A friend has asked me about the removal of textured coatings from concrete walls and ceilings within flats due for demolition in Scotland. The plan is to scrape the textured coating AFARP and for the remaining residues to remain on the concrete. Following demolition, the concrete is due to be crushed and re-used on the site. The special waste regulations allow for 0.1% asbestos in waste materials (obviously not a whole asbestos product). From a belt and braces compliance perspective, is there any other justification for this course of action, or any justification as to why this course of action may not be legally appropriate.
Interesting question that requires more answers before commenting further.
Is the type of textured coating known, and is its Asbestos content known?
How smooth is the concrete or is it heavily pitted (which would leave recognisable Asbestos debris after scraping)?
For this situation let us say that it is similar to Artex at approximately 3% by volume and the concrete is smooth. In such a situation <0.001% (or trace) should be achievable. I understand that trace quantities of Asbestos cannot legally be classified as Asbestos, therefore, the Waste would be classified as Non-Hazardous as it wouldn’t contain any Asbestos.
…<0.001% w/w does not equal ‘trace’. Trace is <3 fibres/fibre bundles in a sample when analysed per HSG248.
<0.001% may be trace. The problem is, most labs that do asbestos quantification do not report trace when it is trace, theY default to the 0.001% LOQ.
Plus, the trace question only applies to CAR2012 and the determination of whether the asbestos present makes the material a regulated asbestos material or not, for health and safety purposes.
You are correct that the material, if it has trace, or <0.001% w/w, would be non-hazardous, per waste classification requirements. But, the OP is talking about the production of recycled aggregate, which should be ‘not waste’, i.e. fully recovered C&D waste, a ‘product’. And products must not contain asbestos ‘intentionally added’.
Arguably, proactively/deliberately not removing ACMs prior to demolition and then using the arisings to produce aggregate constitutes intentionally adding. Otherwise known as illegally mixing waste, or diluting your asbestos in tonnes of concrete to hide it.
My comments re the importance of having a fully documented audit trail of asbestos removal, testing etc. apply to be able to demonstrate compliance with the WML and the Aggregates Protocol/Highways Specification.