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The Ministry of Education is not providing advice to schools and early learning services (ELSs) on whether or not to undertake testing of coloured sand.
The school board or ELS is considered as the legal entity/person conducting a business or undertaking (PCBU) in a learning facility. The decision to engage a licensed asbestos assessor to sample or test the sand rests with them. Schools and ELSs may provide instructions to licensed asbestos assessors directly on whether to undertake testing.
The following process applies to schools and ELSs who have confirmed the use of a recalled sand product listed on the Product Safety website, or where they cannot verify the product they have onsite and are therefore treating it as positive or have requested sampling and testing to be performed.
Assessment#
- Trace and identify
- Confirm the source product and identify all areas where the material may have been used.
- If the school/ELS has chosen to request sampling of the product, the following should be performed:
- Complete sampling of the source product any other visually consistent play sand material/product.
- Sample analysis must be undertaken by an IANZ accredited lab.
- Sample requirements:
- Samples must be of an adequate size. Approximately 3 tablespoons per sample.
- Take 3 samples per colour/variant for verification purpose
- Visual inspection
- Conduct inspection for the spread of product by visual assessment only. The use of sticky tape may provide assistance in observing the presence of sand. Using non-reflective sticky tape, should allow the coloured sand to contrast against the colour of the tape.
- Apply tape to surfaces suspected of containing sand and visually assess for the presence of product.
- If product is present on the tape, conduct further visual inspection to establish an inclusion zone.
- Visual inspection area
- Conduct a thorough visual inspection of all areas where the use of sand has occurred.
- Inspect all vertical and horizontal surfaces, including porous surfaces.
- Inspect all furniture and toys.
- Inspect any stored items.
- Check external waste bins, as the school or ELS may have unknowingly disposed of the product. Include these in scope of remediation if contamination is found.
- Define affected areas
- Provide photographic evidence of all sand affected areas.
- Supply a site plan clearly marking locations of contamination.
- Remediation requirements
- Identify all items requiring removal based on visual assessment and tape lift observations.
- If building materials are impacted and require removal, undertake a localised intrusive inspection prior to remediation to test and confirm the presence of any additional asbestos-containing material (ACM) that may be affected, for example flooring below carpets.
- Provide a detailed inventory of items to be removed and those approved for in situ cleaning.
- Defining the area in scope
- Use information and data gathered from any sampling and visual observations to refine the scope of removal where possible.
- Include a buffer zone as a precaution.
- Preliminary air monitoring
Perform benchmark air monitoring within affected areas likely to be occupied, such as classrooms.
Sampling requirements#
- The source product refers to sand that is currently isolated or contained within a container previously used at the school or ELS.
- Any sampling of sand where significant volumes are visible and reputable sizes can be collected the sampling must follow the principle or frequency for non-homogeneous materials (such as textured coatings), recognising that asbestos may be unevenly distributed.
- Tape samples are not to be submitted for lab analysis and are visual reference only.
- Swabbing is not permitted.
Result interpretation#
If a school or ELS decides to request sampling as part of the assessment, the following definitions on the laboratory certificate should be noted. Interpretation of results will vary depending on the IANZ-accredited laboratory used.
- Laboratory reports all 6 asbestos types – specific asbestos types may be listed. Remediation will be required.
- Laboratory reports UMF (Unknown Mineral Fibre) – indicates asbestos is present, but the specific type cannot be classified. Remediation will be required.
- Laboratory reports NAD (No Asbestos Detected) – no remediation is required.
A school or ELS may wish to seek advice from a licensed asbestos assessor on whether samples reported as UMF or NAD should be resubmitted to a laboratory capable of testing for all 6 asbestos types.
Remediation#
Work classification and responsibilities#
Licensed asbestos removal contractor
WorkSafe has classified this as Class A removal.
Licensed asbestos removalist will be responsible for the following:
- notification to WorkSafe to be done as immediate notification
- preparation of an Asbestos Removal Control Plan (ARCP)
- remediation under Class A controls
- disposal of all waste at an approved facility by a licensed Class A removalist.
Note: If the area can be confined to specific locations, cleaning may be completed using localised enclosure set up.
Licensed asbestos assessor
Must be engaged independently of the removalist to:
- perform air monitoring during remediation
- conduct a 4-stage clearance
- carry out any required sampling.
Stage 3 – clearance specific requirements
Stage 3 clearance will require dust disturbance and air monitoring. Swabbing is not acceptable.
Post-remediation#
Once remediation work is completed, the school or ELS must be issued with an asbestos clearance certificate from the licensed asbestos assessor prior to access being permitted. This certificate confirms that the area has been sufficiently decontaminated and is safe for reoccupation.
