Your Asbestos Register Is Only as Good as the Last Time Someone Updated It

Article from Darren Chinnery, Senior Consultant and Quality Manager

I will tell you where the real danger sits with asbestos, and it is not where most people look. It is the register. Not whether you have got one, but whether anyone has actually kept it up to date since the day it was written.

Here is the thing about our industry that makes this so important. Asbestos does not drop you where you stand. It is not an electric shock or a burn that you feel straight away. It sits there quietly and comes back to find you fifteen, twenty-five, or forty years later. That latency is the whole reason we have the legislation we have, and it is the whole reason Regulation 4 of the Control of Asbestos Regulations 2012, the duty to manage, places so much weight on getting the register right.

Let me give you a real example of how it goes wrong. Say an asbestos register was created three years ago, and a couple of store rooms were always locked and never accessed, so they were marked as no access. Then, in the year four re-inspection, someone finally gets in there, and there is asbestos insulation board sitting in one of them. That gets recorded in our report. But nobody at the site takes that finding and adds it to the master register. Twelve months on, they decide to knock those two rooms into one bigger space, because people are forever reconfiguring buildings, schools and hospitals, especially. The contractor pulls up the register, sees nothing listed, and smashes straight through it. Now you have exposed every person working that day. If it is a school, you have potentially exposed children, right at the start of their lives, to something that might catch up with them decades down the line.

From the duty holder’s side, that is legal action waiting to happen, and it is horrible litigation, because you are trying to prove a point of exposure, a level of exposure, and how long it went on for, all after the event, when there is nothing left in the air to measure. But forget the legal side for a second. The bigger issue is the people who were just doing their jobs in that building.

So when a duty holder tells me their register is probably fine, that phrase on its own is the problem. It should not be ‘probably’. It should be ‘we are bang on, our re-inspection is next month’. If you want to know whether yours actually stacks up, ask yourself three questions. One, do you know where the register is, and can you actually get to it? Two, when was the last survey done, and do you understand your legal duty to re-inspect and manage those materials, not just find them and leave them? Three, who updates the register on the agreed re-inspection date, and do you even know what that date should be? High-risk items might need looking at every six months; others once a year.

The one that catches people out most is the last one. Companies spend good money to have materials managed or removed, and then nobody updates the register. It is useless at that point. You have got rid of the problem, but you are the only bugger in the building who knows it is gone. Everyone else is still working off the old picture. Keep it live, keep it correct, and it does its job. Leave it in a drawer, and it does nothing at all.