english – Successful detention: evaluation completes asbestos cement application
The last doubts about the completeness of the measurement results should now be dispelled: With a further analysis on the cutting of the liner in the manhole, the RSV invalidates objections to the application for recognition of pipe lining as a low-emission procedure in drains made of asbestos cement.
The thriller about recognition as a low-emission procedure became exciting once again: on Monday, RSV presented a supplemented test report from TÜV Nord to the Institute for the Protection of Labour (IFA) and representatives of the decisive working group. The results were discussed directly and questions were answered.
"Even if we should no longer be too optimistic - given our experience: Nothing should now stand in the way of finalising the recognition procedure," reports RSV Managing Director Reinhild Haacker. The parties involved have agreed to examine the documents swiftly and to communicate the results in a timely manner. "Both the employers liability insurance associations and the IFA have made it clear to us that they are also interested in finalising the application."
Authorities await IFA recognition
As numerous local authorities urgently need to maintain their asbestos cement pipes, the RSV application is under scrutiny nationwide. Haacker: "IFA recognition seems to be the decisive step that many are waiting for. Several federal states have signalled this to us. However, the federal states can also recognise the procedure as a low-emission procedure themselves - the documents - including the legal framework - have been available to them via this link since mid-January. We have now supplemented the documents with the current test report."
According to feedback from municipalities in Bavaria, no permits for pipe lining measures are currently being issued in practice on the grounds that there is no low-emission procedure recognised by the IFA. Haacker: "Even if the state ministry responsible for labour inspectorates correctly describes the situation: IFA recognition is obviously the key to the basic approval of remedial actions.’
Under TRGS 519, work on units made of asbestos can also be carried out without IFA approval as a BT procedure with a permit in individual cases and with accompanying fibre measurements. "This procedure is no longer necessary with a low-emission procedure - which of course makes the tendering process simpler and clearer for all sides," says Haacker.
The low-emission procedure is linked to a process description that describes the individual steps and safety measures in detail. In accordance with TRGS 519, a certificate of competence for working with asbestos is also required for construction measures involving cured-in-place pipes.
TÜV employee put in extra shifts
A fortnight ago, due to an objection from a trade association, a re-measurement was requested virtually on the last few metres. This would have delayed the approval by months, as licences are currently rarely granted, even for measuring construction sites.
The RSV was able to avert a further delay thanks to the subsequent evaluation of a further measurement filter from personal measurements at the previous asbestos cement sites and a special shift by TÜV Nord last week.
What the objection was about....
- Three measuring points are required for a low-emission procedure to be recognised. BT procedures designated as low-emission are characterised by the fact that they must be able to be carried out without respiratory protection
- During the cutting of the liner in the manhole, an increased dust load was detected at a site - as part of the personnel measurement. Counting the dust from the respiratory protection filter was initially rejected, as it had to be assumed that TÜV Nord employees would be busy counting scanning electron microscope images for several days. This meant that no statement could be made about the asbestos fibre concentration. The measurement of the background concentration at the manholes did not reveal any fibre exposure.
- At the other measuring sites, two further measurements by persons proved that the fibre concentration was below the maximum limit value when the liner was cut off. From the RSV's point of view, there were sufficient measurements to prove that this step is harmless.
- Recognition as a low-emission procedure was nevertheless denied because only two construction site measurements had been formally submitted for the ‘cutting back the liner in the manhole’ work step. The argumentation was not followed that respiratory protection is also necessary for other reasons during this work step, which is why the rules for the low-emission procedure would be ineffective at this point.
- The subsequent analysis of the filter contaminated with dust, which revealed no asbestos fibres, has now invalidated the objection.