“Bitumen adhesive generates the same materials assessment risk score as textured coating…”
Granted, that may be the case (in the absence of amphibole/anthophyllite) using HSG264, for surveys of ACMs in BUILDINGS to assist Dutyholders in the DTM.
Once we step into the ‘environmental’ domain, however, we must dispense with the HSG264 algorithm/hazard ranking framework, as it bears no relevance whatsoever to the relevant environmental regulatory regimes, in terms of assessing potential hazard and RISK from the reuse of asbestos-contaminated materials in developments.
Arguably, though, the risk of significant amounts of fugitive asbestos emissions being generated from crushing concrete with residual bitumastic adhesive is lower than might be the case for TDCs.
Waste regulation (and the production of aggregate to the Aggregates Protocol is a waste recovery process) is based entirely on hazard properties. Planning and environmental protection (reuse of contaminated materials in developments, etc.), is based on human health risk potential.
A common mistake that asbestos professionals make (and I speak of my own experience in e.g. in contractual/legal disputes) is inappropriately shoehorning building survey data using the HSG264 framework into ‘land’ scenarios (and reuse of contaminated aggregate is a land scenario). It leads to all kinds of inaccurate and misleading statements and decisions being made which can result in excessive costs.
This very issue has been raised at the recent NORAC regional meetings and has resulted in an undertaking that some technical guidance on this subject will be produced to assist asbestos management practitioners navigate the various land-based regulatory obstacles to avoid making such costly mistakes.
My advice would be, understand the various regulatory regimes (understanding fully the relevant legal, codes of practice and guidance framework) in the round, know what type of data you need (its purpose(s)) and how to collect it properly, get your defensible data together, figure out what questions you need to ask of yourself and answer them. If at that point there remains any degree of uncertainty in the legality of a particular approach/scenario, seek clarification from the regulator that they agree with your position(s).
Most importantly, a well-considered, robust and competent assessment is the best tool to get the LA CLO on your side, which in turn should satisfy the Planning Authority.
