Asbestos management checklist for schools: What Do I Need to Know
More than two decades may have now passed since the banning of all forms of asbestos in the UK, but many buildings up and down the country still contain this lethal material. This includes a significant proportion – potentially as many as 75% or more – of schools.
As the importation and use of asbestos in the UK was banned in late 1999, there shouldn’t be any asbestos in school buildings that were constructed after the year 2000. If, however, a given building on school premises for which you are responsible was constructed before this date, there will be a strong likelihood of some form of asbestos-containing materials (ACMs) being present inside.
But are you sure about the steps you will need to take in order to manage any asbestos in your own school buildings? Or are you uncertain as to who will even be responsible for managing the asbestos within your school? Below, we have set out a comprehensive asbestos management checklist for schools, to help answer these questions.
- 1 What is an asbestos management plan, and why is it important?
- 2 Whose responsibility is it to manage the plan? Who is the dutyholder in a school?
What should the management plan checklist cover?
- 3.1 Is the school management team aware who has the overall legal responsibility for the management of maintenance and repair of the school buildings?
- 3.2 Has the dutyholder carried out a management survey?
- 3.3 Does the management survey highlight the location of ACMs?
- 3.4 Has the dutyholder assessed the potential risk from the ACMs?
- 3.5 Does the dutyholder have a management plan detailing how to manage the risks from any ACMs at the school?
- 3.6 Are precautions in place to ensure anyone who may disturb ACMs is provided with information about any asbestos present?
- 3.7 Are any in-house staff, who may undertake maintenance work, adequately trained?
- 4 What action should the dutyholder take to address any issues found?
What is an asbestos management plan, and why is it important?
The term “asbestos management plan” refers to the document – whether handwritten on paper, or typed up on a computer – that states exactly who is responsible for managing asbestos in a given public or commercial building. In addition – and as the term “asbestos management plan” suggests – this document will also need to explain what steps will be taken to manage the on-site asbestos.
So, the asbestos management plan that you create for your school will need to also contain the asbestos register you have in place for the premises (an “asbestos register” being a document that sets out where asbestos is located on the site, or where asbestos may be present).
Furthermore, you will need to ensure your school’s asbestos management plan explains what your plans are to work on asbestos materials on the premises. In addition, it should show the schedule for monitoring the ACMs’ condition, and there should be arrangements to let other people know about your decisions in relation to asbestos on your school site.
The asbestos management plan should also be easy to access and read for anyone who may need to look at in the future. By “anyone”, we mean not only staff and visitors, but also any tradespeople who might need to refer to the document prior to carrying out work at the school that could disturb the ACMs.
As you might imagine, an asbestos management plan is extremely important for ensuring dutyholders manage any on-site asbestos in a safe manner (and we’ll get onto the subject of “dutyholders” in greater detail shortly).
However, an asbestos management plan is also vital for ensuring you fulfil your legal responsibilities in accordance with the Control of Asbestos Regulations 2012 (CAR 2012). Regulation 4 of CAR 2012 makes clear that dutyholders are expected to put together a plan outlining the measures that will be adopted to manage the risks arising from ACMs on a given site.
Whose responsibility is it to manage the plan? Who is the dutyholder in a school?
Central to CAR 2012 is the concept of the “duty to manage” asbestos. The person or organisation that has this “duty” is also known as the “dutyholder”, but it might not be immediately obvious to you who or what would be the “dutyholder” for your school.
As the Health and Safety Executive (HSE) has advised, the dutyholder under CAR 2012 is either the owner of the given non-domestic premises, or the person or organisation that has clear responsibility for the maintenance or repair of the premises.
When it comes to schools and similar public buildings, the identity of the dutyholder depends on how responsibility for the premises’ maintenance is allocated. In the case of most schools, it will be the employer that is the dutyholder. However, the task of determining who or what the employer is, will depend on what type of school is involved.
If, for instance, a given school is under the management of the local authority – as is the case with community schools and voluntary-controlled schools – it is the local authority that will be the employer. In the case of voluntary-aided and foundation schools, though, the school governors will have this status, while for academy and Free Schools, the employer will be the academy trust. As for independent and fee-paying schools, the proprietor, governors, or trustees may be the dutyholders.
Sometimes, a local authority delegates budgets for the maintenance and repair of school buildings to the schools in question. In these instances, the local authority and the school share the duty to manage asbestos on the given school’s premises.
What should the management plan checklist cover?
All dutyholders for a given school will be expected to make sure effective management of any on-site ACMs is in place. However, it is crucial to do everything possible to ensure the right precautions are being taken. You won’t want to miss or overlook anything vital when it comes to the management of asbestos on your school site.
So, to help ensure you cover every conceivable issue, we have set out an asbestos management checklist for schools below.
Is the school management team aware who has the overall legal responsibility for the management of maintenance and repair of the school buildings?
As we explained above, the person or organisation responsible for managing asbestos on your school site, under CAR 2012, will be whoever is responsible for maintaining and repairing the premises. For some schools, there will be multiple dutyholders, who will share responsibility for managing asbestos.
Has the dutyholder carried out a management survey?
The term “asbestos management survey” refers to the standard survey that needs to be undertaken on any non-domestic premises built prior to the year 2000, in accordance with regulation 4 of CAR 2012. A management survey can be crucial for identifying the location and type of any ACMs on your school premises.
Does the management survey highlight the location of ACMs?
The management survey that you arrange for the school premises in your capacity as the dutyholder, should cover every part of the school site.
So, when you request professional asbestos surveying services from a specialist company such as Oracle Solutions, you should check that the survey will include such easily overlooked areas of the school buildings as the storerooms, yards, underfloor services, outbuildings, pipes, ceiling voids and corridors. It is important to recognise that this list is not necessarily an exhaustive one.
Has the dutyholder assessed the potential risk from the ACMs?
When carrying out an assessment of the asbestos situation on their school premises, the dutyholder should take into account the condition of the ACMs, as well as the likelihood of disturbance to the materials.
These factors will help the dutyholder make informed decisions on the courses of action they will need to take, in order to manage the asbestos risks on their site.
Does the dutyholder have a management plan detailing how to manage the risks from any ACMs at the school?
To reiterate what we stated above, the asbestos management plan is of great importance for ensuring the effective management of on-site ACMs at a school.
If you are the dutyholder for your school, you should bring together all the available and relevant information in your preparation of the plan. The plan will need to explain not only what you will be doing, but also when you are going to do it, and how you will do it. You will need to provide such details for ongoing management actions such as periodic checks, as well as for any remedial work.
The asbestos management plan should also set out clear lines of responsibility, so that there is no question of anyone attempting to evade their duties in relation to management of the ACMs.
Are precautions in place to ensure anyone who may disturb ACMs is provided with information about any asbestos present?
If someone is set to carry out work that could cause disturbance to ACMs on your school premises, whether from within or outside your organisation, it is crucial to provide them with details in relation to any asbestos present, before they begin work.
This will allow for implementation of appropriate measures for guarding against asbestos risk.
Are any in-house staff, who may undertake maintenance work, adequately trained?
Three broad types of asbestos training are available: asbestos awareness training, training for work with asbestos for which a licence from the HSE is not required, and training for work with asbestos for which a licence from the HSE is needed.
These distinctions are crucial, given that any training you arrange will need to be suitable for the work that is to be carried out on your school premises.
Awareness training, for example, is invaluable for staff whose work could cause them to come into contact with asbestos while undertaking their day-to-day tasks. It is not, however, sufficient for staff who intend to carry out work directly on the ACMs themselves.
As for training for asbestos work for which a licence from the HSE is not required, this is designed for staff who plan to undertake work on ACMs where there is a much higher likelihood of exposure. An example of such work would be the installation of cables in areas containing undamaged asbestos materials.
Finally, training for asbestos work for which there is a need for a licence from the HSE, covers most work on asbestos insulation, asbestos insulating board and lagging, including sealing and removal. When work needs to be done on these higher-risk ACMs, it is usually necessary to arrange for a licensed contractor to carry it out.
What action should the dutyholder take to address any issues found?
In the event that, as a dutyholder for a school, you do find issues with asbestos on the premises, you will need to consider what the suitable next courses of action would be, in accordance with CAR 2012.
It is important to appreciate that asbestos simply being discovered on your school site doesn’t necessarily mean you will need to remove it. Much will depend on such factors as the location, amount, and condition of the ACMs, and the likelihood of disturbance occurring to these asbestos materials in the future.
We have previously set out a detailed asbestos management guide for those who have the “duty to manage” asbestos on commercial and public premises, such as schools.
Here at Oracle Solutions, we provide wide-ranging asbestos services to assist you with this management process; for further information and a competitive quote, please do not hesitate to call us, or to complete and submit our straightforward online contact form.
Written by Jess Scott
Jess Scott has been an all-round asbestos consultant since 1996. That’s nearly 3 decades of asbestos knowledge. He spends his time sharing that knowledge with the team at Oracle and with their clients. Jess's goal is, and always has been, to use my expertise in helping people to comply with the law. This legal compliance ultimately helps to protect everyone from the harmful effects of asbestos. Jess has acted as an asbestos expert witness in legal cases and is involved in many asbestos educational activities throughout the UK.