Request ID: FOI-0328-2122 Date published: 03 June 2021
You asked
Dear Transport for London,
please would it be possible to see the Asbestos Survey report for Brixton tube station?
We answered
TfL Ref 0328-2021/22
Thank you for your request received by Transport for London (TfL) on 17 May2021 asking for information about an asbestos survey for Brixton tube station.
Your request has been considered in accordance with the requirements of the Environmental Information Regulations and our information access policy. I can confirm that we hold the information you require.
Please find attached the asbestos survey report for Brixton Underground station as requested. You will note that the report lists a significant quantity of asbestos containing materials (ACMs). The reason for this is that this station was constructed in the 1960’s when asbestos was used extensively within the construction industry. Although a considerable amount of asbestos removal work has been undertaken, the majority that remains is in inaccessible locations with minimal risk of disturbance, such as sealed within wall cavities. This makes full removal impracticable without demolishing the station building.
Asbestos is found throughout the Underground; in Public Areas the vast majority of ACMs are contained behind station finishes and cannot be accessed by the general public. Where areas of ACMs interface with the general public they are in a position where they cause no risk to the general public or staff. All stations accessed by the public and staff are re-inspected on a periodic basis to ensure that no adverse damage has been caused to change this status. If it is assessed and the status has changed for any reason, then a risk assessment is undertaken which will result in either encapsulation, encasement, or removal.
We have processes and procedures in place to ensure that the management of asbestos is carried out in compliance with the Control of Asbestos Regulations 2012. Some of the main requirements that London Underground deliver under this regulation are listed below:
Identify the location and condition of hazardous materials
Maintain an asbestos register with known, presumed or strongly presumed asbestos
Assess and manage the risk of exposure
Prepare, implement, review & monitor the management plan to manage the risks
Regularly inspect known instances of asbestos
Provide information on the location and condition of the material to anyone who is likely to disturb it
Carry out management, refurbishment and / or pre-demolition surveys when required
Carry out airborne fibre monitoring where necessary
Maintain records detailing when and where asbestos is removed, treated and disposed
Request and retain Waste Consignment Note upon transportation of Hazardous Materials to Hazardous Waste Landfill site
Hold relevant Asbestos Management Qualifications
It is London Underground’s policy to continue to safely manage Asbestos Containing Materials (ACMs) in-situ, through continued management surveys, re-inspections, risk assessments and pre-work Refurbishment & Demolition (R&D) surveys. We also carry out airborne fibre monitoring for asbestos as reassurance during work on or near to asbestos containing materials.
Please note that in accordance with TfL’s obligations under the Data Protection legislation some personal data has been removed, as required by Regulation 13 of the Environmental Information Regulations. This is because disclosure of this personal data would be a breach of the legislation, specifically the first principle of the legislation, which requires all processing of personal data to be fair and lawful. It would not be fair to disclose this personal information when the individuals have no expectation it would be disclosed and TfL has not satisfied one of the conditions of Schedule 2 which would make the processing ‘fair’.
Please also note that we have redacted the station layout drawings contained in pages 307-315 (inclusive) of the report as these pages contain information which could adversely affect national security or public safety (in line with regulation 12(5)(a) of the Environmental Information Regulations – which includes an exception to the release of material that would adversely affect the security of public buildings). The redacted information contains detailed diagrams showing the station layout and the location of and access into, non-public areas of the station and its release could place members of the public and TfL staff at risk by highlighting areas on the network which could be susceptible to being targeted by individuals intent on causing disruption or harm to the London Underground network.
In this instance the exception has been applied as disclosure of this information could assist any persons wishing to disrupt London’s transport infrastructure by placing into the public domain information which would otherwise not be available via other means. Whilst we make no suggestion that you would use this information for anything other than you own interest, disclosure of information under the EIR has to be regarded as a disclosure to the public at large.
The application of exception 12(5)(a) has been subject to consideration of the ‘Public Interest Test’ (in essence, consideration of whether the greater public interest lies in applying the exception or in releasing the material in any case). While we appreciate the expectation of transparency from public bodies, in this instance we consider that the greater public interest rests in withholding the excepted material (which is relatively limited) to ensure the security of the site.
If you are considering submitting a further FOI request please think carefully about whether the request is essential at this current time, as answering FOI requests will require the use of limited resources and the attention of staff who could be supporting other essential activity. Where requests are made, please note that our response time may be impacted by the current situation.
If this is not the information you are looking for, or if you are unable to access it for any reason, please do not hesitate to contact me.
Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.
Yours sincerely
Sara Thomas FOI Case Management Team General Counsel Transport for London
