Asbestos and schools: the lessons learnt
In recent years, there has been increased attention given to asbestos management in schools. Clearly, health issues affecting children and young people will always raise concerns, particularly with their parents and those running schools. This concern will have been heightened by the publication of the Committee on Carcinogenicity (CoC) report into whether children were particularly vulnerable to asbestos fibre exposure in 2013. The CoC found the following.
“There is evidence that childhood exposure to asbestos can cause mesothelioma in later life. The effect of increased life expectancy of children compared to adults and the long latency period is recognised, with the lifetime risk of developing mesothelioma predicted to be about 3.5 times greater for a child first exposed at age 5 compared to an adult first exposed at age 25, and about 5 times greater when compared to an adult first exposed at age 30.”
So if children are exposed to asbestos, they have a greater risk of developing mesothelioma than if exposed in later life. In addition, there has been an increase in the number of teachers developing mesothelioma within the last 10 years.
In response to these developments, the Department for Education (DfE) established the Asbestos in Schools Steering Group, to bring together various interested parties to help shape the Department’s policies and action. One result has been the publication of Asbestos Management in Schools. However, the DfE has an ongoing programme related to asbestos in schools.
The DfE has been assisted by the Health and Safety Executive (HSE), which has undertaken some “intensive inspections” of different schools. In this article, the findings of the HSE’s latest “intensive inspection” initiative – published in June 2014 – will be reviewed and any lessons learnt that may be of interest to other organisations will be highlighted.
Complying with regulations
During the latest “intensive inspection”, the HSE inspected 153 non-Local Authority managed schools. Independent, academy, foundation, voluntarily-aided and free schools were inspected. Due to the sample size of each, comparisons between different types of schools would have been difficult for some. Hence the HSE only considered independent, academy and free schools when comparing results from different schools. It also selected schools from England, Scotland and Wales to identify whether differences of approach were being taken in different countries.
Some of the key findings were as follows.
- Of the 153 schools visited, 20 (13%) were issued with an Improvement Notice. Of the 20 Improvement Notices issued:
- 8 were due to the absence of an asbestos management plan
- 8 were due to a lack of survey or inadequate assessment
- the remainder were due to insufficient training and information for employees and inadequate management of risk.
- 24 other schools were given “written advice” on improving their controls
- 64% of schools had a full understanding of who the duty holder was, and a further 31% had a broad understanding
- 46% of schools did not have a comprehensive system in place to provide information to those who might disturb asbestos-containing materials (ACMs); this was a slight decrease on the 2010/11 figure
- 85% of schools had completed a management survey, with the most common method of doing so being a combination of sampling and presumption that materials contain asbestos (46% of the schools inspected)
- The proportion of schools checking surveyor competency was lower than in the 2010/11 sample, and variation was evident across regions/nations. Only 31% of schools were able to show that they had checked the competency of the surveyor
- The surveys completed were comprehensive in 67% of the schools visited, a lower figure than that found in 2010/11
- 77% of schools reported having an Asbestos Management Plan (AMP), with around half of these being comprehensive, an improvement on 2010/11 figures
- A majority of schools with an AMP had a system to identify risks relating to the condition of ACMs and a majority also had a system to identify risks related to the location of the ACMs. In both cases, just over half of schools recorded all the details required
- Wales had the highest proportion of schools with a comprehensive AMP, and Scotland the lowest
- In those schools where in-house operatives undertake building and maintenance work there had been an improvement since 2010/11, with 63% now having training in place, but there were regional/national variations
- 39% of schools in England were aware of the DfE guidance.
The HSE report gives much more detailed information but the points identified above give an indication of the extent of compliance with the Control of Asbestos Regulations 2012.
While the HSE was able to see some levels of improvement, the results highlighted some significant problems. Asbestos has received considerable attention over many years but only 39% of schools in England were aware of the DfE’s guidance on managing asbestos in schools.
Asbestos information is included within the HSE review of Approved Codes of Practice and guidance. During the next year the HSE will be publishing reviewed guidance in relation to asbestos contractors and a range of other guidance related to asbestos.
Those involved with managing asbestos must ensure they are using the most current guidance. During this year the HSE will be launching the next phase of its “Asbestos: Hidden Killer” campaign, which will bring more attention to the issue.
The competency of surveyors is critical in identifying where asbestos is and in what condition. Yet only 31% of schools could show to the HSE they had checked the competency of the surveyors they used. There has been concern that the quality of surveyors can lead to inadequate asbestos surveys. The HSE has identified in its survey guide what to look for when identifying a suitable asbestos surveyor.
As part of managing asbestos, managers should be able to identify the competence of the surveyors used to identify where asbestos may be located and what condition it is in. It should be noted that the HSE sees identification of asbestos as a key step in managing it in buildings. Yet six Improvement Notices were issued because no survey had been done. Another was issued because the survey did not cover all the buildings.
In relation to Asbestos Management Plans only half of the schools recorded all the details that were required, 33% had no such plans and a significant number of the Improvement Notices were issued in relation to this failing. For anyone managing asbestos in buildings the HSE sees the AMP as a key document.
The HSE inspection also highlighted that training had been lacking in a significant number of instances. This was of concern particularly in relation to those workers who may work with asbestos. A total of 37% of those involved with building and maintenance work had not been trained on working with asbestos. Given that the successful HSE “Asbestos: Hidden Killer” campaign was directly targeted at such workers, this appears to be a significant failing. With the resumption of the next phase of this campaign, the HSE recognises that information and training is a critical issue. Duty holders must recognise this too.
The “intensive inspections” highlight the compliance levels with asbestos regulations in a representative sample of schools, but the lessons learnt also need to be applied elsewhere.