Noel Arnold & Associates Pty Ltd Level 3 / 818 Whitehorse Road Box Hill Victoria 3128 Australia Ph: (03) 9890 8811 Fax: (03) 9890 8911
www.noel-arnold.com.au
Asbestos Management Plan
Defence Housing Australia
Residential Sites
Statement of Limitations
This report has been prepared in accordance with the agreement between Defence Housing Australia and Noel Arnold & Associates Pty Ltd.
Within the limitations of the agreed upon scope of services, this work has been undertaken and performed in a professional manner, in accordance with generally accepted practices, using a degree of skill and care ordinarily exercised by members of its profession and consulting practice. No other warranty, expressed or implied, is made.
This report is solely for the use for Defence Housing Australia and any reliance on this report by third parties shall be at such party's sole risk and may not contain sufficient information for purposes of other parties or for other uses. This report shall only be presented in full and may not be used to support any other objective than those set out in the report, except where written approval with comments are provided by Noel Arnold & Associates Pty Ltd.
Asbestos Management Plan
DEFENCE HOUSING AUSTRALIA
Residential Sites
1.
Glossary of terms... 1
2.
Background ... 2
3.
Asbestos Products and Materials ... 3
4.
Overview of the Asbestos Management Plan... 5
Element 1 – Asbestos Materials Database Register (The Asbestos Register) ... 5
Element 2 – Responsibilities ... 5
Element 3 – Training Arrangements and Consultation ... 5
Element 4 – Maintenance Contractor Safety Arrangements... 6
Element 5 - Licensed Asbestos Removal ... 6
Element 6 - Timetable for Asbestos Risk Assessment Reviews... 6
5.
Element 1 - The Asbestos Materials Register ... 8
Risk Assessment Criteria ... 8
Risk Ratings... 8
Disturbance Potential for Maintenance ... 9
Element 2 – DHA Management Responsibilities... 10
Defence Housing Authority... 10
HMC Property Managers ... 10
Contractors... 10
Competent Advisors... 11
Tenants... 11
6.
Element 3 – Training, Notification and OHS Induction ... 12
7.
Element 4 – Contractor Safety for Asbestos Related Work... 13
Duty of Care ... 13
Work Authorisation ... 13
Work Method Statements ... 13
Minor Works and DHA Maintenance Contractors... 14
Refurbishment/Demolition Audit... 15
8.
Element 5: Work Performed by Licensed Asbestos Removal
Asbestos Control Records and Revision of Asbestos Materials Register ... 16
9.
Element 6 - Asbestos Risk Assessment Reviews... 17
Table 1: Timetable for ACM Review...18
10.
Labelling of Asbestos Materials ... 18
11.
Summary of Required Actions... 18
12.
Appendices ... 20
Appendix B: Legislation Summary... III
Appendix C: References - Australian Safety and Compensation
Publications and Web-links [NOHSC: 2018 (2005)] and [NOHSC: 2002
(2005)] 2
ndedition...IX
Appendix D: DHA Asbestos Service Providers...XI
1.
Glossary of terms
Abatement
To remedy or repair
ACM
Any material object, product or debris that
contain asbestos
Analysis
Detailed examination of the structure.
Statement of results from the sample taken on
site.
Asbestos
Fibrous form of mineral silicates belonging to
the serpentine and amphibole groups of rock
forming material
Bonded Encapsulated by other material, in a dense
form.
DHA
Defence Housing Australia
Friable
Asbestos containing material which when dry
may become crumbled or be reduced to
powder by hand pressure
HMC
Housing Management Centre (DHA)
NOHSC
National Occupational Health and Safety
Commission
SME
Subject Matter Expert
Work Method Statement
A detailed summary prepared by the
contractor before any work commences
detailing how the contractor will remove/repair
or work with a property containing ACM to
reduce the risk of exposure.
Inaccessible Areas
Means areas which are unable to be accessed
such as wall cavities and low clearance sub
floors
Air Monitoring
Airborne asbestos fibre sampling at assist in
assessing the exposures and the effectiveness
of control measures.
2. Background
The Defence Housing Australia (DHA) manages approximately 17,000 properties Australia wide. DHA provides high quality housing and relocation services to members of the Australian Defence Force and members of the Australian Customs Service.
The National Occupational Health and Safety Code of Practice for the Management and Control of Asbestos in Workplaces [NOHSC: 2018 (2005)] recommend that all agencies in control of premises should develop an asbestos management plan and conduct risk assessments of properties under their control and record all findings in an asbestos register. The management plan also reflects Commonwealth legislation in regards to the Occupational Health and Safety Act (1991) Commonwealth Employment & Occupational Health and Safety Act (Commonwealth Employment) Regulations 1994.
To meet these obligations, DHA has undertaken a review of asbestos materials in the DHA portfolio of residential accommodation Australia wide. DHA engaged selected asbestos industry consultants, to undertake a comprehensive evaluation and risk assessment of materials in the dwellings. All information has been collated in an on-line database (The DHA Asbestos Register). The program involved the evaluation of short term, medium term and longer term control measures and assessed the building materials presumed to contain asbestos and identified the location of asbestos materials at each site. For information regarding the survey and analysis process see Statement of Work for Asbestos survey and Analysis (1)
Over recent years the adverse health risk associated with the use of asbestos have been widely publicised both nationally and internationally and the presence of asbestos in the Defence Housing Australia (DHA) housing stock is an acknowledged issue of concern to the DHA. DHA is committed to achieving the highest standards of management in all aspects of our business. The following asbestos management plan has been developed by DHA to assist it to meet its statutory obligations and to provide a consistent and standardized approach to the management of asbestos in the residences for which it has responsibility.
The Asbestos Register User Guide (2) provides information on how to access the web-based
register, download reports and up-dating asbestos information in each DHA Region.
1 Statement of Work for Asbestos Audit and Analysis
3. Asbestos Products and Materials
Asbestos products and/or asbestos-containing materials (ACM’s) are commonplace in Australian homes pre-dating 1985, while particular caution needs to be taken when working on buildings built prior to 1990, recycled materials in later buildings may also contain asbestos. ACM comprises of but not limited to:
o Asbestos cement (AC) eaves o AC clad garages and sheds
o AC to splashbacks, floor-backing sheet, shower recesses and bath surrounds in bathrooms
o AC walls and floor- backing sheet in laundries
o AC oven surrounds, floor backing sheet, wall and ceilings o Asbestos based floor vinyl floor coverings
o AC flues
o Asbestos based insulation boards and housing in electrical boards o AC porches and veranda soffit and walls
o Ac panelling to stairs
o Compressed AC structural floor sheet
While most items are in the form of non-friable or bonded materials where the asbestos fibres are contained within cement, plastic or other solid material, there is a potential for exposure from disturbance of these ACM from building and maintenance work. For instance, the inadvertent use of tools that drill, cut, or damage the ACM, such as power-operated tools, can generate respirable or breathable asbestos fibres in air.
It is impractical to remove all ACM from the housing stock in the Short-Term. It is widely supported that when ACM is contained in a bonded form and maintained in good condition and left undisturbed, it presents no measurable health risk. Identification and management of ACM is a key obligation of managers and employers at workplaces. In this regard, there is also duty of care obligations for managers of Defence residential properties to ensure householders and tenants living in the residential sites are informed of the presence of ACM and to ensure that contractors abide by processes to avoid disturbance of the ACM.
OVERVIEW OF ASBESTOS MANAGEMENT PLAN
THE ELEMENTS
4.
Overview of the Asbestos Management Plan
The Asbestos Management Plan represents an integrated risk management approach to ensure that all practicable steps are taken to prevent or minimise the risk of exposure to ACM. The Defence Housing Asbestos Management Plan encompasses the following elements:
Element 1 – Asbestos Materials Database Register (The Asbestos Register)
This element covers the recording of ACM locations and Survey and analysis results in a database register, which forms the basis of the Asbestos Register for recording and documenting asbestos abatement and mitigation information.
o Comprises the locations, form, types, and condition of any ACM identified o Details of any material presumed to contain asbestos
o Inaccessible areas that may contain asbestos o Asbestos identification results
o Date the survey was conducted
o The name of the competent person who carried out the survey o Risk assessment ratings
o Results of air monitoring testing
o Control measures recommended and implemented o Abatement and maintenance measures and records Details of this element are discussed in Section 4 of this report.
Element 2 – Responsibilities
The responsibilities outlined are for the various stakeholders assuming management and control of asbestos risks as well as those contractors working to DHA guidelines and Defence tenants (householders) occupying the homes under tenancy agreements.
o Outlines the necessary management processes to control the risk as required by the Asbestos Regulations
o Outlines responsibilities, procedures and systems for the effective management and control of ACM
o Organises asbestos work to be undertaken in accordance with local regulatory requirements
o Requires any ACM removal work to be undertaken by persons who are appropriately qualified
o Ensures that there is a documented procedure prepared by a competent person and/or licensed asbestos removal contractor in order to ensure that contractors undertaking work establish appropriate controls in areas containing asbestos materials Details of this element are discussed in Section 5 of this report
Element 3 – Training Arrangements and Consultation
DHA has obligations to induct contractors in line with their activities and work in the vicinity of ACM and ensure an appropriate level of training has been obtained.
o Requires that persons involved in management and maintenance operations in each residential property are clearly informed and trained in this Plan.
o Requires licensing and/or training of approved contractors working with ACM
o Consultation and notification of contractors working in DHA residential sites containing Asbestos material
o Consultation with the householders
Details of this element are discussed in Section 6 of this report
Element 4 – Maintenance Contractor Safety Arrangements
DHA manages a variety of maintenance and service for the Defence residential properties and this element covers the information and processes to ensure safety for the contractor and resident during these activities.
o Outlines guidance for the SME/HMC Manager located at the HMC to check for ACM and make a determination whether it is appropriate for the work to be conducted by the contractor or be subject to licensed asbestos removal
o Develop safe work methods for maintenance tasks
o Requires the contractor to comply with local statutory requirements, where work involves disturbing and/or demolishing suspected asbestos products and materials. Details of this element are discussed in Section 6 of this report
Element 5 - Licensed Asbestos Removal
This element discusses the management and regulatory obligations for licensed asbestos removal contractors undertaking asbestos removal processes in residential properties.
o Where work involves any friable ACM, or non-friable ACM greater than 10 square metres area of AC sheeting or vinyl floor tiles, must be conducted by a licensed asbestos removalist in accordance with State legislation.
o Preparation of a job-specific removal safety plan, Control Plan or safe work procedures o Notification to regulatory authority prior to commencement
o Air monitoring and clearance air testing during removal work
o Requirement for issue of certification following removal works by an competent person, usually employed independently of the asbestos removalist
o Records of abatement to be maintained by DHA’s SME or DHA Property Consultant. Details of this element are discussed in Section 7 of this report
Element 6 - Timetable for Asbestos Risk Assessment Reviews
DHA has a web-based database register to enable the ongoing management of asbestos information and records. These elements refer to the regulatory requirement to revise and review the Asbestos Register and risk assessment periodically and types of asbestos abatement records to be maintained in this Asbestos Register.
o Establishes a timetable for the ongoing review and assessment of the various ACM o Details the statutory requirement for risk assessment reviews in each State
o Identifies the trigger for new asbestos risk assessments when new rental agreements are entered into or sale of property or renovation is planned.
ASBESTOS MANAGEMENT PLAN PROCESS
THE DETAIL
5. Element 1 - The Asbestos Materials Register
Reference should be made to the DHA Asbestos Materials Register (the Asbestos Register) for each residential address where the tables identify the range and condition of ACM products and materials known to be present in each residence. The Asbestos Register is up-to-date and describes the known ACM confirmed to exist at the date and time of the survey.
While each Asbestos Register provides an indicative register of asbestos material, further confirmatory sampling may be required prior to new installations, refurbishment, demolition or renovation, particularly where the asbestos materials have been presumed (deemed) or suspected to be present and no previous samples were taken.
The Asbestos Register contains information relating to the location, type, condition, actions required and comments regarding any asbestos identified.
The Asbestos Register forms an integral part of an effective Asbestos Management Plan. The Asbestos Management Plan and Asbestos Register must be made available as required – for inspection by Defence tenants, other DHA employed contractors Defence contractors, maintenance personnel, and on request to the relevant DHA’s regional Housing Management Centres (HMC) office, union representatives with regional jurisdiction.
The asbestos register shall be referred to prior to any maintenance or refurbishment work being undertaken by DHA’s maintenance contractors, external service contractors or builders. Appropriate work procedures and hazard controls will be determined prior to commencing any activity that has the potential to disturb asbestos material. This will be done in conjunction with Defence Housing Australian nominated risk management consultant and the State based regulatory authority (where required).
Risk Assessment Criteria
The Purpose of the Risk assessment is to allow informed decisions to be made about control measures, including training, air monitoring and health surveillance requirements.
Only competent persons should perform risk assessments or any subsequent reviews or revisions of risk assessments.
Decisions about control measures to protect workers will depend on the assessed risk to health. The risk assessment shall take into account of the identification information in the register of ACM including:
• The condition of the ACM (e.g. wether they are friable or bonded and stable, and whether they are liable to damage or deterioration)
• The likelihood of exposure
• Whether the nature or location of any work to be carried out is likely to disturb the ACM:
• The results of the risk assessment should be documented in the register of ACM.
Risk Ratings
The following Risk Ratings are applied to the Asbestos Register findings:
immediate removal or repair of the asbestos product and immediate evacuation and sealing of the site.
Risk Rating 2: Has potential for medium exposure risk if actively disturbed and some rectification may be required. The area will usually have ACM present that is unstable or has the potential for disturbance. Remedial action may involve removal or repair of the ACM. Risk Rating 3: Has a Low exposure risk potential and only regular inspection will be necessary to ensure that condition does not deteriorate. However, if materials are to be disturbed as a result of maintenance or refurbishment the risk rating may need to be re-evaluated. Remedial action may involve maintenance.
Risk Rating 4: Has a negligible exposure risk potential in its current state. The ACM located in the residence is undamaged and has a low potential for disturbance. No remedial action is required, although the ACM should be maintained and regular inspections carried out to ensure product does not deteriorate.
A Risk Rating 1 applies to a situation of damaged ACM that could be readily disturbed to liberate asbestos dust from normal residential activity or is moderate damage inside the home.
Disturbance Potential for Maintenance
Where a maintenance activity, renovation or repair is conducted, the assessment would need to consider the disturbance potential of the activity and nature of asbestos material likely to be disturbed and control measures to be implemented at the time the activity was planned. For only minor installation and building work not involving asbestos removal, the disturbance potential is likely to be low and control measures only require use of personal protective equipment and dust controls and removal of any minor fragments of ACM debris. For instance, short-term (less than few minutes), manual-sawing of a small hole in an AC wall, removal of several asbestos floor tiles, or breaking a small opening for a power outlet. Any such work would be subject to an HMC authorised safe work procedure prepared in conjunction with the contractor and notification to the tenant as to controls measures.
In this regard, it is implicit in this Asbestos Management Plan process to provide an up-date Survey or perform additional sampling at the time of planned works specific to the areas of the residence likely to be affected.
Contractor maintenance and work that requires asbestos removal or use of power operated tools on asbestos switchboards or AC sheet must be given a Rating 1 at the time of assessment and suitable control measures implemented to manage or remove the asbestos hazard safely.
Element 2 – DHA Management Responsibilities
The Defence Housing Australia (DHA) is responsible for ensuring that the Housing Management Centres (HMC) in each region or other or authorised representative is responsible for administration and supervision of asbestos-related tasks at DHA Managed Properties. The responsibility of each party is described as follows:
Defence Housing Australia
The DHA is responsible for ensuring that:
o Implement the requirements of the Asbestos Management Plan
o Ensure communication of processes and requirements of Asbestos Management Plan to relevant stakeholders
o Monitor and review the performance of the Asbestos Management Plan
o Prepare budgets and program for management and abatement of asbestos items
HMC Property Managers
Each Property Manager in the regional HMC offices is responsible for:
o Raising maintenance work orders and ensuring a copy of the Asbestos Register at the time of raising the work is provided to the contractor.
o Providing contractors with asbestos product location and condition information on request. This information can be sourced through the web-based asbestos register o Printing the asbestos reports each month by property to monitor and determine if
abatement of asbestos hazards is required or any follow up maintenance work. Actions will depend on the risk ratings and condition reports
o Addressing the asbestos maintenance issues as they arise
o Ensuring that contractors adhere to relevant legislation when performing work on properties that contain asbestos
o Performing ongoing regular inspections on properties to evaluate condition of the ACM
Contractors
The Contractors are responsible for:
o Reviewing the Asbestos Register before undertaking work at DHA properties o Ensure contractor’s employees have required asbestos awareness training
o Immediately notify HMC if further confirmation testing is required for suspected ACM o Notify HMC prior to any works that could directly disturb any existing or known ACM o Comply with local regulatory requirements for asbestos removal
o Prepare and implement safe work method statements for work on or in the vicinity of ACM
o Notify HMC of licensed asbestos removal contractor engagement scope prior to communication of works.
Competent Advisors
Competent Industry Consultants are authorised to access the Asbestos Register and record findings relating to the asbestos content of the residences. Each Contractor is presented with an induction kit, which provided instructions on arranging access to tenanted properties. On receipt of a work order, contractors are instructed to contact the tenant and arrange a mutually convenient appointment time.
All contractors are issued with Contractor ID cards.
Contractors are instructed not to enter into any discussion with tenants concerning their findings while on site and to refer all tenants’ enquiries to the Asbestos Hotline.
A risk management consultant / occupational hygienist can also assist the HMC in the following areas:
1. Conduct up-dated checks/surveys to assess risk involved with proposed works where disturbance of asbestos containing material is likely to occur prior to commencing proposed works
2. Conduct regular reviews of asbestos containing materials as required by the regulations.
3. Develop of ‘Scope of Work’ documentation for: o Service installation works
o Refurbishment and re-fit of tenancies o Removal of asbestos containing materials
4. Assist with induction of contractors and provision of risk communication for tenants and service contractors.
5. Provide occupational hygienist services on behalf of the DHA regional office during asbestos abatement works in the residential site.
Tenants
Tenants may contact a HMC requesting a copy of the Survey and analysis report relating to the property in which they reside, DHA will oblige.
The tenants of DHA properties enter into a Tenancy Agreement with Defence and must therefore abide by the condition of the agreement, including:
o Comply with relevant provisions in the Tenancy Agreement relating to works that they undertaken that may disturb ACM
o Report to the HMC any damage confirmed or suspected of ACM in residential household
o Notify HMC of any proposed installation that would or potentially disturb the building fabric of the residence
6.
Element 3 – Training, Notification and OHS Induction
An up-to-date copy of the Asbestos Register for each residential property will be available at all times for authorised contractors and DHA staff to review. The contractors shall then determine what potential exists for exposure to asbestos during the course of any contract work.
Pre-qualified contractors should have a minimum of one-days Asbestos Awareness Training or an equivalent license for non-friable asbestos removal. The pre-qualified contractors must demonstrate to DHA that their workforce involved in working in proximity to ACM’s have completed appropriate training and are equipped with personal protective equipment and tools to manage minor asbestos works.
The contractor is then obligated to notify the Housing Management Centres (HMC) of the potential for asbestos exposure or need for further confirmatory sampling.
The Defence Department and DHA reserves the right to control all work conducted in their property and requires contractors to implement procedures appropriate to control any asbestos exposure risk to Defence tenants, staff, contractors or visitors to the various residential sites.
The HMC Property Manager requires each service contractor to maintain a high level of housekeeping and implement procedures and work practices to prevent asbestos disturbance.
DHA authorised service contractors shall comply with all relevant State based Occupational Health and Safety regulations. Contractors must prepare necessary safe work procedures and job safety analysis for any works that involve major OHS risks to themselves, to building occupants or visitors.
The HMC shall ensure that the contractors they engage are suitably trained in asbestos awareness and/or have an appropriate license for asbestos removal work.
7.
Element 4 – Contractor Safety for Asbestos Related Work
A residential site becomes a workplace for contractors when they are performing works. DHA’s SME is responsible for advising contractors of the location of asbestos if/when known. When DHA raise maintenance work orders to contractors, an annotation under the heading “warning” will be printed on the work order to alert the contractor that there is a possibility that an asbestos product has been used in the construction or that laboratory results prove conclusively that an asbestos product has been identified.
In all circumstances control measures contained in the National Occupational Health and Safety Council [NOHSC: 2002 (2005)] Code of Practice for the Safe Removal of Asbestos and State based Regulations shall be adhered to.
Duty of Care
DHA have a duty of care to ensure that all maintenance management activities accounts for safe work in the vicinity of asbestos materials. Two aspects of this duty of care exist namely:
o to the resident or tenant
o to the contractors engaged to perform work at the site.
Contract maintenance, both planned and responsive at the residential sites are directly managed by regional Defence Housing Australia Property Manager’s and nominated DHA Head Office employees.
The HMC will co-ordinate local contractors and DHA staff to supervise maintenance and new installations at each of their regional portfolios. Any asbestos-related work must be managed in accordance with this plan in order to ensure that contractors’ works are conducted in a safe manner without harm or nuisance to the contractors themselves, or to the tenants, their families and visitors.
Work Authorisation
Defence Housing Australia or their authorised site representative must be notified prior to any works that could directly disturb any existing or known asbestos materials.
In these situations, it is necessary for the contractor to refer to the Asbestos Register or request a subsequent Survey of the site to check for asbestos as required. In all instances, the aim of the management plan is to prevent risk to the tenants, contractors and other parties from exposure to asbestos dust.
If a contractor receives a work order with an asbestos warning, the contractor shall request a copy of the asbestos register, by contacting the relevant HMC to verify the location of asbestos. All HMC’s have access to the asbestos register database via the internet. HMC’s are obligated to supply contractors with any information relating to asbestos where the information is available.
Contractors will be notified of their obligations to comply with statutory requirements for each region through the Residential Maintenance Service tender presentations and inductions.
Work Method Statements
Defence Housing Australia requires contractors and tenants to abide with all State regulatory requirements in the safe conduct of asbestos-related work. In particular, this means introducing risk controls that will limit human exposure to asbestos fibres.
While the greater majority of work performed by contractors would not involve demolition or significant disturbance of materials containing asbestos, DHA recognises that safe work methods should be employed to prevent exposure to contractors and tenants.
Where Commonwealth, State or Territory Regulations or the local statutory authority requires the work to be performed by licensed tradespersons, the contractors must provide evidence of the required licenses prior to the commencement of any works.
Each HMC will employ at least one Subject Matter Expert (SME), who has knowledge and/or experience in asbestos risk management. The SME will assess site works and the likelihood of asbestos disturbance based upon a standard range of pre determined risk scenarios. Where a contractor identifies that there is a potential exposure risk, the pre-qualified list of selected asbestos industry consultants will survey and revise the risk assessment and/or prepare new procedures.
Work method statements are to be completed by the contractor for works performed where asbestos will be disturbed in any way during the course of undertaking the works. The work method statements are to be prepared prior to commencing work and lodged with DHA on completion of work by attaching to invoices along with a copy of the issued Work Order. All ACM should remain in good repair on conclusion of work.
A standardised training program will be prepared and delivered to ensure training of the DHA SME.
Note: The Asbestos survey and analysis process is an ongoing progress. Any property meeting the age profile that has been flagged on PMS to alert contractors shall take precautions when working in DHA Housing suspected of containing asbestos products. If information relating to a particular property is not available, contractors should be advised to refer to the DHA Contractor Fact Sheet or direct any queries to the DHA Asbestos Hotline 1800 091 562.
In all circumstances control measures contained in the National Occupational Health and safety Council (NOHSC) 2002. Code of practice for the safe removal of asbestos and state based regulations shall be adhered to.
Appropriate notification and consultation with all affected tenants and contractors must be undertaken prior to works commencing
Contractors are not to undertake major demolition or refurbishment works exceeding 10 square metres of non-friable asbestos, or work with any quantity of friable asbestos material unless they are a fully licensed to undertake this work.
Minor Works and DHA Maintenance Contractors
DHA shall provide information on the presence of ACM to their pre-qualified contractors. Minor work should be performed in accordance with guidelines outlined in the National Code of Practice Management of Asbestos Materials in Workplaces [NOHSC 2018: (2005)]1 and in accordance with relevant State legislation.
Minor work usually involves:
o Cleaning of gutters for asbestos roofs o Drilling of asbestos cement sheeting
o Patch repairing damaged asbestos cement sheeting or vinyl floor coverings o Preparation and painting of asbestos cement sheet claddings
The equipment and control measures for minor asbestos works is documented in the National Code of Practice {NOHSC: 2018 (2005)] and conform to local regulatory requirements.
Note: While other States may not at present recognise residential properties used largely for domestic purposes as workplaces, it is generally assessed that obligation is present where the residence is to undergo major refurbishment. Major refurbishment constitutes a licensed quantity of asbestos removal work.
For the purposes of this Guideline, any contractors’ work that may disturb the fabric of the building shall be approved by the HMC and shall ensure that a record of ACM is reviewed in the Asbestos Register. Where there is no definitive result, additional sampling must be conducted to confirm the presence or absence of ACM prior to the work commencing.
Similarly, contractors must have access to records of the ACM locations or be requested to undertake testing where it is suspected that asbestos materials may be present prior to commencement of work on that surface or material.
Refurbishment/Demolition Audit
ACM may be present in a residential site but not recorded in the register. Prior to any major refurbishment work, or major upgrade work on plant and machinery which could disturb known or presumed (deemed) asbestos materials, a detailed asbestos and hazardous building materials audit should be undertaken to identify all asbestos-containing materials that are likely to be disturbed.
Before any building works are undertaken involving materials suspected of containing ACM and there is no confirmation testing recorded on the register, further investigation and additional sampling should occur. This must be organised using the DHA panel of qualified auditors prior to the commencement of any refurbishment work.
An asbestos and hazardous materials survey shall be conducted prior to any tenancy fit-out works, internal demolition, or refurbishment of building Maintenance service activities in areas to determine asbestos exposure risks and extent of other specified hazardous building materials that impacts on the safety or health of contractors, tenants or other occupants during building works.
A detailed survey can involve investigating areas and surfaces not previously accessed in the previous asbestos risk assessments (i.e. above set plaster ceilings, tiled or linoleum lined wall surfaces, eaves, voids and under carpeted areas for example.
8.
Element 5: Work Performed by Licensed Asbestos Removal Contractor
Planned asbestos removal works should be preceded by a further detailed asbestos survey. This is a requirement of the Safe Removal of Asbestos [NOHSC 2002: (2005)] and the State based Asbestos Regulations. It is important to note that most States based authorities require notification by the approved asbestos removal process – unless emergency conditions apply. A licensed asbestos removal contractor will conduct works involving the removal of ACM within a DHA residential property. A maximum quantity of asbestos product is specified in the various States for mandatory engagement of a licensed asbestos removalist for asbestos removal activities, nominally more than 10 square metres of non-friable asbestos product or material.Contractors must ensure that all asbestos related works are carried out in accordance with: o Relevant State legislation covering asbestos removal (Refer Appendix B)
o The Code of Practice for the management and control of Asbestos in work places [NOHSC: 2018 (2005)]
o The Code of Practice for the Safe Removal of Asbestos [NOHSC: 2002 (2005)]
o The Guidance Notes on the Membrane Filter Method for estimating Airborne Asbestos Fibres [NOHSC: 3003 (2005)]
o Commonwealth Occupational Health and Safety Standards (1991 & 1994)
Where asbestos abatement work is required, Defence Housing Australia will nominate the licensed asbestos removalist and any competent person, such as an occupational hygienist service provider to be used.
The following Elements are required prior to any asbestos removal work:
1. Review of proposed work by HMC Subject Matter Expert (SME) with tenant and the service contractor or builder
2. Preparation of scope of work (work method statement) by licensed/approved service contractor or builder
3. Preparation of technical scope of work by a risk management consultant incorporating procedures and guidelines for appropriate health and safety practice to control asbestos exposure risk, if the HMC SME deems this necessary
4. Review of proposed scope of work by nominated risk management consultant for the residential site, if the HMC SME deems this necessary
5. Review of licensed asbestos removal contractor’s Work Method Statement
6. Review of proposed occupational hygienist services relating to any supervision, air monitoring, inspections and clearance inspections
7. Provision of clearance visual inspection and Clearance Certificate 8. Review of previous asbestos abatement records
Asbestos Control Records and Revision of Asbestos Materials Register
The Defence Housing Australia Property Manager will retain copies of all records relating to asbestos risk assessments and abatement work in accordance with State based Asbestos
While each state varies in their prescription of asbestos abatement records, it is seen that the following records are the minimum requirement to document the effective management of asbestos processes. These are:
• Identification
o The date on which the survey was made and the details of the competent person/s who carried out the survey.
o Details on the location type and condition of the ACM o Details of any material presumed to contain asbestos o Any inaccessible area that is likely to contain ACM.
o The results of any analysis that has confirmed a material in the workplace is or is not an ACM
• Risk assessments
o The date the risk assessment was made and the details of the competent person/s who carried out the survey.
o The findings and conclusions of the risk assessment including any reviews or revisions of the risk assessment
o The results of any air monitoring for airborne asbestos fibres and an assessment of these results
• Control measures
o The control measures recommended and decided upon as a result of the risk assessment.
o Any maintenance or service work on an ACM, including the company or person involved, the date and the scope of work undertaken and details of Clarence certificate.
9.
Element 6 - Asbestos Risk Assessment Reviews
In accordance with the State based Regulations and the Code of Practice for the Management and Control of Asbestos in Workplaces [NOHSC: 2018 (2005)], an asbestos risk assessment should be carried out at least once a year at each residential property, to review evidence of the presence of asbestos-containing materials; and review damage to or deterioration of any asbestos-containing materials (Refer Table 1).
In accordance with the (NOHSC 2018 (2005), the web-based Asbestos Register will be revised at least annually through the HMC office, generally at the time of conducting the annual property condition inspection. Prior to any residential renovation managed by DHA, the Register must be reviewed and where necessary, additional detailed asbestos assessment must be conducted.
Table 1: Timetable for ACM Review
State NOHSC 2018: (2005)* Review Period
Victoria Yes Annually
New South Wales Yes Annually
Queensland Yes Annually
Northern Territory Yes Annually
ACT Yes Annually
Western Australia Yes Annually
South Australia Yes Annually
Tasmania Yes Annually
* Refer Appendix B
The Asbestos Regulations generally require either Property Owners, Employers, Occupiers, Self-employed people and other Accountable persons who manage and have control of a residential site to identify and assess and control risks arising from asbestos where the site is a workplace.
10. Labelling of Asbestos Materials
Labelling of asbestos materials should be reserved for ACM products or surfaces. It is not considered necessary to label internal feature walls, tiling and external building claddings of residential homes.
While, the National Occupational Health and Safety Commission (NOHSC) has published an updated Code of Practice(3) that provides advice in relation to labelling it is more necessary
to label in workplaces as opposed to tenant homes.
As DHA will manage asbestos-related issues at each site and that there is an on-line asbestos register, it is not considered necessary to place labels in the home. Clearly, labels can fall off, be defaced or painted over.
The impetus for this Management Plan is the effective proactive management of asbestos at the DHA residential sites and control of activities that could disturb asbestos materials.
11. Summary
of
Required
Actions
Subject to review of the up-dated records of asbestos materials and review of planned and routine maintenance and service tasks in the building, the following actions are required as a minimum:
1. Implement obligations under Asbestos Management Plan in DHA properties that contain known sources of asbestos materials or are suspected to contain asbestos materials (Deemed)
2. Formally notify and consult with Defence tenants on Asbestos Register and Asbestos Management Plan requirements in properties containing asbestos materials.
3. Formally notify and consult with building service contractors and building maintenance / custodial staff for the residential property containing asbestos materials.
4. Provide induction material and asbestos awareness sessions for nominated service contractors and building maintenance and DHA staff.
5. Prepare budgets and programs for abatement of asbestos materials in residential sites based upon risk profile and proposed up-grade of redevelopment works in line with State based Asbestos Regulations and to meet obligations to reduce exposure risk to tenants, DHA service and maintenance contractors.
12. Appendices
A: Defence Housing Australia Asbestos
Register User Guide Version, dated February 2006.
This document has been developed as a basic guide to assist HMC staff in utilizing the Asbestos Register until the final implementation of the Asbestos Management Plan. The Asbestos Management Plan will be finalised at the conclusion of property testing through the Asbestos Audit and Analysis program.
http://dha-p-portal01/AsbestosInternal/
B: Legislative Summary and Key Asbestos Requirements and Issues C: References
Australian Safety and Compensation Council (ASCC) (former National Occupational Health and Safety Commission
Web-links to Publications
NOHSC Code of Practice for the Management and Control of Asbestos in Workplaces [NOHSC: 2018 (2005)] April 2005
NOHSC Code of Practice for the Safe Removal of Asbestos, 2nd Edition [NOHSC: 2002 (2005)] April 2005
Asbestos Management Plan
DEFENCE HOUSING AUSTRALIA
Residential Sites
Asbestos Management Plan
Defence Housing Authority
Residential Sites
Victoria New South Wales
Queensland South Australia Western
Australia
Northern Territory
Tasmania ACT Federal
Legislation
Occupational Health and Safety Act 2004 Occupational Health and Safety (Asbestos) Regulations 2003 Industry Guideline Standard Specification for Asbestos Removal from Buildings, Structures, Ships, Plant and Workplaces – Victorian Asbestos Removal Consultative Committee (VARICC) comprising various industry representative (reprinted 2001 2nd Edition 1991) Legislation Occupational Health and Safety Act 2000 Occupational Health and Safety Regulation 2001
Part 4 Workplace premises and working environment, Part 4.2 Work Premises Division 4 Asbestos
Part 8 – Construction work, Part 8.7 Asbestos – particular provisions * Guideline Guide to the Occupational Health and Safety Regulation 2001 Demolition Licensing Chapters 10 and 11 Licensing Provisions and Permits for Certain Works Asbestos - Guidelines for Licensed Asbestos Removal Contractors Legislation
Workplace Health and Safety Act 1995 Workplace Health and Safety Regulation 1997 (Amended) Part 11Division 1 On-site Management of Asbestos Materials Division 2 – Asbestos Removal Division 3 – Prohibition about Asbestos * Advisory Standards
Workplace Health and Safety (Asbestos Removal) Advisory Standard 1999
Workplace Health and Safety (AC Sheeting) Advisory Standard 1999
Legislation
Occupational Health, Safety and Welfare Act 1986
Occupational Health, Safety and Welfare Regulation 1995 Occupational Health, Safety and Welfare (OHSW) Regulation November 2001 Division 4.2 -Asbestos Division 5.2 - Demolition Schedule 1 – Part 4 Hazardous
Substance and Part 5 Hazardous Work Schedule 5 – Hazardous Substances Prohibited for Specified Use * Code of Practice Code of Practice for the Safe Removal of Asbestos
Code of Practice for Asbestos Work (Excluding Asbestos Removal)
Legislation
Occupational Safety and Health Act 1984 Occupational Safety and Health Regulations 1996
Part 3 Workplace Safety requirements Division 9 Safety requirements in relation to certain work processes r 3.126 Demolition work involving asbestos Part 5 Hazardous Substances Division 4 Further requirements in relation to certain hazardous substances r.5.42 Subdivision 1 - Asbestos Health (Asbestos) Regulation 1992 Code of Practice National Code of Practice [NOHSC: 2002 (2005)] Safe Removal of Asbestos ([NOHSC:2018 (2005)] Management and Control of Asbestos Materials in Workplaces Legislation
Work Health Act and various amendments
Work Health (Occupational Health & Safety) Regulations 1992 Code of Practice National Code of Practice [NOHSC: 2002 (2005)] Safe Removal of Asbestos ([NOHSC:2018 (2005)] Management and Control of Asbestos Materials in Workplaces Legislation Workplace Health and Safety Act 1995 Workplace Health and Safety Regulations 1998 and Division 9 Asbestos Code of Practice National Code of Practice [NOHSC: 2002 (2005)] Safe Removal of Asbestos ([NOHSC:2018 (2005)] Management and Control of Asbestos Materials in Workplaces Legislation Occupational Health and Safety Act 1989 Dangerous Substances (Asbestos Advice) Notice 2006 (No 1) enacted in Dangerous Goods Act 1975 *Code of Practice ACT Workcover Code of Practice 2006 in line with National Code of Practice Legislation Occupational Health and Safety (Commonwealth Employment) Act 1991 Code of Practice National Code of Practice [NOHSC: 2002 (2005)] Safe Removal of Asbestos ([NOHSC:2018 (2005)] Management and Control of Asbestos Materials in Workplaces Other Related Publications [http://www.NOHSC.g ov.au/ohsinformation/ NOHSCpublications/f ulltext/toc/H3-11.htm)
Specific Asbestos Requirement or Issue Victoria New South Wales
ACT Queensland South
Australia Western Australia Northern Territory Tasmania Who is responsible for asbestos management & control? Employer and
Occupier Employer Employer Owner/ Manager/
Occupier
Employer and
Occupier Employer, person with control or contractor
Employer Accountable Person
Restriction on purchase/retailing of asbestos materials? Total Ban on importation, use and re-use
How is compliance enforced? Fines - penalty units (pu) or $
With whom should the employer consult? HSR Employees Employees Employees
and their reps HSR, employees Employees HSC, employees Employees/ contractors
Are surveys required to identify asbestos? Yes Yes Yes Yes Yes Yes Yes Yes
Who is responsible for conducting audits? Employer/
Occupier Controller of premises Owners, lessees Owner, agent or manager Owners & possessor of asbestos Employer, control person contractor Employers Accountable Person
Is labelling required? Yes advised Yes Yes Yes Yes Yes Yes Yes
Are risk assessments required for asbestos materials? Yes Yes Yes Yes Yes Yes Yes Yes
If so, is there a prescribed method for risk assessments. OHS (Asb)
Regs 2003 NSR Yes NOHSC: (2005) 2018 NOHSC: 2018 (2005) NOHSC: 2018 (2005) NOHSC: 2018 (2005) NOHSC: 2018 (2005)
Who is required to conduct assessments? Competent
person Controller of Premises Competent person Qualified person Competent person Competent person Competent person Competent person
Specific controls required for asbestos in buildings? Yes Yes Yes Yes Yes Yes Yes Yes
Are approved removal contractors required for friable
asbestos? Yes Yes NSR Yes Yes Yes NSR Yes
Are approved removal contractors required for non-friable
asbestos? Yes >10m 2 Yes >10m2 July 01, 2007 Yes (DG Amendment) July 2006
Yes >10m2 Yes >10m2 Yes >10m2 Yes >10m2 Yes
Are registers required? Yes Yes Yes Yes Yes Yes Yes Yes
Specific requirements for removal of asbestos OHS (Asb)
Regs 2003 OHS Legislation Yes NOHSC: (2005) 2002 NOHSC: 2002 (2005) NOHSC: 2002(2005) NOHSC: 2002 (2005) NOHSC: 2002 (2005)
Are clearance certificates required to be issued by
competent persons (hygienist) Yes Yes Yes Yes Yes Yes NSR Yes
Where are details of approval process found? Worksafe
Victoria WorkCover Comcare QLD DETIR Workcover Worksafe WA Workplace Safety Workplace Standards
Asbestos Management Plan
Defence Housing Authority
Residential Sites
Appendix B: References - Australian Safety and Compensation Publications
and Web-links [NOHSC: 2018 (2005)] and [NOHSC: 2002 (2005)] 2
ndedition
Asbestos Management Plan
Defence Housing Authority
Residential Sites
Appendix C: DHA Asbestos Service Providers
Australian Safety and Compensation Council – Former National Occupational Health and Safety Commission (NOHSC)
Publication Links
1. National Code of Practice for the Management and Control of Asbestos in Workplaces [NOHSC: 2018 (2005)]
http://www.NOHSC.gov.au/PDF/temp/ManagementCode.pdf
2. National Code of Practice for the Safe Removal of Asbestos , 2nd Edition [NOHSC: 2002 (2005)]
