The Asbestos Register: Why You Need to Update It After Building Work
As summer draws to a close and the rain finally arrives, many organisations will return to buildings after refurbishment, maintenance and improvement works.
Office refurbishments, school upgrades, housing repairs and construction projects often take place during the summer months. Once contractors pack up, Dutyholders should ask one important question:
Has your asbestos register been updated?
Asbestos removal, remediation, refurbishment and alteration work can all change your asbestos records. They can also affect your Asbestos Management Plan (AMP). If you do not update these records, they may no longer reflect the building’s current condition. Building managers, contractors and maintenance teams could then rely on inaccurate asbestos information.
Why is an asbestos register important?
The Control of Asbestos Regulations (CAR) 2012 places a duty on those responsible for non-domestic premises to manage asbestos risks. This includes identifying whether asbestos exists, or could exist, within the premises. Dutyholders must also maintain information about the location and condition of asbestos-containing materials (ACMs). The asbestos register plays a fundamental role in this process.
However, you should never treat your asbestos register as a document that you complete once and file away. Buildings change over time, so your asbestos information must change with them. For example, contractors may remove ACMs from part of a building. Your asbestos register should then record their removal. Refurbishment may also open previously inaccessible areas. This work could expose previously unidentified ACMs. Alterations to walls, ceilings, floors, services or plant can also affect existing ACMs. They may even reveal materials that previous surveys could not identify.
Has your building undergone significant works this summer? Casa Environmental Services can carry out an asbestos Reinspection of your existing asbestos survey. This can help establish whether your asbestos register remains accurate.
Update your asbestos register after asbestos removal
Asbestos removal or remediation provides another important reason to review your asbestos register. Removal contractors may have removed ACMs that your existing register still records. Leaving these items on the register can create uncertainty for future contractors. It can also lead to unnecessary investigation before future work begins. Removal projects can also uncover previously unknown ACMs. They may reveal changes to the condition or accessibility of other materials. You should therefore review your asbestos information when an asbestos removal project finishes.
If you receive a Certificate of Reoccupation, also known as a Four Stage Clearance certificate, check the analyst’s comments carefully. The analyst may have identified further suspect ACMs during the clearance process. These materials could require further investigation and management. The end of an asbestos removal project does not necessarily mark the end of your asbestos management responsibilities.
Casa can assist with reviewing existing asbestos information following asbestos removal or remediation works. We can help ensure your asbestos register and management arrangements reflect the building’s current condition.
Refurbishment can change your asbestos register
Refurbishment projects provide another strong reason to review an asbestos register. An existing Management Survey identifies ACMs that could become disturbed during normal occupation and maintenance. More intrusive refurbishment work may require additional investigation. Contractors may open walls, remove ceilings, lift floors or alter building services. These activities can expose areas that previous surveys could not access. They may also reveal ACMs that the earlier survey could not identify. When this happens, you should add the new information to your asbestos register and asbestos management arrangements.
Do you need a new asbestos survey?
A Reinspection may provide sufficient information where your existing asbestos survey remains suitable. However, more extensive refurbishment may require a new Asbestos Management Survey or additional survey work. The appropriate approach will depend on the scope of the works and the information already available.
Planning or recently completing refurbishment works? Casa can undertake a new Asbestos Management Survey where additional information is required. We can also carry out an asbestos Reinspection where your existing survey remains suitable.
Don’t forget your Asbestos Management Plan
Updating your asbestos register forms only part of the process. You should also review your Asbestos Management Plan when significant changes occur. An AMP sets out how you manage asbestos risks within a property or estate. It should give those responsible for the building a clear and practical management framework. Changes to your asbestos register may therefore require corresponding updates to your AMP.
This could include:
- Removing ACMs from the asbestos register following confirmed removal.
- Adding newly identified ACMs.
- Updating the condition or accessibility scores of materials.
- Recording remedial or encapsulation works.
- Updating management responsibilities or procedures.
- Incorporating new asbestos survey information.
- Updating drawings, plans and asbestos location information.
- Recording relevant asbestos removal or remediation documentation.
Casa Environmental Services can assist with updating your Asbestos Management Plan following survey, refurbishment or remediation works. We can help ensure your asbestos management arrangements reflect the building’s current condition.
The post-summer asbestos register check
September provides a useful opportunity to review your asbestos information. If your building has undergone maintenance, refurbishment or alteration work this summer, check whether anything has changed.
Ask yourself:
- Have contractors removed any ACMs?
- Have contractors opened previously inaccessible areas?
- Have contractors disturbed or altered existing ACMs?
- Have contractors identified new ACMs?
- Has the condition or accessibility of known ACMs changed?
- Have you updated your asbestos register?
- Does your Asbestos Management Plan still accurately reflect the building?
If you cannot answer these questions confidently, consider reviewing your asbestos information. Your asbestos register should describe the building as it is now, rather than how it looked when someone completed the original asbestos survey.
A post-project review can help identify whether you need further surveying, an asbestos Reinspection or an AMP update.
Keep your asbestos register up to date
Your asbestos register provides essential information for anyone who manages, maintains or works within a building. Keeping it accurate can help Dutyholders make informed decisions about asbestos risks and future work. Summer refurbishment and maintenance programmes provide a good opportunity to check your asbestos information.
Whether you need a new Asbestos Management Survey, an asbestos Reinspection or assistance updating your Asbestos Management Plan, Casa Environmental Services can help.
Don’t let this summer’s building works leave your asbestos information out of date. Get in touch with Casa to discuss your requirements and ensure your asbestos register and management arrangements reflect the building you manage today.