.

7. Dutyholder’s use of survey information– This section details how the client should check the survey has been adequate and that the report is suitable and accurate. It states that the survey reports will in most cases not be the asbestos register which will be a simpler document containing much less information. Regular updating of the asbestos register is also addressed briefly stating that it should be updated where asbestos is removed, new areas are sampled / surveyed and changes to the condition of ACM’s.

Six Appendices are also included as follows:-

Should you have any questions regarding HSG 264, it’s implementation, what it means to you as a dutyholder or appointed person and what are the wider ramifications for your business, please contact us now.

Other Silverdell Plc Group Companies:

Kitsons Environmental Europe Limited
Redhills
SAFE (Training)