Introduction

 

Asbestos is a naturally occurring mineral that was incorporated into a wide variety of materials which were part of buildings in the UK up to the year 2000. Asbestos requires careful management as asbestos fibres can be released into the air and breathed in, putting people at great risk of serious diseases in later life, such as lung cancer.

 Schools should take the following steps to managing asbestos:

  1. Have a ‘management survey’ of asbestos-containing materials (ACMs) in the school
  2. Assess the risks associated with ACMs in the school
  3. Devise a plan for managing asbestos in the school
  4. Make sure staff, visitors and contractors know the risks and precautions they need to take
  5. Keep the management of asbestos under review

This guidance informs schools how to achieve the above bullet pointed list effectively, ensuring that schools know how to manage asbestos safely.

 

Responsible persons

 

The legal responsibility for the safe management of asbestos lies with the duty holder

Duty holder: the person/people responsible for maintenance and/or repair of the school – typically, the employer.

For community schools, community special schools, voluntary-controlled schools, maintained nursery schools and PRUs, the employer (and so the duty holder) is the LA. For academies, free schools, voluntary-aided or foundation schools, the employer (and so the duty holder) is the school governors or the trust. In the case of independent schools, the employer (and so duty holder) may be the proprietor, governors or trustees.

It is important to note, however, that even if you are not the duty holder for a school, it is still your responsibility to play your part in the safe management of asbestos.

Informing people about asbestos

  • The duty holder is required to consult with employees on matters that affect their health and safety, including asbestos management.
  • The duty holder is not required to inform parents about the presence of asbestos in their children’s school; however, if parents request information, schools should be responsive to this. Offering the information to parents can be a positive way to showcase that you are effectively managing asbestos.
  • If the management arrangements at the school in place to prevent disturbance of ACMs fail, resulting in an accidental release of asbestos fibres, you must inform those affected.

Step one – Conducting a management survey

 

Duty holders need to carry out an asbestos management survey to identify those ACMs which may be disrupted in the course of routine maintenance or everyday activities – this needs to be done for all buildings constructed before the year 2000, including new buildings with residual elements of pre-2000 buildings.

The aim of the survey is to produce a comprehensive and systematic asbestos register that records the location and condition of the asbestos in your school buildings. The survey should be conducted in line with HSE guidance and undertaken by a United Kingdom Accreditation Service (UKAS) accredited surveying organisation.

As the survey assesses all the accessible places, such as the ceilings and in the floor ducting, there may be some minor intrusion in the fabric of the building and it may involve taking samples to identify if materials contain asbestos; however, to avoid the spreading of any asbestos fibres, disturbance should be kept to a minimum. As a cautionary note, this does mean that the survey will only tell schools about ACMs that are easily accessible.

If your school undertakes any building works, you may need a refurbishment and demolition survey of the areas where the work is being carried out.

Schools may find it helpful to arrange for the surveyor to meet with school staff to brief them on the survey once it is completed and advise them on the risks presented by the materials, including how they should be managed.

 

Step two – Assessing the risks associated with ACMs

 

Once the survey has been completed, the duty holder should assess the risks associated with each identified occurrence of asbestos in the school as part of the Asbestos Management Plan (AMP), which is further explained in Step three.

The assessment has three parts:

  • ‘Material’ assessment: This is usually assessed within the survey and is an assessment of each item of asbestos material identified, based upon the type of material, the type of asbestos it contains, its surface treatment and the extent of the damage.
  • ‘Priority’ assessment: This is the duty holder’s assessment of the likelihood of someone disturbing the material based upon factors such as the number and type of people using the room, the time they spend in the room, the location, accessibility, extent of the asbestos, and the frequency and type of activity that might disturb the ACM.
  • ‘Total’ assessment: This amalgamates the material and priority assessments. This assessment allows for a comparison to be made of the risk presented by each item of ACM in the school, so that priorities can be set and management plans made.

Click here to view HSE’s example scoring system for the material and priority assessment contributions to the total assessment. TheSchoolBus has also produced an Asbestos Scoring Tools and Register, which can be amended and used by schools when conducting an asbestos survey.

It is important that senior leaders of schools work with their asbestos surveyor to establish the risk of ACMs being disturbed. Remember to recognise the use of the location and the people who may be present – pupils may be more likely to engage in activities that may disturb ACMs, e.g. playing unsupervised football in a corridor with asbestos ceiling tiles.

 

Step three – Devising a plan for managing asbestos

 

After establishing where in your school there are ACMs and assessing the associated total risks, you should plan how you will manage the risks and put them into practice. Included in the plans should be details on how you will communicate with and train relevant staff.

If asbestos in your school is in good condition and it is unlikely to be damaged, it is usually safer to leave it in place and regularly monitor its condition. When there is a change of circumstances, such as a change of building use, you are required to review the AMP.

If any ACM is in bad condition or at risk of being damaged, professional advice should be sought regarding the necessary remedial works.

An AMP should include:

  • Your plans to manage the risks from ACMs in the school on a day-to-day basis.
  • Arrangements to inform all staff and contractors about the location of ACMs.
  • Measures that need to be taken to prevent disturbing ACMs.
  • Your plans to check for less easily accessible ACMs, where intrusive work is planned.
  • The schedule for monitoring the condition of ACMs.

You should ensure that your management arrangements are effective during school closure periods, such as after school hours and community use, when school staff presence is minimal.

 

Step four – Spreading awareness

 

It is vital to enforce that everyone in a school management role has a part to play in making sure asbestos is managed effectively – all relevant staff should receive the right information, instruction and training, and should be clear what procedures are in place and how to follow them.

The level of training will depend on the roles of individual staff – caretakers and site managers will likely require more instruction and training than teaching staff. Teaching staff are often not directly involved in managing the buildings or in carrying out repairs; however, they will need to know the location of ACMs and how they can be damaged or disturbed, e.g. work being pinned to walls or through unruly pupil behaviour.

Schools must also include details about asbestos that is present to visitors of the school, e.g. contractors and users of the buildings for community activities. Schools should outline the areas that should be avoided and any other instructions that should be followed – this information should be detailed in the relevant school policies.

It is also important to make sure all staff members are aware of where asbestos can be found within the school to aid the emergency services. Emergency services may request information about the asbestos that is present in your school and you should have plans in place to ensure that you can provide this information if it is requested.

 

Step five – Reviewing asbestos management

 

Schools must review and update their AMP when:

  • You get new information, e.g. from refurbishment and demolition surveys.
  • Work is undertaken on ACMs.
  • Damage to ACMs occurs.
  • ACMs are removed.

The school’s asbestos register should be used to record the regular inspections carried out by school personnel. The register should be reviewed at least annually – any changes to the register or the AMP will need to be communicated to all relevant staff.

Building and maintenance work

The asbestos survey will only cover readily accessible areas and, as a result, may not have identified all the ACMs present. If there is a risk that building and maintenance work will disturb further and hidden ACMs, schools will need to arrange for a refurbishment and demolition survey, as aforementioned, to be undertaken. This is a more intrusive survey done under controlled conditions. Once the survey has been done, schools must pass on the findings of both types of surveys to those who are carrying out the work.

Some small, short duration tasks can be carried out by non-licensed workers, provided they have received appropriate information, instruction and training and the correct risk control measures are used.

Schools must ensure that higher-risk work, such as removal of asbestos lagging and loose insulation, is done by a contractor licensed by the HSE. It may be required for schools to notify the HSE of some types of non-licensed work; advice on this can be found here.

 

Funding

 

The government allocates funding for maintenance works, including work on asbestos, differently depending on the status of your school.

If your school is maintained, a voluntary-aided school or in a larger MAT, money is allocated to the body responsible for maintaining the school. More information about these allocations can be found on GOV.UK. Smaller or standalone academy trusts and sixth-form colleges bid for capital funding through the Condition Improvement Fund.

 

If things go wrong

 

If there has been a disturbance of asbestos in the school, you should:

  • Stop activity in the affected area immediately.
  • Remove everyone from the affected area.
  • Ensure that staff and pupils are not able to access the area and do not remove any items, including equipment, books or personal possessions, from the area.
  • Get advice from an asbestos expert regarding any necessary remedial action.
  • Prevent access to the area until any necessary remedial action has taken place.

Unless the incident is minor, you should notify the HSE, as specified in the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 2013.

Failure to comply with the Control of Asbestos Regulations 2012 is a criminal offence. The HSE investigates incidents where duty holders fail to manage the risks and takes enforcement action where appropriate.

 

What’s next?

 

Ensure your school has a comprehensive policy in place which details how asbestos is managed within your school, by using TheSchoolBus’ Asbestos Management Policy .

Our Premises and Asbestos Compliance Tracker can be used to help you ensure that you meet the statutory requirements with regards to asbestos management.  

 

 

Bibliography

ESFA (2017) ‘Managing asbestos in your school’