Control of Work

Asbestos

Introduction

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


Types of Asbestos

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.

Assessment of Content

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 Paneling;

o Brake Lining

o Gasket and Jointing materials;

Etc


Definitions


Asbestos

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;

Asbestos Containing Material (ACM)

Product containing some percentage of Asbestos

Encapsulated

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.

Demolition or Invasive Maintenance

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.

Asbestos Survey.

A comprehensive Survey of the vessel to assess potential asbestos Content. Where access is difficult the suitability of Encapsulation shall be assessed.

Asbestos location Plan

A Plan based upon General  Arrangement which highlights those areas where Asbestos is present, or potentially present as described in the Asbestos Survey

Asbestos Risk Assessment

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

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.

Asbestos Limit Value

An airborne concentration of asbestos of:

0.1 Fibres per CM3 (f/cm3) as a 4 hour weight average;

OR

0.6 f/cm3 per 10 minutes.


Measured in accordance with WHO 1997 recommended method


Personnel Protective Equipment (PPE)


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)

Coverall

Gloves

Safety Shoes /Boots

Suitable breathing Mask


Short Term Work

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.


Emergency Response Procedure

A WORK specific procedure governing action in the event of contingency including uncontrolled release of Asbestos.


Roles and Responsibilities

Master

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




WOUK

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:

adequate training;

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

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

Hygiene

Application of mitigation measures including  erection of barriers, warning notices, ventilation etc





Scope

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.


Management Hierarchy




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.


Assessment of Risk


Asbestos Survey

Each Vessel shall have:

A comprehensive survey of the vessel with Plan detailing the location of known or suspected areas containing asbestos;

OR

An Asbestos free certificate


Asbestos Location Plan

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.

Asbestos Risk Assessment

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.




Measurement of Air Quality

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.


Action in the event Airborne Fibre limits exceeded

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.













18.3 Control of Exposure to Asbestos


Methods of control

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


Identification of  Areas Where Exposure to Asbestos Exists

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.





Control of Exposure to asbestos Process


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

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

Control of Discarded Asbestos

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

Proper Labelling

Double Bagging

Control of New Material

No new material containing asbestos in any form, or to any amount, shall be supplied to the Vessel

Asbestos Maintenance Plan

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.

Minimum requirements

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

Disposal Method

Control methods to limit exposure ( wetting down etc)

Minimum Standards for PPE


Extended requirements for increased Scope

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

Plan Approval

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 involving  ACM

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.

Actions to reduce risk associated to asbestos

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.


Licensed Work

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

Management of Invasive Maintenance or Demolition Activities

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.


Notification of Work Relating to Asbestos


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

Exclusions

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.



Management of  Personnel exposed to Asbestos.

Registry of Employees

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.



Actions in event of Known Exposure

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


Training


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.



Actions in the event of Unintended release.

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.


References

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


Appendix A Examples of Signage