Asbestos Containing Ceramic Guaze Mats
- Why are the metal mesh gauzes a problem?
The samples tested have a white heat pad material on them which in some cases has been found to contain asbestos. Asbestos use and supply is prohibited in the EU/UK but not everywhere in the world. HSENI understands these are imports. The suppliers are being investigated.
- How did they get onto the market in UK?
HSE and HSENI are investigating that. There is legislation prohibiting import, supply and use of asbestos in the EU (REACH).
- What should I do if I have them?
The gauzes will need to be taken out of use and disposed in accordance with relevant published guidance on hazardous waste. Where non asbestos-containing gauzes are stored directly alongside asbestos-containing gauzes, these should be treated as contaminated waste. Other equipment which has been stored with asbestos-containing gauzes can be wiped clean with a damp cloth if there is any visible dust present. The cloth should be disposed of as contaminated waste.
The work to dispose of asbestos-containing gauzes and waste items is considered to be a low risk activity but it still needs precautions and controls in line with legal requirements. The work should only be undertaken by individuals who can adhere to relevant guidance and have the right equipment. Assistance can be obtained from a specialist asbestos contractor (e.g. a contractor holding an asbestos work licence from HSENI) but this is not a legal requirement.
Where possible, any gauzes stored in a container should be disposed of in the container to prevent further handling of individual gauzes. Container and gauzes should be treated as asbestos-containing waste.
Where it is not possible to dispose of the stored gauze in its container, the gauzes should be carefully wetted using a hand-held spray bottle containing water with a small quantity of detergent (e.g. washing-up liquid) and handled carefully to prevent any further damage. They should be placed in a suitable heavy-duty polythene waste bag which is then placed in a second bag (i.e. double bagged) and labelled accordingly. [In accordance with the HSE’s Asbestos Essentials Guidance EM9 Disposal of Asbestos Waste - http://www.hse.gov.uk/pubns/guidance/em9.pdf]. Caution will need to be taken as the corners of the gauze may be sharp and could penetrate the polythene so it may be more suitable to place the gauzes into a container such as a rigid, sealable plastic container before placing into suitable waste bags.
Any excess water (from spray) and dust/debris from the gauzes should be wiped up using a damp rag and the rag should be disposed of in the same manner. [In accordance with the Asbestos Essentials guidance EM7 Using damp rags to clean surfaces of minor asbestos contamination - http://www.hse.gov.uk/pubns/guidance/em7.pdf].
As this is low risk and short duration work, respiratory protective equipment (RPE) (i.e. a mask or respirator) is not legally required. However, duty-holders may wish to adopt a precautionary approach regarding the use of RPE and personal protective clothing. Where gauzes are damaged and/or there is resultant debris, a disposable coverall and a suitable dust mask (e.g. FFP3 or half mask with a P3 filter) could be worn. If a mask is used, the person should be face-fit tested and trained in its use [Full details in Asbestos Essentials Guidance EM6 Personal protective equipment (including RPE) -http://www.hse.gov.uk/pubns/guidance/em6.pdf]. see also fit2fit.org for face fit tests.
- What is the associated risk from asbestos with use of the material?
Analysis of the gauze material has identified that it is fibrous in nature and that it contains asbestos. Asbestos is a known hazardous substance. Any risk from asbestos depends on the extent of asbestos fibre release and inhalation of these very fine fibres.
The risk from asbestos in the gauze material from normal tripod use will generally be extremely low for several reasons. The material is predominantly non-asbestos. There is very limited physical contact with the material during use (e.g. essentially placing items on top) and any contact is light and momentary. Consequently, any free fibre release into the air will be minimal for normal use.
However, the material is soft and crumbly and some small particles or fragments may detach on occasions including during use. Particles and debris may also break off over time through abrasion or impact in storage. These particles and fragments do not represent an airborne risk.
As a precautionary measure, and in-line with the general legal requirement to prevent exposure to asbestos, the gauzes should be disposed of (see below). Any debris in containers or boxes should be carefully cleaned up and also disposed of.
- Do I need a medical or X-ray?
No, the risk is low. An X-ray will not indicate anything.
- What type of asbestos did you find and how much is present?
HSE has carried out limited quantitative testing on the gauze materials. The results indicate that, where asbestos was detected, it is in the range of around 20-30%. Asbestos was not detected in all samples.
The asbestos found within the gauze material was identified as tremolite asbestos. This is one of the six regulated asbestos types and is similar in appearance and properties to amosite asbestos.
Tremolite is a relatively rare type of amphibole asbestos and may be found as a natural contamination in a range of industrial minerals.
- How can I tell if my gauzes are a problem?
You cannot visually identify asbestos on the gauze mat. You can either assume they contain asbestos, stop using them and dispose of them safely following the requirements of environmental legislation or you can use a laboratory accredited by the UK Accreditation Service (UKAS) to analyse samples to see if asbestos is present.
- Why should I use a UKAS accredited laboratory if I decide to have samples of my gauzes analysed?
If you decide to have samples analysed you would need (by law) to use a UKAS accredited laboratory and should look for local asbestos testing laboratories on the UK Accreditation Service website at https://www.ukas.com/services/other-services/directory-of-accredited-organisations.
- Do I need to use a licensed contractor to clean up?
No. The risk involved is not considered to be high risk asbestos work. Licence holders often do lower risk non-licensed work. HSENI’s advice is that the methods in Sheet EM7 etc of Asbestos Essentials are proportionate. See question 3 above.
- What are the duties of suppliers in the UK and what is the UK system to stop imports which contain asbestos?
If supplies are sourced from or manufactured outside the EU where asbestos is not banned, UK suppliers need to operate a system of assurance including commissioning testing.
HSE and HSENI relies on surveillance of cross border trade by other government departments. However, this is more likely to work if the cargo manifests are accurately declared and described. Far East makers should assure UK importers that the product is asbestos-free. This may not be accurate for a number of reasons, so it is for the UK based supplier to check on compliance given their legal duty not to import or supply articles which contain asbestos. Irrespective of assurances from global non-EU suppliers, UK suppliers should commission accredited laboratory testing on samples of articles from outside the EU which are liable to contain asbestos before placing orders and should arrange repeat testing periodically.
Otherwise users or asbestos surveyors are those likely to encounter the issue and report it for investigation to HSENI, Trading Standards or DAERA.
- Is this reportable to HSENI eg as a RIDDOR DO?
HSENI’s assessment is that this does not meet the risk criteria to be reportable under RIDDOR. HSENI is already aware and taking action regarding the issue in any case.
- Disposal of the Gauzes and Waste Items
The asbestos-containing gauzes are classified as hazardous waste (or Special Waste as it is referred to in Scotland). If such waste arises from work activities and even if you have presumed the gauzes contain asbestos rather than confirming it, they must be treated as hazardous even though they are low risk. As highlighted previously in this document, general guidance on the disposal of asbestos waste can be found in “Asbestos Essentials EM9 Disposal of Asbestos Waste” (http://www.hse.gov.uk/pubns/guidance/em9.pdf].
Once suitably bagged (or contained), all hazardous waste, including asbestos-containing materials, should be disposed of properly and in accordance with the requirements of DAERA. Advice on how to do this can be found on DAERA’s website (https://www.daera-ni.gov.uk/articles/hazardous-waste).
- I’m a school where can I get detailed advice?
Schools can refer to the CLEAPSS website for further advice. http://www.cleapss.org.uk/ Members will also have access to the CLEAPSS Helpline.
Enquiries not answered by this document or the organisations mentioned can be referred to HSENI via the contact form at https://www.hseni.gov.uk/contact
- Why is (or is) HSENI saying a Face fit test is needed for clean-up and how do I get this arranged?
A mask can only provide effective protection to the wearer if it properly fits the person. A proper fit can only be confirmed by carrying out a face-fit test on the mask. Guidance on face-fit testing is available at http://www.hse.gov.uk/pubns/guidance/em6.pdf and fit testers can be found on the website fit2fit.org. HSE advice is that the risk is low and a mask is not essential but if one is used then to be assured of effectiveness a face fit test of the mask is required.
- How did HSENI find out about this / how long might this import have been going on for?
This issue was originally identified by an English school who brought it to the attention of HSE GB who subsequently informed HSENI. The asbestos-containing gauze was originally identified during an asbestos survey in the school. Testing of the subsequent replacement mats by a UKAS accredited laboratory revealed that the new mats also contained asbestos. An investigation was initiated by HSE’s Chemical Regulation Division (CRD) who enforce REACH the UK legislation relating to suppliers.
Anyone importing articles from outside the EU should always take extra care and treat claims that articles are asbestos free with caution because of the potential for different interpretations about that concept in other parts of the world. The manufacture, import, supply and use of products that have had asbestos intentionally added is prohibited under EU legislation.
This is still being investigated and enforcement action may follow so we are limited in what we can say about particular cases at present.
- Reporting new information on supply to HSENI
If an employer finds that either their supplier informs them their gauzes/mats have asbestos content or if the employer arranges for lab analysis and more than a trace of asbestos is confirmed then you are encouraged to report the matter to HSENI e.g. by using the contact point at https://www.hseni.gov.uk/contact When completing this please include your own contact details and the header “Report of supply of asbestos articles re REACH.”
Try and ensure that you cover the following matters:-
- Items supplied
- Approximately when
- Name Address and telephone number of supplier
- Details of lab analysis if applicable or information given by the supplier
All such messages will be seen by the appropriate HSENI staff and decisions made about next steps concerning those who have supplied the articles to you.
- How many schools have been affected?
It is not yet clear at this stage how many schools, colleges and other users within Northern Ireland have accessed these particular materials – that is subject to our ongoing enquiries. Our priority is to ensure that those who have these particular gauze mats are given our precautionary advice.
- If this has happened, what else in the supply chain will contain asbestos?
That will form part of our investigation as to how these particular gauze mats came into circulation. Should any issues emerge, we will inform all affected parties as soon as possible.