Request ID: FOI-2318-2223 Date published: 23 December 2022
You asked
Could the location of asbestos in the station Heathrow Terminal 4 be possibly revealed? In addition, did the Heathrow Terminal 4 loop extension use asbestos materials (the tunnels and whatnot)? If so, where?
We answered
TfL Ref: EIR-2318-2223
Thank you for your request received by Transport for London (TfL) on 12th December 2022 asking for information about asbestos at Heathrow Terminal 4 station.
Your request has been considered in accordance with the requirements of the Environmental Information Regulations and our information access policy.
Specifically you asked:
“Could the location of asbestos in the station Heathrow Terminal 4 be possibly revealed? In addition, did the Heathrow Terminal 4 loop extension use asbestos materials (the tunnels and whatnot)? If so, where?”
I can confirm that we hold the information you require.
Note that due to the age of the Underground, asbestos is found in a number of locations on the network. However, in public areas the vast majority of Asbestos Containing Materials (ACMs) are contained behind station finishes and cannot be accessed by the general public. Where ACMs are found in public areas, they are located where they cause no risk to the general public or staff. All stations are re-inspected on a periodic basis to ensure that no damage has been caused to change this status. If, in the very rare case 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.
TfL 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 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 for reassurance during work on or near to asbestos containing materials.
Turning to your specific request, please find reports attached which show the locations of presumed and known asbestos at Heathrow Terminal 4 station and the Heathrow loop. Note that photographs that appear in the reports have been redacted under Regulation 12(5)(a) of the EIR. This exception applies to information that would adversely affect “international relations, defence, national security or public safety.” The rationale is that the photographs allow the exact location of asbestos to be pinpointed. This information would be of value to anyone looking 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 EIR is regarded as a disclosure to the public at large. As you will no doubt be aware, the transport system in London has been the target of attacks in the past. The information requested contains sensitive information which could be of use for anyone seeking to research or plan for such an attack or to actively cause disruption to the network.
The Information Commissioner’s Office has previously issued the following Decision Notice regarding the security of public transport. Whilst the information requested in this case is different to the information you have requested, we believe the same arguments can be applied:
The use of this exception is subject to an assessment of the public interest in relation to the disclosure of the information concerned. We recognise the need for openness and transparency by public authorities, and acknowledge that there may be some interest in the information in question - as evidenced by the fact that you have requested it. However, as we believe this information could potentially be obtained and utilised by individuals who may wish to use it to cause disruption or harm to London’s transport infrastructure, in this instance we believe that minimising the risk to that infrastructure and protecting the safety and welfare of members of the general public and our staff outweighs the limited public interest in disclosure.
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,
David Wells FOI Case Officer FOI Case Management Team General Counsel Transport for London