Asbestos Management Plan (OB-HAS-PLAN-09.00)

1.1 The Oxford Brookes University will do all that is reasonably practicable to ensure the health, safety and wellbeing of staff, students and visitors, including contractors, and others who may be affected by the Universities activities.

1.2 To this end, Oxford Brookes believes in achieving our aims in partnership with all interested parties, and is committed to complying as a minimum with our legal responsibilities, but we are seeking to continually improve our health and safety performance in line with best practice.

1.3 Oxford Brookes will maintain and continually review the asbestos management as part of an effective health and safety management system, which we consider to be an essential part of a general Health and Safety policy.

1.4 It is the intention of the University that the established asbestos policy together with the health and safety policies, guidance and procedures shall be followed and developed locally to meet the specific needs of the University. 

1.5 The aim is to ensure that Management of Asbestos is fully compliant with the Control of Asbestos Regulations (2012) as an integral part of managing University general health and safety. 

1.6 This plan will be reviewed annually, and employees will be consulted prior to any amendments being made.

1.7 Oxford Brookes recognises that it has responsibility for the management, maintenance and/or repair of the University buildings and has duties, as the ‘Duty Holder’ of non-domestic premises, under Regulation 4 of the Control of Asbestos at Regulations 2012.

1.8 Oxford Brookes understands its duties under Regulation 4 and that it is required as duty holders to:

• Take reasonable steps to find materials in premises and initiate surveys and systems within premises to find materials likely to contain asbestos
• Presume that materials contain asbestos unless there is strong evidence to suppose they do not and monitor (at least annually)
• Maintain all asbestos in a safe and manageable condition so far as is reasonably practicable 
• Ensure the compilation and maintenance of the Asbestos Register in which the location, extent and condition of asbestos containing materials (ACMs) and installations is recorded
• Make use of the Asbestos Register in which the location of ACMs and installations is recorded
• Assess the likelihood of anyone being exposed to these materials
• Prepare a plan to manage that risk and put into effect to ensure that asbestos is maintained in a safe and manageable condition until such time as it is decided to remove it.  Such maintenance will be in accordance with current legislation.

1.9 Oxford Brookes will ensure that the individual(s) who they intend to delegate to are trained to a sufficient level of competency. The responsibility as Duty Holder cannot be delegated and is retained by the University Vice Chancellor regardless of whether the operational function is delegated or not. 

2.1 This Asbestos Management Plan (AMP or Plan) describes how Oxford Brookes manages the risks from ACMs. The AMP should be read in conjunction with the Asbestos Management Procedure. It sets out University policy and procedures and is designed to effectively manage and minimise asbestos‐related health risks to personnel working at Oxford Brookes, or occupying its premises.

2.2 The Plan sets out the mechanism by which asbestos is managed. It includes details on how the Oxford Brookes intends to:

• Protect those working on the fabric of Oxford Brookes.
• Protect those working with or occupying Oxford Brookes.
• Effectively control any works likely to affect asbestos.
• Identify and categorise asbestos and manage those hazards based on prioritisation and assessment of the risk that they present.
• Produce a prioritised programme for the remediation of asbestos that, because of their location and/or condition, present a risk to health.
• Monitor and maintain the condition of identified ACMs that are assessed as being able to be left in-situ.

2.3 The University, in recognition of its duties under the Health and Safety at Work Act 1974, towards its employees, students, visitors, contractors and members of the public, undertakes to responsibly manage all asbestos.

2.4 The ECS Directorate will ensure that assessments are undertaken to determine the presence of asbestos in all premises for which it is responsible and a register of these assessments shall be maintained by the Responsible Person and made accessible to relevant persons.

2.5 The Responsible Person will review these assessments in line with Regulation 4 of the Control of Asbestos Regulations 2012, on a predetermined basis to ensure their validity. In addition the management plan will be reviewed regularly and when there is any significant change in legislation or best practice.

2.6 The ECS Directorate will ensure that all employees involved in the management and maintenance of University property or who are liable to be exposed to asbestos, receive adequate information, instruction and training.

2.7 All contractors who are liable to be exposed to asbestos will be required to show evidence of similar information, instruction and training to University staff, as part of the vetting procedure for contractors to work on University premises.

2.8 The University will only employ organisations that are appropriately accredited to advise, assist and guide in the continued safe management of asbestos. 

This will ensure that organisations employed can demonstrate:

• competence (including training and experience in such work)
• impartiality, independence, and integrity
• an adequate quality management system
• work being undertaken is in accordance with the Approved code of Practice (ACoP) and guidance for the services.

Staff training 

2.9 In line with Regulation 10, CAR 2012, suitable and sufficient training will be provided to all key relevant staff that in their current roles may come into contact with and have the potential to disturb asbestos:

• who by nature of the work they undertake are likely to inadvertently disturb asbestos; or
• with responsibilities to manage asbestos
• who have management responsibilities for asbestos within the University estate
• supervisors of such people.

2.10 The majority of staff within ECS will have little involvement in the active management of asbestos.  However, by virtue of the activities they undertake, the following courses will be a requirement for staff within ECS:

• Asbestos Awareness

  • Members of the Maintenance Department
  • Estates Staff (Buildings, Electrical, Grounds and Mechanical).
  • Campus Services Staff (Campus Service Assistants, Supervisors)
  • Project Managers
  • Accommodation Team.
    
    

• Asbestos Awareness and Responsible Person Training

  • All staff with responsibility for arranging and managing construction work, or with responsibility for control of contractors.
  • Any others at the discretion of Line Managers.
    
    

• P405 Asbestos Management in Buildings

  • Estate Managers
  • Head Of Maintenance
  • Building Team Manager
  • Contract and Compliance Manager.

2.11 In addition, there are likely to be other members of staff from other areas who may require asbestos training. These include for example:

• IT personnel.
• Technical staff.

3.1 Asbestos was used in the UK up to 2000 in the construction and manufacturing industries.  Any building along with its associated plant, constructed or refurbished prior to this year, may contain asbestos in one or other of its many different forms.

3.2 In addition, some equipment (including that used in teaching and research), constructed in the UK prior to this date, may contain asbestos. Asbestos continues to be used in construction and as components within equipment in many other countries.

3.3 It is important to note that Oxford Brookes manages many but not all of the buildings used by its staff and students. Those buildings managed by other institutions/organisations/bodies have their own asbestos management arrangements.

3.4 The presence of an ACM does not in itself constitute a danger. However, the ACM may become hazardous when disturbed or damaged and must be treated accordingly. 

3.5 Activities which give rise to airborne dust, e.g. breaking, sawing, cutting, drilling etc. are most likely to present risks.

3.6 Where staff are aware of equipment that they suspect may contain asbestos, they should contact their local Facilities manager, who will liaise with the University’s Responsible Person.

4.1 The aim of the AMP is to protect the University and its members from the risk of exposure to asbestos.

4.2 At Oxford Brookes level there are four main risks to the effective management of asbestos:

• failure or inadequate AMP which might result in exposure or prosecution
• loss of competency in asbestos management
• loss of the Asbestos Register
• insufficient resource (funding).

4.3 In addition there are specific risks relating to the activities surrounding residencies:

• Risk of Oxford Brookes ECS staff and contractors disturbing ACMs - particularly unlabelled, concealed or hidden materials.
• Risk of exposure to asbestos in premises not controlled by the Oxford Brookes University (e.g. Site partners, external accommodation providers).

4.4 There are also specific risks associated with research and teaching including accidentally disturbing or damaging superficial or hidden asbestos in Oxford Brookes University property or on sites not owned or controlled by Oxford Brookes.

5.1 The Asbestos Register is held within an online database. This records known and suspected ACMs in Oxford Brookes managed campuses, and It contains information on their location, extent and condition.

5.2 The information held within the register enables the identified asbestos to be risk assessed according to its material type, location and likelihood of disturbance.

5.3 The Asbestos Register (available through the online database) is available to all who may reasonably require such information:

• Other enquirers should go through the ECS team, or Building or Project Manager where appropriate.
• Emergency Services can obtain Register information the Premise Information/Gerda boxes.

5.4 The presumption must be made that ACMs may be present in all un‐surveyed areas and for all surveyed areas where the specific location would not have fallen within the scope of the historical survey inspections.

Updates

5.5 The Asbestos Register is updated by the University’s appointed Competent Asbestos Contractor. Where changes are made to the estate which may affect data in the Register, the person/organisation responsible for the change, must supply relevant information to the University’s Responsible person, their Deputy and Competent Asbestos Contractor.

5.4 Oxford Brookes will retain the Asbestos Register, which will be available for consultation on request. All asbestos related activities must be notified to the Responsible person and undertaken only by Oxford Brookes approved Licensed Asbestos Contractors, so that the Register can be updated. 

Updates may be required after:

• identification of further ACMs
• surveys
• removal of ACMs
• inspection/monitoring exercises
• changes in building layout or area use.

Audit

5.6 Regular Register audits will be instructed by the Responsible Person.  This will include comparison of representative Asbestos Register entries against site inspections and records of asbestos remedial works.

5.7 The audit report will be made available to all relevant parties and will form part of the AMP Review.

6.1 All asbestos in the Asbestos Register are objectively assessed (materially) by the Competent Asbestos Consultant, the Responsible Person and or the Deputy Responsible Person using a formal numerical scoring scheme. This considers aspects of materials assessment and priority assessment as described in the HSE document HSG 227 ‘A comprehensive guide to managing asbestos in premises.

6.2 The materials assessment considers features of the material, the priority assessment (undertaken with the supervision of the responsible person) considers the environment in which the ACM is found and the likelihood that persons may be exposed to asbestos fibres.

6.3 The scheme considers the following parameters:

• product type
• condition
• surface treatment
• asbestos type
• location
• position of material, for example how accessible it is during normal building occupancy
• susceptibility to damage
• number of people potentially exposed
• whether the material is subject to maintenance, refurbishment or other possible disturbance.

6.5 ACMs with higher assessment scores are likely to require greater consideration regarding remediation measures than those with lower scores.

7.1 Oxford Brookes currently employs a competent asbestos consultant to support it in ensuring the management of asbestos is appropriate and in line with all current regulations. 

7.2 To this end, asbestos surveys have previously been carried out at Oxford Brookes and this information forms the basis of the current Register.

7.3 Oxford Brookes will conduct annual re-inspections  of all ACMs unless it is believed the asbestos has deteriorated since the last survey, at which point it will be resurveyed.  Full details of the survey programme is available from the Responsible/Deputy Responsible Person –the University’s Head of Maintenance and Building Team Manager.

7.4 Oxford Brookes is committed to ensuring all known asbestos materials are kept in a “safe and manageable” condition, will commission formal re‐inspections of known or suspected ACMs, and these will be carried out by an appropriately accredited inspection body to maintain a high quality of assessment.

7.5 The inspection period will be set by the Responsible Person in consultation with the Competent Asbestos Consultant.

7.6 A programme of remedial actions based on the risk rating of the asbestos will be maintained by the Deputy Responsible Person.  This programme will be subject to regular review with ECS and made available for auditing purposes to the H&S team.

8.1 Labelling with standard ‘asbestos warning labels’ or fixing of appropriate warning signage will be carried out to all known accessible ACMs considered to be of significant risk where this is deemed to help prevent accidental damage, and not cause undue concern.

8.2 In particular all plant rooms where asbestos is known to be located will be labelled with a warning contains asbestos label. Please contact healthandsafety@brookes.ac.uk for a copy of the label. All contractors are made aware of the presence and meaning of these labels through the contractor induction programme.

8.3 Labelling of lower risk materials, for example, packing to soil pipes, seals to ductwork, may not be carried out if other control mechanisms e.g. site awareness, are considered adequate in preventing accidental exposure.  Where it is likely that asbestos could reasonably be assumed to be present, but may not have been subject to a survey (e.g. within boxed in pipes, behind fixed access covers), these areas will be marked with before working beyond this point please contact ECS.  Please contact healthandsafety@brookes.ac.uk for a copy of the label. 

8.6 If a label is not present, this DOES NOT indicate the absence of asbestos, and the asbestos register should be reviewed as per 5.3.

• Jerry Woods, Director of ECS, 15 April 2024
• Paul Bradley, Director of Occupational Health and Safety, 21 March 2024
• Steve Holtom, Head of Maintenance, 21 March 2024
• Lee Smith, Buildings Team Manager, 16 April 2024
• Craig Connolly, Contractor and Compliance Manager, 25 March 2024.