Dear Louis Smith,

TfL Ref: EIR-2249-2223

Thank you for your request received by Transport for London (TfL) on 6^th
December 2022 asking for the asbestos survey report for Stanmore
Underground station.

Your request will be processed in accordance with the requirements of the
Environmental Information Regulations (EIR) and our information access
policy. 

A response will be sent to you by 6^th January 2023.

We will publish anonymised versions of requests and responses on the
[1]www.tfl.gov.uk website. We will not publish your name and we will send
a copy of the response to you before it is published on our website.

In the meantime, if you would like to discuss this matter further, please
do not hesitate to contact me.

Yours sincerely,

David Wells

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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Dear Louis Smith,

TfL Ref: EIR-2249-2223

Thank you for your request received by Transport for London (TfL) on 6^th
December 2022 asking for the asbestos survey report for Stanmore
Underground 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.

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 a copy of the report
attached. Note that photographs that appear in the report 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 presumed 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:

[1]https://ico.org.uk/media/action-weve-tak...

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

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