While it’s now known to be a dangerous carcinogen, asbestos was once an incredibly common building material. As the operator or owner of an industrial site in Australia, it is your responsibility to manage the risks of asbestos exposure.
One of the key methods by which you can achieve this is by implementing an asbestos management plan. While this plan might seem like the sole domain of your site’s health and safety representative, everyone has a role to play when it comes to the safe management of asbestos.
Key Insights
In case you don’t have time to read the whole article, here are the most important points summed up for you.
- Asbestos management plans are a legal requirement for all buildings with identified or assumed asbestos.
- They require detailed, up-to-date information on the condition and location of asbestos and asbestos-containing materials on your site.
- They need to be easily accessible for staff and site attendees.
- Update and review your procedures and control measures at least once every 5 years.
- Professional consultation on your management plan is the best way to ensure that it’s fit for purpose and legally compliant.
What are asbestos management plans?
An asbestos management plan is designed to minimise and eliminate the risks of asbestos exposure. They contain accurate, up-to-date information that can be used by workers on site, as well as site owners and contractors, to manage the risks associated with asbestos exposure. They’re necessary for all commercial and industrial sites in Australia.
A management plan can (and should) include the following information:
Asbestos register – information on identified asbestos
Any building that has asbestos or asbestos-containing materials (ACMs) must, by Australian law, have an asbestos register. This register contains detailed information on the nature of the asbestos materials within a structure. This includes the type of asbestos, its location and its condition.
Decisions and justifications around asbestos management
Your plan will need to contain clear rationales for the way you’ve chosen to manage asbestos onsite. Be prepared to justify why asbestos has or hasn’t been removed, and to outline the necessity for any work involving asbestos on your site.
Incident protocols, control measures, and health and safety information
Asbestos is most commonly disturbed through renovations and demolition work. However, situations such as fires, storms, and structural degradation can also bring about asbestos exposure. Your plans should contain contingencies for all of these situations.
The plans should identify the steps to take immediately after the accident or disturbance, as well as the protocols for establishing exclusion zones around affected areas. You should also delineate the immediate health precautions to be taken by any individuals who may have experienced an exposure. These health precautions should involve information on decontamination, when and how workers should access medical attention, and any air and health monitoring that needs to occur in the aftermath.
Training responsibilities
Explain clearly who onsite needs to have what kind of training around asbestos and asbestos exposure. This level of training will be dependent on their level of risk exposure, but if your site does have asbestos or ACMs, all staff must be aware of the location of the asbestos, as well as emergency response procedures, the appropriate use of personal protective equipment, and know the relevant people to contact in an emergency.
Maintenance register
Your asbestos management plan needs all details of asbestos maintenance or service work onsite, with clear details on date, the scope, and the parties responsible. It should also contain any relevant clearance certificates, including information about any inspections that take place.
Testing results
As an extension of the maintenance register, it’s a good idea to keep track of any test results around asbestos on site. These can include lab data testing conducted by specialist contractors as well as information from regular air monitoring procedures.
Priorities and timelines for asbestos removal
Your asbestos management plans should contain a clear schedule for asbestos removal or review, explaining how the risks of asbestos exposure will be managed long term. Highlight the most important risk management steps, and explain in what order they will be executed.
Roles and responsibilities
Who is in charge of what when it comes to your asbestos control measures and procedures? Clearly outline the roles of workers, health and safety representatives, as well as which emergency contractors should be contacted in the event of an asbestos disturbance.
Do I need an asbestos safety management plan?
According to the Australian Government’s Asbestos and Silica Safety and Eradication Agency, asbestos is estimated to be found in up to a third of Australian buildings, especially industrial and commercial buildings built pre-1990.
If your property has identified or assumed asbestos, you are legally required to have an asbestos management plan.
There are financial and legal penalties associated with not maintaining an accurate management plan. While these penalties vary state-by-state and between individuals and companies, they can be in excess of $30,000 and can include jail time.
You also need asbestos management plans for sites with naturally occurring asbestos. You’ll need to outline the same information on your asbestos register, including location and asbestos type, as well as the appropriate control measures and protocols for emergencies involving asbestos.
What form can my asbestos management plans take?
You need a written asbestos safety management plan: it cannot be a verbal agreement or an informal document. Availability and accessibility are key: your asbestos management plan and asbestos register need to be available to all who might need to access them, not just to the health and safety representative on your site.
Common mistakes in asbestos safety management plans
How do you ensure you have an effective plan with all the right control measures? Here are some common mistakes that companies and site owners make when preparing their asbestos management plans.
Accessing the plan
When there are emergencies involving asbestos, everyone must know their best course of action. Your asbestos safety management plans are of no use if they’re not easy to access. Workers need to be aware of where the plan is and what it contains to avoid asbestos risks. The plan isn’t just the property of a single health and safety representative. While a safety representative may be responsible for creating and maintaining the document, it’s important that every staff member and site attendee knows how to find and use the plan. Include information on procedures and control measures in all onboarding sessions for relevant contractors, and ensure your asbestos management plans are in a physical or digital location that everyone has access to.
Reviewing asbestos safety management plans
Your plan needs to be reviewed at the very least once every five years in all states and territories. This changes depending on the nature of your site: for schools in Victoria, for example, the plan needs to be reviewed annually.
The period of five years is, however, a minimum and should be navigated based on the specific risk profile of your site. More frequent inspections and revisions are necessary for sites with a higher risk profile. A higher risk profile might be the result of an older building or facility, or more easily accessible ACMs within the building. The building’s condition, too, is an important factor here: if your building has significant wear and tear, it’s a good idea to test and review on a bi-annual or annual basis.
Incomplete documentation
It is your responsibility as the site owner or operator to maintain the most complete records possible. This means recording both known and assumed asbestos, regardless of where it is within the structure. Some asbestos management plans fail to declare all asbestos or asbestos-containing materials by omitting asbestos in inaccessible areas. While the areas may be inaccessible to workers, it doesn’t mean that the asbestos fibres can’t be disturbed as a result of planned works, workplace accidents, or natural disasters. To appropriately control asbestos risks, it’s essential that all locations of asbestos or suspected asbestos are recorded.
Not updating the asbestos register.
Asbestos safety management plans aren’t a set-and-forget document: they must be maintained and updated so that appropriate control measures can be upheld and your site’s safety can be protected. Any factors that might cause disturbance to your identified asbestos needs to be recorded, and further testing needs to be prompted.
Damaging winds and rains, as well as fires, can release airborne asbestos fibres: this should trigger additional testing to ensure you’re adequately managing risks.
Accuracy in your asbestos safety management plan must be a priority, especially for large industrial sites with high volumes of contractors. Your control measures, procedures, and plan need to stand up to scrutiny and take the form of genuinely useful documents. Engaging a professional service to create this vital document for you means that you protect both your company’s integrity and the health of workers carrying out their duties onsite. With over 27 years in the management of asbestos, HMG are here to support your safety. If you have any questions about creating your own asbestos register and management plans, get in touch! We’re dedicated to the efficient and safe removal of hazardous materials in commercial, industrial, and residential properties, and we’re just a phone call away.