is there asbestos in your rc? - wordpress.com · guidance 7.16 ciriac733 (2014) c765 (2017)...

Demolition and asbestos in

RC?_MCCSG

8.10.18

Wayne Bagnall Ltd Birchwood WA3 4FS

www.waynebagnall.co.uk 07712 767744 1

MCCSG: Demolition update 8.10.18

Wayne Bagnall MBE

MSc CMIOSH MIDE MCMI

Is there asbestos in your RC?

• Specialist in asbestos & demolition safety

management for advice, solutions & training

– Please visit my Web Site

– Allows access to downloads

– Provides updates

www.waynebagnall.co.uk

– 1984 Director of medium sized Asbestos & Demolition company

– 1995 Authored CITB Demolition & updated Asbestos module (GE 700)

– 1996 Part authored BS6187: 2000 Demolition Code of Practice

– 1997 MBE awarded for “Services to the Building Industry” by HM Queen

– 1999 Set up an independent Asbestos & Demolition Consultancy

– 2000 Masters degree in Construction (H&S) Mgnt, Liverpool JMU

– 2002 Authored new HSE demolition guidance

– 2004 Shell, BP, Sellafield “WAGR & Calder Hall Colling Towers” advisor

– 2005 Assisted HSE launch of Asbestos Regs 2006 & HSE Demolition training

– 2006 BAE Systems asbestos, demolition UK consultant & IDE Council Member

– 2008 Supervised major rail/road bridge demolitions for Network Rail

– 2009 UKATA Registered Member (UK Asbestos Trainers Association)

– 2010 Contributor in the revision of BS 6187 Demolition code of practice

– 2012 Appointed Demolition Consultant on one of the largest projects in the UK

– 2013 Provided RWEN Power with demolition training

– 2015 Delivered papers to National IDE conferences in Leeds & London

– 2016 Expert witness appointments for major corporations; SSE, RWE etc

– 2017 Prepared and delivered training for HSE Inspectors

– 2018 Bespoke training HSENI, working with HSE on new Welfare Regs & ATO

Presentation (as IDE 2.2018)

1. Introduction & background

2. Findings of an Asbestos R&D Survey

3. History of asbestos cement products in concrete

4. Position of the Health & Safety Executive

5. Position of the Environment Agency

6. Protocols and control measures during the

demolition & processing of the arisings

Mill demolition + poor survey = gross asbestos

contamination in recycled aggregate (40K m³) After demolition building slab lifted ACMs found in the

sub-base material (1960 building)

CL:AIRE soil

guidance 7.16 Ciria C733 (2014) Ciria C765 (2017)

http://www.waynebagnall.co.uk/


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8.10.18



(Poor) Asbestos Survey;

CAF gaskets & refractory only

Recommended a controlled

hole (drill) through steel shell

Result = Asbestos Insulating

Board Lining (~40% Amosite)

Projection UK annual mesothelioma deaths

Part 2:

HSG 264

Asbestos R&D Survey

&

findings

Client engaged UKAS

Accredited Surveyors

(ISO 17020) for part of PCI

Asbestos Refurbishment

& Demolition Survey

(HSG 264)

Typical 1960’-70’s 7 storey reinforced concrete frame building built

behind a 1900’s façade (400m³ concrete / floor x 7 = circa 6,500t)

(Asbestos) Cement Spacers are only visible when

they had flipped over (typically 3 or 4 / m²)


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The hole in the

spacer was useful

to take a sample.

Confirmed as a

very hard Asbestos

Cement

~5% Chrysotile

(white)

These shaped

spacers were

identified, sampled

& confirmed as

Asbestos Cement

~5% Chrysotile

(white)~50mm x 50mm x ?

NB: Some spacers

were fibre cement

and others plastic! Extract from Asbestos

R&D Survey

NB They have found these on

one other project

Assuming ALL spacers are Asbestos Cement, which they’re not;

(<4 spacers/m²) with 7 floors x 1600m² (400m³) concrete / floor

circa 6,500t arisings assuming no removal during the demolition

(asbestos range from 0.002% to 0.03% w/w)


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Core sample:

Lab unsuccessfully

attempted to separate

the spacer from the RC

Material was extremely

hard & bonded in RC

History of Asbestos Cement

Spacers

Plus other spacers as used in

reinforced concrete

I carried out a

web search; Blue

Circle, Lafarge,

Concrete Society

& also enlisted the

help of Steve

Sadley – ARCA

Attempts to

contact the

Concrete Society

via their website

failed, however...

Answer:

Frank advertised (via Creteco) asbestos spacers in 1977, see attached. Similar adverts in 1984 omitted the word asbestos for just fibre. Unfortunately we don't have the directories between 77 and 84 to see when the change occurred.

Frank is now Max Frank and I believe Creteco is part of the same organisation. http://www.maxfrank.co.uk/uk/contact-us/index.php

Click here to respond

Richard DayThe Concrete Society Ltd

Please note that The Concrete Society is a membership organisation and, as such, in-depth advice is generally only provided to members of The Concrete Society.

The Concrete Advisory Service is operated by the employed staff or nominated agents of The Concrete Society Ltd. Any advice, guidance, opinion or recommendation must not be interpreted as being representative of the collective view of The Society's membership. The Concrete Society responded to ARCA with;

Asbestos Spacers were advertised in 1977 (Creteco)

1984 similar adverts were out but omitted the word

asbestos inserted fibre (no records between 1977 – 84)

CRETECO

Manufactured Asbestos

Cement products

(in 1cwt / ~50kg bags)

I polled several construction

specialists; one person from

Fairclough used to make their

own Cement spacers for RC

with wires for fixing by;

• Mould set to required depth

• Trowel in a strong mix &

scored before setting

• Left overnight then broken

into pieces (squares)

http://www.maxfrank.co.uk/uk/contact-us/index.php

http://www.concrete.org.uk/contact-form-tech.asp?cmd=respond&id=851


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Current products

for spacers

include;

Fibre reinforced

concrete, plastic

and metal

RC + fibre reinforced concrete spacer/tube

NB older spacers are likely asbestos (AC)

Modern non-asbestos fibre spacers

Examples of

plastic spacers to

provide sufficient

cover to metal

rebar

http://www.southcoa

ststeel.co.uk/index.p

hp

We found these plastic spacers in precast units & waffle slabs


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We found these plastic spacers in precast units & waffle slabs

HSE & Environment Agency

opinion on these Asbestos

Cement Spacers

CAR 2012 (Asbestos Regs)

and

WM3 & REACH(Registration, Evaluation, Authorisation and

Restriction of Chemicals)

Haz Waste 05 REACH 07 Others….

App. Code

of Practice

L143 (2nd edition)

Asbestos ACOP

App. Code

of Practice

Guidance Guidance

Health and Safety at Work Act 1974

Control of Asbestos Regulations 2012(changes e.g. NNLW etc. into force 6.4.12)

CAR 2012, L143 ACOP & Demolition work

• Reg 7: plans of work; ACOP & Guidance

In the case of demolition or major refurbishment, the plan of

work must specify that all asbestos is removed before any

major work begins, where this is reasonably practicable & does

not cause a greater risk to employees than if the asbestos had

been left in place (paragraph 190)

• Where removal of ACMs is time-consuming and resource-

intensive & only involves lower risk material such as textured

decorative coatings containing asbestos, then removal may not

be reasonably practicable (paragraph 191)

• Remember ‘Duty of care’ where known asbestos left in

• Limit of quantification for testing = 0.001% w/w

HSE also referred me to

this old 2008 guidance

1. AC spacers at ~5% white asbestos & very hard;1. Asbestos has not been deliberately added (REACH)

2. It was not reasonably practicable to remove in advance

3. Ensure conventional dust suppression for RCS (wetting)

4. Opinion was that the health risks were extremely low

5. Remote / mechanical demolition was suitable

6. Suitable control measures and sporadic testing

7. This activity would NOT be defined as work with asbestos

2. Must ensure the following:1. Identify spacers; paint to identify & remove pieces >demo

2. Ensure controls to minimise exposure & spread (as above)

3. Could be processed & crushed (keep damp)

4. Process & use arisings sensibly (e.g. under slabs)

HSE: Demolition & health risks from AC spacers


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Respirable crystalline silica (SiO²) = Silicosis**Quarries video; http://youtu.be/sWLPMgpMQCU

Crushing, scabbling, sawing & drilling stone with high silica (quartz) e.g.

Concrete Dust exposure must NOT exceed 0.1 mg/m3 (WEL)

**Similar effect as Asbestosis: Silicosis killing 900 persons/year**

Pictorial Depiction of WEL

IOSH & HSE campaigns; Shadows on X-rays indicates silicosis**

6. Asbestos fibres

(a) Crocidolite

CAS No 12001-28-4

(b) Amosite

CAS No 12172-73-5

(c) Anthophyllite

CAS No 77536-67-5

(d) Actinolite

CAS No 77536-66-4

(e) Tremolite

CAS No 77536-68-6

(f) Chrysotile

CAS No 12001-29-5

CAS No 132207-32-0

1. The manufacture, placing on the market and use of these fibres and of articles and mixturescontaining these fibres added intentionally is prohibited.

However, Member States may exempt the placing on the market and use of diaphragmscontaining chrysotile (point (f)) for existing electrolysis installations until they reach the end oftheir service life, or until suitable asbestos-free substitutes become available, whichever is thesooner.

By 1 June 2011 Member States making use of this exemption shall provide a report to theCommission on the availability of asbestos free substitutes for electrolysis installations and theefforts undertaken to develop such alternatives, on the protection of the health of workers inthe installations, on the source and quantities of chrysotile, on the source and quantities ofdiaphragms containing chrysotile, and the envisaged date of the end of the exemption. TheCommission shall make this information publicly available.

Following receipt of those reports, the Commission shall request the Agency to prepare adossier in accordance with Article 69 with a view to prohibit the placing on the market and useof diaphragms containing chrysotile.

2. The use of articles containing asbestos fibres referred to in paragraph 1 which were alreadyinstalled and/or in service before 1 January 2005 shall continue to be permitted until they aredisposed of or reach the end of their service life. However, Member States may, for reasons ofprotection of human health, restrict, prohibit or make subject to specific conditions, the use ofsuch articles before they are disposed of or reach the end of their service life. Member Statesmay allow placing on the market of articles in their entirety containing asbestos fibres referredto in paragraph 1 which were already installed and/or in service before 1 January 2005, underspecific conditions ensuring a high level of protection of human health. Member States shallcommunicate these national measures to the Commission by 1 June 2011. The Commissionshall make this information publicly available.

3. Without prejudice to the application of other Community provisions on the classification,packaging and labelling of substances and mixtures, the placing on the market and use ofarticles containing these fibres, as permitted according to the preceding derogations, shall bepermitted only if suppliers ensure before the placing on the market that articles bear a label inaccordance with Appendix 7 to this Annex.

HSE & REACH: As with all the restrictions it was not the intention to change the wording or the meaning of them as they were moved into Annex XVII from their previous homes.

Therefore there is nothing to suggest that the legal advice that you previously received has changed in any way.It is clear from para 1 that the restriction only refers to the intentional addition of the asbestos.

Annex XVII of REACH contains a list of the restrictions, number 6 refers to Asbestos. The legal text is above for

ease of reference.

1. We have discussed this waste with National haz

waste colleagues and we consider the codes 17 09

03*/17 09 04 are appropriate for this waste. As this is

a mirror entry classification an assessment must be

made in accordance with WM3. The assessment

(calculation) you have carried out indicates that in this

case the code would be 17 09 04.

2. However, it is important to stress that even if the

asbestos is below hazardous waste thresholds, it is

still present in the waste. Whenever asbestos is

present there are restrictions for its use under

REACH meaning that the waste CANNOT go

for crushing to form aggregate for re-use.

EA initial position on Waste Classification (1:2)

3. That being so regrettably the waste will have to go to

landfill.

4. The presence of asbestos in the waste must be

legally declared on the duty of care transfer note

where it has been assessed as 17 09 04 so that it

can be managed appropriately.

5. The producers must seek specialist advice around

working with asbestos before it is moved off site.

EA initial position on Waste Classification (2:2) After some lengthy dialogue with the

Environment Agency...

http://youtu.be/sWLPMgpMQCU


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1. We have not yet had a response in respect of

REACH but my colleague and I are both of the view

that REACH is about products (including products

made from waste) and hence would apply if you were

wishing to produce a recycled aggregate, for example

under the Quality Protocol.

2. If you only wish to retain some of the waste on site for

use under a slab where it would not be disturbed then

this may be able to be achieved under the current

version of CL:AIRE DoWCoP

https://www.claire.co.uk/projects-and-initiatives/dow-

cop.

EA LATER position on Waste Classification (1:2)

3. This would allow re-use of materials that could be

described as having some hazardous properties,

such as minimal asbestos, if used in certain ways on

site.

4. HSE take also reflects this view. The general concern

is long term management.

5. So cover under concrete slabs or hard surfaces has

been acceptable if passed by the relevant

Environmental Health Officer and planning

requirements for the development in question.

EA LATER position on Waste Classification (2:2)

Protocols & control

measures during

the demolition

Including

processing of the

arisings

CL:AIRE guide 7.16 Ciria C733 (2014)

Ciria C765 (2017)

1. Received PCI including Asbestos R&D Survey;1. Considered the report issued by the client (<0.1% w/w)

2. Not reasonably practicable to full removal in advance

3. Identified these spacers where visible

4. Used conventional dust suppression for RCS (light sprays)

5. Mechanical demolition; top down (floor by floor)

6. Any painted concrete would be removed as an ACM

7. Suitable controls + dust testing to prove effectiveness

2. Arisings to be landfilled & recycled:1. Only separated ACM (painted pieces) to landfill

2. Found a home for the arisings (subject to above protocol)

3. Would be processed & crushed (kept damp)

4. Arisings would be sensibly used (e.g. under slabs)

Demolition Contractors proposed arrangements

Marking Asbestos Cement Spacers, contractor

initially used white instead of RED paint Marking Asbestos Cement Spacers with RED

https://www.claire.co.uk/projects-and-initiatives/dow-cop


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1. Asbestos has not been deliberately added (REACH)

2. It is not reasonably practicable to remove in advance

3. Conventional dust suppression for RCS (wetting)

4. Opinion is that the health risks were extremely low

5. Remote / mechanical demolition was suitable

6. Efforts to remove ACMs during the demolition process

7. Suitable control measures with sporadic testing

8. This activity is NOT defined as work with asbestos

• Arisings (waste & product):1. Picked ACMs double bagged/disposed (Haz Waste >0.1%)

2. Majority >99% will be processed and used appropriately

It is not an exact science, however, given common senseand honesty there are sensible solutions

Summary and outputs

During demolition RED Asbestos Cement

Spacers + adhered concrete were picked, double

bagged & disposed of as Hazardous Waste

Private details

This presentation

is on a specific

project with a

preciś of the full

report; it is

provided on the

basis to raise your

awareness only.

NB: If you come across

ACMs in RC, please seek

specialist advice before

embarking on a strategy.

Thank you, ANY questions?

If you would like more information on this topic

AND, OR SPECIALIST TRAINING;

2 day Demolition Management training (19_20/11/18)

and, or,

2 day Asbestos Management training (21_22/11/18)

Please ring or email me:

07712 767744

email: [email protected]

Wayne Bagnall Consulting

PO Box 41

Birchwood

WA3 4FS

Telephone 01925 767722

Facsimile 01925 767733

Mobile 07712 767744

E-Mail [email protected]

http:// www.waynebagnall.co.uk

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