Asbestos survey before work in existing buildings

Owners and tenants, a July 2019 decree requires you to conduct an asbestos survey before work on buildings constructed before July 1997, in order to protect workers.

Marie Faucon
Consultante HSE
Publication : 
11.12.2019
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Please note: This article concerns French legislation. The requirements described may not apply in other countries.

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As an owner or tenant of buildings dating from before July 1997, you will now be required to have a asbestos survey before work on built structures!

As a reminder, the purpose of the pre-work survey is to identify and locate asbestos-containing materials and products that may be affected by the work. The goal is to inform the intervening companies so that they can protect their personnel during the work.

The decree concerning surveys in built structures was published mid-July*. We'd like to elaborate on this measure.

Mandatory Asbestos Survey

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

The asbestos investigation must be carried out by a preliminary survey prior to the operation, the conditions of which, particularly the search procedures and material analysis methods, are set by decrees.

The obligation to conduct a pre-work survey came into force on July 19, 2019. The decree of July 16, 2019, specifies the implementation procedures.

Scope and Objectives of Asbestos Surveys

This pre-work asbestos survey must be carried out whenever work on buildings or their exteriors risks exposing workers to asbestos. This risk exists for:

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

It is not required if the information contained in the asbestos technical file (DTA) is sufficient to confirm the absence of asbestos.

Please note: the scope of the pre-works asbestos survey is broader than that of the asbestos technical file (DTA). Indeed, the survey includes, for example: bituminous road surfacing, asphalt, fiber-cement elements in outdoor installations, etc.

The pre-works asbestos survey consists of searching for, identifying, and locating asbestos-containing materials and products (ACMPs) likely to be directly or indirectly affected (due to shocks or vibrations) by the works and interventions. A non-exhaustive list of ACMPs is provided in Annex 1 of the decree.

Previous surveys carried out according to standard NF X 46-020, August 2017 version, are considered valid.

1. Asbestos Survey Operator

The asbestos survey operator must:

  • hold an asbestos survey operator certification;
  • be competent to estimate the quantity of asbestos-containing materials and products;
  • be SS4 trained (sub-section 4).

2. Survey Organization

For the survey operator to carry out their mission, the client must, in particular:

  • provide them with the list of buildings or parts of buildings concerned by the operations, their year of construction or modification, and the corresponding building permit dates;
  • provide them with an asbestos technical file (DTA) for each building concerned;
  • provide them with the plans or, failing that, sketches of each building concerned;
  • to provide them with the work schedule, which must be kept up to date in case of any changes to the work schedule after the asbestos survey mission has been ordered;
  • designate an accompanying person who is familiar with the premises and holds the necessary authorizations to access certain technical areas.

The client must not impose the asbestos survey methodology in their order. They cannot determine the number of in-depth investigations, core samples, samples, and analyses to be carried out by the asbestos surveyor.

The asbestos surveyor submits the scope and program of the survey to the client for their potential review.

3. Survey Procedure

The survey includes:

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

The surveyor may work by zones with similar structures (ZPSO) if a part of a building contains similar structures or structural elements, in order to reduce the number of samples.

If necessary, the asbestos survey must be conducted after the removal or relocation of furniture from the building concerned by the operation. In the case of a demolition operation, the building must be evacuated, unless the investigations do not generate fibers.

4. Worker Protection for Companies Performing the Work

If the asbestos survey cannot be carried out (e.g., emergency due to an incident posing a serious risk to people or the environment; suspicion of excessive risk for the surveyor), worker protection must be implemented as if asbestos were present. Waste disposal must be handled as if it contained asbestos.

For repair or corrective maintenance work, which falls under SS4 interventions (*) and implementing one or more processes with an airborne fiber level whose value is less than 100 fibers per liter:

  • the companies involved must demonstrate, for the processes implemented, at least one measurement allowing for control of the OEL (Occupational Exposure Limit) and demonstrating an airborne fiber level below 100 fibers per liter. For this, they may also rely on data from a reliable source.
  • the client ensures that the offer from the intervening company fully incorporates the requirements that apply to SS4 interventions.
  • the intervening companies implement collective and individual protection measures associated with processes corresponding to the relevant airborne fiber level.
  • Each company describes the collective protection measures for each process in its risk assessment document.

The collective and individual protection measures mentioned above are also implemented by the contracting companies when the asbestos survey cannot be separated from the operation itself for technical reasons and must be carried out as the operation progresses.

(*) SS4 (sub-section 4): work on materials, equipment, machinery, or items likely to cause the release of asbestos fibers

5. Documentation

The asbestos surveyor prepares a report for each building involved in the operation, indicating:

  • the identification of the survey and its scope;
  • the identification of the building(s) concerned (address, building permit dates, construction dates, main function of the building(s));
  • the survey program and scope;
  • the identification of the participants and stakeholders;
  • the list or location of identified materials and products, indicating the presence or absence of asbestos and the criteria used to conclude, as well as the estimated quantity of asbestos in these materials and products.

In cases where the asbestos surveyor was unable, for technical reasons, to carry out investigations on certain parts of a building, the beginning of the report must explain the reasons and detail the additional investigations remaining to be carried out between the different stages of the operation.

Additionally, if parts of a building are inaccessible to the asbestos surveyor (for example, lack of keys or a secure access route), the client must be informed in writing to resolve the situation. However, if this persists, a preliminary report, specifying the parts affected by the lack of access, must be prepared by the asbestos surveyor and detail the remaining investigations to be carried out accordingly.

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

Conclusion of the pre-works asbestos survey in buildings

* Decree of July 16, 2019, concerning the asbestos survey before certain operations carried out in built properties [JORF of July 18, 2019]

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