Asbestos-Containing Material Window Putty/Mastic

Asbestos-Containing Material Window
Putty/Mastic
NOTE:
Any potential asbestos containing materials should be entered
in the ACM site register and the information emailed to
asbestos@bmw.wa.gov.au
Prepared by
Building Research and Technical Services
August 2012
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‘Window putty/mastic’- potentially containing asbestos material
Introduction
In May 2012 the Australian Glass & Glazing Association Inc released a safety alert:
‘In line with the Work Health and Safety Regulation 2011, this alert refers to the
possibility of asbestos fibres being present in putty used on steel/aluminium framed
windows sealed with steel frame putty that was originally installed prior to 2004’.
The Australian Government, National Occupational Health and Safety Commission
2008 defines ‘Asbestos Containing Material’ (ACM) as any material, object, product
or debris that contains asbestos. 1
Asbestos fibres were used to reinforce window putty/mastic compounds in Australia
from 1930 to 1985. Some of the major suppliers of the putty were Flintkote, Tremco
Group, DAP Products Inc, Glastick Putty and Buttler Putty. 2
BMW research in response to the AGGA safety alert and has established that ACM
window putty/mastic has been used to seal glass into steel and aluminium frames.
Little empirical evidence exists that ACM putty was used for wood framed windows. 3
ACM window putty/mastic is unlikely to be friable nor a meaningful source of
airborne asbestos hazards in its bonded state, except perhaps during demolition of a
very large amounts of such material or when being mechanically ground out for glass
repair. 4
A total ban on all ACM in Australian products was effective from the 31 st December
2003. Window putty/mastic found in site glazed steel/aluminium framed windows in
buildings built prior to this date should be treated as containing asbestos material.
Statutory Obligation
Agencies have a statutory obligation under the Occupational Safety and Health Act
1984 (the Act) and the Occupational Safety and Health Regulations 1996 (the
Regulations) to provide a safe workplace for employees, whether that workplace is
owned or leased. Although there are occasions where multiple duty holders exist for
a single premise, agencies are still obligated as persons in control of that workplace
to ensure it is safe. 5
1 http://www.safeworkaustralia.gov.au/sites/SWA/AboutSafeWorkAustralia/WhatWeDo/Publications/Pages/C
P2005ManagementAndControlOfAsbestos.aspx
2 Safe Environments.com.au
3 Environmental Health Solutions Victoria & National Association of Testing Authorities Australia (NATA)
4 Environmental Health Solutions Victoria & Asbestos Network , Murdoch University Western Australia
5 http://www.finance.wa.gov.au/cms/uploadedFiles/Building_Management_and_Works/Asbestos_Steering_Co
mmittee_‐_Information_Guide_for_Agencies.pdfn=8455
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Legislative Requirement
The Agency as an employer, has responsibility to maintain a safe working
environment under the provisions of:
• Regulation 3.1a of the Occupational Safety and Health Regulations 1996 (OSH
Regulations 1996), which requires an employer to identify hazards at a
workplace, assess the risk of harm to a person from each hazard and to take
steps to reduce the risk.
• Regulation 5.43 (OSH Regulations 1996) which specifically requires the presence
and location of asbestos at a workplace to be identified and that the process of
identification and risk assessment is conducted in accordance with the Code of
Practice for the Management and Control of Asbestos in Workplaces
[NOHSC:2018 (2005)].
Recommendations
Recommendation 1: BMW contract project managers should alert relevant
contractors to the Australian Glass & Glazing Association Inc, AGGA SAFETY
ALERT-“Hacking out and removing steel/aluminium putty”. 6 Note that relevant
contractors may include but not be limited to: demolition and construction
contractors, glaziers, painters, window fabrication and installers, and any
miscellaneous tradesmen involved in maintenance or refurbishments.
Recommendation 2: In specific instances where the presence of asbestos in
window putty is suspected:
a. In the Perth Metropolitan area and areas covered by Service Arranger
Contracts, the panel contractors and the BMW metropolitan Breakdown
Repair team engage licensed asbestos contractors. 7
b. In regional areas Regional Contractors (including Service Alliance
Contractors) involved in window repair, contact the local BMW office to
determine further action 8
Recommendation 3: Window putty/mastic in steel/aluminium framed windows
should only be removed when reglazing or repairing damaged putty is necessary.
6 http://nswgga.org.au/wp‐content/uploads/Safety‐Alert‐Asbestos.pdf
7 BMW Breakdown Procedures Manual 2009 page 17 “Work requiring additional trades’
8 BMW regional staff in consultation with the contractor, determine the presence of ACM, based on age of
building etc, whether to use work practices in accordance with the Health and Safety Executive (HSE) (UK)
work sheet a37. Removing asbestos‐containing mastic, sealant beading , filler putty or fixing or engage a
licensed asbestos contractor, http://www.hse.gov.uk/pubns/guidance/a37.pdf
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The Service Arranger Contracts in the metropolitan area and the Service Alliance
Agreements in the regions do not require contractors to hold unrestricted asbestos
licence and it is not practicable to impose such a condition to the allocation of further
work.
The Zone Maintenance Contract for Glazing zones 1 & 2, Clause 3.2.2 states in part:
the glazing contractor can appoint a person or business that holds the appropriate
asbestos removal licence to remove the ACM putty/mastic on their behalf. The
Service Alliance agreements and other arrangements with contractors in regional
areas make no such provisions.
Recommendation 4: Specific clauses and information will be required in future
contracts and documents to ensure contractors understand safe working practices
and their obligations relating to ACM.
Recommendation 5: A safe work procedure for use by contractors working on
ACM window putty/mastic be developed by BMW for inclusion in the Asbestos
Booklet to enable contractor to remove the material themselves without engaging a
licensed asbestos remover where it is safe to do so.
Dealing with window putty/mastic (suspected ACM)
The removal, repair or maintenance of ACM window putty/mastic should be treated
in accordance with the guidelines set for dealing with asbestos in the work place
including reference to the Asbestos Management Plan, the Asbestos Booklet and the
‘Code of Practice for the Safe Removal of Asbestos- 2 nd Edition’ [NOHSC:
2002(2005)]. These documents give some guidance to the safe removal of ACM. 9,10
Unrestricted Licence allows people to remove all forms of asbestos (friable and
non friable) and replaces the current asbestos removal licence. 11,12
Restricted Licence (commenced June 2010) allows people to remove amounts
exceeding 10 square metres of bonded (non friable) asbestos. 13
9 http://www.finance.wa.gov.au/cms/uploadedFiles/Building_Management_and_Works/AMP_template.docn
=5732
10 http://www.finance.wa.gov.au/cms/uploadedFiles/Building_Management_and_Works/asbestos_booklet100
111(1).pdfn=7031
11 http://www.commerce.wa.gov.au/worksafe/content/Services/Certification_registration_and/Asbestos_rem
oval_licence_No_3.html#Unrestricted%20licence
12 Friable Asbestos : means material that can be crumbled, pulverised or reduced to a powder by hand
pressure when dry that contains asbestos. Non Friable : means material containing asbestos that is not
friable, including materials containing asbestos fibres reinforced with a bonding component (code of Practice .
How to safely remove asbestos)
13 http://www.commerce.wa.gov.au/worksafe/content/Services/Certification_registration_and/Asbestos_rem
oval_licence_No_3.html#Restricted%20licence
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Window putty/mastic containing asbestos material is referred to as non friable/low
risk product in its original state. However as it deteriorates with age (see Figure 1), is
sanded, scraped or mechanically ground there is a risk that asbestos fibres may be
released (friable) and therefore this risk needs to be managed.
Figure 1: Example of window putty used in a steel window frame. The second image is a close up of
the putty in this frame. Note: (this putty was tested and asbestos material was detected) image
courtesy of inspectapedia.com 2009.
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