Asbestos detection prior to work in built-up areas

Owners or tenants of buildings dating from before July 1997: from now on, you'll need to have an asbestos survey carried out before any work is carried out on built-up areas!

As a reminder, the aim of the pre-construction survey is to identify and locate asbestos-containing materials and products likely to be affected by construction work. The aim is to warn contractors so that they can protect their personnel during the work.

In mid-July*, the decree on the identification of contaminants in built-up buildings was published. Here's a look back at the new regulations.

Obligation to identify asbestos

The client, project owner or owner of buildings, equipment, materials or articles must have the presence of asbestos investigated prior to any operation involving the risk of worker exposure.

The search for asbestos must be carried out by a survey prior to the operation, the conditions of which, in particular the search methods and material analysis methods, are set by decrees.

The obligation to carry out a pre-construction survey came into force on July 19, 2019. The decree of July 16, 2019 sets out the procedures to be followed.

Scope and objectives of asbestos detection

This pre-work asbestos survey is required whenever work on buildings or their exteriors is likely to expose workers to asbestos. This risk exists for :

• components manufactured before the asbestos ban, i.e. manufactured before January^1, 1997;
• buildings for which a building permit was issued before July^1, 1997.

It is not compulsory if the information contained in the asbestos technical file (DTA) is sufficient to conclude that no asbestos is present.

Please note: the scope of the pre-construction inspection is broader than that of the DTA asbestos technical file. The following, for example, are covered by the survey: bituminous asphalt for road surfaces, asphalt, fiber-cement elements for exterior fittings, etc.

Pre-work surveys involve searching for, identifying and locating asbestos-containing materials and products (ACMPs) likely to be affected directly or indirectly (by shocks or vibrations) by work and interventions. A non-exhaustive list of MCPA is provided in Appendix 1 of the Order.

Previous surveys carried out in accordance with NF X 46-020 version of August 2017 are to be considered valid.

1. Locating operator

The operator in charge of the asbestos survey must :

• be certified as an asbestos spotting operator;
• be competent to estimate the quantity of asbestos-containing materials and products;
• be trained in SS4 (sub-section 4).

2. Tracking organization

To enable the surveyor to carry out his work, the client must, in particular:

• provide him with a list of the buildings or parts of buildings concerned by the operations, their year of construction or modification and the dates of the corresponding building permits;
• provide him with a DTA for each building concerned;
• provide him with plans or, failing that, sketches of each building concerned;
• send him the work schedule, which must be kept up to date in the event of changes to the work schedule subsequent to the commissioning of the survey;
• appoint a supervisor who is familiar with the premises and has the necessary clearance to enter certain technical areas.

The client's order must not stipulate the location methodology. He cannot determine the number of in-depth investigations, surveys, samples and analyses to be carried out by the survey operator.

The asbestos surveyor sends the scope and program of the survey to the client, for approval.

3. Spotting procedure

Spotting includes :

• a visual inspection to identify materials likely to contain asbestos;
• samples if the operator does not have sufficient information on the possible presence of asbestos. Samples are analyzed by an accredited organization.

The operator can work by ZPSO (zone présentant des similitudes d'ouvrages) if part of a building has similar structures or parts of structures, in order to reduce the number of withdrawals.

Where necessary, asbestos surveys should be carried out after the removal or relocation of the building's furnishings. In the case of a demolition operation, the building must be evacuated, unless the search generates no fibers.

4. Protection of workers employed by companies carrying out work

If it is not possible to carry out the survey (e.g. in the event of an emergency caused by a disaster posing a serious risk to people or the environment, or if the surveyor suspects an excessive risk), workers are protected in the same way as if asbestos were present. Waste is disposed of as if it contained asbestos.

For repair or corrective maintenance work, covered by SS4 (*) and involving one or more processes with a dust level of less than 100 fibers per liter:

• for the processes implemented, contractors must provide proof of at least one measurement enabling the VLEP (occupational exposure limit value) to be checked, and demonstrating a dust level of less than 100 fibers per liter. For this, they can also rely on data from a reliable source.
• the client ensures that the contractor's offer includes the requirements applicable to SS4 operations.
• contractors implement collective and individual protection measures associated with processes at the relevant dust level.
• each company describes the collective protection measures for each process in its single document.

The above-mentioned collective and individual protection measures are also implemented by contractors when, for technical reasons, it is not possible to dissociate the location from the operation itself, and when it has to be carried out as the operation progresses.

(*) SS4 (sub-section 4): work on materials, equipment, materials or articles likely to cause the emission of asbestos fibres.

5. Documentation

The spotting operator draws up a report for each building concerned by the operation, indicating :

• identification of the location assignment and its scope;
• identification of the building(s) concerned (address, date of building permits, construction dates, main function of the building(s));
• the program and scope of identification ;
• identification of stakeholders;
• the list or location of identified materials and products, mentioning the presence or absence of asbestos and the criteria used to reach this conclusion, as well as the estimated quantity of asbestos in these materials and products.

In cases where, for technical reasons, the surveyor has been unable to investigate certain parts of a building, the beginning of the report must explain the reasons for this, and detail the additional investigations to be carried out between the different stages of the operation.

In addition, if parts of a building are inaccessible to the inspection operator (e.g., due to a lack of keys or safety access), the client must be informed in writing, so that the situation can be remedied. However, if the situation persists, the surveyor must draw up a preliminary report, specifying the parts concerned by the absence of a visit, and detailing the remaining investigations to be carried out accordingly.

The client forwards the survey report to the building owner. The owner updates the DTA and its summary sheet to include asbestos-related elements identified during each inspection.

Conclusion of asbestos surveys prior to work in built-up areas

* Arrêté du 16 juillet 2019 relatif au repérage de l'amiante avant certaines opérations réalisées dans les immeubles bâtis [JORF of July 18, 2019]

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