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Asbestos Management Procedure

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Section 1 - Purpose

(1) Charles Sturt University (the University) acknowledges that due to the age of some structures and infrastructure on its campuses that there will be some materials containing asbestos present, and it has an obligation to ensure that they are managed in accordance with legislative requirements to prevent health and environmental related risks

(2) This Procedure sets out how the University intends to manage asbestos identified in its plant, equipment, buildings, grounds and other infrastructure.

(3) This Procedure is to be applied to all Charles Sturt University owned properties and 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.

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Section 2 - Glossary

(4) For the purpose of this Policy:

  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;
  4. Asbestos Assessor – means a person who holds an assessor licence by SafeWork NSW to carry out air monitoring, clearance inspections, issue clearance certificates; 
  5. Asbestos Containing Material – means any material or thing that, as part of its design, contains asbestos;
  6. Asbestos Licence Class A Licence – allows a contractor to remove friable asbestos, non-friable asbestos and any asbestos contaminated dust or debris; 
  7. Asbestos Licence Class B Licence – 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. 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;
  9. Building Asbestos Management Plan – means a document that details asbestos controls specific to a building/asset;  
  10. Friable Asbestos – means 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;    
  11. Licensed Asbestos Removalist – means a person conducting a business or undertaking who is SafeWork NSW licensed under the Work Health and Safety Regulations to carry out Class A asbestos removal work or Class B asbestos removal work;      
  12. Long Term Asbestos Management Plan – details the long term management strategy for buildings/assets with asbestos;   
  13. Non-friable Asbestos – means material containing asbestos that is not friable asbestos, including material containing asbestos fibres reinforced with a bonding compound. Note that non-friable asbestos may become friable asbestos through deterioration;    
  14. 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; and 
  15. Properties – means any University owned and controlled lands, including structures and infrastructure.       
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Section 3 - Policy

(5) Nil.

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Section 4 - Procedures

Regulatory Framework

(6) The management of asbestos at the University shall be performed in accordance with the relevant State and Territory Acts, Regulations and Codes of Practice. These include:

  1. Work Health and Safety Act 2011 No 10
  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

(7) The Vice-Chancellor is responsible for: 

  1. approval of the Asbestos Management Procedure; and
  2. ensuring that sufficient resources are provided for a safe workplace.

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

  1. managing critical incidents at the University. See the Critical Incident Management Guidelines.  

(9) The University Manager, Health Safety and Wellbeing, Division of People and Culture is responsible for: 

  1. managing the communication of information relating to asbestos to staff, students and workers;

(10) The Executive Director, Division of 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 and contractors 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.

(11) The Director, Facilities Planning and Development, Division of Facilities Management 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 i.e. removal; and
  3. maintaining a record of any works on or removal of asbestos containing materials and provide details to the Manager, Work Health and Safety (Facilities), Division of Facilities Management.

(12) The Director, Operations, Division of Facilities Management is responsible for:

  1. ensuring asbestos compliance for University properties is maintained via the respective Manager, Campus Services; and
  2. 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.

(13) The Manager, Work Health and Safety (Facilities), Division of Facilities Management 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;
  3. maintaining the Long Term Asbestos Management Plan;
  4. maintaining the Asbestos Register and ensuring it is accessible;
  5. preparing an Annual Asbestos Risk Report to the Division of Facilities Management Executive; and
  6. providing advice on the management of asbestos.

(14) The Manager, Campus Services 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.

(15) The Project Officers, Facilities, Planning and Development, Division of Facilities Management 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, Work Health and Safety (Facilities);
  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.

(16) Executive Director, Division of Information Technology is responsible for:

  1. the use, maintenance, repair and removal of asbestos containing materials associated with the University’s information and communication technology (ICT) infrastructure in accordance with the requirements of this Procedure.

(17) Executive Deans or Executive Directors 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 Plan

(18) The University's Asbestos Management Plan consists of the following components:

  1. Asbestos Management Plan;
  2. Asbestos Registers;
  3. Building specific Asbestos Management Plan(s); and
  4. Long Term Asbestos Management Plan.

(19) A Building Asbestos Management Plan shall be developed for each building or group of similar buildings that contains or is suspected of containing asbestos or asbestos containing materials and contain:

  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 asbestos including date of the works, contractor involved and any related records.

(20) Building Asbestos Management Plans shall be reviewed by the Manager, Work Health and Safety (Facilities) and with the respective Manager, Campus Services, Division of Facilities Management following any review of the:

  1. Asbestos Register;
  2. Asbestos Management Plan;
  3. identification of new asbestos or asbestos containing material in the building; and
  4. construction works involving asbestos or asbestos containing material in the building.

(21) Review of the Asbestos Management Plan

  1. the Building Asbestos Management Plan shall be reviewed annually within the University's risk management reporting timelines to ensure that it adequately addresses the management of asbestos at the University;
  2. the Building Asbestos Management Plan shall also be reviewed 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 or 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.

(22) The meeting to review the Asbestos Management Plan shall include comprise all members of the Division of Facilities Management Executive, and other relevant roles as required.

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

(24) Access to the Asbestos Management Plan and asbestos registers:

  1. the Asbestos Management Plan, including the Asbestos Register and Building Asbestos Management Plan(s) shall be available to all University staff, students, visitors, and health and safety representatives;
  2. the Asbestos Management Plan, including the Asbestos Register and Building Asbestos Management Plan(s) shall also be made available to contractors and workers as a hard copy at the contractor sign in location;
  3. asbestos details will be provided as part of the work engagement and contractor management process.

Long Term Asbestos Management Plan

(25) The Long Term Asbestos Management Plan shall document the decisions and reasons of the Division of Facilities Management 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; or
  2. Priority 2 (P2) Organise remedial works in the next few months and manage any remaining materials as part of an Asbestos Management Plan.

(26) The Long Term Asbestos Management Plan shall be reviewed annually.  The Executive Director, Division of Facilities Management will advise the Chief Financial Officer of any changes, and the impact or potential impact on the University.

Risk of Exposure

(27) 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. 

(28) 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.

(29) 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 Asbestos Management Procedure - Appendices 1-5, taken from the Code of practice, How to manage and control asbestos in the workplace.

Asbestos Registers  

(30) The Manager, Work Health and Safety (Facilities) is responsible for maintaining the Asbestos Registers.

(31) 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.

(32) The Asbestos Register shall conform to the requirement of the Work Health and Safety Regulation 2017.

(33) 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”.

(34) 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. 

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

Communication

(36) Staff will be provided information on asbestos as part of their induction to the University, and including information on the location and details of building asbestos registers.

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

(38) The Division of Facilities Management 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; and
  5. University Manager, Health Safety and Wellbeing, Division of People and Culture.

(39) 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' as under the Work Health and Safety Regulations.

(40) 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.

(41) 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

(42) 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.

(43) 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

(44) 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.

(45) Other University workers, who may assist or be associated with those in clause 44, should undertake the University's general asbestos awareness online course.

(46) Training records for University workers shall be maintained with the Human Resources staff records section.

(47) 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.

(48) 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

(49) The Manager, Work Health and Safety (Facilities) shall 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 the Division of Facilities Management's Asset Plan.

(50) The Long Term Asbestos Management Plan shall be reviewed annually. The Executive Director, Division of Facilities Management will advise the Chief Financial Officer of any changes and the impact or potential impact on the University.

Management Options

(51) Where asbestos has been identified in a building/asset, the preferred control method shall be agreed as per the Division of Facilities Management's Asset Plan.
Control options include:

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

(52) For more information on management options see “Appendix 2 – Control methods for the management of asbestos” in Asbestos Management Procedure - Appendices 1-5.

Labelling of Asbestos containing material

(53) 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. 

(54) 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.

(55) The review shall update the Asbestos Register and each Building Asbestos Management Plan.

Maintenance Contractors

(56) The process flowchart regarding the engagement of Maintenance Contractors is detailed in “Appendix 3 – Managing asbestos and maintenance contractors” in Asbestos Management Procedure - Appendices 1-5.

Construction works

(57)  The Principal Contractor shall provide to the Division of Facilities Management a Work Health and Safety Management Plan and Asbestos Removal Management Plan that addresses the removal of asbestos. These plans shall be reviewed by Division of Facilities Management for adequacy.

(58) During the project, the Division of Facilities Management Project Officer shall monitor compliance by the Principal Contractor against the project Work Health and Safety Management Plan and Project Asbestos Management Plan.

(59) At the completion of the project the Principal Contractor shall provide Division of Facilities Management with an Asbestos Clearance Certificate, air monitoring records and asbestos disposal records.

(60) A flow chart of construction process is available in “Appendix 4 – Managing asbestos and construction works” in Asbestos Management Procedure - Appendices 1-5.

(61) 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.

(62) An Asbestos Clearance Certificate must be received by the Project Officer before the building/construction area is reopened.

(63) 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

(64) 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

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

(66) Any health monitoring records shall be kept within the Division of People and Culture staff records.

Reporting Management of Asbestos discovery or disturbance on Campus

(67) 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 Asbestos Management Procedure - Appendices 1-5.

(68) The Manager, Campus Services, Division of Facilities Management, shall assume control of the area and implement the necessary actions to secure the area. 

Emergencies involving Asbestos

(69) 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;
  5. exposure through surface erosion or illegal dumping of waste. 

(70) Emergencies involving asbestos shall be handled as per Appendix 5 - “Reporting and Management of Asbestos discovery or disturbance on Campus” in Asbestos Management Procedure - Appendices 1-5. Any incident or perceived incident must be reported via the University’s Accident, Incident and Hazard Reporting System (Protecht). 

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Section 5 - Guidelines

(71) Nil.