Asbestos Removal

S & S Scaffolding Ltd held an 'ancillary asbestos license' for several years, being one of the first scaffolding contractors to be awarded one. We have considerable experience within this field and our operatives regularly erected access scaffolds and basic enclosure frameworks for various asbestos removal contractors. All our operatives have 'scaffolder asbestos training' which is periodically updated and many have had further site instruction in the use of decontamination units. All our operatives have their own personnel 'asbestos' PPE & RPE which they take to site. All employees undergo medical surveillance and all have face fit test for their 'half-face' masks.

With the introduction of further guidance for scaffolding contractors (ALG memo 04/08), issued May, 2008 and a meeting between S & S Scaffolding and Manchester HSE in October, 2009 at which the memo was further clarified it should be noted that; Although Regulation 2 of the CAR regulations states that 'work with asbestos' includes work which is ancillary to the removal, repair or disturbance of asbestos or asbestos materials containing asbestos(scaffolding is therefore classed as ancillary) and that work withasbestos requires a licence issued by the ALU, there are exemptions. Regulation 3 (2) states that regulation 8 (licensing), 9 (notification), 15(1) (arrangements to deal with accidents, incidents and emergencies) and 22 (health records and medical surveillance) shall NOT apply where;

1. exposure of employees to asbestos fibres is sporadic and of low intensity
2. it is clear from the risk assessment that the exposure of any employee to asbestos will not exceed the control limit; and
3. the work involves;
   1. short, non-continuous maintenance activities
   2. removal of materials in which the asbestos fibres are firmly linked in a matrix (such as asbestos cement sheets or AIB boarding etc)
   3. encapsulation or sealing of asbestos-contaminated materials which are in good condition, or
   4. air monitoring and control, and the collection and analysis of samples to find out if a specific material contains asbestos.

The ALG Memo 04/08 states that short non-continuous maintenance activities may include ancillary activities, such as scaffolding. Where scaffolding is provided as access for licensed asbestos work, the situation needs to be assessed with regard to likely exposure. ACOP paragraph 90(b) states that a licence for ancillary work will be required for the scaffolding 'where it is foreseeable that the scaffolding activity is likely to disturb the asbestos'. However, it is now the view of the ALU that the provision of access scaffolding in the vicinity of asbestos that is in good condition is not likely to constitute work with asbestos. In such situations, it is not likely that competent scaffolders will disturb asbestos. Though the work would NOT require a license or notification, the ALU still recommend that, SCAFFOLDING OPERATIVES WOULD STILL REQUIRE APPROPRIATE AWARENESS TRAINING AND RISK ASSESSMENTS AND SAFE WORKING