Control of Work
This procedure describes the management of Asbestos.
The management approach shall be in accordance with the requirements of the Control of Asbestos regulations 2012 and MGN 429 The Merchant Shipping and Fishing Vessels (Health and Safety at Work )(Asbestos) regulations 2010
Although the potential harm caused by exposure to Asbestos varies considerably with the Type, for the purpose of this procedure each are considered of equal harm.
Where assessed material exact content is unknown, shall be considered to contain Asbestos and appropriate management, in accordance with the requirements of this procedure applied.
These relevant materials shall be considered to include, but not be restricted to:
o Steam Pipe Insulation;
o Calorifier Insulation;;
o Fire Retardant materials and Coatings;
o Brake Lining
o Gasket and Jointing materials;
Fibrous Silicate material .
(a) asbestos actinolite, CAS No 77536-66-4;
(b) asbestos grunerite (amosite), CAS No 12172-73-5;
(c) asbestos anthophyllite, CAS No 77536-67-5;
(d) chrysotile, CAS No 12001-29-5 or CAS No 132207-32-0;
(e) crocidolite, CAS No 12001-28-4; and
(f) asbestos tremolite, CAS No 77536-68-6,
and reference to “CAS” followed by a numerical sequence are references to CAS Registry
Numbers assigned to chemicals by the Chemical Abstracts Service, a division of the American Chemical Society;
Product containing some percentage of Asbestos
Asbestos shall be considered to be encapsulated when it is contained within a Matrix or within fixed solid boundaries which are in good condition and which, in normal circumstances, prevents creation of Air borne fibres.
This is WORK which;
Has Activities surrounding the asbestos Containing material in large quantities as a significant scope of Work;
Has Activities which involve asbestos Containing materials which are friable and likely to generate air bourn fibres in excess of limits.
Not included would be limited work with encapsulated material to gain access, or where sufficient control measures could be applied to remove ALARP exposure risk.
A comprehensive Survey of the vessel to assess potential asbestos Content. Where access is difficult the suitability of Encapsulation shall be assessed.
A Plan based upon General Arrangement which highlights those areas where Asbestos is present, or potentially present as described in the Asbestos Survey
Associated to the Asbestos Location Plan and demonstrates the potential risk of exposure in the areas highlighted on the Plan
Any WORK Planning in the areas described shall incorporate the findings of this Risk Assessment within the Asbestos Maintenance Plan
Any work where there exists a potential for exposure to asbestos, including but not exclusively those areas identified on the Asbestos Location Plan and described in the Asbestos Risk Assessment, shall have a Job Specific Assessment of Work in accordance with companies Permit to Work System. Depending on the scope of work this may be a standalone document or incorporated with a generic TBRA.
An airborne concentration of asbestos of:
0.1 Fibres per CM3 (f/cm3) as a 4 hour weight average;
0.6 f/cm3 per 10 minutes.
Measured in accordance with WHO 1997 recommended method
Shall be suitable for the work carried out and include but not be restricted to:
Goggles/Safety Glasses/Face Shield
Head covering ( or integral to coverall)
Safety Shoes /Boots
Suitable breathing Mask
Work which may be undertaken by vessel Crew with correct planning, training and control measures in place.
This should be taken as where, within a 7 day period:
WORK which, including that which whilst not being specific to the Asbestos Containing Material my disturb it, takes more than 2 hours;
WORK which requires continuous attention by a person for greater than one hour.
A WORK specific procedure governing action in the event of contingency including uncontrolled release of Asbestos.
Is responsible for the health and Safety of vessel Crew members, and third party employees directly engaged to perform maintenance activities involving Asbestos on that vessel
The Management team shall ensure that all necessary arrangements are in place to minimise risk of exposure to ACM by vessel crew members.
Such arrangements shall include but not be limited to:
provision of adequate PPA appropriate to planned work scopes;
provision for proper assessment of risk;
provision of occupational health assessment and monitoring;
proper planning of any work.
This responsibility shall be considered to apply both to employees direct or indirect , but additionally to employees of any third party contractor employed to carry out activities .
Crew members should apply knowledge learnt in training to consider where they feel risk exists that Asbestos Containing Material has been exposed. Further WORK Should be halted and correctly inform Management team immediately.
Where WORK involving ACM is ongoing any Crew members not involves shall obey any signage segregating areas adjacent to this and take any other considered necessary action to prevent exposure.
Where a Crew member believes themselves to have been exposed they are to inform the MEDIC immediately for further assessment and treatment where necessary
For Crew Members engaged in Short Term WORK ensure that they make use of all control measures stated in the TBRA / Management Plan / Permit to Work. This would include but not be limited to
Wearing of PPE
Application of mitigation measures including erection of barriers, warning notices, ventilation etc
This procedure applies to vessels for which an Asbestos free certificate has not been issued or where the validity of such certificate is questioned due to, for example, poor control of supply of new material to the vessel which may have allowed asbestos content to be brought on board.
For vessels having an asbestos Free Certificate and having properly controlled supply Chain able to prevent Asbestos containing material from having been brought to the vessel then the scope of this document should be limited to application of good practices and periodic re-assessment of potential risks associated to Exposure of Asbestos on that vessel .
The Management of Asbestos shall be through the following methods
Adequate Training for all Personnel
Targeted additional training where required for Project Managers
Identification of location of Asbestos on Vessel, recording in a Survey report
Where practical removal of Asbestos from Vessel
No new Asbestos containing material to be brought onto vessel
Adequate planning of WORK, limiting WORK by vessel crew to Short Term work only.
Short-term work scopes shall be managed by existing TBRA and permit to work system is. Non-short-term work shall be managed by the Marine superintendents-technical who, shall arrange is suitable risk assessment and create an asbestos management plan in accordance with the requirements of this procedure.
In each case a functional reporting line shall exist to the Marine manager-technical he shall be informed of any such plan work.
In each case, short-term non-short-term work including non-marine Projects, where the vessel Crew may be exposed to asbestos through planned activities the Vessel Master must provide a final agreement that such work may be carried out.
Each Vessel shall have:
A comprehensive survey of the vessel with Plan detailing the location of known or suspected areas containing asbestos;
An Asbestos free certificate
Where survey demonstrates the presence or potential presence of Asbestos a Ships Plan shall be developed in which the location of Asbestos material is clearly shown. This shall include where Asbestos containing material such as gaskets and Jointing has been stored.
The Location Plan shall identify the condition of the Asbestos described and in particular if it is considered to be Encapsulated. Where Asbestos is not considered to be encapsulated than an additional assessment of Air borne fibres and any required method for continuous monitoring shall be described.
A Risk Assessment shall be associated with any Asbestos Location Plan clearly demonstrating the potential for exposure either indirectly when transiting adjacent to identified areas or following any planned invasive maintenance activities.
The validity of this Assessment shall be proved not less than each 5 years or following any WORK which may have compromised the integrity of any encapsulation. Such re-assessment shall include assessment of Air borne fibres where continuous monitoring is not employed.
The Risk of exposure should consider the differing routes of exposure and absorption.
Where the Risk Assessment determines a potential exposure due to Airborne fibres then the Company shall carry out suitable sampling in accordance to the requirements laid out in MGN 429.
Samples shall be tested by an approved laboratory and any results considered again the planning for Work and Occupational health program in place for personnel exposed.
In the event that Limits are exceeded a re-assessment of control measures shall take place. Additional warning signage, and physical barriers should be place around the worksite to prevent unnecessary access.
Where it is required to continue WORK then additional control measures including management of personal exposure, workload and suitability of provided PPE including respirators are to be considered. Any continuation should be considered a s temporary until levels can be brought below Limits.
The Primary method for the control of exposure to asbestos is to maintain Encapsulation.
The Secondary method is the removal from the vessel any material Containing Asbestos.
In circumstances where Work is required to be carried out the control shall be through assessment of potential exposure, Risk Assessment and mitigation through good practices
Any area where containing asbestos should have suitable warning signage. Encapsulated areas, which through future Maintenance Activities may have asbestos exposed, shall have suitable warning signage.
Examples of these are given in Appendix A
Areas which may contain Asbestos especially where invasive activities are occurring shall be visually and physically barriered to prevent unnecessary persons from entering until it has been cleaned.
Where WORK is required to be carried out on areas identified in the asbestos Location Plan then the type of work shall be assessed. For WORK which is considered to be Invasive or of demolition type then this work should be completed by Third Party.
Risk Assessment and the Asbestos Maintenance Plan should consider potential exposure to others not directly involved in completing the WORK
Where WORK is not considered Invasive or of Demolition Type, and where such work is required to be completed by Vessel Crew and/or Third Party Employees engaged in direct employment who are not Licensed to carry out such work, then the Asbestos Maintenance Plan
Mitigation measures shall include
Modifying scope or method of WORK to reduce Asbestos exposure
Limiting Personnel involved
Limiting Period of Involvement
Wetting down area
Prevention of Eating or Drinking at site
Appropriate de-contamination procedures
Asbestos disposal shall be strictly controlled as a hazardous product. Any waste shall be dealt with in accordance with local regulation and the companies garbage management procedure including
No new material containing asbestos in any form, or to any amount, shall be supplied to the Vessel
Depending on the scope of work the Asbestos Maintenance Plan [Plan] may be a standalone document or be incorporated within a generic TBRA as part of the Companies Permit to Work System.
Description including Scope and Extent of WORK
Location of WORK
Assessment against Asbestos Location Plan and Asbestos Risk Assessment
Identification of Asbestos Type
Estimation of Asbestos involved, its condition.
Description of how Asbestos handled
Control methods to limit exposure ( wetting down etc)
Minimum Standards for PPE
Where WORK involving ACM cannot be considered to be:
o of Low intensity or Short term Work;
o were the asbestos is not properly contained in a matrix or encapsulated;
o as determined by air monitoring lead to levels of Air bourn fibres less than limits.
then a more comprehensive Asbestos Maintenance Plan is required.
The Plan Shall additionally incorporate, amongst other, the following elements:
Identification of parties involved
Number of Workers Involved
Starting Time and duration of WORK
Recording of period of exposure
Identification of Responsible Person for Plan Approval
Recording of Airborne fibres
Decontamination Procedures including Hygiene provision
Management and refurbishment of tools and PPE between Usage.
Emergency response Procedure
The Vessel Master is identified as Responsible Person for approval or Work described within the Asbestos Maintenance Plan. The Master may defer this responsibility as required to the Chief Officer / Chief Officer Safety.
Invasive maintenance activities shall be taken as non-short term work. Typical examples are work undertaken during extended maintenance periods, dry-docks or over periods where the use of third party employees are required due to the scope of work.
Where opportunity is afforded, effort should be made to remove Asbestos during extended maintenance Periods and Dry-dockings especially where encapsulation is believe to be compromised.
Where the risk is greater to disturb Asbestos then alternative methods for encapsulation should be considered.
No employee shall undertake Licensed work as described in The Control of Asbestos regulations 2012. Any such work shall be performed by accredited Third party experts.
The Management of this work and the control of exposure for persons employed , and other third party employees directly engaged , shall be in accordance to the requirements of this procedure
The employer shall ensure that any Third party Company employed to carry out Invasive Maintenance or demolition Activities involving Asbestos are suitably Competent to carry out such work. Evidence of such shall be made available to the Vessel Master before commencement of WORK.
Any WORK, except where specifically excluded under regulation, which requires an employee or any Third party directly engaged, to undertake activities which are likely to expose them to asbestos must first Notify the Secretary of State in Writing not less than 14 days before WORK commences.
This requirement shall equally apply where such Personnel are required or unavoidably liable to be exposed due to attendance to areas in which WORK is being completed.
Such Notification Shall be in accordance with the requirements of MGN 429
Such notification is not required where one or more of the following applies:
work is of short term;
risk assessment clearly demonstrates that the limit value not be exceeded in the air of the area of activity;
the ACM is firmly fixed in a matrix or encapsulated;
continuous air quality monitoring is employed.
The employer shall maintain a register of those persons where risk exists of exposure to asbestos. This risk shall include personnel who may transit areas where air bourn asbestos is known or suspected to be present.
This register shall be managed in accordance with companies Occupational health Program.
Where there is reasonable cause to suspect that an employee has been exposed then notice shall be given to the Employee and suitable Medical Support given as is necessary including an Assessment of any potential Impact leading from such exposure. Further action shall be in accordance with Companies Occupational Health program and in compliance with the requirements of MGN 429 and The Control of asbestos regulations 2012
Where there is reasonable cause to suspect that a Third party Contractor who has been directly engaged has been exposed to levels of Exposure greater than Limits then notice shall be given to their employer. All information pertaining to the Type of asbestos, level and period of exposure shall be made available on request.
When considering a persons exposure to Asbestos no account should be given to any respiratory protective equipment worn
All crew members shall receive Training in accordance to the requirements of MGN 429 and the Control of Asbestos Regulations 2012.
Any person who is, or may be involved, in the Planning and Management of WORK where exposure to Asbestos is a potential Risk must have completed this training before they are considered competent to do so.
Training shall be repeated each 5 years unless person is specifically identified as being benefited by more frequent repetition.
An unintended release of ACM shall be considered a safety related incident and companies Incident investigation and reporting procedures applied.
Actions taken will depend on the type and extent of release should, as a minimum, involved the following actions:
erection of physical and visible barriers warning crew members of release;
mitigation measures to contain release including such as stopping of ventilation, wetting of the area, physical barriers.
I’d list of all persons who have or may potentially have been exposed to asbestos should be passed to the medic who shall take further action as required.
The Control of Asbestos Regulations 2012 SI 2012 No632
and MGN 429 The Merchant Shipping and Fishing Vessels ( Health and Safety at Work) (Asbestos) regulations 2010