Asbestos in coloured sand – Guidance for asbestos professionals

If you’re an asbestos assessor or removalist, you’ll find information about how to assess, safely remove and remediate asbestos in schools here.

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We don’t provide advice to schools on whether or not they should test coloured sand.

The school board is considered the legal entity or ‘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 may provide instructions to licensed asbestos assessors directly on whether to undertake testing.

The following process applies to schools who:

  • have confirmed the use of a recalled sand product listed on the Product Safety website
  • can’t verify the product they have onsite and are therefore treating it as positive
  • have requested sampling and testing be performed.

Assessment

  1. 1

    Trace and identify

    Confirm the source product and identify all areas where the material may have been used.

    If the school has requested the product be sampled:

    • complete sampling of the source product and any other visually consistent play sand material/product.
    • ensure the sample analysis is undertaken by an IANZ accredited lab.

    Sample requirements.

    • Samples must be of an adequate size, approximately 3 tablespoons per sample.
    • 3 samples per colour/variant must be taken for verification purposes.
  2. 2

    Visual inspection

    Conduct an inspection for the spread of product – as a visual assessment only. Sticky tape may help identify the presence of sand – non-reflective sticky tape should let the coloured sand contrast against the colour of the tape.

    Apply tape to surfaces suspected of containing sand and visually assess for the presence of the product.

    If the product is present on the tape, conduct further visual inspection to establish an inclusion zone.

  3. 3

    Visual inspection area

    Conduct a thorough visual inspection of all areas where the sand has been used.

    • 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 may have unknowingly disposed of the product. Include these in the scope of remediation if contamination is found.
  4. 4

    Define affected areas

    Provide photographic evidence of all sand affected areas.

    Supply a site plan clearly marking the location of any contamination.

  5. 5

    Remediation requirements

    Identify all items that need to be removed based on visual assessment and sticky tape observation.

    If building materials are impacted and need to be removed, undertake a localised intrusive inspection prior to remediation. This will test and confirm the presence of any additional asbestos-containing material (ACM) that may be affected, such as flooring below carpets.

    Provide a detailed inventory of the items to be removed and those approved for in-situ cleaning.

  6. 6

    Define the area in scope

    Use the information and data gathered from any sampling and visual observation to refine the scope of removal where possible.

    Include a buffer zone as a precaution.

  7. 7

    Preliminary air monitoring

    Perform benchmark air monitoring in any affected areas that are 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.
  • Any sampling of sand where significant volumes are visible and reputable sizes can be collected 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 a visual reference only.
  • Swabbing is not permitted.

Interpreting results

If your school decides to request sampling as part of the assessment, the following definitions on the lab certificate should be noted. Interpretation of results will vary depending on the IANZ-accredited lab used.

  • Lab reports all 6 asbestos types – specific asbestos types may be listed. Remediation will be required.
  • Lab reports UMF (Unknown Mineral Fibre) – indicates asbestos is present, but the specific type cannot be classified. Remediation will be required.
  • Lab reports NAD (No Asbestos Detected) – no remediation is required.

You can seek advice from a licensed asbestos assessor on whether samples reported as UMF or NAD should be resubmitted to a lab 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.

The licensed asbestos removalist will be responsible for:

  • notifying WorkSafe – as an immediate notification
  • preparing 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 a localised enclosure set up.

Licensed asbestos assessor

A 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 complete, the school 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 to occupy again.