Up until its ban in 1999, asbestos was used widely for its insulating and fire resistant properties - with use in the rail industry no exception. Buildings in the rail sector as well as the train rolling stock were – and continue to be - commonplace for asbestos containing materials.
Because asbestos is not considered an immediate risk unless it is disturbed and the fibres become airborne, it can still be found in a variety of places, despite the ban over nineteen years ago.
There are numerous regulations relating to asbestos management, which railway companies must comply with to ensure optimum protection for the people using their facilities. As a result of this ban, the rail sector – just like any other industry – has a legal duty to ensure it has systems in place to manage the risk asbestos poses to the health of workers and the public.
Managing asbestos in rail regulations
The first stage to effective and compliant management is understanding the regulations you must adhere to.
Under Control of Asbestos Regulations (CAR) 2012 Regulation 4, duty holders of non-domestic premises have a requirement to manage asbestos risk. The Office of Rail and Road (ORR) has clarified the definition of ‘non-domestic premises’ to include railway lineside structures, railway vehicles and rolling stock, in addition to train stations and other public buildings.
Within CAR 2012 Reg 4, the obligation to manage must include:
- Locating ACMs throughout the premises, structures and vehicles and assessing the risk posed to health
- Keeping up-to-date records about the location of asbestos
- Developing a risk management plan, and update it regularly as conditions across the premises change
- Informing people carrying out maintenance and repairs in affected structures about the presence of ACMs, and take steps to minimise risk
As with any building or sector, not knowing if asbestos is present – where it may reasonably be expected to be present - means you are non-compliant in your duty to manage.
Asbestos in rolling stock
Selecting a competent asbestos surveyor can support you in identifying the locations of asbestos in your premises, structures, rolling stock – and therefore support you in your obligatory responsibilities.
With a wealth of rail experience, SOCOTEC has seen many uses of asbestos on train rolling stock. Examples of such include Chrysotile – known as ‘white’ asbestos and the most common form of asbestos - often found in the millboards used in catering vehicles, the tapes found on exhaust pipes of engines and locomotives or skirting within partitions under seats. Amosite, known as brown asbestos, can be found in the form of paste under locomotive frames or as insulating boards. Even sprayed fibres on the sides, roofs, ends and floors of vehicles used to contain blue asbestos, and it's still possible to find remnants even after British Railways put vehicles through a blue asbestos stripping programme between 1969 and 1985.
Any number of rolling stock manufactured before the ban in 1999 has the potential to contain asbestos. Records are kept by the various Rolling Stock Operating Companies (ROSCO) but the Train Operating Companies (TOC) who operate the trains are responsible as duty holders in remaining complaint with CAR Regulation 4.
Since November 2015, R2, the rail industry’s database, has provided organisations with a single system interface for recording information for rolling stock, maintenance, maintenance planning, component tracking and defect recording.
The RSSB (Rail Safety and Standards Board) Customer self-service portal allows organisations to request information from the R2 system by opening up a case on their website.
The RSSB is currently conducting a research project into the health risks and impacts of exposure to a number of work environments, including exposure to asbestos.
While the RSSB acknowledge that “health risk assessments in common work environments [are] currently undertaken by health managers”, they also stress the point that those health managers “do not always have the scientific or technical knowledge to address certain aspects of work environments, or properly assess the related risks.”
Seeking expert support where needed is crucial to organisations in both the rail sector and other industries where you must have measures in place to safeguard building occupants and comply with regulations.
As well as this, and if not already done so, our advice would be to:
- Identify all the hazards on the premises
- Work out the most appropriate controls for the needs of the property and put them in place
- Appoint a duty-holder for the premises, sharing responsibility where the property is leased
- Ensure all responsible persons are appropriately trained
Managing asbestos risk is more than just a legal requirement; it is crucial to protect the health and wellbeing of workers and anyone else using the railway. Organisations should talk to asbestos experts to ensure they fully understand their legal duties, and to receive guidance on putting in place the most appropriate measures to manage risk throughout their premises.
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