Written evidence from the Health and Safety Executive (HSE) (ASB00260
1. What are the current risks posed by asbestos in the workplace? Which groups of workers are most at risk?
Workers most at risk of asbestos exposure are those working directly with asbestos-containing materials (ACMs). When asbestos fibres are inhaled, they can cause serious diseases, including mesothelioma, an aggressive cancer principally of the external pleural lining, and the lining of the lower digestive tract, other lung cancers, and asbestosis. There is a latency period typically of at least 20 years between exposure to asbestos fibres and asbestos related disease appearing, in many cases more than 35 years. The health risks are also dose related – work that disturbs or damages ACMs, such as drilling into asbestos insulation board can generate short term high concentrations of asbestos fibres in the air. This can potentially be orders of magnitude above environmental levels. These fibres are then in the breathing zone of the workers involved in that work, leading to an increased likelihood of inhalation and subsequent disease. Those most at risk from asbestos fibres today are trades people who may unknowingly and repeatedly disturb ACMs and inhale fibres in this way.
The extent of the current risks posed by asbestos in the workplace (i.e. the future likelihood of asbestos-related disease because of current working conditions) must be assessed in the context of the available evidence about the risks arising from past industrial conditions. Specifically, the impact that the ban on asbestos in the 1980s and the progressive strengthening of controls on working with or managing existing ACMs, have had on these conditions over time.
The mesothelioma case-control study , confirmed that ‘end-users’ of asbestos products in the construction industry (e.g. building trades, such as carpenters, electricians, and plumbers) prior to 1980 now have particularly high risks of mesothelioma . The building material, Asbestos Insulating Board (AIB), containing amosite (brown) asbestos were widely installed during this period. Exposure to amosite and crocidolite (blue) asbestos have a recognised higher risk of causing asbestos related diseases than other ACMs. The UK is known to have imported significantly more amosite than other countries until importation of amosite into the UK was banned in 1980. See Annex 1 & 2.
Occupational and domestic exposures in the 1970s and 1980s through building and trades work, does not fully explain the extent of current cases of mesotheliomas, particularly among women. However, it is likely that many of these cases are as a result of an increase in ambient exposures to the general population that coincided with these widespread occupational exposures. Those past occupational exposures have since reduced.
This is consistent with the reporting patterns on death certificates from the national mesothelioma mortality data . The last occupation of the deceased, recorded for men, who had died of mesothelioma was at a much higher frequency for jobs associated with past exposure in building work. There was no clear pattern for the last occupation of women recorded, who had died of mesothelioma, and these deaths are less likely to reflect the direct handling of asbestos products at work but are more likely the result of past ambient exposures.
The risk of exposure to asbestos in the workplace has changed over time leading to different exposure profiles for different age groups. The peak use of asbestos in the UK was in the 1960s reducing until the final complete asbestos ban in 1999. The trend in national mesothelioma rates for specific age groups and periods of birth correlate with the pattern of asbestos use. While the overall mesothelioma death rate has been broadly constant during the last 10 years at a peak of around 68 per million per year in men, rates in those aged below 70 has been falling since before 2010. Death rates (up to any given age) were highest for those born in the early 1940s (this cohort would have started work during the period of peak use in the 1960s) but have reduced substantially in those born more recently. For example, the male death rate at age 55-59 years was 90 per million per year in those born in 1940-44 compared with 18 per million per year in those born in 1960-64. Few mesothelioma related deaths occur below age 40, so we will not be able to determine the rates for those born after 1980 until further time has elapsed. At this point we would anticipate a complete reflection of the impact of the current control regime on exposure.
The key research document covering more recent exposure to asbestos is the Inhaled Particles Study (aka Lung Burden study ) published in 2018. This study examined the lung content of individuals without asbestos-related disease. Its findings corroborated the downward trend seen in the national mesothelioma deaths data. The study found a significant reduction in asbestos exposure risks for men and women who have been working after the period of peak asbestos (See Annex 3 for details). These substantial reductions in lung burdens were observed in both the known high-risk occupations and among those who were less likely to have been exposed through the direct handling of asbestos at work. For example, for men born in the period 1940-54, the asbestos lung content (‘the lung burden’) was very high for men who had worked as carpenters (154 fibres/mg) and as plumbers, electricians or painters (88 fibres/mg) during the period of peak asbestos use (those born 1940-54). In contrast men born later (1975-84) had substantially lower asbestos lung content (1.7 fibres/mg for carpenters and 9.1 fibres/mg for plumbers, electricians and painters). However asbestos exposures in jobs that can disturb asbestos materials (e.g. maintenance trades that disrupt the fabric of buildings and refurbishment work), were still about 10 times higher than the average risk across all other low risk jobs.
These results constitute the best available estimates of recent asbestos exposures (those accrued by about 2005, the average date when lung samples were taken) that are representative of the GB population. We do not have more recent evidence of exposure levels because of the challenges of obtaining lung material from the youngest individuals. The duty to manage asbestos was introduced in 2002 which we anticipate will have controlled exposure risks further as it directly tackles the issue of ACM disturbance by those most likely to come across them (Q2 refers).
HSE has also recently examined the exposure risks of licensed asbestos contractors - the group of workers responsible for asbestos removal. This research conducted between 2016 – 2019 (due to be published shortly) found that, even with good control techniques, airborne asbestos fibre is still generated during removal. The worker exposure can be reduced below the control limit in CAR, with suitable respiratory protective equipment (RPE), but the study suggests further research is needed to understand asbestos worker exposure.
Q2. How effective is the current legislative and regulatory framework for the management of asbestos?
The risks of asbestos exposure through work-related activities in non-domestic premises in Great Britain is regulated effectively through a comprehensive legislative framework. This legislation is owned by the Health and Safety Executive and enforced by HSE and local authority environmental health according to which regulator has the vires for the premises. Disposal of asbestos waste and other non-domestic circumstances, such as social housing, are handled by the Environment Agency and the Ministry of Housing, Communities and Local Government (MHCLG) respectively.
The overarching legislative workplace health and safety framework is provided by the Health and Safety at Work etc Act (HSWA) 1974.
All work-related activity with asbestos is covered, more specifically, by provisions within the Control of Asbestos Regulations 2012 (CAR first introduced into law in 2002). This is the principal piece of legislation that ensures that all asbestos within a non-domestic premise is identified and safely managed by dutyholders.
Specifically, Regulation 4 of CAR is central to GB’s regulatory approach. This regulation sets out the ‘duty to manage’. This duty requires everyone who is in control of non-domestic premises to identify, assess and manage any asbestos on site. This duty helps tackle both the cause of most of the asbestos exposure in the workplace – disturbance of ACM during repair, maintenance and refurbishment - and the need to progressively deal with legacy asbestos in non-domestic premises. The purpose of the duty is to actively manage asbestos ahead of work activities in non- domestic premises that might give rise to exposure. HSE’s publication L143 ‘Managing and working with asbestos’ supported by guidance on HSE’s website provides all dutyholders with information on how to comply with this duty.
The duty to manage requires that a dutyholder assesses whether asbestos is present, what condition it’s in and whether it gives rise to a risk of exposure. The dutyholder must then draw up a plan to manage the risk associated with asbestos which must include removal of the asbestos if it cannot be safely managed in situ. Each dutyholder must take effective steps to inform any building maintenance workers where asbestos is and ensure they do not accidentally disturb it. The steps taken to safely manage asbestos across GB non-domestic premises are in proportion to the risk associated with the condition of the ACM. Removal of ACM is to be actively considered if the risks associated with removal are outweighed by the risks associated with the ACM remaining in place, or if the lifecycle of the building gives rise to an opportunity to deal with the asbestos risk - e.g. during refurbishment/demolition. In this way, ACMs are removed in a phased way across non-domestic premises.
CAR also contains a rigorous approach to exposure control limits for those involved in asbestos work-related activity, which is intended to drive dutyholders to continuously improve standards and controls. While the regulations set a maximum exposure limit of 0.1 fibres/ml, this is not regarded as being a ‘safe’ level which if reached is satisfactory; dutyholders must continue to ensure that exposure is below the limit and then as low as reasonably practicable (ALARP). The employer must do sufficient air testing during work to satisfy themselves that exposures are being minimised.
HSE licenses high-risk categories of asbestos work to ensure that more stringent safety requirements are placed on dutyholders most likely to expose their workers to risk.
The framework for controlling asbestos has evolved over time; the more recent regulatory changes were made in 1987, 1999, 2002, 2006 and 2012. Over successive iterations of CAR new duties have been added. These duties have been added after public consultation and consideration of any research or evidence to ensure that the framework remains grounded in the best available science.
Details on HSE’s enforcing responsibilities for asbestos related work and the roles of other regulators, such as Local Authorities, are found on the HSE website.
Dutyholder views of the effectiveness of the asbestos regulatory framework gathered through the 2017 post implementation review (PIR) of CAR were positive. The PIR was the most recent large-scale assessment of whether the regulations had achieved their purpose. The responses recognised the effectiveness of the Regulations in keeping workers and others safe from the risks of exposure to asbestos. Dutyholders stated that the regulations minimised the risks to workers, set clear standards and requirements for the controls that needed to be in place, raised awareness of the risks and provided an assurance to those working with asbestos that they are controlling the risks effectively. There were some requests for more to be done to explain some elements of Regulation 4 (Duty to Manage) to the wider small business audience and clearer guidance on plans for licensed work.
HSE is carrying out a second PIR of CAR at present. We have already collected the views from over 1,800 respondents, including from worker representative groups. These views are currently being analysed and the final report will be published in 2022.
HSE and local authorities undertake a range of regulatory activities to promote compliance with the regulatory framework. All regulatory activity is underpinned by the principles found in HSE’s Enforcement Policy Statement (EPS). The EPS aligns with the better regulation framework of being transparent, accountable, proportionate, consistent and targeted. HSE explains how we plan and carry out our regulatory functions on our website, including what regulatory resource we will allocate to achieve our objectives.
Our annual regulatory objectives are derived from HSE’s commitment to tackle causes of serious ill health as part of securing effective management of risk. HSE’s objectives for asbestos regulatory activity cover inspection, investigation, enforcement and licence assessment. The licensing process set out in CAR 2012 allows HSE to regularly confirm that licensed dutyholders are fit to continue operation. HSE have made the strategic decision to target our operational resources at highest risk work activities through license reviews and inspections of licensed contractors
In our 2021/22 workplan we state that we will ‘... evaluate all licence applications and carry out a proportionate inspection programme of notified licensed asbestos removal work to ensure compliance.’ Our 2021/22 licensing objectives are a continuation of HSE’s ongoing activity in this area in recent years i.e. the numbers of inspections of licensed asbestos companies and the time taken to assess asbestos licenses. The 2019/20 report on HSE’s activities indicated that a programme of 900 inspections of licensed contractors had been completed and that HSE had hit its target of assessing 90% of licence applications within the time limit. More information on HSE’s licensing work can be found in the response to Question 7.
Annually, HSE Inspectors will also deal with asbestos where it arises as a matter of evident concern – often related to the duty to manage - during any site intervention. Our operational procedures require inspectors to take regulatory action if they observe conditions on site that they believe give rise to risk to health or if they feel that a dutyholder’s safety management is inadequate. HSE’s Enforcement Management Model (EMM) gives a framework to inspectors taking enforcement action. Under the EMM, asbestos is defined as a ‘Serious’ health risk (the highest level possible) which means that HSE inspectors are more likely to take enforcement action if shortcomings are identified. Full details of HSE’s enforcement approach on asbestos are published on the HSE website. HSE tracks the numbers of enforcement notices served and prosecutions taken in relation to asbestos. These are not used to monitor the effectiveness of the regulatory framework as enforcement action is reactive in nature, however we are in the process of analysing enforcement notices to help identify trends and possible future intervention strategies. Details of recent enforcement activity is found in Annex 4
HSE has over the years targeted interventions on asbestos at particular industry sectors and we intend to do so in the future. For example, during 2021/22, HSE will be raising duty to manage during farm inspection work where there is evidence that asbestos may not be being managed appropriately. HSE also wants to do more to tackle the known issue of poor communication of survey information to contractors. We are exploring with the industry how Building Information Standards (BIM – see details in Q10) could be one of the pathways to improved asbestos risk communication.
There is scope for HSE to develop our approach to asbestos regulation in the future as we consider the impact of the new Building Safety Regulatory regime. This will require HSE to adjust our operational priorities to include assessing dutyholders’ ability to hold and monitor asbestos risk information. The net zero agenda has also been identified as an area which could potentially give rise to increased exposure risk through the extensive refurbishment of buildings. HSE engages with other government departments such as the Department for Education to provide support as they enable effective management of asbestos in public buildings. HSE’s regulatory approach will continue to evolve so that it supports the UK economy move to net zero over the next decade and the introduction of the new building safety duties.
Q3. How does HSE’s approach to managing asbestos compare to the approach taken in other countries? Are there lessons that the UK could learn from best practice elsewhere?
The UK has its own asbestos exposure risk profile arising from historic patterns of importing, manufacture and usage – for example UK imports of amosite (brown) asbestos during the 1960s and 70 exceeded all other EU countries primarily to manufacture fire resistant asbestos insulating board (AIB) - see Annexes 1 & 2. Our national asbestos risk profile directed how our regulatory regime evolved and should be considered when making comparisons to other countries.
There are a number of common challenges that regulatory regimes in all countries need to address in order to have an effective framework to manage asbestos risk. Broadly, these cover understanding where asbestos is present in buildings, what condition it is in and how vulnerable to damage it is, coupled with ensuring dutyholders’ understanding and awareness of exposure prevention and asbestos removal.
The approach taken by different countries in addressing these challenges varies. EU member states implemented the same framework asbestos directive, which focused on the risk to building maintenance workers rather than routine occupancy. Consequently, how the legal framework then developed within EU member states (which at the time included the UK) depended on country specific factors, such as the pre-existing domestic framework for occupational health and safety regulation within the country.
The requirements set out in the regulatory framework in GB are similar to a number of other countries in relation to inspection, record keeping, testing and disposal. For example, Belgium, the US and Germany all require proactive management, inspection and air monitoring to provide assurance during and after asbestos removal.
France also has similar requirements for inspection, record keeping and disposal. However, since 2011, France has an additional requirement to carry out air sampling at least every 3 years, in all buildings, except domestic premises, containing higher risk materials such as sprayed asbestos and insulation. France also has a national environmental limit for asbestos (in buildings in the absence of work) set out in the public health code from the Ministry of Health. The results of the 3 yearly air sampling are compared against this limit. Our understanding is that this approach is used to act as an early warning that higher risk ACMs may be deteriorating and to provide reassurance that no one using a building has been exposed to asbestos.
HSE recognises that air sampling can play an important role in safe management of asbestos – for example static sampling is a fundamental component of clearance procedures after licensed removal work to ensure that any remaining non-visible residual surface dust will not give rise to elevated fibre concentrations during future activities such as cleaning and maintenance work when the area is re-occupied (see para 416 of L143 ‘Managing and working with asbestos’).
HSE is concerned that there may be several drawbacks to the French approach to air sampling. The monitoring equipment used by France does not provide a real-time continuous record of peaks and troughs. The results obtained only relate to the concentration of fibres found during a specific time window – it does not give ongoing assurance that asbestos risks are being managed. Monitoring for fibres in an air sample is also a lagging indicator – something has failed leading to exposure before action is taken. With an issue such as asbestos management, HSE’s preference is for proactive management of the situation.
It is also known that airborne asbestos fibres resulting from physical damage decrease and settle by 50% after 10 minutes and by 90% after 60 minutes. Consequently, there is little value in undertaking ambient air monitoring in buildings, unless it is combined with appropriate simulated dust disturbance activities. Where damage to ACMs is suspected simulated disturbance is not recommended as it could potentially lead to inadvertent spread of asbestos. Finally, HSE notes that a triennial asbestos sampling exercise could give rise to complacency about onsite risk due to an over-reliance on receiving a clear report.
Currently HSE’s view is that we have no evidence that the approach taken in France offers additional benefits to the approach in GB where we require regular visual inspection of the condition of asbestos in buildings by a competent person based upon a management plan. The key determinate of whether fibres are released is the physical condition of ACMs which can be assessed through visual examination as part of a management plan. Sampling of the air beneath an otherwise intact, sealed ACM is of very limited value and does not inform risk-based decision making.
In addition to the requirement for triennial air monitoring, France now uses Transmission Electron Microscopy (TEM) routinely for asbestos work. In GB, HSE requires the World Health Organisation (WHO) Phase Contrast Microscopy (PCM) method for asbestos fibre measurement. This is also the method specified in the EU Directive. There is a difference in what the two methods (TEM and PCM) can measure, this is due to (a) the higher magnification achieved by TEM (x5000 to x20000 compared to x500 for PCM) and (b) the fact that TEM incorporates further analysis to determine the composition and therefore type of fibre. PCM measures fibres greater than 0.2 microns in diameter and counts all fibres – including any asbestos fibres – present within the sample. TEM methods can measure fibres as thin as 0.03 microns in diameter providing a method to measure asbestos fibre numbers. However, the data provided by PCM analysis allows dutyholders to make positive decisions about risk prevention (eg as part of clearance testing after asbestos removal) and enables them to take any appropriate action. A more detailed discussion about the merits of analytical techniques can be found in the response to Question 6.
France has also adopted an environmental limit several orders of magnitude lower than the EU directive occupational exposure limit. Assessing compliance with the limit requires careful interpretation and may again lead to complacency if relied on at the expense of visual inspection.
HSE’s view is that while there is an occupational exposure limit for those working with asbestos, this does not represent a safe threshold. GB law requires exposure to be reduced to a level as low as reasonably practicable (ALARP). This coupled with the duty to manage remains the most effective approach for proactively addressing asbestos related risk.
Countries, such as Poland, have programmes to remove asbestos from buildings. These programmes largely cover removal of asbestos cement roofs which are easy to remove and replace as they are external to the building and low risk. The risk profile of this type of asbestos is significantly different to what is found in many GB buildings. Where the amount and type of asbestos presents a lower risk, such as in Poland, removal on a national scale is feasible. However, HSE does not mandate removal of all ACMs in GB as the act of removal is a dangerous task and would expose those workers to this significantly increased risk. If GB were to embark on a similar large-scale removal programme, careful consideration needs to be given to the balance between the risks of exposure that arise from removal against the risk associated with leaving in situ. More information is needed about the quantity, distribution and type of asbestos present in GB buildings, the availability of skilled asbestos removers, and the impact on the asbestos waste handling chain.
HSE remains of the view that if asbestos can be safely and actively managed in situ, it is preferable to leave it in place. Where it cannot be safely managed then it must be removed. In GB, many businesses choose to, and are required to do, as part of planned refurbishment work. In this way, it is removed in a phased way across non-domestic premises in GB. This is why there is a very active asbestos removal industry in GB, driven in part by the duty to manage legislation which is risk based.
HSE is aware that technology in this area continues to develop and we remain committed to maintaining links with other countries so that we can keep abreast of latest developments and, where appropriate, research how they could be of benefit to GB circumstances
4. How does HSE measure and report its progress in mitigating the risks of asbestos?
Under HSWA and CAR, the responsibility to mitigate risks from asbestos lies with the dutyholders who own or manage asbestos or who work with asbestos. HSE’s role is to act as an independent regulator of dutyholders managing those risks. We also work with other regulators who have related responsibilities such as those regulators who deal with nuclear, transport and local authority enforced sites and the control of waste with the Environment Agency and equivalent devolved administration functions.
As the regulator, HSE measures and reports on the progress of enforcement and regulatory activities (see Q7). HSE also monitors data and international research, and commissions its own research, to review and track the impact of asbestos on workplaces and to identify any new approaches which might benefit dutyholders in managing the risks. Examples of these include:
5. Does HSE keep adequate records of asbestos in public buildings?
The legal duty set out in CAR 2012, to identify asbestos and record the location of asbestos in buildings lies with those in ultimate control of maintenance of each building. This duty does not rest with HSE.
The best determinant as to whether any building is liable to contain asbestos is the date of construction. All HSE’s guidance stresses that any building constructed prior to 2000 is highly likely to have asbestos within it. This means the relevant legal requirements set out in CAR 2012 must be met by each individual duty holder in control of any non-domestic building. The duty to manage in CAR 2012 requires that the person in control of a non-domestic premises (whether public or not) identifies and records the type, location and condition of ACMs present and takes action to manage the resulting risks and keeps the record up to date.
Dutyholders are also required to have a system to proactively ensure this information is made available to, for example, contractors who may disturb ACMs during work. This ensures that records of asbestos in non-domestic buildings (public or otherwise) are current, dynamic and shared in a timely way with people who need them most in the course of their work.
HSE operational staff may request to see records of asbestos inspections and action plans as part of their regulatory activities such as investigating a concern or because they have identified a matter of evident concern relating to asbestos. Any records that HSE staff acquired would be kept in line with HSE’s policies on information retention.
6. Is HSE making best use of available technology and systems to monitor the safety of asbestos which remains in buildings?
HSE monitors and is actively involved with research and development on asbestos both domestically and internationally. HSE will assess new innovations on managing risks associated with asbestos and where appropriate support, promote and occasionally mandate their implementation. The detail below is a sample of HSE’s work and, where relevant, findings relating to the management and monitoring of asbestos in buildings.
These committees develop new International Standards for measurement of asbestos. HSE represents GB on Technical Committee 146 (air quality), a standing committee which has developed standards for measurement of airborne asbestos fibres (PCM, SEM (Scanning Electron Microscopy) and TEM) and in the identification and quantification of asbestos in bulk materials by optical microscopy and electron microscopy. HSE contributes to the work of two sub-committees:
HSE are regularly approached by developers of new technology and novel techniques for the measurement of asbestos fibres. For example, over the last 10 years:
To date, HSE has not found sufficient evidence to recommend using these techniques instead of current measurement methods such as PCM.
The ‘duty to manage’ asbestos in CAR requires the active management of asbestos in buildings/premises (survey, development of management plan and proactive management of asbestos). Inaccessible asbestos in good condition e.g. sealed off, is managed in-situ and accessible asbestos in poor condition, must be remediated or removed. Regular ‘condition’ inspections ensure any change in asbestos condition is picked up and managed (refer to Q2).
Refer to response to Question 3 for more information on measuring airborne asbestos fibres.
Analysis of air and bulk samples of asbestos is carried out using microscopes. There are different types which offer different benefits. Phase Contrast Microscopy (PCM), uses light rather than electron beam and has practical advantages in the asbestos work environment. It is simpler, faster and inexpensive to buy, maintain and operate. It is also portable meaning it can be brought to site and speed analysis turnaround. Training and maintaining on-going operator competence are also significantly easier for PCM, compared with equivalent electron microscopy (EM) techniques. PCM is effective where a relatively simple analytical test is required and, as during asbestos work, predominantly asbestos fibres will likely be present. PCM is used for most asbestos analysis and is the WHO and EU recommended method. EM offers analytical advantages over PCM, with better resolution and the ability to determine fibre composition giving a much more complete picture of the fibres present. HSE guidance to analysts includes advice on the use of EM, identifies when EM is appropriate and refers to methods for electron microscopy.
Transmission electron microscopy (TEM), a type of EM, is used by HSE for research analysis alongside PCM. HSE are one of only two UK labs which have accreditation from the United Kingdom Accreditation Service (UKAS) for TEM use for asbestos. This type of equipment is rare in GB asbestos analytical laboratories. HSE is aware that France uses TEM as part of its arrangements for surveyors identifying remedial work on ACMs in premises (refer to response to Question 3). However, the process in France is based upon visual assessments of ACM condition which are performed every 3 years. Airborne fibre monitoring followed by TEM analysis is only required where visual damage/deterioration is identified and only on high-risk materials. In practice, airborne monitoring with TEM analysis is not carried out as a matter of routine in France.
Whilst TEM is a more sensitive technique and can identify a greater range of fibres, it is a much more expensive and a less practical technique with severely limited laboratories in GB able to offer this analysis. As referred to above, in relation to its use in measuring ambient airborne fibres, PCM provides a more cautious result by measuring all fibres present. PCM is an affordable, quick, practical method suitable for most work activities related to asbestos, there is a trained and competent workforce, a rigorous system of accreditation by UKAS and a system of consistency checking by a proficiency testing body.
HSE is also aware of the use of Scanning Electron Microscopy (SEM - another form of electron microscopy) in other European countries, namely The Netherlands, Germany, Switzerland and Austria. While SEM has greater sensitivity than PCM (i.e. can detect thinner fibres), and the ability to determine fibre composition, the ISO method used for SEM analysis stipulates that only fibres of diameter greater than 0.2 microns are counted, thus offering no benefit over PCM in this respect.
All the epidemiological research on risk of asbestos exposure relies on past PCM measurements. There is no clear relationship that allows conversion between PCM and Transmission Electron Microscopy (TEM) measurements. Any change in method would mean a discontinuity in the research. Recent HSE research (6), concluded that the relationship between results from PCM and EM techniques is complex, particularly at low asbestos concentrations.
HSE is also aware of other innovations and novel uses for technologies relevant to this area and is monitoring their development: Examples include:
HSE does not regulate levels of indoor air contaminants in in the absence of work processes or activities which generate hazardous substances. The Environment Agency (and devolved equivalents) regulate emissions from industrial processes with ambient air levels being the responsibility of the Department for Environment and Rural Affairs (DEFRA). Please also refer to Q3.
7. Does HSE commit adequate resources to asbestos management in line with the level of risk?
8. How robust is the available data about the risks and impact of asbestos in the workplace? What gaps in evidence need to be filled?
9. Is HSE drawing on a wide body of international and national regulatory and industry expertise to inform its approach to the management of asbestos safety in buildings?
10. How effectively does HSE engage with external stakeholders and experts about its approach to the regulation of asbestos?
Details of enforcement action taken by HSE
Asbestos licenses and inspections of work undertaken by licensed asbestos removal contractors.
Improvement Notices continued
 Northern Ireland has its own set of identical Regulations - The Control of Asbestos Regulations (Northern Ireland) 2012 (legislation.gov.uk)