Asbestos Pipe Lagging Removal — Class A Friable SWMS

Asbestos pipe lagging removal is the removal of asbestos-containing insulation — lagging — from pipes, ducts, boilers, valves and fittings, typically in plant rooms, basements, risers and industrial buildings constructed or serviced before asbestos was prohibited. Pipe lagging is almost always friable asbestos: the material is soft and readily crumbled, and removing it releases very high concentrations of airborne asbestos fibres unless it is rigorously contained and wetted. This makes pipe lagging removal one of the highest-risk asbestos activities, and the model Work Health and Safety Regulations and the asbestos removal Code of Practice use it as a defining example of work that requires a Class A asbestos removal licence. Asbestos is a Group 1 carcinogen and the diseases it causes — asbestosis, lung cancer and mesothelioma — commonly appear decades after exposure, so the controls are built on the principle that the fibre must never become airborne and escape the controlled area.

Because pipe lagging is friable, this work can only be carried out by the holder of a Class A asbestos removal licence, working under a suitably qualified supervisor, and it is high risk construction work because it involves the disturbance of asbestos, so a safe work method statement is required as well as an asbestos removal control plan. Air monitoring is mandatory for friable removal: control air monitoring is conducted during the removal, and clearance air monitoring forms part of the clearance inspection. Both the control and clearance monitoring, and the clearance certificate, must be carried out and issued by an independent licensed asbestos assessor engaged by the PCBU who commissioned the work, so the assessment is independent of the removalist. A clearance certificate can only be issued when the enclosure has been dismantled, the area is clear of visible asbestos contamination, and the airborne fibre level is below 0.01 fibres per millilitre. This document is written on the basis that enclosure, negative pressure, wetting and supplied-air respiratory protection are applied together throughout the removal.

Hazards identified

9 hazards covered, sorted by priority.

Control measures

Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.

1. 1Elimination: where the lagging can remain safely undisturbed and the work does not require its removal, manage it in place under an asbestos management plan rather than removing it.
2. 2Substitution: where removal is required, remove lagged components whole where practicable, or use the lowest-disturbance wetted technique, rather than aggressive stripping.
3. 3Engineering: a sealed enclosure under negative pressure with HEPA-filtered extraction for the friable removal, maintained and monitored so containment holds throughout the work.
4. 4Engineering: controlled wetting of the lagging with a wetting agent before and during removal to suppress fibre release, and HEPA vacuuming of surfaces and debris.
5. 5Administrative: confirm the removalist holds a current Class A asbestos removal licence and works under a suitably qualified supervisor, because pipe lagging is friable asbestos.
6. 6Administrative: prepare an asbestos removal control plan before the work begins and a SWMS for the high risk construction work, and notify the regulator of the licensed removal as required.
7. 7Administrative: the PCBU who commissioned the work engages an independent licensed asbestos assessor to conduct the mandatory control air monitoring during removal and the clearance air monitoring, and to issue the clearance certificate.
8. 8Administrative: isolate, drain and where necessary cool the pipework and plant before removal so the lagging is not removed from live or hot services, and control plant-room access and egress.
9. 9Administrative: provide a personal decontamination unit and a decontamination procedure for workers and equipment leaving the enclosure, so fibres are not carried out of the controlled area.
10. 10Administrative: double-bag and label the asbestos waste, and dispose of it at a facility authorised to accept asbestos, with the transport arrangements documented.
11. 11PPE: supplied-air or, at minimum, fit-tested powered air-purifying negative-pressure respiratory protection appropriate to friable removal, selected and maintained per AS/NZS 1715 and AS/NZS 1716, with disposable coveralls removed and bagged at decontamination.
12. 12PPE: gloves, eye protection to AS/NZS 1337.1, and Class I or Class II safety footwear with protective toecap to AS/NZS 2210.3, decontaminated or disposed of as asbestos waste.
13. 13Administrative: confirm all workers hold a valid White Card (General Construction Induction Training, CPCCWHS1001) and current Class A asbestos removal training before the work, and consult the workers and record the consultation.
14. 14Administrative: do not reoccupy or hand back the area until the enclosure is dismantled and the independent licensed asbestos assessor has issued a clearance certificate confirming the area is clear of visible contamination and below 0.01 fibres per millilitre, and review the control plan and SWMS whenever the scope or conditions change.

Applicable Codes of Practice

High-Risk Construction Work triggered

Worked example

A Class A licensed asbestos removalist is engaged to remove asbestos lagging from heating pipework in the basement plant room of an older commercial building before a mechanical upgrade. Because pipe lagging is friable asbestos, the removalist confirms the Class A licence and a suitably qualified supervisor, prepares an asbestos removal control plan and a SWMS, and notifies the regulator of the licensed removal. The PCBU who commissioned the work engages an independent licensed asbestos assessor for the mandatory air monitoring and clearance. A sealed enclosure is built around the pipework and held under negative pressure with HEPA-filtered extraction, and the pipes are isolated, drained and allowed to cool so the lagging is not removed from live or hot services. The lagging is wetted with a wetting agent and removed without aggressive disturbance, with surfaces and debris HEPA vacuumed. Removalists wear supplied-air respiratory protection and disposable coveralls, and pass through a personal decontamination unit on leaving the enclosure. The independent assessor conducts control air monitoring during the removal. The waste is double-bagged, labelled and taken to a facility authorised to accept asbestos. When removal is finished, the enclosure is dismantled and the assessor carries out the clearance inspection and air monitoring; only when the area is clear of visible contamination and below 0.01 fibres per millilitre is a clearance certificate issued and the plant room handed back.

Related legislation

• Model Work Health and Safety Act — primary duty of care; the duty to consult workers; the reckless-conduct offence; and notifiable-incident provisions, as enacted in each jurisdiction.
• Model Work Health and Safety Regulations — the friable asbestos removal provisions and Class A licence requirement; the asbestos removal control plan; the licensed asbestos assessor requirements for mandatory control and clearance air monitoring; and the high risk construction work provisions requiring a SWMS for the disturbance of asbestos, as enacted in each jurisdiction.
• Clearance certificate requirements: issued only when the enclosure is dismantled, the area is clear of visible asbestos contamination, and the airborne fibre level is below 0.01 fibres per millilitre.
• Asbestos waste must be double-bagged, labelled and disposed of at a facility authorised to accept asbestos in line with jurisdictional waste requirements.
• Victoria operates under the Occupational Health and Safety Act 2004 and the Occupational Health and Safety Regulations 2017, with the friable asbestos removal, licensing and clearance provisions and Compliance Codes applying in place of the model instruments.

Frequently asked questions