The link between exposure to asbestos fibres and adverse human health conditions – asbestosis, pleura and mesothelioma – is well established. Previously developed land, old landfills and imported materials regularly harbour sources of asbestos, either as asbestos containing material (ACM) or loose fibres present in soil.
duncan scott talking point
As many ground engineering projects in the UK occur on such sites and interact with imported materials, it would seem imperative that today’s ground engineering industry is equipped with an understanding of the Control of Asbestos Regulations (CAR) 2012 and the contaminated land industry’s interpretation of these Regulations in the context of asbestos present in the ground (CAR-Soil), which are intended to prevent the dispersion of asbestos fibres and manage health risk.
However, a brief search of GE’s technical papers indicates that the regulation of asbestos in the ground has received scant coverage in recent years. In fact, notwithstanding a brief technical note published in February 2017, there has been little/no coverage on this subject since an initial call for a wider awareness of asbestos issues within the ground engineering community in an article in May 2014, which was seemingly triggered by a storyline in Emmerdale whereby a young girl was diagnosed with mesothelioma following exposure to asbestos.
Rather than summarising CAR-Soil here, I would urge the reader to seek out the document and ensure they (and, indeed, their staff) are familiar with its contents. Instead, the objective here is to briefly highlight two of the less obvious sources of asbestos – pile arisings and imported recycled aggregate – to which ground engineering operatives may become exposed, with the wider aim of encouraging the sector to consider others on a site-specific basis.
It is not uncommon on brownfield sites, having undergone remediation, to have asbestos containing soils at depths beyond which the future site user would not be exposed. The re-use of asbestos containing soils at such depths would be in-keeping with CAR-Soil and would not pose unacceptable risks in the long-term. Therefore, during the construction phase it is possible that augured pile arisings could contain asbestos so careful management of this material could be critical from both a health risk and cost perspective. The cost element is becoming particularly pertinent where the content of asbestos in the arisings exceeds the hazardous waste threshold.
While frequently imported to construct working platforms, the origins of recycled aggregate are highly variable and this is reflected within its composition and quality. Despite the existence of a quality protocol for the production and use of aggregates from inert waste, my own experience is that this protocol is not consistently adhered to by all aggregate suppliers. As a result, it is not uncommon to detect the presence of asbestos in imported aggregate.
Where encountered, the levels of asbestos are typically low, however the presence of ACM interspersed within the aggregate remains a possibility where the product has been purchased from suppliers operating poorly managed production techniques. Therefore imported materials should undergo regular checks to confirm the absence of asbestos from imported loads.
In the context of CAR-Soil, the concept of the requirement for a “competent person” to manage asbestos containing soils resonates throughout. Training and experience of remediation contractors operating in this field makes it easy to fulfil this requirement. However, contractors operating within solely within ground engineering may not necessarily retain this skill-set in-house. Where this is the case, and the presence of asbestos is anticipated on a site, I would urge that a specialist subcontractor is employed to undertake a watching brief during the works to ensure compliance with CAR 2012.
Non-compliance with CAR 2012 risks the health of employees and harms businesses – and this is something we should all be keen to prevent.
- Duncan Scott is technical director at Vertase FLI and FLI QDS