This policy details how Connexus fully complies with the requirements of The Control of Asbestos Regulations (CAR) 2012.
To support this policy, Connexus has an Asbestos Management Plan (AMP) to ensure customers safety is a priority. The plan is referenced in this policy.
Breathing in air containing asbestos fibres can lead to asbestos-related diseases, mainly cancer of the lungs and chest lining. Asbestos is only a risk to health if asbestos fibres are released into the air and breathed in. Past exposure to asbestos currently kills around 5,000 people a year in Great Britain.
1.2
There is usually a long delay between first exposure to asbestos and the onset of the disease (15-60 years). Only by preventing or minimising these exposures now can asbestos-related disease eventually be reduced.
1.3
Any Connexus home or building built or refurbished before the year 2000 may contain asbestos. As long as the asbestos containing material (ACM) is in good condition and is not going to be disturbed or damaged, there is negligible risk. However, if it is disturbed or damaged it can become a danger to health because people may breathe in any asbestos fibres released into the air. Workers who carry out repairs and maintenance work are at particular risk. If asbestos is present and can readily be disturbed, is in poor condition and not managed properly, others who may be occupying the homes or buildings could also be put at risk.
1.4
Connexus is responsible for the maintenance and repairs to homes, non-domestic (communal blocks) and ‘other’ properties (e.g. offices, commercial shops, depots, etc.), many of which will have been constructed using asbestos containing materials. As such, the organisation has a legal ‘duty to manage’ asbestos in its homes and buildings and this must be done in accordance with The Control of Asbestos Regulations (CAR) 2012.
The policy applies to the whole of the Group. This means Connexus Homes Limited (ultimate parent) and all of its subsidiaries.
2.2
Connexus must establish a policy which meets the requirements of The Control of Asbestos Regulations (CAR) 2012, which came into force on 6th April 2012. In addition to this, the policy must provide assurance to Connexus that measures are in place to identify, manage and / or mitigate risks associated with asbestos. In addition, Connexus must establish an Asbestos Management Plan (AMP), which outlines key information on roles and responsibilities, and the management of information, works, and ACMs.
2.3
Connexus must also ensure that compliance with asbestos related legislation is formally reported at SMT and Board level, including the details of any non-compliance and planned corrective actions.
2.4
The policy is relevant to all Connexus employees, tenants, contractors and other persons or other stakeholders who may work on, occupy, visit, or use its premises, or who may be affected by its activities or services.
2.5
It should be used by all to ensure they understand the obligations placed upon Connexus to maintain a safe environment for customers and employees within the homes of each customer, and within all communal areas of buildings and ‘other’ properties (owned and managed).
Regulatory Standards - the application of this policy will ensure compliance with the regulatory framework and consumer standards (Home Standard) for social housing in England, which was introduced by the Regulator of Social Housing (RSH).
3.2
Legislation - the principle legislation applicable to this policy is The Control of Asbestos Regulations (CAR) 2012, which came into force on 6th April 2012. Connexus has a legal obligation under Part 2, Section 4 of the legislation (Duty to manage asbestos in non-domestic properties) and is the ‘Duty Holder’ for the purposes of the legislation. Connexus is the ‘duty holder’ by virtue of the fact that they own and manage homes and buildings housing tenants and leaseholders through the tenancy and lease agreement obligations it has.
3.3
Approved Codes of Practice and Guidance – the principle approved codes of practice and guidance (as updated) applicable to this policy are:
ACoP L143 - ‘Managing and working with Asbestos’ (Second edition December 2013)
HSG264 - ‘Asbestos: The survey guide’ (Second edition 2012, this holds ACoP status)
HSG248 – ‘Asbestos: The analysts guide for sampling, analysis and clearance procedures’ (Second edition May 2021)
HSG247 - ‘Asbestos: The licensed contractors’ guide’ (First edition 2006)
HSG227 - ‘A comprehensive guide to managing asbestos in premises’ (First edition 2002)
HSG210 - ‘Asbestos Essentials – A task manual for building, maintenance and allied trades and non-licensed asbestos work’ (Fourth edition 2018)
3.4
Sanctions – Connexus acknowledges and accepts its responsibilities in accordance with the regulatory standards, legislation, and approved codes of practice, and that failure to discharge these responsibilities properly could lead to a range of sanctions including prosecution by the Health and Safety Executive under the Health and Safety at Work Act 1974, prosecution under the Corporate Manslaughter and Corporate Homicide Act 2007 and via a serious detriment judgement from the Regulator of Social Housing (RSH).
3.5
Tenants and Leaseholders – Connexus will use the legal remedies available within the terms of the tenancy and lease agreement should any tenant, leaseholder or shared owner refuse access to carry out essential asbestos related inspection and remediation works.
The duty to manage asbestos is included in The Control of Asbestos Regulations (CAR) 2012. The duty requires Connexus to manage the risk from asbestos by:
Finding out if there is asbestos present, where Connexus has an obligation to do so, in the homes and buildings they own and manage (or assessing if asbestos containing materials are liable to be present and making a presumption that materials contain asbestos, unless Connexus has strong evidence that they do not). As well as, identifying its location and identifying what condition it is in. If the home or building was built prior to the year 2000 Connexus will assume asbestos is present. If the home or building was built after the year 2000, asbestos is unlikely to be present and no further action will be required.
Making and keeping an up-to-date record (referred to as the ‘asbestos register’) of the location and condition of the asbestos containing materials or presumed asbestos containing materials in the homes and buildings owned and managed by Connexus.
Assessing the risk from the asbestos containing materials found.
Preparing an Asbestos Management Plan that sets out in detail how the organisation is going to manage the risk from the asbestos containing materials and taking the steps needed to put the asbestos management plan into action.
Connexus must also review and monitor the asbestos management plan and the arrangements made to put it in place; and set up a system for providing information on the location and condition of the asbestos containing materials to anyone who is liable to work on or disturb these materials.
5.2
Anyone who has information on the whereabouts of asbestos in homes and buildings is required to make this available to the organisation as the ‘duty holder’, but the organisation then must assess its reliability.
Connexus recognises that the main hazard in relation to asbestos is the non-identification of ACMs and as such will protect those persons potentially exposed to asbestos as far as is reasonably practical by minimising the exposure through the use of appropriate control measures and working methods.
6.2
Connexus accepts that asbestos is likely to be present in the majority of its properties built prior to the year 2000 and will therefore manage these properties accordingly.
6.3
In order to fully comply with the legislation Connexus will have a Board approved Asbestos Policy. In addition the organisation will have an Asbestos Management Plan and an Asbestos Register which will hold records of the assets which have asbestos containing materials in them.
6.4
Connexus will hold accurate records against each property it owns or manages, identifying whether the property has had its initial asbestos management survey and when the next re-inspection is due.
6.5
Survey and re-inspection dates, details of ACM’s and asbestos management survey reports will be held electronically in MRI Housing Asset Management.
6.6
Connexus will employ competent external contractors (in line with HSG264) to undertake asbestos management surveys. Licensed asbestos removal operatives and/or contractors will be employed to carry out licensed remediation works (where necessary) to non-domestic (communal blocks/’other’ properties) and domestic properties as outlined in section 8 of this policy.
6.7
Connexus will employ suitably competent persons to undertake asbestos re-inspections and the removal of non-licensed asbestos.
6.8
Connexus will undertake a targeted intrusive refurbishment and demolition (R&D) survey to domestic and non-domestic properties as and when required as per HSG264. This will also be in accordance with the criteria set out in the Connexus Asbestos Management Plan, which should be read in conjunction with this policy.
6.9
Connexus considers good communication essential in the safe delivery of asbestos management and will therefore ensure that information about asbestos containing materials (known or suspect) is provided to persons liable to disturb it, accidentally or during the course of the work. This includes employees, contractors and tenants.
6.10
Connexus will provide advice to customers regarding asbestos containing materials through leaflets and information held on the organisation’s website.
6.11
Connexus will ensure that all contractors’ employee and public liabilities are up to date on an annual basis.
6.12
Connexus will ensure contracts / service level agreements are in place with the contractors responsible for delivering the compliance service.
6.13
Connexus will ensure there are effective contract management arrangements in place, in the form of client-led meetings taking place regularly, with standard agendas and minutes produced, key performance indicators analysed and programmes and performance scrutinised.
6.14
Connexus will provide leaseholders and tenants with an asbestos survey report during the new tenancy sign up process if one exists. Tenants and Leaseholders may request a copy of the survey for communal areas of their block.
6.15
Connexus will provide tenants with information about asbestos via leaflets that will tell them of possible asbestos containing materials (ACMs) in their home, advise what to do if they wish to carry out DIY or employ a contractor to undertake work and advise who to contact if ACMs are accidentally disturbed.
6.16
Connexus will generally not use asbestos labelling in domestic premises, however, in non-domestic premises and common areas of domestic blocks, labelling may be used where practicable.
6.17
Connexus will implement a robust process to deal with all changes to stock, including new property acquisitions, disposals and stock transfers, in order to ensure that properties are not omitted from the compliance programme, and to ensure the programme remains up-to-date.
6.18
Connexus will ensure that there is a robust process in place for the management of immediately dangerous situations identified from any asbestos related works undertaken on properties.
Non-Domestic Stock – Connexus will review existing asbestos management survey information prior to carrying out any repairs or planned maintenance works which may involve working on, or adjacent to, any asbestos containing materials within non-domestic (a communal block) or ‘other’ properties (e.g. offices, commercial shops etc.). This is to ensure that any asbestos containing materials likely to pose a risk are identified prior to works commencing and the details passed onto the relevant operatives or external contractors and managed in an appropriate way. Where required a new hybrid R&D/management survey should be commissioned prior to work commencing.
7.2
Connexus will ensure that all non-domestic (communal blocks) and ‘other’ properties in ownership or management have an initial asbestos management survey carried out. All surveys will comply with the CAR 2012 legislation. Any management surveys which currently pre-date 2012 will be reviewed and updated if deemed necessary. These updated surveys where required will have a targeted completion date of 12 months following the approval of this policy.
7.3
Thereafter all non-domestic (communal blocks) and ‘other’ properties will have a re-inspection survey and an assigned re-inspection date where applicable. This date will be in accordance with the specific needs of the building. It will either be annually or at a period dictated by the previous survey/re-inspection. Re-inspection dates may change following the re-categorisation of a property or a building.
7.4
Connexus will not need to re-inspect any non-domestic (communal blocks) or ‘other’ properties built after the year 2000.
7.5
Domestic Stock – Connexus will review existing asbestos management survey information prior to carrying out any void repairs, day to day repairs, or planned maintenance works which may involve working on or adjacent to any asbestos containing materials within a domestic property. This is to ensure that any asbestos containing materials likely to pose a risk are identified prior to works commencing and the details passed onto the relevant operatives or external contractors and managed in an appropriate way.
7.6
Where there is no previous asbestos related information in respect of a domestic property which requires an asbestos survey ahead of responsive repairs a survey will be undertaken and the scope of the survey agreed with the Compliance Team, in accordance with the works due to be carried out.
7.7
Connexus will not need to re-inspect any domestic properties built after the year 2000.
7.8
Refurbishment Work (Planned and voids) – Connexus will undertake an intrusive refurbishment and demolition (R&D) survey to domestic, non-domestic (communal blocks) and ‘other’ properties prior to planned maintenance or void works taking place to the areas of the property that are likely to be disturbed as part of the proposed works. They will also undertake a management survey to the remainder of the property as part of the same R&D survey if there is no existing management survey in place. This will be in accordance with the criteria set out in the Asbestos Management Plan, which should be read in conjunction with this policy.
7.9
Garages – Connexus has 2,513 garages in ownership. Many of these garages may contain asbestos containing materials. As such, Connexus will carry out a programme of sample inspections (as per the relevant HSG) per garage site, to assess the location and condition of the asbestos containing materials within these garages and implement a remedial programme of works thereafter if necessary.
Connexus will ensure there is a robust process in place for the management of any follow-up works required following the completion of an asbestos management survey or re-inspection.
8.2
Where asbestos is positively identified and as a result of a risk assessment (conducted in accordance with published guidance) removal, sealing or encapsulation is recommended, this will be carried out for:
Non-licensed works – as defined in regulation 2 of the CAR 2012 – by specifically trained contractors (including operatives working for the in-house team) with appropriate equipment and working procedures in place which are sufficient to comply with the CAR 2012.
Notifiable non-licensed works – as defined in regulation 2 of the CAR 2012 – by a licensed asbestos removal contractor (LARC) licensed by the Health and Safety Executive in compliance with the CAR 2012, or
Licensed works - as defined in regulation 2 of the CAR 2012 – by a LARC, licensed by the Health and Safety Executive in compliance with the CAR 2012.
Connexus will establish and maintain a programme of non-domestic (communal blocks) and ‘other’ property surveys and re-inspections and an Asbestos Register of all the asbestos containing materials by type, address, location and condition.
9.2
Survey dates, details of ACMs and asbestos management survey reports will be held electronically on MRI Housing Asset Management.
9.3
MRI Housing Asset Management will be used to record the details of all asbestos surveys undertaken on Connexus’ non-domestic (communal), domestic and other properties. This system will include the date of the most recent survey.
9.4
The findings from the asbestos survey, including any ACMs and remediation works identified and subsequently completed (including evidence of removal and encapsulation) should also be recorded on either Orchard Assets (licensed works) or Orchard Repairs (in-house works).
9.5
Appropriate asbestos information will be made available to all interested stakeholders as required.
Connexus Board will have overall governance responsibility for ensuring the asbestos policy is fully implemented to ensure full compliance with the regulatory standards, legislation and approved codes of practice. SMT will formally approve this policy and review it every two years (or sooner if there is a change in regulation, legislation or codes of practice).
10.2
The SMT and Board will receive regular updates on the implementation of the Asbestos Policy and asbestos performance along with notification of any non-compliance issue which is identified. This is so they have assurance that the policy is operating effectively in practice.
10.3
The Director of Property has strategic responsibility for the management of asbestos and ensuring compliance is achieved and maintained. The Director of Property will also oversee the implementation of the Asbestos Policy.
10.4
The Asbestos Manager in conjunction with the Compliance Manager will be responsible for overseeing the delivery of the agreed survey inspection programmes and the prioritisation and implementation of any works arising from the surveys. They will ensure Connexus Repairs and/or external contractors deliver the programme of inspections and remedial works in accordance with this policy.
10.5
The housing teams will provide key support in gaining access into properties where access is proving difficult and use standards methods to do so. They will also facilitate the legal process to gain access as necessary.
10.6
The Director of Property will be responsible for ensuring the policy is reviewed every two years, and will notify the Board, SMT and operational team responsible for the delivery of the compliance programme, of the upcoming review. The Director of Property will ensure that this review process takes place before the policy expires in June 2024.
10.7
The Director of Property will ensure that this policy is saved on the organisations shared drive and distributed to all relevant members of staff.
Connexus will ensure that the Asbestos Manager with lead responsibility for operational delivery is suitably qualified holding a P405, P402, or P407 qualification.
11.2
Connexus will ensure that competent (as per HSG264) UKAS accredited contractors are procured and appointed to deliver asbestos management surveys.
11.3
Connexus will ensure that competent licensed asbestos removal contractors are appointed for all notifiable non-licensed work or licensed works.
11.4
The operational team with responsibility for delivery will check the relevant qualifications of employees working for these contractors on an annual basis and evidenced appropriately.
Connexus will ensure that all operatives working for, or on behalf of the organisation have the relevant training required for their role. This will be managed via periodic assessments of training needs and resulting programmes of internal and/or external training.
Robust key performance indicator (KPI) measures will be established and maintained to ensure Connexus is able to report on performance in relation to asbestos.
13.2
KPI measures will be produced and provided at SMT level on a monthly basis and at Board level on a quarterly basis. As a minimum these KPI measures will include reporting on:
The total number of:
Properties – split by non-domestic properties (communal blocks) and ‘other’ properties
Properties on the asbestos management / re-inspection programme
Properties not on the asbestos management/re-inspection programme
Properties with a valid ‘in date’ survey / re-inspection. This is the level of compliance expressed as a number and a %
Properties where the survey / re-inspection has expired and is ‘out of date’. This is the level of non-compliance expressed as a number and a %
Properties which are due to be surveyed/re-inspected within the next 90 days. This is the early warning system.
The percentage of domestic stock with full asbestos data
Connexus will commission ongoing third-party auditing of both asbestos surveys and asbestos removals.
14.2
Connexus will commission an independent audit of asbestos at least once every two years. This audit will specifically test for compliance with the regulation, legislation and codes of practice and identify any non-compliance issues for correction.
Any non-compliance issue identified at an operational level will be formally reported to the Director of Property in the first instance.
15.2
The Director of Property will agree an appropriate course of corrective action with the operational team in order to address the non-compliance issue and report details of the same to the SMT.
15.3
The SMT will ensure the Board are made aware of any non-compliance issue so they can consider the implications and take action as appropriate.
15.4
In cases of a serious non-compliance issue the SMT and Board will consider whether it is necessary to disclose the issue to the Regulator of Social Housing in the spirit of co-regulation, or any other relevant organisation such as the HSE, as part of the Regulatory Framework.
This glossary defines the key terms used throughout this asbestos policy:
Duty Holder: the owner of the non-domestic premises or the person or organisation that has clear responsibility for the maintenance or repair of non-domestic premises, for example through an explicit agreement such as a tenancy agreement or contract.
UKAS: the appointed national accreditation body for asbestos surveyors. Accreditation is a means of assessing, in the public interest, the technical competence and integrity of organisations offering evaluation services.
Asbestos Policy
Primary tabs
Welcome to the Asbestos Policy
This policy details how Connexus fully complies with the requirements of The Control of Asbestos Regulations (CAR) 2012.
To support this policy, Connexus has an Asbestos Management Plan (AMP) to ensure customers safety is a priority. The plan is referenced in this policy.
Asbestos Policy
Approved by
Director of Property
Effective date
June 2022
Review date
June 2024
Policy developed by
Director of Property
Approved
SMT 28th July 2022
Associated procedure
Asbestos Management Plan
Contents
Introduction. 1
1. Purpose. 1
2. Scope. 1
3. Regulatory Standards, Legislation, and Approved Codes of Practice. 2
4. Additional Legislation. 3
5. Obligations. 3
6. Statement of Intent 4
7. Compliance Risk Assessment/ Inspection Programmes. 6
8. Compliance Follow up Work. 7
9. Record Keeping. 7
10. Key Roles and Responsibilities. 8
11. Competent Persons. 9
12. Training. 9
13. Performance Reporting. 9
14. Quality Assurance. 10
15. Non-Compliance/Escalation Process. 10
16. Glossary. 10
Introduction
1.1
Breathing in air containing asbestos fibres can lead to asbestos-related diseases, mainly cancer of the lungs and chest lining. Asbestos is only a risk to health if asbestos fibres are released into the air and breathed in. Past exposure to asbestos currently kills around 5,000 people a year in Great Britain.
1.2
There is usually a long delay between first exposure to asbestos and the onset of the disease (15-60 years). Only by preventing or minimising these exposures now can asbestos-related disease eventually be reduced.
1.3
Any Connexus home or building built or refurbished before the year 2000 may contain asbestos. As long as the asbestos containing material (ACM) is in good condition and is not going to be disturbed or damaged, there is negligible risk. However, if it is disturbed or damaged it can become a danger to health because people may breathe in any asbestos fibres released into the air. Workers who carry out repairs and maintenance work are at particular risk. If asbestos is present and can readily be disturbed, is in poor condition and not managed properly, others who may be occupying the homes or buildings could also be put at risk.
1.4
Connexus is responsible for the maintenance and repairs to homes, non-domestic (communal blocks) and ‘other’ properties (e.g. offices, commercial shops, depots, etc.), many of which will have been constructed using asbestos containing materials. As such, the organisation has a legal ‘duty to manage’ asbestos in its homes and buildings and this must be done in accordance with The Control of Asbestos Regulations (CAR) 2012.
2.1
The policy applies to the whole of the Group. This means Connexus Homes Limited (ultimate parent) and all of its subsidiaries.
2.2
Connexus must establish a policy which meets the requirements of The Control of Asbestos Regulations (CAR) 2012, which came into force on 6th April 2012. In addition to this, the policy must provide assurance to Connexus that measures are in place to identify, manage and / or mitigate risks associated with asbestos. In addition, Connexus must establish an Asbestos Management Plan (AMP), which outlines key information on roles and responsibilities, and the management of information, works, and ACMs.
2.3
Connexus must also ensure that compliance with asbestos related legislation is formally reported at SMT and Board level, including the details of any non-compliance and planned corrective actions.
2.4
The policy is relevant to all Connexus employees, tenants, contractors and other persons or other stakeholders who may work on, occupy, visit, or use its premises, or who may be affected by its activities or services.
2.5
It should be used by all to ensure they understand the obligations placed upon Connexus to maintain a safe environment for customers and employees within the homes of each customer, and within all communal areas of buildings and ‘other’ properties (owned and managed).
3.1
Regulatory Standards - the application of this policy will ensure compliance with the regulatory framework and consumer standards (Home Standard) for social housing in England, which was introduced by the Regulator of Social Housing (RSH).
3.2
Legislation - the principle legislation applicable to this policy is The Control of Asbestos Regulations (CAR) 2012, which came into force on 6th April 2012. Connexus has a legal obligation under Part 2, Section 4 of the legislation (Duty to manage asbestos in non-domestic properties) and is the ‘Duty Holder’ for the purposes of the legislation. Connexus is the ‘duty holder’ by virtue of the fact that they own and manage homes and buildings housing tenants and leaseholders through the tenancy and lease agreement obligations it has.
3.3
Approved Codes of Practice and Guidance – the principle approved codes of practice and guidance (as updated) applicable to this policy are:
3.4
Sanctions – Connexus acknowledges and accepts its responsibilities in accordance with the regulatory standards, legislation, and approved codes of practice, and that failure to discharge these responsibilities properly could lead to a range of sanctions including prosecution by the Health and Safety Executive under the Health and Safety at Work Act 1974, prosecution under the Corporate Manslaughter and Corporate Homicide Act 2007 and via a serious detriment judgement from the Regulator of Social Housing (RSH).
3.5
Tenants and Leaseholders – Connexus will use the legal remedies available within the terms of the tenancy and lease agreement should any tenant, leaseholder or shared owner refuse access to carry out essential asbestos related inspection and remediation works.
4.1
This asbestos policy also operates in the context of the following additional legislation:
5.1
The duty to manage asbestos is included in The Control of Asbestos Regulations (CAR) 2012. The duty requires Connexus to manage the risk from asbestos by:
5.2
Anyone who has information on the whereabouts of asbestos in homes and buildings is required to make this available to the organisation as the ‘duty holder’, but the organisation then must assess its reliability.
6.1
Connexus recognises that the main hazard in relation to asbestos is the non-identification of ACMs and as such will protect those persons potentially exposed to asbestos as far as is reasonably practical by minimising the exposure through the use of appropriate control measures and working methods.
6.2
Connexus accepts that asbestos is likely to be present in the majority of its properties built prior to the year 2000 and will therefore manage these properties accordingly.
6.3
In order to fully comply with the legislation Connexus will have a Board approved Asbestos Policy. In addition the organisation will have an Asbestos Management Plan and an Asbestos Register which will hold records of the assets which have asbestos containing materials in them.
6.4
Connexus will hold accurate records against each property it owns or manages, identifying whether the property has had its initial asbestos management survey and when the next re-inspection is due.
6.5
Survey and re-inspection dates, details of ACM’s and asbestos management survey reports will be held electronically in MRI Housing Asset Management.
6.6
Connexus will employ competent external contractors (in line with HSG264) to undertake asbestos management surveys. Licensed asbestos removal operatives and/or contractors will be employed to carry out licensed remediation works (where necessary) to non-domestic (communal blocks/’other’ properties) and domestic properties as outlined in section 8 of this policy.
6.7
Connexus will employ suitably competent persons to undertake asbestos re-inspections and the removal of non-licensed asbestos.
6.8
Connexus will undertake a targeted intrusive refurbishment and demolition (R&D) survey to domestic and non-domestic properties as and when required as per HSG264. This will also be in accordance with the criteria set out in the Connexus Asbestos Management Plan, which should be read in conjunction with this policy.
6.9
Connexus considers good communication essential in the safe delivery of asbestos management and will therefore ensure that information about asbestos containing materials (known or suspect) is provided to persons liable to disturb it, accidentally or during the course of the work. This includes employees, contractors and tenants.
6.10
Connexus will provide advice to customers regarding asbestos containing materials through leaflets and information held on the organisation’s website.
6.11
Connexus will ensure that all contractors’ employee and public liabilities are up to date on an annual basis.
6.12
Connexus will ensure contracts / service level agreements are in place with the contractors responsible for delivering the compliance service.
6.13
Connexus will ensure there are effective contract management arrangements in place, in the form of client-led meetings taking place regularly, with standard agendas and minutes produced, key performance indicators analysed and programmes and performance scrutinised.
6.14
Connexus will provide leaseholders and tenants with an asbestos survey report during the new tenancy sign up process if one exists. Tenants and Leaseholders may request a copy of the survey for communal areas of their block.
6.15
Connexus will provide tenants with information about asbestos via leaflets that will tell them of possible asbestos containing materials (ACMs) in their home, advise what to do if they wish to carry out DIY or employ a contractor to undertake work and advise who to contact if ACMs are accidentally disturbed.
6.16
Connexus will generally not use asbestos labelling in domestic premises, however, in non-domestic premises and common areas of domestic blocks, labelling may be used where practicable.
6.17
Connexus will implement a robust process to deal with all changes to stock, including new property acquisitions, disposals and stock transfers, in order to ensure that properties are not omitted from the compliance programme, and to ensure the programme remains up-to-date.
6.18
Connexus will ensure that there is a robust process in place for the management of immediately dangerous situations identified from any asbestos related works undertaken on properties.
7.1
Non-Domestic Stock – Connexus will review existing asbestos management survey information prior to carrying out any repairs or planned maintenance works which may involve working on, or adjacent to, any asbestos containing materials within non-domestic (a communal block) or ‘other’ properties (e.g. offices, commercial shops etc.). This is to ensure that any asbestos containing materials likely to pose a risk are identified prior to works commencing and the details passed onto the relevant operatives or external contractors and managed in an appropriate way. Where required a new hybrid R&D/management survey should be commissioned prior to work commencing.
7.2
Connexus will ensure that all non-domestic (communal blocks) and ‘other’ properties in ownership or management have an initial asbestos management survey carried out. All surveys will comply with the CAR 2012 legislation. Any management surveys which currently pre-date 2012 will be reviewed and updated if deemed necessary. These updated surveys where required will have a targeted completion date of 12 months following the approval of this policy.
7.3
Thereafter all non-domestic (communal blocks) and ‘other’ properties will have a re-inspection survey and an assigned re-inspection date where applicable. This date will be in accordance with the specific needs of the building. It will either be annually or at a period dictated by the previous survey/re-inspection. Re-inspection dates may change following the re-categorisation of a property or a building.
7.4
Connexus will not need to re-inspect any non-domestic (communal blocks) or ‘other’ properties built after the year 2000.
7.5
Domestic Stock – Connexus will review existing asbestos management survey information prior to carrying out any void repairs, day to day repairs, or planned maintenance works which may involve working on or adjacent to any asbestos containing materials within a domestic property. This is to ensure that any asbestos containing materials likely to pose a risk are identified prior to works commencing and the details passed onto the relevant operatives or external contractors and managed in an appropriate way.
7.6
Where there is no previous asbestos related information in respect of a domestic property which requires an asbestos survey ahead of responsive repairs a survey will be undertaken and the scope of the survey agreed with the Compliance Team, in accordance with the works due to be carried out.
7.7
Connexus will not need to re-inspect any domestic properties built after the year 2000.
7.8
Refurbishment Work (Planned and voids) – Connexus will undertake an intrusive refurbishment and demolition (R&D) survey to domestic, non-domestic (communal blocks) and ‘other’ properties prior to planned maintenance or void works taking place to the areas of the property that are likely to be disturbed as part of the proposed works. They will also undertake a management survey to the remainder of the property as part of the same R&D survey if there is no existing management survey in place. This will be in accordance with the criteria set out in the Asbestos Management Plan, which should be read in conjunction with this policy.
7.9
Garages – Connexus has 2,513 garages in ownership. Many of these garages may contain asbestos containing materials. As such, Connexus will carry out a programme of sample inspections (as per the relevant HSG) per garage site, to assess the location and condition of the asbestos containing materials within these garages and implement a remedial programme of works thereafter if necessary.
8.1
Connexus will ensure there is a robust process in place for the management of any follow-up works required following the completion of an asbestos management survey or re-inspection.
8.2
Where asbestos is positively identified and as a result of a risk assessment (conducted in accordance with published guidance) removal, sealing or encapsulation is recommended, this will be carried out for:
9.1
Connexus will establish and maintain a programme of non-domestic (communal blocks) and ‘other’ property surveys and re-inspections and an Asbestos Register of all the asbestos containing materials by type, address, location and condition.
9.2
Survey dates, details of ACMs and asbestos management survey reports will be held electronically on MRI Housing Asset Management.
9.3
MRI Housing Asset Management will be used to record the details of all asbestos surveys undertaken on Connexus’ non-domestic (communal), domestic and other properties. This system will include the date of the most recent survey.
9.4
The findings from the asbestos survey, including any ACMs and remediation works identified and subsequently completed (including evidence of removal and encapsulation) should also be recorded on either Orchard Assets (licensed works) or Orchard Repairs (in-house works).
9.5
Appropriate asbestos information will be made available to all interested stakeholders as required.
10.1
Connexus Board will have overall governance responsibility for ensuring the asbestos policy is fully implemented to ensure full compliance with the regulatory standards, legislation and approved codes of practice. SMT will formally approve this policy and review it every two years (or sooner if there is a change in regulation, legislation or codes of practice).
10.2
The SMT and Board will receive regular updates on the implementation of the Asbestos Policy and asbestos performance along with notification of any non-compliance issue which is identified. This is so they have assurance that the policy is operating effectively in practice.
10.3
The Director of Property has strategic responsibility for the management of asbestos and ensuring compliance is achieved and maintained. The Director of Property will also oversee the implementation of the Asbestos Policy.
10.4
The Asbestos Manager in conjunction with the Compliance Manager will be responsible for overseeing the delivery of the agreed survey inspection programmes and the prioritisation and implementation of any works arising from the surveys. They will ensure Connexus Repairs and/or external contractors deliver the programme of inspections and remedial works in accordance with this policy.
10.5
The housing teams will provide key support in gaining access into properties where access is proving difficult and use standards methods to do so. They will also facilitate the legal process to gain access as necessary.
10.6
The Director of Property will be responsible for ensuring the policy is reviewed every two years, and will notify the Board, SMT and operational team responsible for the delivery of the compliance programme, of the upcoming review. The Director of Property will ensure that this review process takes place before the policy expires in June 2024.
10.7
The Director of Property will ensure that this policy is saved on the organisations shared drive and distributed to all relevant members of staff.
11.1
Connexus will ensure that the Asbestos Manager with lead responsibility for operational delivery is suitably qualified holding a P405, P402, or P407 qualification.
11.2
Connexus will ensure that competent (as per HSG264) UKAS accredited contractors are procured and appointed to deliver asbestos management surveys.
11.3
Connexus will ensure that competent licensed asbestos removal contractors are appointed for all notifiable non-licensed work or licensed works.
11.4
The operational team with responsibility for delivery will check the relevant qualifications of employees working for these contractors on an annual basis and evidenced appropriately.
12.1
Connexus will ensure that all operatives working for, or on behalf of the organisation have the relevant training required for their role. This will be managed via periodic assessments of training needs and resulting programmes of internal and/or external training.
13.1
Robust key performance indicator (KPI) measures will be established and maintained to ensure Connexus is able to report on performance in relation to asbestos.
13.2
KPI measures will be produced and provided at SMT level on a monthly basis and at Board level on a quarterly basis. As a minimum these KPI measures will include reporting on:
The total number of:
14.1
Connexus will commission ongoing third-party auditing of both asbestos surveys and asbestos removals.
14.2
Connexus will commission an independent audit of asbestos at least once every two years. This audit will specifically test for compliance with the regulation, legislation and codes of practice and identify any non-compliance issues for correction.
15.1
Any non-compliance issue identified at an operational level will be formally reported to the Director of Property in the first instance.
15.2
The Director of Property will agree an appropriate course of corrective action with the operational team in order to address the non-compliance issue and report details of the same to the SMT.
15.3
The SMT will ensure the Board are made aware of any non-compliance issue so they can consider the implications and take action as appropriate.
15.4
In cases of a serious non-compliance issue the SMT and Board will consider whether it is necessary to disclose the issue to the Regulator of Social Housing in the spirit of co-regulation, or any other relevant organisation such as the HSE, as part of the Regulatory Framework.
16.1
This glossary defines the key terms used throughout this asbestos policy:
Share
Themes
Dashboard