Asbestos management policy

1.1 This policy document sets out Stonewater’s approach regarding managing asbestos containing materials that may be present in its commercial buildings, communal areas of residential buildings, and infrastructure for which it has a management responsibility.

1.2 This policy will be implemented through the application of a management plan and supporting processes which provide the operational guidance for colleagues and suppliers to enable them to meet Stonewater’s policy requirements.

1.3 The objective of this document is to prevent colleagues, contractors and residents from being exposed to health risks associated with asbestos containing materials that may be present in any of our properties.

2.1 The overall objective of this policy is to ensure that Stonewater meets its obligations under the Control of Asbestos Regulations in particular the ‘duty to manage asbestos’ requirements defined within Regulation 4.

2.2 This policy applies to all buildings and associated structures, where the Control of Asbestos Regulations (CAR) applies, either owned, leased or managed by the Group.

3.1 Asbestos containing materials (ACM’s) were used extensively in the UK, in the construction industry during the latter half of the 20th Century. The health risks associated with asbestos were gradually recognised, and legislation was introduced to control the risk of exposure to asbestos, although an outright ban was not passed until 1999.

3.2 Stonewater’s property portfolio is widespread in location, age, and type and given the extensive volume and usage of ACMs in construction in the UK, it is presumed that all properties built before 2000 are likely to contain some form of ACM unless positively proven otherwise.

3.3 Stonewater accepts its duty of care under CAR and seeks to ensure that all its buildings are effectively maintained to eliminate where possible, or otherwise reduce as far as reasonably practicable, the release of asbestos fibres

3.4 Either directly or via specialists to undertake general and specific precautions to ensure, the safety of Stonewater’s residents, employees, contractors, visitors, and all other relevant persons to ensure its premises are safe.

3.5 Ensuring there is a clear chain of command with ‘responsible’ person(s) identified for the management of asbestos throughout the Groups structure.

3.6 Ensure adherence to current asbestos legislation and performing its legal duties.

3.7 Maintaining an asbestos management regime, together with reviews and tracking changes in legislation.

3.8 Maintaining a regime to confirm what is already known about ACM’s, how they are being managed, implementation of surveys of properties in the absence of any information to identify the presence of any ACM’s, assessment of their material condition and management priority as the basis for operating and updating of an Asbestos Register and/or relevant asbestos information for its property portfolio. The Register will undergo regular reviews and will be updated periodically after any treatment and/or removal works have been undertaken

3.9 Ensuring that an Asbestos Register and/or asbestos information is maintained and regularly updated, and which is accessible to all internal and external partners, stakeholders, and other organisations with whom Stonewater operates.

3.10 Ensuring the prevention of work which will disturb the fabric of a building until the presence or absence of ACM’s has been established.

3.11 Ensuring that any ACM’s that may be present in any of its buildings are maintained in a safe condition to prevent the possibility of any harm to health.

3.12 Ensuring there is effective interactions with supply chains to ensure their procedures are in line with Stonewater’s or go further to protect employees and residents against asbestos exposure.

3.13 Promoting awareness of the risks associated with ACM’s and Stonewater’s Asbestos Management Plan through induction training and provision of information to all colleagues.

3.14 Maintaining a long-term management plan utilising material and priority assessment algorithms to produce reports to direct and implement a clear and effective asbestos management regime.

3.15 Providing information to residents about asbestos in a clear and un-emotive language with advice, reassurance, and guidance.

3.16 Ensuring that all Stonewater suppliers provide adequate resources for the issue of appropriate information, instruction, training, and supervision, for their operatives and subcontractors.

3.17 Ensuring that information regarding the presence of asbestos is contained in tender documentation as may be appropriate and that all contractors and sub-contractors have in place risk assessments and method statements for its removal and/or management as appropriate.

3.18 Ensuring contractors and sub-contractors shall not commence works without submission of their method statement and risk assessments prior to approval by responsible or nominated person(s) managing the works.

3.19 Ensuring licensed contractors and/or sub-contractors conduct all asbestos works, in accordance with relevant legislation and HSE guidance. Asbestos removal work which is classified as “minor” by the HSE must also be conducted by licensed contractors and / or sub-contractors.

3.20 Regularly reviewing the asbestos management plan and all associated procedures.

4.1 The Board is responsible for ensuring this policy is adhered to and compliance monitored.

4.2 The Chief Investment Officer is responsible for providing assurance to the Board that this policy is adhered to and that sufficient resources are provided for its ongoing delivery.

4.3 The Head of Building Safety is responsible for overseeing the implementation of this policy and day to day delivery of the asbestos management plan, including effective monitoring of the asbestos survey and analytical suppliers and removal contractors;

4.4 The Health & Safety team are responsible for ensuring a tier 1 audit is in place to provide assurance that group procedures are being complied with;

4.5 The Head of Procurement will support the requirements of this policy and supporting process requirements within Stonewater’s Procurement policy and processes.

4.6 Directors will be responsible for the routine monitoring and performance of their operational area to ensure compliance with this policy and supporting procedures.

4.7 All colleagues who are undertaking work activities or procuring construction work are responsible for complying with this policy and procedures.

4.8 Members of the Building Safety Group are responsible for monitoring and addressing any non-compliance, identified via inspection and audit and reporting to the Operational H&S Group action taken to address non-conformances.

5.1 Stonewater acknowledge that to meet our obligations we must maintain a robust approach to identifying the assets and components for which it has responsibility.

5.2 To ensure we effectively manage our data we will:

• Maintain an up-to-date Master Database (TEAMs Enterprise) of all properties that have asbestos containing materials present

• Where a requirement exists, hold data and certification relating to at a minimum the last two Safety Checks and the next due date.

• Where a requirement does not exist hold appropriate evidence.

• Maintain current and up to date records of remedial works for the entire portfolio, which will detail all recommendations from the Safety Checks.

These records will include;

1. Address and Risk Profile of the property,

2. Detail of the Work Item required,

3. Priority and Target Completion Date/s,

4. Person Responsible,

5. Date of when the Work was Completed

6. Who it was Signed-Off by and

7. Evidence of Completion.

5.3 Further details will be contained within the Asbestos Management Plan.

6.1 This policy (and associated procedures) is designed to deliver the following outcomes:

1. All communal areas of residential blocks of flats and commercial buildings constructed prior to 2000, have a management survey in place;

2. A central corporate asbestos register is in place and maintained;

3. All locations where an asbestos containing material has been confirmed (or is presumed to be present) are subject to a re-inspection programme;

4. All materials are adequately managed to ensure risks are controlled until such time as materials can be safely removed or permanently remediated;

5. Refurbishment surveys are commissioned for all works where the structure of the building is to be disturbed, prior to work commencing;

6. All colleagues are provided with suitable and sufficient information, instruction and training;

7. Competent suppliers are in place to undertake survey and analytical services and asbestos remediation works.

8. Contractors undertaking refurbishment and repair activities have access to the asbestos register to enable them to undertake their work safely.

7.1 Stonewater shall ensure that adequate information; instruction and training is made available to all colleagues, relevant and proportionate to their role and span of control.

8.1 Residents will be provided with information relating to the Asbestos Safety through a variety of means. This will take the form of regular articles in our newsletters, information leaflets, tenancy handbook, the Groups website and a range of ad-hoc publications and advice leaflets when required.

9.1 Key strategic performance indicators for all areas of compliance are agreed by the Board and monitored by the Groups Strategic Health & Safety Group.

9.2 Operational KPIs are monitored monthly via the Building Safety Group.

9.2 To provide assurance regarding the quality of the groups survey data and contractors performance an independent audit company is employed to complete sample audits of all survey and asbestos works on a rolling monthly basis.

9.3 Audit outcomes are monitored by the Head of Building Safety and actioned via contract meetings. A non-conformance report is also presented to the Building Safety Group as part of the compliance performance report.

9.4 The Groups H&S team will also complete a thematic audit of asbestos management on an annual basis.

10.1 The following associated documents provide the detailed procedures to deliver the asbestos management policy objectives and outcomes;

• GS – PR - 050 Asbestos Management plan

• GS – PR – 050 A Emergency work procedure

• GS – PR – 050 B Asbestos removal procedure

• GS – PR – 050 C Asbestos Survey procedure

11.1 This Policy shall be reviewed and updated by Stonewater biennially or if there are any major changes to current Regulations, HSE approved codes of practice and guidance.

11.2 Approved documents are valid for use after their approval date and remain in force beyond any expiry of their review date until a new version is available.