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Facilities and Premises Procedure - Asbestos Management

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Section 1 - Purpose

(1) This procedure supports the Facilities and Premises Policy and:

  1. sets out how the Charles Sturt University (the University) will manage asbestos when it is identified in its plant, equipment, buildings, grounds and other infrastructure,
  2. is developed to meet the requirements of an Asbestos Management Plan as per the Work Health and Safety Regulation 2017 under the Work Health and Safety Act (NSW) 2011, and
  3. anticipates that, due to the age of some structures and infrastructure on the University’s campuses, there will be some materials containing asbestos present and there is an obligation to ensure that they are managed in accordance with legislative requirements to prevent health and environmental related risks.

Scope

(2) Refer to the Facilities and Premises Policy.

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Section 2 - Policy

(3) This procedure supports the Facilities and Premises Policy.

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Section 3 - Procedures

Regulatory framework

(4) Asbestos on University premises will be managed in accordance with the relevant state and territory acts, regulations and codes of practice. These include:

  1. Work Health and Safety Act 2011 (NSW)
  2. Work Health and Safety Regulation 2017
  3. How to Manage and Control Asbestos in the Workplace, Code of Practice (SafeWork NSW)
  4. How to Safely Remove Asbestos, Code of Practice (SafeWork NSW)
  5. Protection of the Environment Operations Act 1997 (NSW)

Responsibilities

(5) The Chief Operating Officer is responsible for: 

  1. ensuring that sufficient resources are provided for a safe workplace.

(6) The Critical Incident Response Group is responsible for:

  1. managing critical incidents at the University in accordance with the Resilience Policy and any supporting procedures and plans, the Critical Incident Management Guidelines and the Facilities and Premises Schedule - Asbestos Management.

(7) The Manager, Health Safety and Wellbeing, is responsible for: 

  1. managing the communication of information relating to asbestos to staff, students, contractors and other persons entering University premises, and
  2. ensuring SafeWork NSW (or the equivalent state or territory authority) are notified when the amount of friable asbestos detected meets or exceeds the relevant threshold levels.

(8) The Director, Facilities Management is responsible for:

  1. approval of the long term asbestos management plan which provides advice on the costs and risks, including mitigation and/or removal of asbestos at the University,
  2. ensuring asbestos compliance and the safety of staff, students, contractors and others within the built environment,
  3. developing and maintaining the long term asbestos management plan for the University,
  4. ensuring workers who will be or are potentially exposed to asbestos have received training, and
  5. ensuring workers that handle asbestos undergo health monitoring.

(9) The Manager, Campus Development is responsible for: 

  1. ensuring contractors and workers are advised of asbestos containing materials and any building asbestos management plans as part of all projects or works under their control,
  2. ensuring that project planning will utilise, as far as practicable the highest order of mitigation (e.g. removal),
  3. maintaining a record of any works on or removal of asbestos containing materials and provide details to the Manager, Health Safety and Wellbeing,
  4. ensuring asbestos compliance for University premises is maintained via the respective Campus Facilities Manager,
  5. ensuring contractors and other workers are advised of asbestos containing materials and any building asbestos management plans as part of all maintenance or repair works under their control,
  6. maintaining the long-term asbestos management plan,
  7. maintaining the asbestos register and ensuring it is accessible, and
  8. preparing an annual asbestos risk report to the Director, Facilities Management.

(10) The Manager, Health Safety and Wellbeing is responsible for:

  1. maintaining and facilitating the review of the asbestos management plan and any building asbestos management plans,
  2. ensuring that all asbestos management plans are accessible to staff, students and workers, and
  3. providing advice on the management of asbestos.

(11) The Campus Facilities Manager is responsible for:

  1. ensuring all structures have a current asbestos register,
  2. ensuring that all asbestos containing materials are clearly labelled,
  3. ensuring contractors are advised of asbestos containing materials and that a documented safety assessment is undertaken prior to works commencing,
  4. ensuring workers are advised of asbestos containing materials within their workplace,
  5. maintaining a record of any works on asbestos, and
  6. coordinating the review of the condition of asbestos containing materials.

(12) The Project Officers, Facilities Management (FM) are responsible for:

  1. ensuring an appropriate hazardous materials survey is undertaken before construction works commence,
  2. informing construction work contractors of asbestos and providing copies of surveys and registers,
  3. reviewing contractors’ asbestos removal management plans and work health and safety management plans in conjunction with the Manager, Health Safety and Wellbeing,
  4. monitoring contractor compliance with asbestos removal management plans and work health and safety management plans,
  5. obtaining clearance certificates from contractors, and
  6. obtaining disposal certificates or notices from contractors.

(13) Chief Information and Digital Officer is responsible for:

  1. ensuring that asbestos containing materials associated with the University’s information and communication technology (ICT) infrastructure are listed in the relevant asbestos registers and are managed in accordance with the requirements of this procedure.

(14) Executive Deans/Executive Directors/Band 7 equivalents of organisational units that have non-infrastructure related asbestos or asbestos containing materials under their control:

  1. are to ensure that the material is listed in the buildings asbestos register and that the materials used are compliant with this procedure.

Asbestos management plans

(15) The University's asbestos management plan consists of the following components:

  1. Asbestos Management Plan.
  2. Asbestos registers - a list of all identified, or assumed, asbestos on University premises.
  3. Building asbestos management plan(s) – detailing asbestos controls specific to a building or asset.
  4. Long-term asbestos management plan – detailing the long-term management strategy for buildings/assets with asbestos.

(16) The meeting to review the asbestos management plan shall include all members of FM executive and other relevant roles as required.

(17) The Manager, Health Safety and Wellbeing is responsible for coordinating the review, minuting and distributing minutes of the meeting.

Building asbestos management plans

(18) A building asbestos management plan will be developed for each building or group of similar buildings that contain or are suspected of containing asbestos or asbestos containing materials and will include:

  1. the relevant extract from the asbestos register related to that building,
  2. location of asbestos labels in the building,
  3. any specific instructions for contractors or workers in the building,
  4. actions for the management of asbestos in the building, and
  5. register of construction works related to the building detailing removal, enclosure, encapsulation or sealing of asbestos including date of the works, contractors involved and any related records.

(19) The building asbestos management plan will be reviewed annually within the University's risk management reporting timelines to ensure that it adequately addresses the management of asbestos at the University.

(20) Building asbestos management plans will also be reviewed by the Manager, Health Safety and Wellbeing and with the respective Campus Facilities Manager when:

  1. there is a review of the asbestos register or a control measure for mitigating the risk from asbestos or asbestos containing material,
  2. asbestos is removed from, disturbed, sealed or enclosed at the workplace,
  3. the plan is no longer adequate for managing asbestos or asbestos containing materials at the workplace,
  4. a health and safety representative requests a review if they reasonably believe that any of the matters listed in the above points affects or may affect the health and safety of a member of their designated work group and the asbestos management plan was not adequately reviewed, or
  5. legislative or code of practice changes occur.

Long term asbestos management plan

(21) The long term asbestos management plan shall document the decisions and reasons for FM concerning the long term management of asbestos on the campus that has been classified in the asbestos register as:

  1. Priority 1 (P1) Restrict access to area, organise abatement works as soon as practicable, manage any remaining materials as part of an Asbestos Management Plan,
  2. Priority 2 (P2) Organise remedial works in the next few months and manage any remaining materials as part of an asbestos management plan,
  3. Priority 3 (P3) Organise remedial works in the next 3 years and manage any remedial works as part of an asbestos management plan, or
  4. Priority 4 (P4) No short term remedial works are required. Maintain and monitor the condition of the materials. Manage as per long term plan.

(22) The long-term asbestos management plan shall be reviewed annually.  The Director, Facilities Management will advise the Chief Financial Officer of any changes, and the impact or potential impact on the University.

Asbestos registers

(23) The Manager, Health Safety and Wellbeing, is responsible for maintaining the asbestos registers.

(24) An asbestos register is required for any buildings or structures constructed prior to the 1st January 2004 unless no asbestos has been identified at the workplace.

(25) The asbestos register shall conform to the requirement of the Work Health and Safety Regulation 2017.

(26) If no asbestos or asbestos containing material has been identified or is likely not to be present at the workplace, the asbestos register should state that “no asbestos or asbestos containing material has been identified at the workplace”.

(27) A copy of the asbestos register shall be made available to any worker or contractor who will be working in areas containing or suspected to contain asbestos.

(28) An asbestos register will be required for all property Lessors prior to signing the contract or occupation.

Access to the asbestos management plan and asbestos registers

(29) The asbestos management plan, including the asbestos register and building asbestos management plan(s) shall be available to:

  1. all University staff, students, visitors, and health and safety representatives,
  2. contractors and workers as a hard copy at the contractor sign in location, and asbestos details will be provided as part of the work engagement and contractor management process.

Risk of exposure

(30) If asbestos or asbestos containing material is in good condition and left undisturbed, it is unlikely that airborne asbestos will be released and the risk to health is extremely low.

(31) If asbestos or asbestos containing material has deteriorated, been disturbed, or if asbestos-contaminated dust is present, the likelihood that airborne asbestos will be released into the air is increased.

(32) The likelihood of airborne asbestos fibres being released from different types of asbestos containing materials is identified in the diagram in “Appendix 1 -Risk of exposure to airborne fibres from different asbestos containing materials” in Facilities and Premises Schedule - Asbestos Management, taken from the code of practice ‘How to manage and control asbestos in the workplace’.

Communications

(33) Staff will be provided information on asbestos as part of their induction to the University and building asbestos registers will be available through FMCentral.

(34) Staff shall be informed of issues related to asbestos as required by the Manager, Health Safety and Wellbeing (or delegate) in person, via bulletins, emails, newsletters or other suitable means.

(35) FM shall ensure the following are advised that asbestos works are to be carried out and the date that work is to commence:

  1. Occupiers and users of the building.
  2. Occupiers of premises in the immediate vicinity of the building.
  3. Workers who may be required to work in or in the immediate vicinity of the building.
  4. Designated health and safety representatives.
  5. The University Manager, Health Safety and Wellbeing.

(36) Contractors shall successfully complete the University's general Work Health and Safety induction prior to commencing works. The induction will include information on asbestos, its presence, how to report asbestos finds, asbestos signage, the location of registers, surveys and building asbestos management plans and note that works involving asbestos or likely to involve the disturbance of asbestos are classified as 'high risk work' under the Work Health and Safety Regulations.

(37) Maintenance, repair and minor works contractors shall receive a copy of a (BEIMS) service request work order request and these work orders will highlight if the building contains asbestos, requiring further review by the contractor prior to works commencing.

(38) Construction contractors shall be advised of asbestos via the provision of a hazardous materials survey including the asbestos register during the scoping and prior to the start of works.

Consultation

(39) University staff shall be consulted on the management of asbestos in the workplace via the Health and Safety Committees and elected Health and Safety representatives, including information regarding accidents or incidents related to asbestos exposure and asbestos related works.

(40) For information on the University's agreed work health and safety consultation procedures and nominated health and safety representatives refer to the Work Health and Safety Consultation at CSU webpage.

Training

(41) University workers whose role involves work with or, work potentially with, or near asbestos containing materials are required to have completed an accredited asbestos awareness course.

(42) Other University workers, who may assist or be associated with those in clause 41, should undertake the University's general asbestos awareness online course.

(43) Training records for University workers shall be maintained with the Division of People and Culture (DPC) staff records section.

(44) Contractors to the University whose work may involve contact with asbestos containing materials are required to have completed an accredited asbestos awareness course and be able to provide evidence prior to commencing works.

(45) All workers potentially coming into contact with asbestos as a part of works that may disturb asbestos containing materials shall be trained in a high risk construction work, safe work method statement that addresses the risks and controls related to asbestos.

Risk management

(46) The Manager, Health Safety and Wellbeing will conduct an annual review of the asbestos register and produce an asbestos risk report. The asbestos risk report together with building condition reports shall be used to assess the risk from asbestos to users of and workers in each building. Details of the risk and proposed management of asbestos shall be detailed in FM's asset plan (see also the Risk Management Policy).

(47) The long term asbestos management plan shall be reviewed annually. The Director, Facilities Management will advise the Chief Financial Officer of any changes and the impact or potential impact on the University.

Management options

(48) Where asbestos has been identified in a building/asset, the preferred control method shall be agreed as per FM's Asset Plan.

(49) Control options include:

  1. removal,
  2. enclosure,
  3. encapsulation/sealing, and
  4. leaving the asbestos left in-situ, if the asbestos is in a good condition and not subject to mechanical damage.

(50) For more information on management options see “Appendix 2 – Control methods for the management of asbestos” in Facilities and Premises Schedule - Asbestos Management.

Labelling of asbestos containing material

(51) All identified asbestos or asbestos containing material, as listed in the Asbestos Register, shall be clearly labelled as per the requirements of the work health and safety legislation. 

(52) Labels and label locations shall be reviewed at least every 12 months or as per the requirements of the asbestos register. The review shall be set up as a task in the BEIMS service request system as a maintenance Request.

(53) The review shall update the asbestos register and each building asbestos management plan.

Maintenance contractors

(54) The process flowchart regarding the engagement of Maintenance Contractors is detailed in “Appendix 3 – Managing asbestos and maintenance contractors” in Facilities and Premises Schedule - Asbestos Management.

Construction works

(55)  The Principal Contractor shall provide a work health and safety management plan and asbestos removal management plan to FM that addresses the removal of asbestos. These plans shall be reviewed by FM for adequacy.

(56) During the project, the FM Project Officer shall monitor compliance by the Principal Contractor against the project work health and safety management plan and project asbestos management plan.

(57) At the completion of the project the principal contractor shall provide FM with an asbestos clearance certificate, air monitoring records and asbestos disposal records.

(58) A flow chart of construction process is available in “Appendix 4 – Managing asbestos and construction works” in Facilities and Premises Schedule - Asbestos Management.

(59) Workers carrying out licensed asbestos removal work must hold a certification that is relevant to the class of licensed asbestos removal work they will be carrying out.

(60) An asbestos clearance certificate must be received by the Project Officer before the building/construction area is reopened.

(61) Asbestos waste must be transported and disposed of in accordance with the Environment Protection Authority (EPA) requirements at a site licensed by the EPA. Disposal records must be provided by the contractor to the Project Officer

Accidents or incidents involving asbestos

(62) Accidents or incidents involving asbestos, including those where a person has been or believes they have been exposed to asbestos at the University must be reported via the University’s Accident, Incident and Hazard Reporting System (Protecht).

Health monitoring

(63) The Division of People and Culture (DPC) shall ensure health monitoring for workers who handle asbestos is undertaken. 

(64) Any health monitoring records shall be kept within DPC staff records.

Reporting management of asbestos discovery or disturbance on campus

(65) A flow chart for the reporting management of asbestos discovery or disturbance on campus is provided in “Appendix 5 – Reporting and Management of Asbestos discovery or disturbance on Campus” in Facilities and Premises Schedule - Asbestos Management.

(66) The Campus Facilities Manager shall assume control of the area and implement the necessary actions to secure the area. 

Emergencies involving asbestos

(67) An emergency situation is most likely to entail the inadvertent disturbance of asbestos by:

  1. University staff or students,
  2. contractors,
  3. vandalism or criminal entry,
  4. damage due to severe weather conditions, and
  5. exposure through surface erosion or illegal dumping of waste. 

(68) Emergencies involving asbestos shall be handled as per Appendix 5 - “Reporting and Management of Asbestos discovery or disturbance on Campus” in Facilities and Premises Schedule - Asbestos Management. Any incident or perceived incident must be reported via the University’s Accident, Incident and Hazard Reporting System (Protecht). 

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Section 4 - Guidelines

(69) Nil.

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Section 5 - Glossary

(70) This procedure uses the terms defined in the Facilities and Premises Policy. For the purpose of this procedure, the following terms are also defined:

  1. Air monitoring – means the sampling of airborne asbestos fibres to assist in assessing exposure to asbestos and the effectiveness of implemented control measures.
  2. Airborne asbestos – means any fibres of asbestos small enough to be made airborne. For the purposes of monitoring airborne asbestos fibres, only respirable fibres are counted.
  3. Asbestos – means the asbestiform varieties of mineral silicates belonging to the serpentine or amphibole groups of rock-forming minerals including the following: actinolite asbestos; grunerite (or amosite) asbestos (brown); anthophyllite asbestos; chrysotile asbestos (white); crocidolite (blue); tremolite asbestos; or a mixture that contains 1 or more of the minerals referred to above. Asbestos may be:
    1. friable, meaning material that is in a powder form or that can be crumbled, pulverised or reduced to a powder by hand pressure when dry, and contains asbestos, or
    2. non-friable, meaning material containing asbestos that is not friable asbestos, including material containing asbestos fibres reinforced with a bonding compound. Non-friable asbestos may become friable asbestos through deterioration.
  4. Asbestos assessor – means a person who holds an assessor licence by SafeWork NSW to carry out air monitoring, clearance inspections and issue clearance certificates.
  5. Asbestos containing material – means any material or thing that, as part of its design, contains asbestos.
  6. Asbestos-contaminated dust or debris – means dust or debris that has settled within a workplace and is, or is assumed to be, contaminated with asbestos.
  7. Licensed asbestos removalist – means a person conducting a business or undertaking who is SafeWork NSW licensed under the Work Health and Safety Regulation to carry out Class A asbestos removal work or Class B  asbestos removal work:
    1. Class A – allows a contractor to remove friable asbestos, non-friable asbestos and any asbestos contaminated dust or debris, and
    2. Class B – allows the contractor to remove 10 square metres or more of non-friable asbestos. Having a class B licence only allows the contractor to remove the asbestos contaminated dust or debris that is directly associated with the removal of non-friable asbestos.
  8. Permit to work – means the issue of an authority to be issued and signed by the contractor, acknowledging presence of asbestos containing materials in the work area/s identified in the register prior to commencing work.