Item 7 b 2024_25_InternalAudit_AsbestosManagement_ReportFinal
Argyll and Bute Council · 12 June 2025
Back to Audit and Scrutiny Committee — 12 June 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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Argyll and Bute Council Internal Audit Report April 2025 Final High Medium Low VFM Number of Findings 0 5 4 0 Asbestos Management Audit Opinion: Reasonable
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2 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 Contents 1. Executive Summary ........................................................................................................................ 3 Introduction ............................................................................................................................................ 3 Background ............................................................................................................................................. 3 Scope ....................................................................................................................................................... 4 Key Dates ................................................................................................................................................ 4 Risks ........................................................................................................................................................ 4 Audit Opinion ......................................................................................................................................... 4 Recommendations ................................................................................................................................. 4 2. Objectives and Summary Assessment ........................................................................................... 5 3. Detailed Findings ............................................................................................................................ 7 Appendix 1 – Action Plan ..................................................................................................................... 12 Appendix 2 – Audit Opinion ................................................................................................................. 17 Contact Details Internal Auditor: Annemarie McLean Telephone: 01700 501354 e-mail: annemarie.mclean@argyll-bute.gov.uk www.argyll-bute.gov.uk
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3 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 1. Executive Summary Introduction 1. As part of the 2024/25 internal audit plan, approved by the Audit & Scrutiny Committee in March 2024, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of internal control and governance in relation to Asbestos Management. 2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS) with our conclusions based on discussions with council officers and the information available at the time the fieldwork was performed. The findings outlined in this report are only those which have come to our attention during the course of our normal audit work and are not necessarily all the issues which may exist. Appendix 1 to this report includes agreed actions to strengthen internal control however it is the responsibility of management to determine the extent of the internal control system appropriate to the Council. 3. The contents of this report have been agreed with the appropriate council officers to confirm factual accuracy and appreciation is due for the cooperation and assistance received from all officers over the course of the audit. Background 4. Although asbestos is a hazardous material, it can only pose a risk to health if the asbestos fibres become airborne and then inhaled. Asbestos Containing Materials (ACMs) only release fibres into the air when they are disturbed. If ACMs are not disturbed airborne fibres will not be released and therefore, they will not pose a risk to health. 5. The Control of Asbestos Regulations (CAR) 2012 requires employers to prevent the exposure of their employees to asbestos, or where this is not practicable, to reduce the exposure to the lowest possible level. Specifically, the broad legal duties are to: • take reasonable steps to find materials likely to contain asbestos; • presume materials contain asbestos, unless there is strong evidence to determine they do not; • assess the risk of the likelihood of anyone being exposed to asbestos from these materials; • make a written record of the location and the condition of the ACMs and presumed ACMs and keep it up to date; • repair or remove any material that contains or is presumed to contain asbestos, if necessary, because of the likelihood of disturbance, and its location or condition; • prepare a plan to manage that risk and put it into effect to ensure that: o information on the location and condition of ACMs is given to people who may disturb them during work activities; o any material known or presumed to contain asbestos is kept in a good state of repair; • monitor the condition of ACMs and presumed ACMs; and • review and monitor the action plan and the arrangements made to put it in place. 6. The management of asbestos in premises is also covered under Health and Safety legislation, including:
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4 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 • The Management of Health and Safety at Work Regulations 1999, which requires an assessment of the risks to employees and users of premises be undertaken and appropriate arrangements made for protecting those people’s health and safety; and • The Workplace (Health, Safety and Welfare) Regulations 1992 which includes duties to maintain workplace buildings/premises to protect occupants and workers. Scope 7. The scope of the audit was to review and assess the arrangements for the management of asbestos across Council establishments, as outlined in the Terms of Reference agreed with the Head of Commercial Services on 23 October 2024. Key Dates 8. The Terms of Reference provided provisional timescales for the review to take place, the actual dates are noted below. Exhibit 1 – Key Dates Stage Actual Date Terms of Reference agreed 23 October 2024 Fieldwork Commencement 23 October 2024 Draft Report issued 04 February 2025 Management Comments received 01 April 2025 Final Report issued 02 April 2025 Audit and Scrutiny Committee 12 June 2025 Risks 9. The risks considered throughout the audit were: • Audit Risk 1: Failure to comply with the Control of Asbestos and Health and Safety at Work, Regulations. Audit Opinion 10. We provide an overall audit opinion for all the audits we conduct. This is based on our judgement on the level of assurance which we can take over the established internal controls, governance and management of risk as evidenced by our audit work. Full details of the five possible categories of audit opinion is provided in Appendix 2 to this report. 11. Our overall audit opinion for this audit is that we can take a reasonable level of assurance. This means that internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend, there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system objectives at risk. Recommendations 12. We have highlighted five medium priority recommendations and four low priority recommendations where we believe there is scope to strengthen the control and governance environment. These are summarised below:
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5 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 • The Council’s Asbestos Management Plan (the 2013 Plan) should be updated to ensure it reflects the current Council structure and revised working practices. • HSE guidance requires that individual buildings plans should be monitored and reviewed every 12 months or sooner if necessary. The 2013 Plan and all associated documents and checklists should be reviewed to ensure they reflect this requirement. • Gaps in staff training and awareness were identified. A pilot scheme providing training to staff in Education Dept, proved successful. This should be rolled out to all Council Services. • When reviewing and updating the 2013 Plan and associated documents/ checklists, the storage and retention period of the document should be clearly stated. • The 2013 Plan and associated procedures, materials and information, should be updated to clarify the role and responsibilities at individual site/premises level and should include the requirement for a Deputy to be appointed to ensure cover for absence. • Property Services must be advised of any changes to staff, nominated by Heads of Services, to be the Site Premises Manager/ Site Responsible Persons for each site/ establishment. • Mandatory LEON training for Facility Responsible Persons should be extended to include the Site Premises Manager/ Site Responsible Persons and their nominated Deputies. This should be completed annually. • The Duties of the Facilities Responsible Person document should be updated to include their responsibilities in relation to the management of asbestos. There may be benefit to producing a checklist of facility related checks for sites/premises to collate these in one place. 13. Full details of the audit findings, recommendations and management responses can be found in Section 3 of this report and in the action plan at Appendix 1. 2. Objectives and Summary Assessment 14. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our assessment against each objective. Exhibit 1 – Summary Assessment of Control Objectives Control Objective Link to Risk Assessment Summary Conclusion 1 The Council has a plan/policy in place to manage its duty relating to the risks associated with asbestos- containing materials (ACMs) across Council establishments. Audit risk 1 Reasonable • The Council has the Asbestos Management Plan (the 2013 Plan) in place to manage its duty relating to the risks associated with asbestos-containing materials (ACMs) across Council establishments. This should be updated to ensure it reflects the current Council structure and revised working practices. • HSE guidance requires that individual buildings plans should be monitored and reviewed every 12 months or sooner if necessary.
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6 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 • 186 of the 188 premises required, have had a re-inspection within the last 12 months. • The Council has procedures and guidance in place to follow if ACMs are disturbed, these are detailed in the plan and published in the Facility Responsible Person section on the Hub. • The Health and Safety Team and Property Services identified gaps in awareness amongst staff and potential to consolidate the information available. Testing confirmed this. • A pilot scheme providing training to site responsible persons, within Education Services, has been developed and carried out by Health and Safety staff. This has proven successful and is planned to will be rolled out across all Council Services. • There is no clear mention of the retention period for the various documents relating to the management of asbestos. • A review of the processes and training materials associated with the management of asbestos, is currently underway, once completed the 2013 Plan will be updated. 2 Council staff are aware of their responsibilities in relation to monitoring buildings and reporting issues that may relate to asbestos- containing materials (ACMs). Audit risk 1 Reasonable • The Facility Responsible Person (FRP) takes responsibility for overseeing facility safety and facility related activities. • The Site Responsible Person (SRP) co- ordinates arrangements between Property Services and other Services occupying the premises. The SRP role and its responsibilities should be detailed in the 2013 Plan and referred to in the wider information and materials. • Key contact details for staff nominated by Services as SRP are not up to date. • Mandatory LEON training for Facility Responsible Persons, does not reference the SRP role nor their deputies and there is currently no mandatory training for these staff. • The Duties of the Facilities Responsible Person document should be updated to include their responsibilities in relation to management of asbestos. There may be benefit to producing a checklist of facility related checks for sites/premises to collate these in one place.
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7 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 15. Further details of our conclusions against each control objective can be found in Section 3 of this report. 3. Detailed Findings The Council has a plan/policy in place to manage its duty relating to the risks associated with asbestos-containing materials (ACMs) across Council establishments. 16. The Council has the Asbestos Management Plan (the 2013 Plan) in place to manage its duty relating to the risks associated with asbestos-containing materials (ACMs) across Council establishments. It applies to all parts of the Council’s estate constructed prior to 2000, when the use of asbestos in construction was considered to be officially banned. 17. The 2013 Plan, and the management system it contains, is designed to provide the basis for implementing the key legislative elements, some examples include: • to provide and maintain an Asbestos Register for each site where asbestos may be present and an Onsite Control of Asbestos Logbook; • to develop, implement and review an effective management strategy so that appropriate measures, such as sealing, labelling, inspection or removal of ACMs are undertaken to prevent exposure to the hazards associated with asbestos; • to promote awareness of the Asbestos Management Plan and the hazards of asbestos, through training and induction of staff and those working on behalf of the Council. 18. Property Services is responsible for maintenance of the building fabric and building services. In relation to the management of asbestos within Council premises, Property Services arrange for the compilation, consultation, implementation and monitoring of specific management arrangements for Asbestos Containing Materials (ACMs) or suspected ACMs. 19. The Health and Safety Team offer advice and support on all matters relating to health, safety and welfare. The relevant asbestos policies and procedures are contained within the Health and Safety Team site on the Council’s Intranet, the Hub. 20. The 2013 Plan is the over-arching guide for all Council staff and while it is comprehensive and takes cognisance of the legislation it has not been updated since its approval in May 2013 as there has, we are advised, been no significant changes in legislation or working practices. 21. A review of the processes, procedures and training relating to managing asbestos is currently being undertaken by staff from Property Services and the Health and Safety Team, once complete the 2013 Plan will be updated to reflect the revised working practices. 22. In line with statutory requirements, the Council has defined the organisational structure and management responsibilities for the Control of Asbestos. The 2013 Plan contains a flow chart depicting the organisation structure and the roles/ titles of those persons appointed to key roles of Dutyholder, Responsible Person, and Competent Persons. Alongside this structure the Health and Safety Team are involved in providing advice, specifically in terms of the legal requirements, at all stages of the management process. 23. The Dutyholder has overall responsibility for ensuring that the Control of Asbestos is adequately managed to mitigate the risks identified, they can delegate tasks to the Deputy Dutyholder and
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8 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 can nominate others to do tasks. The Responsible Person, nominated by individual Services, implements the Control of Asbestos Management Plan with assistance from the designated Competent Persons. Competent Persons, ensure local control of the Risk Assessment Process at a site or multi-site level. Site Responsible Persons are the employees appointed by Services to be the person responsible for individual Council establishments. 24. Appendix One – Register of Role holders details the Organisational Structure Key Personnel. This includes the names and contact details of individuals and deputies that have been appointed to the main roles, Dutyholder, Deputies, Responsible Persons and Competent Person, and while some of the names remain the same, this list has does not reflect the current Council structure. Action Plan 1 25. The management of asbestos in non-domestic premises requires the Council, as Dutyholder, to have as a minimum a Management Survey to have been undertaken for its premises. The purpose of the survey is to gather the base information required for an asbestos register and plan to be prepared, a suitable risk assessment to be carried out and a written plan to manage the risks is required to be produced. 26. The Management Surveys for each premises will identify whether the establishment is affected by the Control of Asbestos Regulations by: • Checking for, identifying and assessing the condition of Asbestos Containing Materials; • Assessing the risk; • Providing a Control of Asbestos Risk Assessment indicating the relevant information and recommendations necessary to manage the risk and to minimise the risk of ACMs being disturbed. 27. Property Services maintain the Asbestos Site History spreadsheet which is a central register of establishments/premises where the initial Management Survey has identified as containing or suspected to have Asbestos Containing Materials (ACMs). The register includes details of: • the site name: • management survey date; • re-inspection by a competent person date; • date next re-inspection due; and • whether the sites have an asbestos register and asbestos location plan. 28. Property Services issue the Onsite Control of Asbestos Logbook folder to each of the establishments, this is onsite information specific to that facility. It includes the most up to date asbestos management survey, a location plan showing where ACMs are present, a register of where there is ACM present and re-inspection register. For completeness, if applicable, copies of any Refurbishment/Demolition surveys that have been undertaken in the facility. There is a visitor’s sign in sheet for most facilities and a contractors sign in/register for all sites. If something changes in the building, the Property Asbestos Officer will arrange for the register to be updated to reflect this. 29. The review of the 2013 Plan includes the re-alignment of scheduled re-inspections by Property Services to match the geographic areas covered by staff and the review of the Health and Safety risk assessments for each site. Given the size and geography of the Council area this is a resource
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9 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 intensive exercise, in terms of both staff time and travel related costs. Where possible staff plan the site visits to coincide with other inspections. 30. The HSE duty to manage asbestos in buildings guidance states that, as part of the Control of Asbestos Regulations, buildings plans should be monitored and reviewed every 12 months or sooner if necessary. There is limited mention of this requirement within the 2013 Plan and the associated documents. These should be reviewed to ensure that they refer to this requirement and that they specify staff roles and responsibility for completion of reviews, monitoring of the ACMs and where applicable carrying out risk assessments. Action Plan 2 31. A review of the Asbestos Site History spreadsheet confirms that of the 188 Council premises that have been identified as containing, or are suspected to have ACMs, 186 have been re-inspected within the past 12 months. 32. The Council has procedures and guidance in place to follow if ACMs are disturbed. The 2013 Plan provides details of the internal requirements for each of the duties within the roles and responsibilities section. It also sets out Emergency Procedures which are predominately targeted where works are being carried, so aimed at external contractors. The information is published in the Facility Responsible Persons section of the Health and Safety site on the Hub. 33. The Health and Safety Team and Property Services identified that there were gaps in awareness amongst staff and potential to consolidate the information available. They decided to update the Onsite Control of Asbestos logbook by collating the relevant information and guidance into one place rather than have it spread between the 2013 Plan, the site plans/logbooks and the Hub. 34. The Health and Safety Team have produced a Site Asbestos Management Plan (Site AMP), based on the Council’s overarching 2013 Plan and developed new awareness training materials for Site Responsible Person (SRP). This includes showing how to complete the Site AMP and highlights what their responsibilities are. This has been piloted within Education services with awareness training sessions delivered to Head Teachers, as the SRP. 35. Testing, as noted in paragraph 45 below confirms the awareness and training gap and highlights the success of the pilot scheme. Following completion of the pilot, staff within Health and Safety and Property Services are reviewing and updating the documentation, processes and procedures, to ensure that they reflect the revised working practices. The awareness training is planned to will be rolled out by the Health and Safety Team to other Services after the review. Records of this training should be maintained. Action Plan 3 36. There is no clear mention of the retention period for the various documents relating to the management of asbestos. When reviewing and updating the 2013 Plan and associated documents/ checklists and training materials, the storage and retention of the document should be clearly stated. Action Plan 4 37. As noted in paragraph 21 above, the 2013 Plan will be updated once the working practices and training is fully revised. For completeness, any linked documents referred to or based upon the
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10 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 2013 Plan, including the Education Management Circular 1.31, should be listed to ensure that they are updated/ reviewed any time the Plan is revised and vice versa. Council staff are aware of their responsibilities in relation to monitoring buildings and reporting issues that may relate to asbestos-containing materials (ACMs). 38. The Facility Responsible Person (FRP) is the Head of Service, they have responsibility for overseeing facility safety and facility related activities (other than maintaining building fabric and building services which remain the responsibility of Property Services). Heads of Service nominate a member of staff as the Site/Premises Manager for each establishment and notify Property Services who record the appointment on the Council’s Property Management System, Concerto, which contains the central register. 39. The SRP co-ordinates arrangements between Property Services and other Services occupying the premises and performs specific facility related tasks, including monitoring buildings and reporting issues that may relate to disturbances of areas identified as having asbestos containing materials (ACMs). Some documents in the Health and Safety Intranet site refer to Site Premises Manager. To avoid confusion there should be consistent use of one title. 40. The 2013 Plan currently refers to Site Manager or Head Teacher rather than the current title of Site Responsible Person. While there is no requirement for the 2013 Plan to include titles of the individual SRP, this is an important role. The 2013 Plan and associated procedures, materials and information and the Education Management Circular 1.31, should be updated to clarify the role and responsibilities of the SRP and include the requirement for a Deputy to be appointed to ensure cover for any absences. Action Plan 5 and 6 41. Services should advise Property Services of any changes of staff nominated as SRP but in practice this does not happen consistently meaning that these records are not up to date. Property Services have in the past issued emails to Heads of Services asking for staffing updates, but due to a lack of response this practice was stopped. Consideration should be given to whether this could be reinstated and where there is no response if this should be escalated to DMT/SMT. Action Plan 7 42. Mandatory training for staff nominated by Services as FRP, is available on the LEON system, which also records and monitors completion. This does not reference the SRP role and there is currently no mandatory training for staff appointed to this role. Mandatory training should be extended to include SRPs and their nominated Deputies to ensure that there is cover for absence. Action Plan 8 43. To establish the extent to which Council staff are aware of their responsibilities in relation to monitoring buildings and reporting issues that may relate to ACMs, a survey was issued to 34 sites/ establishments. These were selected on a risk basis so included schools, Homes For the Elderly, Customer Service Points, Social Work premises and Roads Depots. In total, we received 26 completed surveys, the results are set out in the table below.
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11 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 Survey Questions and Results y n % Yes Q1 Is there an asbestos management plan the building? 20 6 77% Q2 If yes, is it prominently displayed 19 7 73% Q3 Have you received training in relation to your duties? specifically, your duties relating the monitoring and reporting of Asbestos Containing Materials (ACM) 12 14 46% Q4 Have you completed the Facility Responsible Person LEON training? 12 14 46% Q5 Do you carry out undertake regular inspections of the establishment/ building, (this includes checking the whether the location of ACM has been disturbed)? 13 13 50% Q6 Do you know where to find information and who to contact if you have queries relating to: • Management of Asbestos 19 7 73% Q6a • Health and Safety of users of that Council establishment 21 5 81% Q6b • the location of ACMs 18 7 69% Q6c • where to find information and who to contact if you have queries 17 9 65% Q6d • what to do/how to report if the ACMs may be disturbed? 18 8 69% Q7 Have you ever reported a potential disturbance to the area containing the ACMs? 0 26 0% 44. The responses from schools were positive with all 12 confirming they have received training and only one school unaware that Property Services have to be notified of potential asbestos related issues, in addition to contacting Health and Safety Team. This highlights the success and impact of the recent pilot scheme. As noted in paragraph 33 above, the awareness training is planned to be rolled out to other Services, after the plan and linked materials have been updated. 45. The survey responses highlight the gap in awareness of staff responsibilities and training already identified by Property Services and Health and Safety Teams as 46% of staff have not received training - neither awareness training nor the LEON module. In particular five of the six Council Depots contacted have not received training and were unaware of the asbestos management plan for the site, staff highlighted a lack of handover in relation to SRP duties, when changes of staff occurred. 46. Currently the Duties of the FRP document makes no mention of their responsibilities relating to the management of asbestos. This should be updated to include the need to appoint an SRP and Deputy for each site/premises and where appropriate, a visual check for disturbances to locations identified as containing or suspected to contain ACMs. 47. Half of the staff surveyed carry out regular inspections. In addition to clarifying the role and responsibilities of the SRP, there would be benefit to producing a checklist of facility related checks for sites/premises to collate these in one place e.g. fire alarm testing, legionella testing, visual check of ACMs, including the frequency that these are required. Action Plan 9
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Appendix 1 – Action Plan No Finding Risk Agreed Action Responsibility / Due Date Medium 1 Asbestos Management Plan (the 2013 Plan) The 2013 Plan, states that it will be reviewed annually, but it has not been updated since approval in May 2013. Appendix 1, includes the Register of Role holders which details the Organisation Structure Key Personnel, however, this does not reflect the current Council Structure. At the time of the audit, the 2013 Plan was under review. This should be updated to ensure it reflects the current Council structure and revised working practices. Consideration should be given as to what is an appropriate period of review for this document. Failure to comply with the Control of Asbestos at Work, and, Health and Safety at Work, Regulations. Property Services and Health and Safety Team are reviewing the 2013 Plan. It will be renamed as the Management Standard for the Control of Asbestos and will be updated to refer to the job titles of key personnel. Heads of Service will need to make necessary commitment to any changes. Property Services will monitor this every 12 months. Property Maintenance Manager Governance, Risk and Safety Manager 1st April 2026 Medium 2 Managing Asbestos in Buildings The HSE duty to manage asbestos in buildings guidance states that buildings plans should be monitored and reviewed every 12 months or sooner if necessary. The 2013 Plan, Onsite Control of Asbestos Logbooks and Individual Site AMPs, and all associated documents and checklists should be reviewed to ensure that they refer to the above requirement and specify staff roles and responsibility for completion of reviews and monitoring of the ACMs, including risk assessments. Failure to comply with the Control of Asbestos at Work, and, Health and Safety at Work, Regulations. Property Services and Health and Safety Team will include this requirement and make any necessary amendments, while they are reviewing the 2013 Plan, the individual Site Asbestos Management Plans and associated/ linked documents. The updated documents will be provided to audit to evidence completion Property Maintenance Manager Governance, Risk and Safety Manager 1st April 2026 Low 3 Training and awareness raising Gaps in asbestos awareness amongst staff were identified. Testing confirmed this. A pilot scheme providing training to Site Responsible Persons, within Education Services, has been developed and carried out by Health and Safety staff. This has proven successful and is planned to be rolled out across all Council Services. Records of this training should be maintained. Failure to comply with the Control of Asbestos at Work, and, Health and Safety at Work, Regulations. The Pilot with Education dept is now complete. Health and Safety Link Officers will liaise with other Services to develop the asbestos system across council for monitoring buildings and reporting issues. Governance, Risk and Safety Manager 1st April 2026
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13 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 No Finding Risk Agreed Action Responsibility / Due Date Medium 4 Document Retention There is no clear mention of the retention period for the various documents relating to the management of asbestos. When reviewing and updating the 2013 Plan and associated documents/ checklists etc., the storage and retention period should be clearly stated. For completeness, any linked documents referred to, based upon the revised 2013 plan, should be listed to ensure that they are updated/ reviewed any time the plan is revised and vice versa. Failure to comply with the Control of Asbestos at Work, and, Health and Safety at Work, Regulations. Property Services and Health and Safety Team when reviewing the 2013 Plan (and updating to the Management Standard for the Control of Asbestos) and associated documents, will develop a list of linked documents and specify a storage & the retention period for these. Property Maintenance Manager Governance, Risk and Safety Manager 1st April 2026 Medium 5 Roles and Responsibilities There is inconsistent use of the title, role and responsibilities when referring to the member of staff, nominated as the individual Site Responsible Person. Different titles include Site Manager, Head Teacher, Site Premises Manager or Site Responsible Person (SRP). To avoid confusion there should be consistent use of one title. The 2013 plan and associated procedures, materials and information, should be updated to clarify the role and responsibilities of the SRP and include the requirement for a Deputy to be appointed to ensure cover for absence. Council staff may be unaware of their responsibilities in relation to monitoring buildings and reporting issues that may relate to asbestos containing materials (ACMs). Property Services and Health and Safety Team are reviewing the Plan (and updating to the Management Standard for the Control of Asbestos) currently to update and include a consistency in role titles across the various documents. Property Maintenance Manager Governance, Risk and Safety Manager 1st April 2026 Medium 6 Education Management Circular 1.31 This document will need reviewed to ensure it reflects: The HSE guidance that buildings plans should be monitored and reviewed every 12 months or sooner if necessary. Any revision to titles, roles and responsibilities of the member of staff, nominated as the individual Site Responsible Person Retention period for the various documents relating to the management of asbestos. Council staff may be unaware of their responsibilities in relation to monitoring buildings and reporting issues that may relate to asbestos- containing materials (ACMs). School Services Support Manager will update the EMC 1.31 and will liaise with Property Services and Health and Safety Team, who are reviewing the Plan (and updating to the Management Standard for the Control of Asbestos) currently to update and include a consistency in role titles across the various documents. School Services Support Manager Governance, Risk and Safety Manager 1st April 2026
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14 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 No Finding Risk Agreed Action Responsibility / Due Date Low 7 Site Responsible Person Records Services should advise Property Services of any changes of staff nominated as SRP but in practice this does not happen consistently meaning that these records are not up to date. Property Services have in the past issued emails to Heads of Services asking for staffing updates, but due to a lack of response this practice was stopped. Consideration should be given to whether this could be reinstated and where there is no response if this should be escalated to DMT/SMT. Council staff may be unaware of their responsibilities in relation to monitoring buildings and reporting issues that may relate to asbestos- containing materials (ACMs). Property Services will issue emails to Heads of Services asking for staffing updates then enter details into Concerto Commercial Services Admin Officer 30th September 25 Low 8 Mandatory Training Mandatory training for Facility Responsible Persons (HoS), is available on the LEON system, which also records and monitors completion. This does not reference the Site and Premises Manager/ Site Responsible Person role and there is currently no mandatory training for staff appointed to this role. Mandatory training should also extend to these roles and their nominated Deputies to ensure that there is cover for absence. Consideration should be given to this being an annual requirement. Council staff may be unaware of their responsibilities in relation to monitoring buildings and reporting issues that may relate to asbestos- containing materials (ACMs). Mandatory Training will be developed and available on LEON for all appropriate personnel. Deputies will be included Governance, Risk and Safety Manager 30th September 25 Low 9 Duties of the Facility Responsible Person Currently the Duties of the FRP document makes no mention of their responsibilities relating to the management of asbestos. This should be updated to include, the need to appoint an SRP and Deputy for each site/premises and where appropriate, a visual check for disturbances to locations identified as containing or suspected to contain ACMs. There may be benefit to producing a checklist of facility related checks for sites/premises to collate these in one place e.g. fire alarm testing, legionella testing, visual check of ACMs, including the frequency that these are required. Council staff may be unaware of their responsibilities in relation to monitoring buildings and reporting issues that may relate to asbestos- containing materials (ACMs). Property Services and Health and Safety Team are currently reviewing the Plan (and updating to the Management Standard for the Control of Asbestos) to update and include roles and responsibilities for key personnel. Health and Safety Link Officers will liaise with other Services to develop the asbestos system across council for monitoring buildings and reporting issues. Property Maintenance Manager Governance, Risk and Safety Manager 1st April 2026
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15 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 No Finding Risk Agreed Action Responsibility / Due Date There are various site checklists on the hub, these will be reviewed to include Asbestos. In order to assist management in using our reports a system of grading audit findings has been adopted to allow the significance of findings to be ascertained. The definitions of each classification are as follows:
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16 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 Grading Definition High A major observation on high level controls and other important internal controls or a significant matter relating to the critical success of the objectives of the system. The weakness may therefore give rise to loss or error. Medium Observations on less significant internal controls and/or improvements to the efficiency and effectiveness of controls which will assist in meeting the objectives of the system. The weakness is not necessarily substantial however the risk of error would be significantly reduced if corrective action was taken. Low Minor recommendations to improve the efficiency and effectiveness of controls or an isolated issue subsequently corrected. The weakness does not appear to significantly affect the ability of the system to meet its objectives. VFM An observation which does not highlight an issue relating to internal controls but represents a possible opportunity for the council to achieve better value for money (VFM).
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17 Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025 Appendix 2 – Audit Opinion Level of Assurance Definition High Internal control, governance and the management of risk are at a high standard. Only marginal elements of residual risk have been identified with these either being accepted or dealt with. A sound system of control designed to achieve the system objectives is in place and being applied consistently. Substantial Internal control, governance and the management of risk is sound. However, there are minor areas of weakness which put some system objectives at risk and specific elements of residual risk that are slightly above an acceptable level and need to be addressed within a reasonable timescale. Reasonable Internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend, there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system objectives at risk. Limited Internal control, governance and the management of risk are displaying a general trend of unacceptable residual risk above an acceptable level and placing system objectives are at risk. Weakness must be addressed with a reasonable timescale with management allocating appropriate resources to the issues raised. No Assurance Internal control, governance and the management of risk is poor. Significant residual risk and/or significant non-compliance with basic controls exists leaving the system open to error, loss or abuse. Residual risk must be addressed immediately with management allocating appropriate resources to the issues.