Summing up the FAAM conference, and a look ahead to EAF
Written by Nick Garland on Thursday November 23rd 2023
Last month’s Faculty of Asbestos Assessment and Management (FAAM) conference already feels like ancient history – but at the time of writing it’s all of three weeks ago! Below is a brief look at some of the highlights for me. Broadly speaking, the conference’s focus on new research really summed up what FAAM should be about. As an organisation, we really can bring the structure, independence and academic rigour that can help bind our industry together.
In last month’s newsletter I wrote about an incredible piece of research that FAAM undertook to investigate the viability of a brand new removal method. At the conference, FAAM’s earlier research into the working relationship between analysts and supervisors provided a real highlight.
Cat Holmes, a colleague of mine on the FAAM committee and a consultant at ION in North Wales, gave a groundbreaking talk examining our unique attempt to bridge the gap between two sides of our industry: analysts, and licensed asbestos removal contractors (LARCs), during the period of highest stress and conflict – the clearance of enclosures.
Cat explained the lessons that were learned on the day – the fact that the supervisors can teach analysts a lesson or two in the first stage (completion of the job and condition of the enclosure). But also how the analysts showed their experience in the mocked up second stage (visual inspection), and in particular their ability to find the small things.
The biggest reveals though were the lack of formal training that any supervisor receives in this critical area, or the attention given to it by the Health and Safety Executive (HSE). To my knowledge, no LARC has ever been asked to prove a supervisor’s competence in visual inspections.
Cat outlined that the next step will be another round of workshops, this time focusing on how best to deliver that training. These may possibly lead to joint refresher courses for supervisors and analysts. Professional bodies such as BOHS, IATP, ACAD and ARCA have all expressed interest in sharing in that experience.
A sticky subject
The HSE’s Martin Saunders gave a fascinating talk on the regulator’s research into the effectiveness of control measures in asbestos removal. And there were some very useful takeaways. Despite the site teams knowing the HSE was observing them, time pressures tended to lead to poor practice. In one example methodical removal of asbestos insulation board ceiling tiles morphed into uncontrolled breakage (caught on recorded CCTV footage).
Martin also discussed the use of PVA (the white glue we all remember from primary school) in improving asbestos control. It’s actually been used in asbestos removal for many years, as when diluted and sprayed it can act as a temporary binder or sealant for asbestos fibres. There have always been two uses – one bad and one good.
The first is spraying the enclosure liberally before an analyst starts their visual and air test in the four-stage clearance process. This has been quite rightly outlawed for a very long time, as it prevents the analyst from adequately testing the enclosure. The second is spraying the polythene enclosure walls after the third stage (air test). This is good practice but has largely fallen out of favour for some reason – possibly because it’s become wrongly linked to the former nefarious use.
The reason why it is good practice is that when you dismantle the enclosure after a successful clearance, there is a new exposure risk that can be minimised if an effective sealant is applied to the sheeting. As the polythene is disposed of as asbestos waste anyway, sealing any rogue fibres to it is a good thing.
And that brings me to another point raised regarding the reuse of sheeting. All polythene is considered contaminated waste, and therefore shouldn’t be re-used. This includes airlocks: while they are visually inspected by the analyst, they’re rarely if ever air tested, so they are considered waste even more so than the enclosure polythene.
Sam Lord, also of the HSE, gave a great overview of the ongoing HSE school investigation. I say ongoing, because the regulator is about to start on a new series of inspections. Sam’s talks are always worth catching, as she manages to summarise the key information in incredibly accessible language. Two slides encapsulate that perfectly – the first concerned things that are frequently done wrongly:
- No confirmation that actions are completed
- The location of asbestos-containing materials (ACMs) was not easily accessible or easy to understand by the users
- No photos of the ACMs for location and easy condition monitoring
- Specific roles and responsibilities often missing – as were deputies and contingencies in case of absence
- No clear plan as to how information is made available to emergency services
Staff and Contractors
- In-house staff not aware of the limitations of the surveys – e.g. which areas have NOT been inspected
- No permit-to-work type system for controlling work on site
- Training for staff with assigned responsibilities
The second summed up key messages to all schools:
- Check your asbestos register for clarity – can you find ACMs using the information on the register?
- Does the register reflect actions you have taken?
- Can the register be updated to add new information on condition, risk or remediation work (e.g. a link to certificates of reoccupation following licensed removal)?
- Has the plan been tested with simulations:
- A realistic emergency scenario e.g. burst pipe damaging AIB ceiling
- Something routine e.g. new fire alarm
- Does everyone assigned responsibilities for asbestos management
- know who they are
- know who the others are
- have appropriate training
- understand the asbestos management plan at the school
- Check that everyone who could disturb asbestos at the school knows where it all is, and what to do if it is accidentally damaged.
And finally a teaser for the upcoming European Asbestos Foundation (EAF) conference. Dr Yvonne Waterman of the EAF gave an overview of the current global state of affairs – a sweeping look at the asbestos bans across the world, and legal cases where some are hopefully being brought to account for their, and their companies misdeeds.
Yvonne has also been able to reveal the incredible news that the Dutch government is co-hosting this year’s conference. This means that the World Health Organisation, along with a wide range of member states, will be sending delegates. The keynote speech is by Gordana Materljan LLM. (EU Commission DG EMPL), who was intimately involved in the new Asbestos at Work Directive.
This critical piece of legislation will have impacts on not only the cleanliness of an asbestos enclosure before it is handed back, but also the nuts and bolts of protecting the worker tasked with cleaning it. Can the respirators available on the market today cope with the new limit and the existing methods of removal? Probably not. Do the methods need to change wholesale? Almost certainly.
If the FAAM conference is the first must-attend conference of the year, the EAF is clearly the other. It’s a two-day event, with the main conference taking place in Brussels on Friday 1 December – I hope to see you all there.
Gel Cutting – A New Removal Technique
Written by Nick Garland on Wednesday October 25th 2023
In late 2022 I attended the European Asbestos Forum conference in Amsterdam. This won’t come as a surprise – I wrote about it shortly afterwards, and anyway I’ve been going since the very first conference. In part inspired by EAF, I’ve regularly talked about how important it is for us to look beyond our shores to find new solutions to old problems.
I’ve also talked about how UK asbestos innovation seemed to stop with the introduction of wet injection. Don’t get me wrong: injection – and the huge safety benefit that comes with removing asbestos that is properly suppressed – was a huge improvement on what went before. But for 20 years we have been resting on our laurels somewhat.
That’s why at EAF 2022 I was so interested in BCL Invent, and their product Easy Gel. In layman’s terms, this is a range of shaped plastic pouches filled with gel. The application that sparked my imagination was for cutting cement pipes, where the pouch is secured to the pipe before being cut through. Rather than just suppressing the dust – which it appeared to do – the gel remained on the surface, forming a barrier – separating the worker from the activity.
This is a crucial consideration if we want to improve safety: how do we separate the worker from the activity? It will become increasingly important as and when the European occupational exposure limit (OEL) is reduced by 10- and 50-fold in the coming years.
BCL Invent’s new approach transformed a very direct and personal activity into one that was significantly more remote. The air test results that they were obtaining were also very impressive; less than 0.0048 fibres per millilitre (f/ml) for cutting a cement pipe and <0.0032f/ml when cutting fibreglass-insulated pipe. I asked myself – how would it perform with the very common challenge in the UK of asbestos-insulated pipes?
Wrap and Cut
Of course, there’s already wrap and cut, a similar method which works as follows:
- Wrap the pipe in polythene
- Select cut points
- Inject these cut points with surfactant so that the insulation is locally soft and doughy
- Test to ensure that the insulation has been fully wetted (re-inject if not)
- Start to remove – checking for dry spots (re-inject if there are)
- Remove approximately 150mm of the insulation
The bare section of pipe is then cleaned, the exposed edges of insulation sealed, and the pipe is cut. The whole process is repeated until the entire pipe has been removed.
Wrap and cut has an advantage over cleaning the whole pipe, as it’s safer: there’s less asbestos disturbance, and it’s quicker so there’s shorter exposure. As a bonus, it’s also cheaper.
It has downsides – in particular vibration and noise. Hand-arm vibration syndrome (HAVS) is particularly challenging. A reciprocating saw is so vibrating that the normal limit per person per day is just 15 minutes. There are also several points in the procedure where we expect the worker to stop, check and repeat. It’s therefore understandable that operatives tend to over-inject, reducing the possibility of coming across dry patches – but dramatically increasing the spread of contaminated water.
Easy Gel seemed much simpler, with very few ‘moving parts’. If its barrier approach worked, it could fall into that sweet spot that the original wrap-and-cut method occupied – safer, quicker and cheaper.
A practical test
If it works – but who finds out whether it can? The Health and Safety Executive (HSE) doesn’t approve methods: that’s not its job and it never has been. Innovators should be those creating the hazard. But we operate in a fractured industry where licensed contractors have a lot to lose. And we as consultants have become very risk-averse, guilty of blindly applying and enforcing guidance.
Step up BOHS and FAAM, who are in the ideal position to investigate the safety or otherwise of innovative techniques. We designed a rigorous experiment to examine the hypothesis that the use of a barrier gel would be enough to suppress fibre release.
As a control, we first tested the traditional wrap and cut method. Three cuts were made, which took 57 minutes. The results of the two personals for the cutter were both 0.02f/ml.
Here’s a video of the cuts being made…
I intentionally held the video on the last frame with the cut end visible. If we were relying purely on wetting of the insulation – the clear dry spots would have led to significant fibre release. But we didn’t see this.
Five horizontal cuts were made in a 45-minute period using Easy Gel. The results of the two personals for the cutter were 0.02f/ml and 0.04f/ml respectively. The cutter achieved a further four vertical cuts in a 48-minute period. Here the personals were slightly higher at 0.03f/ml and 0.06f/ml.
Our results confirmed that the key quality of the gel-cut method was the formation of a physical barrier, which prevented fibre release. You can see this in this still frame, which shows the extent of (imperfect) wetting from the gel. Were we relying solely on the gel’s wetting properties, this would have resulted in high fibre release.
While the individual personal results with gel-cutting were slightly higher, we were able to make cuts more quickly, so total exposure was reduced. Another way to look at this is to ask what would happen if more cuts were made.Twelve cuts using the wrap and cut method would take approximately four hours. The same gel cuts would take less than two. Reducing exposure time by 50% would reduce total exposure.
For this test we also used an ALERT constant monitoring device, and the data we received gave us fascinating insight into the fibre release. We could see the distinct cut points as they happened. The wrap and cut method was particularly interesting – giving us peak exposure after the cuts, not during. You can see this in the chart below, where the pink trace shows fibre levels, and particles are shown in green.
So what did we learn? While the results for vertical cutting with gel packs were still low, it’s slightly more difficult to control than horizontal, so they were slightly higher than the horizontal values.
There’s a more significant, if subtle, difference when it comes to HAVS. With a quicker process, workers could make more cuts in a shift, increasing their exposure to harmful vibration. In addition, the cutting technique required the user to keep the foot plate away from the gel pack to avoid crushing it. This in turn leads to less control and more vibration.
There’s a narrower margin for error with gel cutting – effectively the width of the gel pack, rather than the 150mm you get with the wrap and cut method. When considered with the reduced cutting control, this reduced margin for error might be significant.
The increase of the already significant vibration hazard is particularly problematic for the method and must be addressed before it is used commercially.
We observed comparable air test results: wrap and cut at 0.02f/ml, and gel cut (horizontal) of 0.03f/ml. As wrap and cut resulted in an excess of injection liquid leaking out, gel cutting gave a higher degree of control – there was virtually no spread of contaminated gel.
The gel cut process is much quicker. If 12 horizontal cuts were to be made using the traditional method this would take approximately four hours. Using gel cutting would take approximately half this (meaning the exposure in the subsequent two hours would be zero) . Therefore, whilst the test results are comparable, a total exposure or four-hour time-weighted average (4hrTWA) calculation would be approximately 50% of the wrap and cut equivalent.
This increased efficiency could lead to shorter project duration – which would be commercially attractive to clients and licensed asbestos removal contractors (LARCS).
However, due to the commercially attractive nature of the method, the increased vibration and reduced control must be countered before the procedure is adopted. The following currently available solutions should be considered:
- Low vibration (pneumatic) reciprocating saws to reduce HAVS exposure
- On-wrist measurement of HAVS exposure
- Chain clamps to impose a straight line cut (picture depicts the Yokotu pipe saw and clamp)
Whilst the picture shows an uninsulated pipe, these devices are equally usable on wrapped insulated pipes. This approach imposes a great deal of control on the cut and virtually eliminates vibration. This modification should be considered for all uses of reciprocating saws, and would be crucial when considering the new method.
This project shows what a fully functioning, joined-up industry can achieve. The innovators must be the hazard creators, but FAAM can provide the structure, independence and academic rigour to prove a method can work.
I’d like to extend our particular thanks to Ben Ives of Horizon Environmental, for tolerating a research project on an asbestos removal project, and to G&L Consultancy for the analytical work. Special thanks also to ALERT for providing the constant monitoring kit, and last but not least BCL, for modifying Easy Gel for the UK application.
Our thanks also go to the site teams:
Horizon Site Team –
G&L Site Team
Exploring the Asbestos Network guidance on personal sampling and exposure
Written by Nick Garland on Wednesday September 13th 2023
I’ve written several times about the Asbestos Network (AN)’s personal sampling and exposure guidance, and I’m pleased to report that it’s finally been published. You can get a copy from your trade association, from the AN’s new official home on the CONIAC website, or download it from our website.
Like most guidance, this has been a long time coming, predominantly because the AN is mostly made up of members of the technical working group – who are by definition volunteers. This guidance covers a very important topic that as an industry we have struggled with, and it’s been worth the wait. It’s a fairly weighty 21-page document, but the meat of the guidance is contained within seven pages. Overall it’s very much aimed at the licensed contractor – i.e. the sharp end – but it’ll be useful to analysts and end clients too.
So what does it say? Here’s my summary of the main body of the guidance, with the key elements to look out for. Helping companies with exposure monitoring is very much our thing at Assure360, so I’ll also weave in a few tips as to where we can help implement the guidance effortlessly.
Strategy and Policy
This is a great start to the document, examining why we do personal sampling, and exploring tips on how to be as efficient as possible. The main reasons for doing personals are:
- To minimise exposure and check it’s below the Control Limit
- To confirm controls (including respiratory protective equipment (RPE)) are adequate
- To support current and future risk assessments
- To maintain employee exposure records
The AN’s guidance confirms what Assure360 has been advocating for some years: that with a properly designed strategy and system to analyse, a single air test could address all of these requirements.
The starting point of any strategy is clearly the question of what type of job you’re dealing with:
- The asbestos-containing material (ACM) – for example, asbestos insulating board (AIB), sprayed coating or pipe insulation
- Quantity – debris is very different to multiple panels
- The environment – e.g. tight spaces or above head height
- Whether the situation perfectly matches your controls – can you spray, will there be breakage etc?
It might be useful to think about personal monitoring as an audit of a particular removal activity. You don’t audit every site: you select a wide range so it’s representative, and you weigh it in favour of higher risk activities – whether that’s because of the activity itself, or the experience and competence of the staff. Clearly anything new (new technique or new staff) should be in the high-risk category. Another area you should focus on is obviously ones where you are getting higher than expected results.
So target high-risk activities for monitoring first, then when you have enough data on them, broaden out to other areas like set up, fine cleaning, waste runs and enclosure dismantling. Remembering that anything new always goes to the top of the list. Similarly, make sure you cover all workers, with new starters, short-term workers and agency staff getting a particular focus.
A change in focus
What this means in practice is the old strategic approach to get a personal on 40% of all AIB, 60% of insulation, and 100% of ‘flock’ jobs is very much no longer acceptable. You now have to have a strategy for specific activities. Consider the risk presented by AIB alone. Clearly AIB is more risky to remove when it’s nailed than when it’s screwed, or lying around as debris. But now consider the same activities, but with a team of short-term workers you have no experience with.
For years now, Assure360 has followed this approach, with individual targets for all activities. We also have a new feature that focuses this down to individuals – with some staff tagged as needing additional supervision. The combination will allow enhanced rates of auditing and personals where they’re needed. Data is provided by the supervisor’s Paperless App faster than they could have recorded it on paper – and the database analyses it for you instantly.
We rarely get numbers in guidance, but this one is an exception. If you have a small stable workforce, repetitive work and low previous results, a single monthly personal to keep on top of monitoring is considered sufficient. It goes further – if you don’t do any licensed or Notifiable Non-Licensed Work (NNLW) work in a month – no monitoring would be required. The long-term aim of your strategy shouldn’t be to test every employee on every job, but to eventually cover all employees on all activities.
At this point the guidance adds two important notes. When faced with a certificate giving you the results, there will be lots of numbers. Confusingly you’ll be told what the Calculated and Reported results are. For your purposes always use the Reported result.
The second note is when and how to use the protection factor of the mask being worn. You only use these when comparing it to the Control Limit – i.e. the four-hour time-weighted average (4hr TWA).
There are two types of personal monitoring that we all undertake. The main workhorse is the Specific Short-Duration Activity (SSDA). The second is the Four-hour Control Limit compliance check, more commonly known as the Four-hour Time Weighted Average (4hr TWA). The guidance explains both in some detail.
I’ll start with the dreaded 4hr TWA. As I’ve written a few times, this test is less about fibre levels for a particular activity, and more to do with the operative’s exposure over the course of a shift.
If a normal day for your team is:
- build the enclosure (two hours),
- remove asbestos (30 mins),
- fine clean (one hour)
- and assumed nil exposure for the rest of the day
then a single air test that covers all of that would be the perfect 4-hr TWA test. However, it wouldn’t be very good at determining the peak in the middle (removal).
The reason why I call the SSDA the workhorse is that, while it’s principally used to measure a specific activity, the results can be used for all of the purposes laid out in the strategy section above. It can even tackle the 4hr-TWA provided the test matches the World Health Organisation (WHO) criteria: a flow rate of 1-2 litres per minute, and a minimum volume of 240 litres – which may be pooled from more than one sample. For maximum flexibility – if you can move your standard test to two litres per minute (2l/m) for two hours – it will cover most areas and will result in a good limit of quantification. As an extra bonus, Assure360 has long had this parameter built in, so we automatically do the calculation for you.
The guidance calls for close supervision, so that when the activity stops, the test should stop. Going back to the example above, the SSDA test should only be run for that middle 30 minutes of AIB removal. You would need to ramp up the flow rate to close to 4l/m to get a good limit of quantification. The analyst should watch the operative throughout the test, summarising what they did on the certificate – especially if they diverged from the planned method.
Advice for Clients and Analysts
Refreshingly, the guidance now speaks directly to the client, prompting them to consider the role of personal monitoring data in helping them discharge their duties under the Construction (Design and Management) Regulations (CDM).
It also helps us rethink the relationship between the licensed asbestos removal contractor (LARC) and the analyst. Irrespective of who is paying for the consultancy, it’s the LARC that should specify the requirements of the personal monitoring, for example specifying a two-hour SSDA at 2l/min, on James Smith, while removing nailed AIB.
Analytical companies are directed to ensure analysts have the right equipment, and that they’re competent to undertake the test. This seems obvious, but it is definitely not just LARCs who have historically struggled with personal monitoring. The Faculty of Asbestos Assessment and Management (FAAM) recognises a poor level of competence in this area, and is looking at how it can improve the skill set across the board.
The guidance also states (in bold!) that analysts must always provide full PM results directly to the LARC as soon as possible after the collection of the sample via either hard copy or electronic means. It also states: “Failure to supply this information might be a breach of the analyst organisation’s duty under Section three of the Health & Safety at Work etc. Act 1974.” So, LARCs should no longer have to hear ‘This is the client’s data, I can’t give it to you’.
Analysis and Review
A LARC is expected to review all personal monitoring reports on site and extract management information from the data.
There are two PM thresholds above which we need to do something. The first is when the result is above what the mask can deal with. This is a combination of the assumed protection factor (APF) of the mask and the control limit (which is 0.1 fibres per millilitre of air sampled (f/ml)). The APF is 20 for a half-face mask, 40 for a full face, and 2000 for a respiratory airline supply (RAS) mask. Therefore:
- Half mask – 20 x 0.1 = 2f/ml
- Full Face – 40 x 0.1 = 4f/ml
These are clearly shockingly high results. If you got them, your instinct to stop work immediately and investigate would obviously be the correct course of action.
It’s worth noting that in Europe they are going to reduce the occupational exposure limit (equivalent to our Control Limit) to 0.01f/ml, so the above numbers would become 0.2f/ml and 0.4f/ml. I think the goal here was always to reduce the exposure faced by normal (non-asbestos) workers. However, when these same numbers are applied to removal activities, we’ll have to reassess whether our methods and RPE are capable of meeting them. It’s also worth noting that, while European law no longer automatically applies to the UK since Brexit, on this, we’ll most likely be forced to follow suit. Watch this space.
The second threshold is when PM results are significantly (the guidance says 25%) above your anticipated level. In this case you need to investigate and review the method if necessary.
Prompt investigation underpins everything – identifying (ideally immediately) if a test is elevated, and then establishing why. This then allows you to do the next steps that the Health and Safety Executive (HSE) requires:
- Improve methods
- Drill down and compare operatives conducting the same activity.
- Trend analysis
Assure360 does indeed make all of this simple. We alert the supervisor when the reading is above the mask capacity, and management are informed instantly if either threshold is exceeded. We also have reports that compare and contrast data for individual operatives, and trend analysis is on all of our dashboards.
Required uses for personal monitoring
The guide details specific, required, practical uses for personal monitoring:
|Estimation of exposure
||This is a section that has been long included in competent method statements, but the guidance looks for a little more detail than is perhaps in some documents: a breakdown into activities. Therefore include pre-clean, enclosure construction and fine cleaning in monitoring strategies, as well as the removal phases. You of course get this data from analysing the personal monitoring that you have previously conducted.
The guidance says that industry figures can be used as a starting point for new activities. Assure360 gives you benchmarked access to over 28,000 personals that have been recorded on the system.
||This is the written (or digital) record of the personal sampling/air monitoring required in the regulations. The actual detail is in para 482 of the Approved Code of Practice (ACOP), and it’s reproduced in the guidance.
It should be noted that this does not need to be one document, and it can be stored in more than one system.
|Record of each test
||The ACOP also requires you to keep a suitable summary of test results for each individual, so that average exposure for individuals and different activities can can be accurately estimated. It suggests a spreadsheet document(s) or a database.
||You must maintain health records for all employees, whether directly employed, short-term or agency.
Other than names, medicals and other information as detailed in the guidance and the ACOP, you must record the work carried out, location, dates, duration (hours per week), and the RPE used. Records must be kept for 40 years or until the employee is 80, whichever is longer. Therefore, the records of a 20-year-old short-term worker employed for one day must be kept for 60 years, not 40.
Recording, calculating and displaying all of this data is complex. While it’s possible to create spreadsheets for the job, we’re really at the stage where a database is needed. There are many database programs out there that will allow you to create the analytical systems that the new guidance demands. But there is only one in which the systems are already built for you, and where they’re linked directly to the supervisor and to management teams.
Assure360 Paperless is designed specifically for the average supervisor, shaving hours off their daily admin duties. They’re able to record all of the data needed for this analysis faster than they could have written it down in the first place, and it’s transmitted directly to a database that has the power to analyse it as the HSE wants.
Not only does the system capture and securely store all the required safety and monitoring data, it uses it to give you far greater insight into the way your asbestos removal projects are running. At a glance, you can see how each job is progressing, and use reports to identify training needs. It’s not just a way to stay in compliance with the guidance: Assure360 gives you huge practical benefits that improve safety and quality, and save you money.
We’re always happy to show people how our system works, and how it can benefit every aspect of their business. If you’re interested in a free demo, and a free pilot, please do get in touch.
It’s asbestos, not just RAAC that schools need to be concerned about
Written by Nick Garland on Friday September 1st 2023
The announcement from the government that multiple schools will have to close or partially close due to the long known presence of RAAC has further ramifications. Reinforced autoclaved aerated concrete or RAAC was used extensively in public buildings between the 1950s and the 1990s, for those of you that know your asbestos prohibition dates – this is the ‘heyday’ of asbestos use.
Asbestos is frequently hidden in the structure of the building, and can take weeks of planning and careful removal to find and address. In buildings of this vintage, such an issue will be highly likely. This additional delay could extend the school closures, potentially to months. But that is not even the main issue – the urgency of the RAAC question, might lead schools to overlook the asbestos question entirely.
The recent Department of Work and Pensions Select Committee report (April 22) highlighted the specific risk of asbestos in schools. ResPublica have recently stated that 80% of schools contain asbestos. The recent study paper by the National Organisation of Asbestos Consultants (NORAC) and the Asbestos Testing and Consultancy Association (ATaC) has similar figures, with 78% of the buildings they looked at having contained asbestos.
Following the select committee report, the HSE visited 421 schools to inspect their compliance with the regulations. 140 were considered to be falling short and received letters from the HSE instructing them on improvements that were needed in their management of asbestos. Of these, 27 received improvement notices (legal instruction for mandatory specific improvements), and one a prohibition notice (not to enter their boiler room until asbestos was removed). Whilst 33% non-compliance will not be a surprise to the industry, it should be seen as a worryingly high figure.
The Cliff Edge
I recently wrote about the cliff edge the country is heading towards in the race to net zero and the lifespan of system built buildings – deadlines a few years off. Now there is another ultra urgent deadline – repair or replacement of these RAAC structures so the schools can re-open. That is an awful lot of construction work that needs to be done immediately on buildings with clear potential to contain asbestos. The pressing and very public urgency to fix the RAAC problem might overwhelm other considerations – and in particular the asbestos risk.
HSE’s recent findings confirm what has been long suspected, that the model of manage-in-situ is not working well in schools. If the asbestos risk is overlooked now and not factored into the emergency, this latest crisis could be made even worse.
Asbestos, construction and safety events calendar
Written by Nick Garland on Thursday July 27th 2023
Conferences, events, meetings and other get-togethers are the lifeblood of specialist sectors like construction, health and safety, and asbestos. Every one is a chance to make contacts, learn from the experts, and share your own insight and experience. Here’s our list of all the essential meetings, briefings and other dates for your diary.
ARCA regional meetings
7 – 30 November 2023
Regional locations & online
ARCA’s third round of meetings take place at regional locations throughout November. They end with a Zoom-only meeting on the 30th. Click the link below for full details and to register your place.
Find out more
The European Asbestos Forum conference
30 November-1 December 2023
Hotel Marriott Grand Place, Brussels, Belgium
Regular readers will know how highly we rate the EAF conference, and this year it takes place in the historic heart of Brussels. As always, we eagerly await more details of this year’s programme and speaker lineup, but expect a broad church of the sector’s most experienced regulators, removalists, scientists and innovators – together with charities and other organisations representing those who’ve fallen victim to asbestos diseases. There’s also an asbestos photo exhibition by renowned photographer Tony Rich.
Find out more
Personal sampling and exposure webinar
16 January 2024
The Asbestos Network’s personal sampling and exposure memo is the first official guidance the Health and Safety Executive has provided on the subject, and it contains major departures from how contractors traditionally approach it. We’re hosting a free webinar to talk in detail about the changes that the guidance demands. We’ll be exploring practical steps on how to implement them, and demonstrating how you can use Assure360 to achieve full compliance – at the same time as saving hours of work for both your supervisors and admin team.
Booking link to come soon!
Safety, Health and Wellbeing Live – Manchester
23-24 January 2024
Manchester Central, Manchester
Safety, Health and Wellbeing Live (SHW Live) takes place twice a year, from bases in Farnborough and Manchester. Like its southern sibling, the north of England show aims to reconnect regional occupational safety and health communities. It’s set to offer essential educational, networking and procurement opportunities across two days. This free, live event promises the chance to speak to industry experts, learn about the latest innovations and build direct relationships with key suppliers.
Find out more
IOHA 2024, 9-13 June 2024,
9-13 June 2024
The Occupational Hygiene Society of Ireland (OHSI) and the British Occupational Hygiene Society (BOHS) are privileged to jointly host the 13th IOHA International Scientific Conference.
The conference theme has been confirmed as – ‘Protecting workers from health hazards: Advancing in this changing world’. The conference aims to promote occupational hygiene and worker health protection by the minimisation of worker exposure to hazardous agents globally through plenary sessions, keynote lectures, parallel talks, workshops, and poster presentations, as well as networking opportunities and social functions.
You can find more information and book your place here.
The Safety & Health Expo (2024)
2-4 December 2024
The Safety & Health Expo’s December 2024 dates come 18 months after the 2023 show, so there should be plenty to catch up on. It’s an unusually late slot for a major conference, and likely to come near both the FAAM and European Asbestos Forum conferences – we hope the dates don’t clash!
The Safety & Health Expo bills itself as the biggest exhibition in the field. Expect strong opportunities to learn, network, and find health and safety solutions for your business.
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If you’re hosting, postponing or cancelling an event you’d like us to list here, please get in touch.
Asbestos in schools: is the awareness building?
Written by Nick Garland on Wednesday July 12th 2023
The Times is turning into a real champion for those of us who want to change the UK’s approach to asbestos. The paper has kicked off a new – and extremely welcome – campaign to eradicate asbestos from schools [paywall], launching it with another excellent article.
It’s fantastic to finally see the issue getting some mainstream coverage. You’ll probably remember that I’ve written before about asbestos in schools. I think it’s an issue that many of us in the industry feel increasingly strongly about.
It’s instructive to remind ourselves as to the Health and Safety Executive (HSE) advice to schools regarding asbestos. They must:
- Keep an up-to-date record of the location and condition of asbestos-containing materials (ACMs) in the school
- Assess the risks from any ACMs in the school
- Make plans to manage the risks from ACMs in the school
- Put those plans into action
In a school setting, those most at risk of disturbing ACMs are tradespeople, caretakers and others who work on the fabric of the building. The school’s plan needs to contain provisions to ensure that they have information about the location and condition of ACMs. The duty-holder should also ensure that any staff likely to disturb asbestos are suitably trained.
As I’ve pointed out before, this is essentially the same advice that applies to any other employer, and any other workplace: manage the ACMs in situ. But schools are unique.
In law, a school is a workplace, but the majority of people using them are children – sometimes as young as three. Despite the known vulnerability of children to pollutants, contaminants and other environmental hazards, when it comes to asbestos, schools are treated like any other workplace: they’re subject to workplace asbestos fibre limits, regulations and management approaches. And that’s a problem – both for our children, and the professionals who teach them.
The Times’ article brings together lots of stats that, when read together, paint a very stark picture of the current situation. Figures gathered by the National Union of Teachers’ Joint Union Asbestos Committee (JUAC) reveal that, since 1980, around 400 British school teaching professionals have died of mesothelioma, the cancer almost exclusively linked to asbestos exposure. An average of 19 school teaching professionals now die each year from mesothelioma – up from three per year in 1980.
This is likely to be an underestimate, as occupation is not stated on the death certificate of those over 75 – which is the age group accounting for most victims of this horrible disease. To my mind, the real figure could even be double or triple this number.
Research by the US Environmental Protection Agency estimates that for every teacher that succumbs to the disease, a further nine pupils will go on to die from mesothelioma in later life. The JUAC estimates that as many as 10,000 pupils and staff have died to date due to exposure to asbestos in schools.
A unique challenge
Why is asbestos such a serious problem in schools? Aside from the particular vulnerability of pupils to the substance, the UK has a major problem with how widespread ACMs are – and also with the poor state of repair that some school buildings are in. More than this, schools are under budgetary pressure – heads are thinly spread as it is.
In 2018, the government asked schools to provide information on asbestos in their buildings, through the Asbestos Management Assurance Process. In 2019, AMAP reported that 80% of schools contained asbestos.
In addition to this, the National Audit Office has estimated that 24,000 school buildings are beyond their design life. Nearly two-thirds of these are the system-built buildings that so frequently contain asbestos. Last year the Department for Education revealed that there was a risk of the collapse of one or more blocks in some of these schools.
A recent Freedom of Information request by JUAC to 60 of these system-built schools revealed that nearly half did not have an “up to date” asbestos survey, and two-thirds had not identified where all of the asbestos was.
In an ordinary workplace, the HSE’s ‘manage in-situ’ advice can work very well. Surveyed, recorded and managed properly, ACMs should pose no risk – provided the management plan ensures that they remain undisturbed. Proper management starts with a management team that has the training and experience to properly understand the risk, and design and implement appropriate controls.
The Times’ article brings together a body of evidence demonstrating that, for schools at least, this is not working. Headteachers have been unreasonably forced into the role of duty holder, responsible for management of asbestos in their schools without adequate training, support or budget.
When you add in the fact that the majority of the school population can’t be considered competent around asbestos, and the complication that we don’t know the true scale of the problem, it is not surprising that the system isn’t working.
If management in-situ doesn’t work for schools, the only answer is surely the phased removal called for in the excellent Work and Pensions Committee investigation and report. As I have written before, the government rejected the report’s key recommendation to remove all asbestos from public and commercial buildings, and this is where the Times is taking up the banner for schools, with its five-point plan:
- A 40-year programme to remove all asbestos
- National register of properties
- Make access to this information easy for those most at risk – via an App and online digital register
- Regular air testing in buildings that contain asbestos
- Minimum standards of training for those in charge of managing asbestos
The paper’s campaign has already gained support from significant political figures including Nadhim Zaharwi , Alan Johnson and Matt Hancock, who between them have formerly held the roles of Chancellor, Education Secretary, Home Secretary and Health Secretary.
The Times clearly doesn’t want to let this lie, and I applaud it for that. Its launch article ends by asking if you have been affected by asbestos. If you have, email the paper at email@example.com.
Overhauling the four-stage clearance
Written by Nick Garland on Wednesday July 12th 2023
You may have read about my recent experience in organising the Faculty of Asbestos Assessment and Management (FAAM)’s first four-stage clearance (4SC) workshop. The event produced a trove of information that we can feed back into the faculty conference, and ultimately into better, joint training for analysts and asbestos supervisors. But since the event, I’ve also been keen to use the insight we gained to make sure Assure360 is making the 4SC as straightforward as possible for everyone involved.
That’s why we’re embarking on a complete overhaul of the enclosure 4SC process on the industry-leading Assure360 Paperless app. The aim is to make it a lot clearer to supervisors and analysts, streamline the whole process, and use our learnings from the FAAM joint workshop to make it less confrontational and encourage team effort.
At the same time, we’re also starting an industry-first research project. By harnessing the power of the data management that comes as standard with Assure360, we’re trying to identify the underlying reasons behind whether an enclosure passes or fails the 4SC.
Our new-look process will record not just passes or fails, but the stage at which the enclosure failed:
- Stage 1 – this is the normal enclosure and assessment of scope completion
- Stage 2 (Initial Assessment) – this is a little-understood stage where the analyst enters the enclosure for their preliminary review. The analyst only looks at main / obvious areas, which might result in an early failure
- Stage 2 (Full Inspection) – this is the normal analyst’s visual that we all know
- Stage 3 – the air test
- Stage 4 – the post-completion test, decontamination unit and transit / waste routes
Assure will also include a statement from the analyst as to whether they were familiar with the scope and project in advance. This should help with understanding the impact of involving or not involving them in the planning stage.
Crunching the numbers
These are all fairly routine data points to collect, but where Assure360 can go further than any other is by cross-referencing them with other data. Examples of where we can do this include:
- People – the system knows which individuals are working on a project, and whether they’re full-time employed or short-term workers (STW). It also knows the year they started with you, and the year that they started in their role (supervisor or operative). We can therefore investigate such factors as the percentage of STWs on the project team, and the team’s overall experience, tenure with your organisation and so on.
- Distance – again the system knows where the project is, so analysis could reveal whether distance from home base has an impact.
- Anticipated duration of work in the enclosure – this will let us examine large projects down to micro ones, and compare the plan with how long it really took.
- What were you removing? – the type of ACM, fixing and the task could all have an impact.
- Management influence – everything can obviously be cross-referenced against the supervisor and the contracts manager.
Like everything we do at Assure360, the number crunching will all be done in the background, and the insight presented to you in handy and easy to use reports. There’ll be absolutely no additional effort needed on your part.
We’re particularly keen to harness the vast expertise of our community of users, so please let us know what other factors might have an impact on the success of a project. We’d really appreciate it if you email your input to us on firstname.lastname@example.org
Assure360 is the industry standard – if you are yet to experience the only productivity tool designed specifically for the asbestos removal industry, please contact us here, or email us on email@example.com
Celebrating our 15,000th audit
Written by Nick Garland on Wednesday July 12th 2023
Ours is a small industry, so I’m incredibly proud to report that last week we hit a huge milestone: the 15,000th audit completed using the Assure360 system. This particular audit was recorded by Asbestech, one of our longest-standing community members.
Clearly audit information is 100% confidential, but I’m sure Asbestech won’t mind me sharing that it was an unannounced ARCA perfect, A-rated audit that was translated onto the system.
This is an important feature of Assure360. Translating all of their ARCA audits to Assure360 has allowed Asbestech to benefit from the independence that a trade-body audit gives them – but also harness the power of the Assure360 management system. Not only do the ARCA audits now inform Asbestech’s compliance processes, they also contribute to training needs, trend analysis, and even drive the agenda for supervisor meetings
While we believe that the Assure360 Audit 3.0 App is the best on the market by a country mile, Assure360 itself is an all-encompassing health and safety management system. Crucially, we are not protective, or prescriptive as to where the data comes from. The Audit 3.0 App syncs findings directly to your dashboard in seconds. Translation of an ARCA (or ACAD) audit takes approximately five minutes.
Either way, the benefits you get by using the most powerful analysis system are incredible. We even allow independent auditors to use the app completely free of charge. It’s an expression of the underlying principle of what we do at Assure360: simply to help you manage all the information you have in the most efficient and productive way.
“We’ve been a long standing client of the A360 auditing suite; we find it both simple to use to conduct audits and simple to use to interpret the audit findings from all parties. The dashboard and report generating tools allow us to cascade learning points through our business very quickly.”
“It covers just about everything you could want on an asbestos audit, along with general health and safety. I think it’s industry standard. It’s the benchmark we should all be working to.”
D & N Asbestos Advisory Services
“There’s a benefit to auditing based on a consistent process. Fundamentally it means you can’t forget to do something – either on site, or when writing up the audit. With Assure360 it’s got that consistency: the layout’s the same, the information is the same. It’s easy to follow, and it’s easy to identify needs in operatives as well.”
Discover how Assure360 and the Assure360 Audit app could improve your management, understanding and planning of asbestos removal. Get in touch today to learn more or book a free demo.
Reducing the asbestos exposure limit: a tough act to follow
Written by Nick Garland on Thursday June 22nd 2023
I’ve previously written about the ongoing standoff between the European Parliament, EU member states, and the European Commission regarding the exposure limit for asbestos. Well, that standoff is set to enter a new phase at the upcoming interinstitutional talks with the European Council.
To recap, the Commission has proposed a reduction in the exposure limit of asbestos at work to 10 times lower than the current value. That would mean reducing it from 0.1 fibres per cubic centimetre (f/cm³) to 0.01 f/cm³. But for the European Parliament’s employment committee (EMPL), this is not enough – they are insistent on a 100-fold reduction, to 0.001 f/cm³, after a transitional period of four years.
In the UK there isn’t an exposure limit for asbestos, but it’s analogous to our Control Limit, which is also 0.1 f/cm³. We have another limit called the Clearance Indicator. That’s the level that an asbestos enclosure must pass before it can be handed back, and that’s set at 0.01 f/cm³.
The lines are fairly firmly drawn with the EU ministers of employment setting out their position in early December last year, which was to agree with the Commission’s 0.01 f/cm³ proposal. But Danish MEP Nikolaj Villumsen wants the Parliament to keep its stronger position.
“Sadly, we know that some member states are satisfied with a limit value 10 times as high as what we propose, with outdated methods of measuring and less stringent approaches to training and certification,” he said. “This is what we will be up against next.”
This matters to the UK because, if the EU reduces its exposure limit, it will be very difficult for us not to follow. But I’ve previously touched on a more fundamental problem if the limit chosen is 0.001 f/cm³. There’s currently no equipment or testing technique available that can do personal monitoring tests at these levels. The technology simply isn’t ready to support them.
Furthermore, the masks that asbestos removal workers use have a protection factor of 40. This would mean that to stay within the lower 0.001 f/cm³ exposure limit, any method used to remove asbestos must not release concentrations above 0.04 f/cm³. I’m not aware of any working method that would reliably achieve this.
There are two things at play here: what is safe to hand back to the normal users of the property, and what’s safe for the workers actually removing asbestos in enclosures. It’s concerning that the implications to asbestos removal appear not to have been thought through.
It’s vital to protect workers and other users of the built environment, and I can see a lower exposure limit is a positive move. More stringent cleaning and more accurate testing will be able to achieve this. But, how will these new levels affect the removal operatives themselves? Protection technology improves all the time, and perhaps the lower limit will force some kind of breakthrough, but in the absence of that it’ll be a hard limit for the industry to meet.
The Retained EU Law Bill – is sense prevailing at last?
Written by Nick Garland on Thursday June 22nd 2023
You might have already read or heard my thoughts about the Retained EU Law (REUL) Bill, which is making its way through parliament. If you’re not familiar with it, it’s a piece of Brexit legislation that aims to bring into UK law regulation that has its origin in European law. While it’s seen as a crucial step by those who want a stricter interpretation of ‘Brexit’, the bill as originally set out had huge and manifest problems.
First of all, REUL covers a vast amount of legislation – the current count is that it affects approximately 5,000 laws, and (terrifyingly), nobody seems to know exactly how many. It includes such critical and effective regulations as the Control of Asbestos Regulations.
The biggest issue with this is that the bill contains a sunset clause, which would essentially provide that, unless an individual piece of law is ported over to UK law or re-written (a mammoth task), then it will disappear at the end of the year. If this clause survives unchanged, the prospect of accidentally losing vital legal mechanisms is very, very real.
So it was some comfort when I came across a fantastic article published by the Institute for Government last month, which brought to my attention the significance beyond the headlines of a statement by Business and Trade Secretary Kemi Badenoch.
There seems to have been an outbreak of sense in the approach to the REUL, inasmuch as Rishi Sunak and Kemi Badenoch “have agreed to ditch the sunset from the bill and instead provide parliament with a list of all REUL the government intends to repeal.” It will now be these selected laws that disappear automatically at the end of the year, rather than all EU based laws.
It will still be a mammoth task for legislators to unpick the long list of regs that are disappearing – but at least the immediate risk of oversights and mistakes, has gone away.
As the Institute for Government article also recognises, the wording of Badenoch’s statement, suggesting a much more sensible approach to regulatory reform. Words such as “proper assessment and consultation” make a welcome appearance, for example.
However, a concerning element of the amended REUL is that in the original legislation, only the Supreme Court could depart from established EU case law, but the bill now effectively opens the way for any court to do it. That leaves a legal avenue for anyone who did not like a decision under EU law. The government is also giving itself a permanent power to amend REUL under the bill, without any additional commitment to consultation or proper parliamentary scrutiny.
In this matter, the House of Lords has done a great service to the country, forcing the government to address the unrealism and risks of its self-imposed deadline. But there are still big question marks over the amended approach – and more work to be done.
Summing up the ACAD awards dinner and golf day
Written by Nick Garland on Thursday June 22nd 2023
The ACAD awards dinner and golf day has been and gone, and I have to say it was another triumph. Graham Warren managed to organise excellent weather – a trick he seems to repeat every year.
I don’t golf personally, but apparently it was very tricky – a local golfer told me ominously that the course wasn’t long, but that ‘it defends itself’. Our Phil Bowen, who was on a team with Ashley from SAR, returned a very creditable three under par. We didn’t get close to any of the prizes though.
Back at the hotel, Sam Lord of the Health and Safety Executive presented a technical update on the regulator’s workings. She shared interesting previews of the Asbestos Network technical working group’s focus for this year. The personal monitoring and health records guidance that I wrote about recently is due to be finalised at the next meeting.
After that the most interesting new piece is guidance for supervisors on the four-stage clearance and doing visual inspections. This is partially informed by the excellent work that FAAM did with the joint analyst and supervisor workshop in the spring. FAAM is planning another workshop, probably in the autumn, I am sure we will be sharing the lessons from that to support improved guidance in the same way.
Assure360 had the honour of sponsoring the Excellence in Audit awards again. The awards go to all members that received a 100% audit – which is impressive to say the least. There is a further award that goes to the team that has a very high standard, but also excels in best-practice innovation on site.
I had the great pleasure of presenting trophies to Amianto, MSS, Omega and Westcross on the night. Other winners not able to make it for the presentation were:
- Countrywide Environmental Services
- DCUK FM
- Fleet Insulation Company
- Greenair Environmental
- Integral Environmental Solutions
- Multi Discipline Solutions
- Rainham Industrial Services
Congratulations again to all winners. It’s a joy to be acknowledging and celebrating their thorough and exemplary work.
John Barnes was excellent as the after-dinner speaker. He always was a very thoughtful, considered and entertaining sportsman, and in his speech he was able to weave his very interesting life and career into revealing observations on running businesses. He clearly remembered his time at Watford with great fondness, and came out with the amazing fact that Graham Taylor took the team from the old fourth division to top-flight runners-up in just five years. More importantly, the team that finished second to Liverpool that year was 80% the same as the one that started that first season at the bottom.
As I say, a thoroughly enjoyable day and evening, but there was one sadness to it all. Mavis Nye was due to present the Supervisor of the Year award, but unfortunately illness prevented her. I am sure Mavis is in all of our thoughts, and I hope that her sheer determination wins through again in her fight against this horrendous disease.
Approaching the cliff edge – unknown asbestos
Written by Nick Garland on Tuesday May 16th 2023
The Times recently carried a special report on asbestos (paywall). Steve Boggan’s excellent article was a rare example of a detailed, thoughtful, well-researched and intelligent piece of writing on the subject in the mainstream press. Without the unscientific scaremongering that is so often peddled out, this piece told the unvarnished reality – which frankly should be scary enough.
Boggan interviewed several sufferers and family members. These included Wayne: an HGV mechanic, Grace: a retired teacher, and Garry: who recently lost his wife Debbie to the disease. While their stories are all different in the detail of their unfairness and tragedy, they all share a central core – the fact that they didn’t know that they were being exposed.
The article discusses the recent Department of Work and Pensions Select Committee report, and focuses on the two main recommendations that would address this ignorance. These were a national register of asbestos, so we know where all of the material is, and a plan to remove it all. Both have been rejected by the government.
Boggan quotes the prominent campaign group ResPublica who state that 90% of hospitals and about 80% of schools contain asbestos. The recent study paper by the National Organisation of Asbestos Consultants (NORAC) and the Asbestos Testing and Consultancy Association (ATaC) has similar figures, with 78% of the buildings they looked at having contained asbestos.
I don’t know how accurate the ResPublica figures are, and I know the NORAC/ATaC piece was only a snapshot, but in part that’s the point: no one has an authoritative overall view of how big a challenge we have.
The Cliff Edge
As a country we are heading towards two impending cliff edges. The first is that many of the schools and other structures that contain asbestos have a light steel frame construction. These have a design lifespan of 40 years, and we’re at least 10 years beyond that now.
The second is Net Zero. If we’re going to achieve this, there’ll be an awful lot of building work required.
Between these two massive construction challenges, many of the buildings we currently use are either going to be demolished or heavily refurbished in the next few years. Without knowing how big the asbestos problem is or having a national removal plan in parallel, it would be human nature to lose sight of the issue.
Many still see asbestos as a problem we fixed long ago. It’s still there, though, just not widely known or understood. The climate emergency, by contrast, comes with a very pressing and public deadline. But if we don’t get the asbestos plan right, it seems inevitable that the rush to Net Zero will lead to an avoidable spike in asbestos exposure – and it could be centered on the schools and hospitals used by the most vulnerable in our society.
Asbestos in cosmetics – why are we still using talc?
Written by Nick Garland on Tuesday May 16th 2023
Another great asbestos article by the Times (paywall), this time on a subject I’ve raised a couple of times in the past – asbestos exposure from makeup. Katherine Quarmby and Andrew Ellson’s story reveals that over 100 British women suffering from mesothelioma are currently taking on American cosmetic giants to get compensation.
A bit of background. Talc is a mineral that is mined out of the ground. What is not so widely known is that it’s chemically fundamentally the same as asbestos. The mineral develops into asbestos or talc according to slightly different geological conditions. In fact most talc mines also contain asbestos deposits and some fibres even start at one end as talc and end up asbestos. The low-tech nature of mining for talc has inevitably led to contamination of the supply chain.
What’s also not so widely known is that talc is not just sold as talc and in baby powders. Many brands and types of makeup use the mineral as a key ingredient. In fact you’ll be hard pressed to find eye-shadow, foundation or blusher that doesn’t contain it.
The article highlights that the latest UK statistics showed a 7% increase in women being diagnosed with mesothelioma, a faster rise than in the previous eight years. New cases in women have doubled since the early 1990s, while they’ve ‘only’ increased by about half in men.
The Times doesn’t draw a direct line between these alarming numbers and makeup, but the latest HSE statistics indicate that only around a third of female diagnoses are linked to occupational exposure, or living with a partner who was exposed.
It does seem the potential for asbestos contamination in talc has been known by these companies for decades. But setting that to one side for a moment, we certainly know it now, and we know that talc in makeup presents a health risk. Whilst we haven’t yet quantified the level of risk, the regulations state that there shouldn’t be any. There are safe and cheap alternatives, such as corn starch. Which begs the question: why does talc’s use persist?
An update on the Asbestos Network monitoring guidance
Written by Nick Garland on Wednesday April 12th 2023
Regular readers might remember that, last summer, I wrote a summary of the monitoring, health and exposure guidance that the Asbestos Network has been working on since 2019. I’m reliably informed that, with a fair wind, this guidance will actually be released this summer.
I’m aware I’ve said this before, but the latest draft has come quite a long way since my last review. Now it really does feel like it’s nearly there, but this also means that it’s worth revisiting – as a lot has changed.
I’m going to cover the main points in this update to my previous review, but I strongly suggest you give the original a read. It’s also worth providing your feedback through the trade organisations, as there’s still time for your input to help shape the outcome.
In this review I’m going to highlight how Assure360 users are already prepared. Essentially, this new industry best practice has been Assure360 standard practice for years. It’s all powered by Assure360 Paperless, which is both compliant AND massively more efficient than using Excel and paper.
Since my last review, the guidance document has been honed down to eight pages, plus appendices. The Asbestos Network recognises that this is first and foremost a communication piece for licensed contractors, and by focusing on that audience it does the job well.
That said, there are nuggets for clients, which give the guidance a wider reach. The likes of FAAM will be looking at it closely in their attempts to investigate and improve the personal monitoring skill set of analysts.
The first couple of pages set out the what and the why. The ‘what’ summarises the tests that need to be done. It’s now been honed down to a simple four-bullet list:
- Four-hour Control Limit Time-Weighted Average (TWA)
- Specific Short-Duration Activity (SSDA)
- Ten-minute Short-Term Exposure Limit (STEL)
- Assessment of suitability of Respiratory Protective Equipment (RPE)
Those who need more detail can find it in the appendices, but two tests are picked out as being key, and these get a bit more detail within the main body of the guidance. Not surprisingly, these are the 4Hr TWA and the SSDA tests that I’ve written about before. As a reminder, here’s my analysis of the techniques:
Specific short-duration activity (SSDA) Monitoring
This is the workhorse test that you will use most of the time. It’s used to test a specific activity. The guidance talks about the importance of really focusing on the individual task. To this end it stresses that it’s no longer good enough to, for example, talk about removal of asbestos insulation board (AIB) – now you need to detail the fixing too. An example given is breaking out a single AIB panel, followed by fine cleaning. This should be viewed as two separate tasks, and either you should test them separately, or prioritise the high-risk element.
As the purpose of the test is to examine an activity, you are allowed quite a bit of licence. The flow rate (how hard the pump is working) should be between two and four litres per minute, and the minimum volume tested should be 120 litres. These recommendations are very much intended to ensure you get a decent limit of quantification.
Four-hour time-weighted average (4Hr TWA)
The dreaded 4Hr TWA should be far less opaque if you’ve read my previous articles on the subject. Its main purpose is to discharge your duty to ensure workers are not exposed above the Control Limit (after taking into account the mask protection). Essentially, if an employer causes an operative to be exposed to asbestos, we should be able to tell them accurately how much they have been exposed to. The testing rules are set internationally, so the results can be accurate and comparable.
As 4Hr TWA is all about the person, rather than the activity, it can’t be used to populate the SSDA data. However the reverse is not true – if you select test parameters that comply with both, then you will be able to satisfy both duties in one. In short – if your default SSDA test is run for two hours at two litres/minute and 200 graticules – you will get a good accurate test that can also be used to populate the 4Hr TWA data. As Assure360 users will know, the system automatically does the calculation for you, provided your test follows the rules.
The guidance then goes into more detail on the ‘why’, mostly pointing you at the various regulations that demand compliance. However, littered through the document are more ‘whys’. Fundamentally, it makes the case that exposure monitoring – if done correctly – can be a practical management tool for testing competence.
The next part of the guidance focuses very helpfully on strategy. The starting point is to give an indication of absolute minimums – for example if you have a small, stable team, with consistently low readings and a predictable list of project types, you should aim for at least one test per month.
The first very important steer that you need to be aware of comes next. The traditional approach for LARCs’ exposure strategy is that 40% of all AIB jobs, 60% of all pipe insulation, and 100% of all flock jobs get a personal. This isn’t going to be good enough anymore.
Just as with audits, you should be targeting high-risk situations over low risk. The guidance gives you areas to consider when setting your strategy:
- Work activities – ultimately all should be covered, with a focus on high risk, but what constitutes high risk? The obvious first trigger is the asbestos-containing material, so AIB and pipe insulation are higher risk than floor tiles and cement. The next trigger is the fixing. Nailed is clearly higher risk than screwed, as is hard-set insulation over sectional. Finally, anything new – for example techniques that you haven’t used before – should be prioritised.
- People – everyone should be tested. People who are new-to-you, inexperienced, temporary (agency), or who have had high readings, should be seen as high risk, and targeted for higher frequency testing. Your long-term, experienced employees with good results are less so.
To obtain this data, the LARC therefore needs to be very clear as to what they want. No matter who is actually employing the analyst, you need to specify when, where, doing what, and who (will be doing it).
This new granular strategy, able to focus on individual removal techniques and the experience of a worker is going to really test your Excel skills. For Assure360 users however, it’s again very easy. We allow you to set targets for individual activities, and the system tracks how many times anyone uses each method on site. With every recorded instance it reassesses your strategy and alerts you to any personals you might need to do. Again, it’s all automatic through the Paperless system. We can even tag agency or new starters to increase their testing frequency.
Looking to the Construction (Design and Management) regulations and the duties that these place on clients, the guidance makes the point that personal monitoring data is a valuable measure for management of a project, and that clients should therefore insist on personal monitoring data in the contract. The implication is that if the client is appointing the analyst as good practice dictates, they should specify personal monitoring, along with leaks and clearances.
The LARC should view the dynamic between themselves and the analyst as customer and supplier. At this moment, no matter who actually pays the analyst, they’re providing the LARC with a service. To further underline this new way of looking at the relationship, the LARC should ensure the competence of the analyst to conduct personal monitoring, just as they should with any supplier.
The implication is that the Health and Safety Executive (HSE) is starting to believe that United Kingdom Accreditation Service (UKAS) accreditation alone isn’t enough. But the guidance doesn’t suggest how a LARC can be assured a consultancy has demonstrated competence in this area. Possibly this is where the likes of FAAM step in to investigate and improve the skill set across the board.
As delays in getting personal monitoring data could lead to increased exposure to asbestos, the guide states that analysts must provide the certification ASAP, no matter who is paying for the service. There is a stark warning that failure to do so could be seen as a breach of their duties under the Health and Safety at Work Act.
Using the data
The second half of the guidance is very heavy on how you should analyse and use the data – which takes us firmly away from the thoroughly outdated idea that ‘we test because the HSE says we must’. The key to all of the points I’ll detail now is that you need to be responsive in how you interact with the data.
The supervisor needs to analyse the results, and there are two triggers for intervention:
- Above the control limit – this is after the protection factor of the mask is taken into account. If this happens you should stop work immediately and investigate. This is not surprising, as the control limit when wearing a full face mask is a huge four fibres per millilitre.
- Above what you anticipated for the works (with a 10% buffer)
With some training, the supervisor should be able to keep on top of this for you. Assure360 users have an extra layer of control, as any elevated result automatically sends an email to management and tracks what action has been taken.
All of the results must be reviewed by management, and the guidance tells you what you need to be checking:
- Individual employees, and how they compare against each other at a given method
- Trends – both for the tested method, but also for individual employees
There are really only two ways that you can do all of the analyses that the full guidance requires. The first is through a spreadsheet, which involves some skill with software and a great deal of time entering in the data from paper site records. The other is with Assure360 – there’s no real alternative system.
Our software takes the data that the supervisor is routinely recording, and does all the analysis for you. This doesn’t happen by luck, for years we’ve been exploring how to use site data more intelligently to provide greater safety and insight.
As our industry guidance increasingly calls for smarter data collection and analysis to drive safety, Assure360 customers are already reaping the benefits of this approach. In the words of one HSE inspector – ‘Assure360 presents all the information to you on a plate, allowing you to make sensible decisions’.
If you’ve got concerns around the guidance and the changes you’ll need to make, or simply if you’re yet to see what Assure360 can do for you, why not contact us? We’d be delighted to give you a demo, and set up a free pilot of the system.
Something new: FAAM’s first four-stage clearance workshop
Written by Nick Garland on Thursday March 9th 2023
Friday the 24th February was a big day for me, albeit one that probably wasn’t on your radar. For some time I’ve been planning a workshop on the infamous four-stage clearance (4SC), and I was delighted to take the lead on delivering this inaugural event for FAAM.
This wasn’t just another P404 – BOHS’ official training course on 4SCs – but a unique attempt to bridge the gap between two sides of our industry: analysts, and licensed asbestos removal contractors (LARCs).
The very fact that we all understand what I mean by ‘two sides’ hints at the suspicion and conflict that exists between removalists and analysts. It’s been getting worse over the last 20 years, as the pressure increases on the 4SC – and in particular the visual inspection – as the key check on licensed removal work. Today, the 4SC is the cauldron where the pressures of business come up against the mandatory checks of heavy regulation. Improving the process, and adding to everyone’s understanding, is one of the biggest challenges we have.
With fellow FAAM committee members Louis Slattery of Air Surveys, and Cat Holmes of ION, we tried something new – a practical session to bring together experienced supervisors and analysts so that they could learn from each other. While we didn’t know quite what to expect, we hoped they’d each benefit from the strengths of the other, and also that they’d get an insight into each other’s point of view. The ideal outcome would be better communication and ultimately a stronger team attitude.
We used the fabulous facilities at Airborne Environmental Consultants (AEC) in Manchester, where they have full-scale mock enclosures set up. We focused on the first two key stages of the process.
With the attendees placed into analyst / supervisor pairs, they were thrown in to do the preliminary stage one inspection, where we saw the strengths of the supervisors coming to the fore. And while the supervisors obviously felt in their element, it was also great to hear a different viewpoint from the analysts, and see an instant rapport building between the two. The following debrief was also refreshing, with everyone being open in revealing gaps in their knowledge or things that they might have missed.
After lunch were two realistically mocked up enclosures with a host of issues hidden in each. Now the analysts showed their experience – not particularly with the significant failings, as both members of the team easily found those – but more in their ability to find the small things. We had the pleasure of witnessing analysts’ ‘dark arts’: the carefully angled use of a torch to reveal settled dust, or mirrors to inspect behind and under obstacles. It’s an amazing skill set, so crucial in preventing an unsafe enclosure being handed back.
The final debrief was as good as the first. For me personally there were two significant moments in the end-of-the-day chat. While everyone knew that it is the LARC’s duty to ensure that the enclosure is 100% clean, changes to the handover certificate were also brought up – for the first time the supervisor’s name is being attached to this liability, making them more directly responsible.
For me, the logical conclusion of this personal liability is that it should reposition analysts as the supervisor’s best friend. After all, they’re the final backstop before the supervisor’s enclosure is handed back.
This discussion produced another eye-opener for us all. Although it’s always been the LARC’s responsibility to ensure that an enclosure is free from asbestos when handed back, supervisors have never been given formal training in this as part of their initial or refresher training. This is something I’d personally always assumed was included. And if that incorrect assumption runs all the way up to the Health and Safety Executive (HSE), it would lead to this critical competence issue being overlooked at licence assessment.
I and the other organisers hope that this will be the first of many workshops, with feedback provided to the FAAM conference, and ultimately that our findings will also inform future analyst and supervisor training. The ideal outcome is that joint training in this key competency becomes a routine reality.
I’d like to extend my special thanks to Kellie Naughton of AEC, Ian Halpin of RSK, Liam Bodger of Emchia, Nick Butters of ABP, Aidie O’Neil of East Coast Insulation, Nicola Ratcliffe of TRAC-Associates, John Malloy of RS Asbestos, Neil Hardy of IATP and Phil Roberts of the HSE, who all very generously gave up their time to make this workshop possible.
Sorry for the inconvenience – the HSE cracks down on site facilities
Written by Nick Garland on Thursday February 9th 2023
Site welfare is something that’s all too often overlooked on asbestos-removal jobs. We’ve all worked on sites with incredibly inadequate facilities, whether it’s too few loos, unsuitable washing facilities, or just nowhere to sit and take a break.
One of the main reasons it’s so common is that a lot of these projects are quite short term. Sometimes it’s just one or two days. Management can become too focused on the complexity of the job itself, which leaves welfare as an afterthought. Another issue is that these short-term jobs are typically in flats and houses, and by their very nature they prevent access to on-site facilities. For example, asbestos removal of the riser in a toilet might mean that the loo is available for the first couple of hours, but then it’s very much not for the rest of the day.
But while the management may forget to provide it, the Health and Safety Executive (HSE) views adequate welfare as a fundamental basic necessity for workers. In fact, during the COVID restrictions, Prohibition and Improvement Notices that mentioned COVID almost exclusively targeted inadequate welfare.
Management can also misinterpret the ‘so far as reasonably practicable’ (SFARP) exception, thinking along the lines of “It’s a one day job. What’s it reasonable for me to allow for?”. The law sets out a basic expectation of toilets, a supply of hot and cold (or warm) water for washing, changing facilities, drinking water, and somewhere to eat and rest. You’d have to have very significant reasons to not provide the minimum.
The HSE is reinforcing this with the release of some new guidance: Construction – Welfare Standards. I’m grateful to Graham Warren at ACAD for flagging it up in the latest newsletter. The guidance is actually for its own officers, not us, but understanding how the HSE will be looking at the subject is crucial: inspectors are directed to take ‘appropriate’ enforcement action to secure compliance.
The guidance makes clear that where toilets, hand basins, drying rooms etc. haven’t been provided, or they’re inadequate, an Improvement Notice (IN) is the appropriate response. There will be local exceptions that might even dial this up to a Prohibition Notice (PN), for example if there’s an imminent risk to health. But the guidance also states that prosecution should be considered for repeated offences – or even if the first offence is bad enough.
The penalties for getting it wrong are therefore significant. The guidance quotes multiple regulations and guidance documents, weaving together a framework for the inspectors to justify enforcement action. The most significant is obviously the Construction (Design and Management) 2015 (CDM 2015) regulations. Among other things, these introduced clear definitions for all parties in construction (including clients), removing the cloak of invisibility that had allowed some clients to claim ignorance.
In practice a client needs to create an environment where work can be carried out with the appropriate welfare facilities in place. If the works involve a specific fenced-off construction site, use of the client’s own facilities should not be the default option. The regs go on to say that where there isn’t such a specific construction site, clients are legally required to make their own facilities available for use.
Domestic clients are the exception. CDM 2015 and the HSE guidance both recognise that they don’t have legal duties, so it falls to the principal contractor (PC) and other contractors to ensure compliance.
Principal contractors have clear and unavoidable duties to provide facilities from prior to the start of construction work, all the way through to the end of the project. Contractors’ duties shadow those of the PC. If there are several contractors on a site, it’s a case of liaising and cooperating with the PC. If there’s only one, then all of the duties are yours.
That ‘so far as reasonably practicable’ get-out gets some clarification with regards to welfare. In essence it’s about weighing the measures needed against the sacrifices involved. Crucially, though, it’s weighted in favour of health and safety, i.e. it’s assumed you’ll provide the welfare, unless you can demonstrate it would involve ‘grossly disproportionate sacrifices’. Cost is not the primary focus and shouldn’t be considered ‘disproportionate sacrifice’.
Toilets are mandatory (i.e. you don’t get to say they’re not reasonably practicable), and there’s a hierarchy, with flushing toilets at the top and chemical Portaloos very much at the bottom. The guide states that for large or long-running sites the provision of ‘only portable toilets’ is considered insufficient – as it would very much be reasonably practicable to provide better.
All welfare facilities must also be ‘readily accessible’. What this means varies with the urgency: rest breaks can be planned, so the distance to travel can be greater. Toilet facilities, however, need to be much more convenient. The guide quotes BS6465(1) as stating that construction sites should provide WCs within 150 metres of the workplace. Arranging toilet use with a café that’s 10 minutes’ drive away would not cut it.
For the same reason the numbers of cubicles are also pre-determined:
|Number of people
||Cubicles (not urinals)
There are some other key requirements:
- Separate rooms for males and females. This HSE guidance is for the construction industry in general – it’s not specific to the asbestos industry – but it would have shown joined up thinking if inspectors were also directed to consider that most of our decontamination units are non-compliant with this.
- Washing facilities. Unlike toilets, washing facilities are qualified with SFARP. In other words, they should be provided except where this involves grossly disproportionate sacrifices. The HSE’s view is that suitable washing facilities (separate ones for toilets and rest areas) are easy to plan for and provide, and that justifiable exceptions are few and far between. Note – specific mention is made that cold water on its own is not sufficient.
- Drinking water. This must be readily available and – it nearly goes without saying – also fit for human consumption. Running water or sealed water bottles along with cups and mugs are specified.
- Rest rooms. These are another mandatory facility, like toilets. What constitutes a rest room is not clearly defined, but there are some pointers, which indicate something more significant than many of the welfare areas I come across. The Workplace (Health, Safety and Welfare) Regulations (WHSWR) state they must be equipped with an adequate number of tables, and adequate seating with backs for the number of workers likely to use them at any one time.
What I find particularly interesting about this guidance is the way that it details other regs and approved codes of practice (ACoPs) detailed in the guidance. It features them along the lines of ‘areas to be considered when considering enforcement and prosecution’. But to think of it another way, I always like to ask one of my favourite questions: ‘Why are we doing this?’ – as understanding why is often the lightbulb moment.
Of course, there’s the basic human dignity of providing somewhere to go. Not to mention hygiene 101: wash your hands before you eat. But as these often don’t seem enough reason, how about:
- First aid. Clearly things go wrong on site, and we are used to providing training for staff and first aid kits. The first day of First Aid school teaches you to wash your hands first, so a sink, soap, and hot and cold water is therefore a must.
- Hazardous substances. Washing requirements are often a key control measure when working with hazardous substances. For example, with lead paint it’s crucial to wash after work and before each break. That washing needs to be more than just the hands, covering the whole forearm up to the elbow. A small sink is therefore not suitable, and something else would need to be provided.
I’m sure you can think of more examples and, if they apply to the work you’re doing, the HSE inspectors will doubtless think of them too. Perhaps it’s time for those of us who design and commission work to stop treating facilities as so much of an afterthought, and start planning work around the comfort of the people who do, after all, do the work on the ground.
Revisiting the Control of Asbestos Regulations 2012
Written by Nick Garland on Thursday February 9th 2023
Last December the Health and Safety Executive (HSE) completed its second post-implementation review (PIR) of the Control of Asbestos Regulations, 2012. A PIR is essentially a state-of-the-nation report to look at whether a set of regulations are working, whether they’re achieving the intended aims, and whether there were any unintended consequences. PIRs are enshrined in the regulations themselves – i.e. as part of the regs, the HSE has to mark itself every five years to make sure it’s achieving what it set out to do.
PIRs are typically huge documents, containing a great deal of evidence. This one is no exception. It includes minute detail on who responded to the associated questionnaire. This time, 1,850 people did, which is clear evidence of the importance our small industry attaches to this legislation.
The people who responded were broken down as follows:
- 6% of responders conducted licensable work
- 0% conducted non-notifiable work
- 1% conducted notifiable non-licensed work
- 0% conducted ‘other’ types of asbestos-related work
- 4% who manage asbestos via ‘Duty to Manage’ requirements
Those figures make it clear that the industry as a whole was engaged in the process.
One unusual thing is that this PIR was delayed by six months. This was for good reasons – the HSE wanted to incorporate the findings and feedback from the Work and Pensions Committee report. Mostly, though, how this featured was where the HSE referred back to its written response to the committee, or even that it fell outside of the scope of the questions they asked the responders – so not much extra light shone on the recommendations.
After the delay, the PIR is now published, and is a vast 160 pages long. If you’re interested in more detail, fortunately the good people at NORAC have boiled it down to something more digestible. In a nutshell, it’s all good, and there are no plans to change the legislation at this time – which hopefully will save it from the bonfire of the European legislation that is coming our way.
New year, new features
Written by Nick Garland on Tuesday January 17th 2023
It’s only mid-January, and already the Christmas holiday is beginning to seem long ago. We spent the run up feverishly working on some major updates to the Assure360 platform. Releasing them just before Christmas meant that we could down tools and relax, but we realise that many of our customers won’t have found the changes yet. With that in mind, here are some of the new features and improvements.
First up, we’ve made a really big change for our larger Enterprise clients – those with multiple divisions that may have very different ways of working. Site staff inductions and work area workflows can now both be tailored for different divisions in your company. Need a different workflow for the licensed scaffoldings group, or a team that works exclusively outside and in remote areas? That’s now no problem to set up – just give us a call if you’re interested in upgrading.
We regularly get client requests for new data, improvements and reports – this feedback is invaluable for our development plan, so thank you. The Assure360 project is a community solution. Many of our best ideas come from you, and everyone gets the benefits in the form of free updates.
With this release, the Assure360 Paperless app dashboard gets two community-led innovations. The first is Plant Usage – a brand new report that tracks where equipment was last used on site, and by whom. One of the beautiful things about Assure360 is that we collect everything as data. And because this is already in the system, any new report is automatically backdated and available for previous, current and future jobs.
Another community request was that the Paperless Work Area dimensions should get a decimal point. Done – a simple win for all you detail-focused Contract Managers. Keep all your requests coming, please.
Among the other updates, we’ve enhanced two admin reports – the Manage Multiple SHEQ Actions and Manage Multiple Exposure Actions reports. Both get extra information to help pinpoint what was happening on site. For those of you that haven’t used either yet, the first is a very useful report for closing out actions after team meetings. The second is brilliant for your admin team to group exposure actions into single strategies. You can find them both in your Admin drop down menu.
We’ve made another improvement to the Assure360 Audit App that should appeal to all our trusted auditors. The app now puts all of your client’s People into different pots. This is automatically sorted, so you will now be able to focus more on identifying issues on site, closing them out, and kick-starting recurrence prevention.
Our last app tweak represents a small but important victory against acronyms and unclear language. In Assure360 Paperless, the exposure section used to ask: “Was the activity measured?” This ludicrous question was always intended to mean ‘did you get a personal done on this?’, so we’ve changed it to “Personal Monitoring test carried out?”. All I can say is sorry, but it’s fixed now!
Finally, we’ve made an important and useful change beyond our web and app interfaces. To streamline actions from audits, we’ve added lots more site-specific information to the emails you receive from the system. Now you can triage and prioritise more effectively.
We hope you enjoy using the Assure360 system and all three of our apps, and we hope these changes make them even better. If you’d like any more information on any of these enhancements, please do get in touch.
EAF 2022 review
Written by Nick Garland on Wednesday December 7th 2022
The fifth European Asbestos Forum (EAF) lived very much up to its billing, with a breathless conference programme featuring 21 international speakers. But, as I’ve said before, what sets Dr Yvonne Waterman’s EAF apart is that it is so much more than a conference. The clue to why is in its name – forum.
The conference itself was on Friday 11 November, but the wider event got under way the day before, with a field trip to the Asbestos Museum and the Asbetter asbestos denaturing plant.
The first of these was absolutely fascinating: a private collection showing off a fraction of the vast number of products that have, and still do contain asbestos. From fake (fireproof) Christmas snow, through moulded cement ceiling tiles that looked like carved wooden panels straight out of a Jacobean mansion, to toy Eternet trucks with real asbestos cement pipes! Good Lord.
Next for us was the Asbetter factory. Asbetter is an innovative firm that is attempting to develop commercially viable means to destroy asbestos. Asbestos is known to dissolve in high alkaline solutions. Cement itself is strongly alkaline. Therefore if you add water to a ground up cement debris and heat the resulting suspension (to approx. 90oC), you end up with a cementitious slurry with ostensibly no asbestos fibres remaining.
Such a simple solution would seem to be witchcraft – but the science is sound, and Asbetter has scanning electron microscope (SEM) data to suggest that all of the fibres have dissolved. The company does, however, face challenges in ramping its current pilot plant up to a full commercial outfit:
- SEM is not necessarily the right technique for finding fibres in highly milled material, as near-invisible, tremendously thin fibres may go unobserved
- Grinding up the cement in hoppers present its own fibre release issues
- The initial packages of asbestos waste aren’t limited just to cement, but also used overalls, plastic, metal fixings and wood. All of these will remain as contaminated waste that still needs to be disposed of
- The process produces a slurry that is highly alkaline. Unless Asbetter can sell that back to the cement industry (of which it is hopeful), it will probably represent an insurmountable financial obstacle
I wish the business good fortune, as the world very much needs a solution for asbestos that isn’t simply burying it in the ground.
One of the unique appeals of EAF is that Yvonne works time and space into the schedule. It’s the vital magic that makes all the difference to your enjoyment of, and what you get from, the conference. After the field trip, we all headed back to the hotel for a laid-on meal. By the time delegates get to the conference day itself, they’ve already met many of the speakers and other delegates, got to know each other, and formed friendships.
At the conference itself, I was chairing Session B (technology). It was brilliantly fascinating, but being on duty I didn’t have the time to just simply enjoy the event, or to make all the notes I might have liked to. With apologies to any of the delegates that I don’t mention here, or don’t cover in the detail they deserve, here are some of my highlights from the day.
Member of European Parliament (MEP) Nikolaj Villumsen opened the conference, explaining the European Union’s goal to reduce the Occupational Exposure Limit (OEL) for asbestos. You may remember that I talked about this in my post from the FAAM conference.
While the new OEL goal was initially 0.001 fibres per millilitre of air (f/ml), in the end the figure settled upon was a less stringent 0.01f/ml. This compromise level was seen by the Commission as more practical, and not requiring much in the way of prolonged technical adaptation. Mr. Villumsen explained his disappointment and frustration with this, and said that it would likely be amended.
In a later talk Federica Paglietti, of the Italian worker safeguarding body INAIL, was able to reveal that only the day before, the EU member states had indeed agreed to amend the limit to the original 0.001f/ml. In addition, they’d agreed that PLM (optical microscopy) would be prohibited in favour of electron microscopy. There will be a lead-in period of somewhere between five to seven years.
I know the UK is no longer part of the European Union, but if ‘they’ implement this, the gravity may well prove un-resistible. It’s not possible to morally argue against a lower limit, but to adopt 100% electron microscopy in the UK within a mere seven years – from a base of virtually nothing – is a daunting task.
It has to be said that we were slightly stunned by these revelations. So much so that another revelation – that the encapsulation of asbestos would be prohibited in favour of removal – almost slipped by unnoticed.
Huge changes are afoot.
Later in the day, Professor Arthur Frank gave us a tour-de-force analysis of asbestos exposure sources new and old. He also shared an eye-opening look at the vested interests that still prevent the US from introducing an asbestos ban – more than 15 years since it was banned throughout the EU.
Next came two very difficult-to-hear talks. Syed Mezab Ahmed is a Pakistani asbestos campaigner, fighting for an asbestos ban in his country. He was able to organise a conference in Karachi with many internationally renowned speakers. Alas from that moment on, his life, and that of his family, has been under constant threat. He’s suffered the crushing of his car, death threats, and even a 40-plus hour kidnapping of his father, all to shut him up. The final straw came when the local police said they could not protect him. He and his family fled for their lives, and now exist in hiding somewhere in Europe.
Colette Willoughby brought her testimony of the experiences of female analysts to a new international audience. I wrote about her experiences after she first shared them at last year’s FAAM conference, and Colette herself was kind enough to write us an update last month. Colette shines a light on this very dark aspect of our industry. Despite the progress she has helped bring about, it doesn’t get any easier to hear her talk on the subject.
After Colette, keynote speakers Inez Postema and Angelo de Jong laid out Asbetter’s revolutionary new approach to dissolving asbestos. While this was of most interest to those who weren’t able to go on Thursday’s field trip, it remained fascinating to those of us who did.
After this the forum split into two groups. I had the privilege of ‘refereeing’ the technology breakout session. We had Sean Fitzgerald on measuring microfibres, and the state-of-mind that a fibre has to have to be asbestiform. Rikard Hodgberg (of INASCO Asbestos Converting AB) discussed another potential treatment of asbestos – using high-temperature denaturing. Tony Smith of Sundstrom also took us through the new ISO standards, which will revolutionise how we approach respirator design and, crucially, training for the wearer.
I also had the pleasure of introducing Jody Schinkel of TNO, a Netherlands-based research firm. He presented the findings of a project establishing the risks posed by the vast acreage of asbestos cement roofs in Holland. The report is in Dutch, but Google Translate is fabulous – here’s its English translation of the full report.
Among other test parameters, the researchers collected the water run-off from the roofs. The collected sludge was found to be an average of 12% asbestos. Further analysis and testing allowed them to discover that each square metre of roof ‘lost’ 1.2g of asbestos to rainwater annually. With an estimated 74 million square metres of cement roofs in Holland, this works out at approximately 90 tonnes of asbestos per year going into the surface water, drains, or the top 50mm of the ground adjacent to the roofs.
I was fascinated to hear from Aron Cserkaszky of Frontier Microscopy – the home of Marvin the robot microscope. For those of you that haven’t read my other pieces on this, Marvin is not a paranoid android, but an innovative bit of technology. It combines a standard optical asbestos microscope, a 3-D printer, and a computer, with AI.
Load Marvin with an asbestos air test slide and he will read it for you. Marvin does not get tired. He diligently reads the slides exactly to the rules no matter the external pressures, and can keep counting as long as you like – increasing his sensitivity hugely.
This has tremendous implications for the asbestos industry, as it is portable, and gives a traceable and repeatable result fast. Depending on the settings, Marvin can measure down to the new OELs proposed by the EU. Even better, it allows the analyst to focus on the most important part of the UK clearance procedure: the visual inspection. Hopefully the apparent EU moratorium on optical microscopy won’t affect this technology: we wouldn’t want to throw the baby out with the bathwater.
Loretta King and Daniel Rushton also presented on Alert’s live asbestos monitor. If I’m honest, I have previously been doubtful of the device – this may have come from when they pipped Assure360 to the post of Innovation of the Year at the Contamination Expo! But seriously – Daniel effectively and neatly acknowledged and addressed my previous concerns.
While Alert doesn’t tell us the concentration of asbestos (and therefore risk), what it does give us is the ability to instantly spot when asbestos release has happened. This has very wide ranging applications. Firstly, in investigating short duration ‘low-risk’ removal techniques where it can help identify the precise behaviour that led to fibre release. It’s also very useful in leak testing from enclosures. A team that knows immediately when something has happened can act immediately, rather than wait for a quantitative air test. There is even the possibility of hooking up the device to a high flow pump to immediately start a test.
The final speaker in our session was Alexandre Chasteloux, of BCL Invent – a French company. I’ll admit to a certain amount of professional resentment towards France, as they always seem to have the best advances, technology and kit when it comes to asbestos.
Alexandre was presenting on a gel fibre-suppression technique. The concept (gloopy substance that helps retain fibres) is pretty much as old as the hills, but the application was very impressive indeed. Essentially BCL Invent contains the ‘special’ gel within a localised plastic pod. The user fixes the pad to the substrate, and drills or cuts through it into the material beyond.
I have no idea how special the secret gel is, but the videos were incredibly convincing. One showed a simple wrap around a cement pipe, then a reciprocating saw cutting straight through both pad and pipe, with no apparent dust release at all. The data sheet that I’ve seen claims that cutting through raw MMMF (man-made mineral fibres) pipe insulation generates a fibre release of <0.01f/ml (or <10f/m3 for our European colleagues). The potential to improve the safety and speed of wrap and cut pipe removal is tantalising.
To sum up, it was an incredible event, full of ideas, technology, and opportunities to share knowledge. The energy and enthusiasm that EAF generates is visceral. All of the 150-ish delegates I spoke to – whether policy makers, consultants, activists, asbestos removalists, or policy wonks – left energised and enthused about this niche in which we make our careers.
How well are duty holders managing asbestos?
Written by Nick Garland on Wednesday December 7th 2022
The recent Work and Pensions Committee report on asbestos management has started to move the conversation in some very positive directions. I wrote recently of how 13 of the committee’s 16 recommendations had been taken up by the Health and Safety Executive (HSE), which was actively investigating how to implement them. As I understand it, such a positive hit rate from a select committee report is near unheard of.
One recommendation that isn’t being adopted is that there should be a national database of asbestos. Like many in the industry, I’ve written about the shortsightedness of this decision, but it has had a very interesting result – the industry is attempting to fill the void itself.
This is principally happening through two initiatives. In the first, UKNAR, Asbestos Smart and Open Asbestos are working to bring all of the asbestos software companies together. The goal is to make it easier to communicate asbestos registers to the people at risk, i.e. those that need to know.
The second initiative owes its existence mostly to the HSE’s assertion that we don’t know what we don’t know. In other words, that there isn’t much data available to measure the effectiveness of duty holders’ management of asbestos in the real world. And what evidence the HSE does have (through visits to properties) is broadly very positive.
Now, the asbestos consultants reading this would have mostly spat their tea out, as it didn’t match what we were seeing. Happily, ATaC and NORAC stepped up to investigate and create a report on what we really do know. Their exercise is intended to be repeated annually, so that we will effectively get a grade card of how well we are doing and how things are changing over time.
The result is a very impressive example of joint research and collaboration. The data set is vast, taking in more than a million lines of information. The data covered 128,761 individual sites, and of these, 100,660 contained asbestos-containing materials (ACMs). The analysis was complicated by the range of terminology used, and some significant reconciliation was needed. Despite this, the study was able to produce some really impressive headline stats.
Damage in the details
A total of 710,433 ACMs were identified. These were mostly non-licensed materials, but some 157,940 (spread over 32,814 buildings) were the higher risk ACMs such as asbestos insulation board (AIB) and pipe insulation. Some 10,054 (6%) of these ‘licensable’ ACMs were deemed to have medium damage, and 19,347 (12%) high damage.
The researchers also segregated between new surveys and reinspection reports (i.e. known asbestos that was being re-checked as part of a management plan). The latter showed:
- 4,769 medium-damage licensable products
- 10,452 high-damage licensable products
It’s clearly a very impressive piece of research, and as a point-in-time spot check on asbestos it is an enormously useful data set. But other than “we still have a lot of asbestos” and “there is a long road yet to walk”, what does it tell us?
It’s clear that the report isn’t set up to be a worthy, academic piece. In fact, I think that its messaging was intentionally straightforward. The bulk of the report is given over to ‘Findings’, but it’s actually a blend of the findings and the authors’ take on what this data means.
To my eyes there’s a lack of nuance. For example, in one of the sections it suggests that the very fact that reinspection surveys identified 10,452 ACMs with high damage indicates that either:
- the material has been like that since the survey and ignored by the duty holder, or
- It has deteriorated/been damaged in the intervening 12 months
The report suggests that either way it demonstrates poor management of the risk. That might be the case, but it could also be that the number was nearer to 12,000 a year ago, and that the duty holders are prioritising their remediation plan, for example by locking away the rest so it is no risk to anyone. The same information could now be seen as evidence of excellent management. We just don’t know.
Perhaps I’m looking at it too deeply, and the point of this first report is just to get the attention of the layperson. I certainly hope it achieves that, but its real value (and it should be huge) will come when it’s repeated year on year. Do we see the percentage of asbestos in poor condition reducing? Are we eliminating ACMs? Are we moving fast enough?
Or, as the report seemingly indicates now, are we actually seeing inactivity, and an attitude more akin to box-ticking than active management of risk? I look forward to finding out, and for us all to be able to act on the answer.
FAAM 2022 roundup – and what comes next
Written by Nick Garland on Thursday November 10th 2022
(Image courtesy of @IsteadAV / Twitter)
This year has felt rather full with conferences, which isn’t exactly surprising after the couple of years’ Covid-enforced hiatus that led up to it. To top it all off, my favourite two come almost back to back. I’ll circle back to EAF, which is on 11 November in Amsterdam, but first I wanted to give my customary write-up of the FAAM conference, which took place on 18-19 October.
Organised by the Faculty of Asbestos Analysis and Management (our home as asbestos professionals), FAAM was a thorough success. This year marked the first time it’s been launched by a policy maker: Stephen Timms MP, chair of the Work and Pensions Select Committee.
Mr Timms revealed some of the inner workings, thoughts and movements leading up to – and in the aftermath of – the committee’s crucial report on the Health And Safety Executive’s Approach To Asbestos Management. Of its 16 recommendations, 13 have been taken forward by the HSE, a remarkable success.
It’s a bit harder to pin down which three suggestions didn’t make the cut. One is the deadline for removing asbestos, and another is the centralised national register. I believe the last is including more work history information on death certificates, which is outside the purview of the HSE anyway.
It’s a shame: all of these would have enormous value. The 40-year deadline on removing asbestos from non-domestic buildings is simply crucial: if there’s no plan, the retrofitting and refurbishment required to reach Net Zero could bring about a catastrophe of disturbed materials.
And, as Mr Timms explained, just having to submit your asbestos survey to a central register would encourage better behaviour and be a sampling point for enforcement: when building X doesn’t have a register on the system, it’s a good idea to pay it a visit. However, as the Government Digital Service would have to lead on this, it seems there’s been a government decision not to provide funds.
My reading of the report’s reception is that the HSE has taken forward everything it can, and that the government has blocked – or at least shown no interest in actioning – the remainder. I’ve written before about the significance of the funding crisis facing the HSE, and Mr Timms finished his talk with a welcome call to arms – write to your MPs and demand more funding for the HSE so it can do its job properly.
Occupational exposure – a fascinating challenge
The rest of the first morning was taken up by a series of discussions centering on the European Union goal to reduce the Occupational Exposure Limit (OEL) for asbestos, and the challenges it might create – in the UK we have a control limit instead. Dr Yvonne Waterman spoke about the very strong political movement to reduce the European OEL to 0.001 fibres per millilitre of air (f/ml), but in the end the figure that’s been settled upon is a less stringent 0.01f/ml. This compromise level is seen as more practical, in that it wouldn’t need much in the way of prolonged technical adaptation.
Morally it is not possible to argue against this, as less exposure can only ever be a good thing. However, Gary Burdett was there to articulate the challenges of achieving this target – and in particular a fundamental flaw with the proposal.
Principally, the issue is that to test to a given level, the EN standard (EN482) demands that we are able to measure an order of magnitude lower: to reach the current OEL of 0.1f/ml, for example, we must be able to measure down to 0.01f/ml. That’s possible with the existing optical microscopy methods, but if the OEL is 0.01f/ml, we need to get down to 0.001f/ml. If it were 0.001f/ml, then the method needs to achieve 0.0001f/ml!
Gary was doubtful that the current WHO method could achieve these lower levels, so we need to agree on something new. As Gary explained, that means new technology, new competencies, and having the time to implement both. To be clear, he’s not arguing against the new limits, more that we need to agree on a method and work together on implementing it. He did go further, suggesting that research into reducing dust emissions would potentially reduce the risk more effectively.
The move to new methods throws up other challenges, such as how you find conversion factors to link new and old fibre-counting methods. In his talk, Remy Franken reported on an attempt to do just that. There was also a perceptive question from Andrey Korchevskiy on whether there should be different OELs for different fibre types – I’ll return to that in a moment.
Next up was a short presentation by Philip Hibbs of FAMANZ, about the burgeoning new Faculty of Asbestos Management of Australia and New Zealand. The key moment for me was when Philip mentioned that 3.8% of their membership are asbestos removal professionals – or as they put it splendidly, removalists.
Gary Burdett said later that was a lightbulb moment, and I couldn’t agree more. In the UK our industry has always been very much them and us, with a schism between the removers and analysts that only seems to get worse. Would this be the answer here – welcoming in asbestos professionals from all elements of the sector?
Into the afternoon
In the afternoon, Andrey Korchevskiy took us deep into the weeds of lifetime risk assessments. To illustrate his points, he presented two imaginary case studies – Mr and Mrs Smith.
Mr Smith was exposed to 0.1f/ml of asbestos over 20 years whilst working in the construction industry. This was predominately (95%) chrysotile, but 5% of his exposure was to amosite. For Mr Smith, the lifetime risk analysis identifies an increased risk of cancer of 391 cases in 1,000,000. Interestingly 64% of this risk arises from his comparatively tiny exposure to amosite, and this explains Andrey’s earlier question concerning different OELs for different fibres. Tightening the amphibole OEL makes a lot more sense to him, as it is responsible for so much more of the risk.
Mrs Smith’s exposure was through talc contaminated with asbestos – 0.07% tremolite, 50% of which was not asbestiform (essentially chunky fragments that don’t have the morphology that indicates a high risk). Her risk calculation indicated 0.24 cases of cancer in 1,000,000. This seems absolutely tiny – and if correct it would be a huge comfort to anyone that is concerned about similar exposure. That said, it doesn’t line up with the increasing case law emerging from the states, or the decision of Johnson & Johnson to stop selling talc.
To kick off day two, the HSE’s Sam Lord gave us an overview of the executive’s plans to implement one of the DWP report recommendations: a focus on improved monitoring in schools. Four hundred primary and secondary schools will be selected for visits – in fact, these have already started, and are expected to be completed by March 2023. The idea is for this to be a collegiate supporting visit, with more of a focus on why and how schools actually manage asbestos. In short, how they go beyond just “the survey report is available”.
A year earlier, Colette Willoughby had shocked FAAM 2021 with her testimony about the personal safety of female analysts. She was here again to update us on the Female Analyst Working Group – one of the many positive outcomes from her courage in speaking out. Real measurable progress has been made, although she would say there is still a mountain to climb.
The group recognises that analysts (no matter their gender) are often put into a difficult position, with huge responsibilities that result all too often in abuse. But its findings show that for female analysts it’s even worse – and sadly not in the least consigned to history. Their mission is to start with the female experience and focus on that. This should improve matters for everyone, before they widen the remit.
The group’s first meeting set several key areas and goals:
- Review why and how we decontaminate (a key point of vulnerability)
- Understand the scale and range of the abuse
- Create safety guidance for analysts
- Create policy advice for companies
Its main progress to date is in the area of decontamination, with recognition by the HSE that currently available Decontamination Units don’t comply with the Construction (Design and Management) regulations on welfare. This can be fixed – Colette name-checked Beacon International’s simple but revolutionary magnetic lock, which allows the user to secure all doors from the inside. The wider focus is on education for LARCs. Specifically, the need to help supervisors better understand the role of analysts, what all the stages of the four-stage clearance are, and what exactly they’re signing with the handover form.
There’s a continuing need to hear from analysts and others in the industry who have suffered or witnessed abuse, intimidation or other unacceptable behaviours. If you need to share an experience, you can contact the group through two confidential email addresses: firstname.lastname@example.org and email@example.com.
Colette will also be attending the ACAD regionals in the coming weeks to brief LARCs directly, and staying for questions afterwards. Hopefully ARCA will be able to extend a similar invitation to her – we all need to be better.
The toughest slot of the conference – the final 30 minutes of a two-day event – was filled with some finesse by ACAD’s Graham Warren. He closed the circle by providing the LARC’s view of the four-stage clearance process. Graham covered recognition by the trade organisation, the importance of the supervisor visuals, and how ACAD is using its audit scheme to explore compliance. “Developing, getting there – but some way to go” was the message.
ACAD had also completed some research on its members. Ninety one percent either introduced the clearance handover form in 2018, or already had an equivalent system. The final 9% only introduced the form with the recent publishing of HSG248 – the HSE’s Analysts’ Guide.
When asked, “Are analysts demanding the form?”, the news was less encouraging.
While just 9% said analysts rarely asked for the form, only two thirds (65%) of analysts were always or nearly always demanding it – that’s surprisingly low compliance overall.
When asked how the process could be improved, members cited improved planning, communication, and better analyst understanding of the removal process. Graham recognised the fact that this was echoing the goals of a workshop proposal that had come up earlier in the day.
Helping FAAM’s membership beyond the conference
Gary Burdett and I spoke just before lunch on joint research ideas for improving the value of FAAM’s membership. FAAM wants to help its members be more directly involved with – and benefit from – faculty membership beyond the conference. As FAAM Committee members, it’s a subject close to our hearts.
The first suggestion we came up with was to explore the dearth of advice for the general public when they are presented with small and large-scale asbestos issues at home. Often the advice from local authorities is to contact the HSE or ARCA, with not much else on top. The initial step in improving this would be for interested members to help with contacting local authorities to explore the advice available. We’d then work together with the goal of designing competent advice. Participants in the research would be able to use this for CPD.
The second suggestion is something quite close to my heart, echoing what FAMANZ’s Philip Hibbs said, and feeding directly into the behaviour issues that Colette talked about. The premise is that our supervisors and operatives don’t understand what analysts do or need, and vice versa.
Our proposed solution is that FAAM organises workshops where the two sides of the industry can get together and learn from each other. The hope here is that closer ties will produce better understanding and cooperation. Ultimately, we all might just get better at our jobs. We’re still at early stages, but initial conversations with the Independent Asbestos Training Providers (IATP) have been very positive, and I am hopeful that both ACAD and ARCA will be enthusiastic supporters.
If you are interested in getting more information, helping develop, or participating in either of these ideas, FAAM will be reaching out with ways you can do that. The same goes if you’d like to share and have support with any other bright ideas that will help the industry. If you’re not a FAAM member, you’re always welcome to contact me directly (see below).
Returning briefly to the conference, it was again a thoroughly interesting and engaging event. More than that, I found it a very welcome return to the face to face experience. As I said at the top, my favourite two conferences are back-to-back, and the brilliant EAF is on Friday 11th of November. Depending on when you read this, I hope to see you there, or at one of next year’s events.
Expo 2022 – are LARCs being abandoned?
Written by Nick Garland on Wednesday October 12th 2022
As you’ll no doubt know, mid-September brought the annual Contamination and Geotech Expo to the Birmingham NEC. Of the event’s four ‘themes’, its Hazardous Materials area focuses on contaminants and the protection of the environment – it’s one of the leading asbestos events on the calendar.
But increasingly I find myself rather conflicted when I talk about the Expo. I think it’s perhaps because I represent both sides of our industry. On the one hand, I’m a techy policy consultant, with a slightly embarrassing passion for exposure monitoring. On the other, I’m very much concerned with the nuts and bolts of asbestos removal.
The asbestos industry is not an ivory tower – it is a very practical application of science. Obviously, it must constantly change and improve as the demands grow and the technology gets better. But while the science of finding and monitoring asbestos is critical at major events, we mustn’t overlook the needs of licensed asbestos removal contractors (LARCs). Yet LARCs have been poorly served over the years by industry events, and the Expo was an exciting breath of fresh air in that respect. Unfortunately the Contamination Expo is not what it once was.
Cement and sharing
As I say – I am quite conflicted, because on the day I went this year there were some great talks. The first one I attended was on asbestos cement. Dr Yvonne Waterman spoke brilliantly about a new Dutch report that will highlight the slightly ignored danger around the material. Expect more detail on this theme at November’s EAF conference.
In the afternoon we heard some exciting developments relating to the sharing of asbestos register information. Andrew Paten, Andy Brown and Robin Bennett spoke about OpenAsbestos, a new open source interface that links asbestos registers like Tracker and the UK National Asbestos Register (UKNAR) with portals that need the information – like UKNAR’s Asbestos Smart.
Just the very fact that a single open source portal now exists is fantastic – it’s a huge step towards everyone being able to get asbestos information when they need it. But further exciting news was announced. Along with the Tracker and UKNAR, Teams is apparently also aiming to become compatible with OpenAsbestos, and Lucion is now also looking into it. The fact that the three big players in the industry are prepared to set aside their commercial differences for the greater good should give hope to us all.
The changing Expo
Assure360 has been attending the Contamination Expo since its inception back in 2016. In the early years, it was held at the Excel in London and it was very much targeted at the whole industry: it covered analysis and surveys alongside removal. LARCs exhibited as well as equipment manufacturers from the UK and across Europe.
Our stand was opposite ACAD’s, and just down the aisle from ARCA. We were next to a fantastic French manufacturer – CNSE – who had brought a decontamination unit over. At the time it really put the ones on offer here in the shade – though it was expensive, as I understand it. There were talks on a wide range of issues directed at consultants, but also LARCs. It was a well rounded and very exciting couple of days.
I’ve been unsure about the Expo’s direction of travel for the last couple of years – and Covid can hardly have helped – but fast forward to last week’s Expo and it has changed markedly. The floor area devoted to the asbestos industry was much smaller than previous years. Gone were most of the LARC-focused manufacturers – the last one standing was Thermac.
ACAD and ARCA were still there, of course, but all of the other stands were consultancies, and new technology for consultancies. That’s fantastic for me if I’m wearing my techy, policy consultant hat, but it offered almost nothing for LARCs. The few that did show up must have asked themselves: “Is there anything here for me?” The answer was: “Not a great deal.”
There was and is a vital place for a good event that showcases and promotes innovation and best practice in our industry (all of our industry). However, unless the Contamination Expo does something dramatic to arrest its drift, it will just be a show for the consultants and policy wonks like me, and that’ll be a great shame.
Assure360 Paperless – announcing the new and improved Site Diary
Written by Nick Garland on Wednesday October 12th 2022
Long-term customers will already know that we’re constantly developing the Assure360 suite of products to make it better. This isn’t tinkering for the sake of it: we’re always gathering feedback from our community so we can target any issues, and add in features and improvements that help make our software more powerful and effective for everyone. Not just that, but we use our software every day for demos, audits and other consultancy work – we’re always finding things we can improve.
So I’m happy to announce that the latest update to the Assure360 Paperless app is a belter. We’ve added signatures to the Site Diary and, when you link this to the dictation feature and photographs, you get an incredibly flexible productivity tool for supervisors
Now there’s a hassle-free way to add longer entries without all the typing. That’s great when you’ve got a unique situation that isn’t already covered by our fast, menu-based entry system. It’s ideal if you hate typing on a tablet, or when the site demands safety gloves.
Signatures is the icing on the cake. Say you have a new Method Statement on site. The supervisor can detail the key changes using the dictation mode and tag the operatives as present. They can sign, and then photos can be taken to demonstrate they were there.
More than anything, the changes make record-keeping quicker and more accurate. And that’s the whole point of the Paperless app.
The 100% clean – comparing blasting and needle guns
Written by Nick Garland on Wednesday September 14th 2022
Photograph courtesy of Horizon Environmental Ltd.
Consider the case of a client with a boiler room, once liberally splattered with asbestos-based insulation material. It’s comparatively easy for a licenced asbestos-removal contractor (LARC) to strip out the bulk of the material with low-risk techniques, but it soon becomes a case of diminishing returns. The less asbestos there is remaining, the harder it can become to remove it, and the greater the expense.
When faced with asbestos insulation residues on semi-porous substrates like brick and concrete, removal of the final 0.1% of asbestos-containing material (ACM) is very challenging. Residual fibres can be embedded in pits, dimples and micro cracks – making the traditional, low-impact approach of hand scraping accompanied by suppression and shadow vacuuming extremely time-consuming. Often, the removal ends in an admission of failure and encapsulation – a process all too likely to be repeated by another LARC in a few years time.
Clearly this is quite an unsatisfactory position for the client. They’re spending a vast sum of money on asbestos removal, only to be presented with a residual risk that still has to be managed – and probably at the same level and cost as before.
It’s therefore easy to understand the temptation of aiming for 100% ACM removal in a boiler room. It’s broadly possible through the use of two competing techniques: blasting (using wet media), and low-vibration needle gunning. Both have their champions – two LARCs I know are very firmly in opposing camps. In the red corner we have: ‘Blasting is faster at cleaning than needle guns, even when you factor in the additional clean-up’. And in the blue corner: ‘Needle gunning is a much simpler method that creates lower exposure and is easier to manage’.
Comparing blasting and needle guns
It’s important to start with one thing that both needle guns and blasting have in common: you’re not supposed to use either technique unless you’ve already done your best to remove all significant deposits of asbestos through traditional methods. This means scraping off all but the last miniscule ACM traces manually – accompanied by sprayed surfactant and shadow-vaccing.
With the use of needle guns on the rise, I’ve also heard that HSE inspectors are coming across it more. And, quite rightly, they’re asking whether the method has been properly assessed. I’ve heard that while the HSE isn’t tremendously keen on blasting, it has questions over the vibration levels of needle guns (more on this later). Clearly this is crucial to any technique or technology: it must be properly assessed, and your team must be competent to use it.
Both techniques present their own challenges which need to be considered if you are aiming for spotless. You’ll need to balance all of the pros and cons when you complete your risk assessments.
Noise and vibration
The noise levels of blasting vary dramatically depending on several factors including the choice of media, and even the location (boiler rooms usually reverberate more, for example). Due to this uncertainty, Quill – one of the leading blasting manufacturers – is a little cautious about publishing noise figures. Essentially, it’s not possible to predict an accurate noise level unless you know the usage situation. Quill says that noise at the lance could be >110dB(A). Vibration magnitude is negligible at around 0.2m/s2. That’s 10 times lower than the EC-specified minimum level for unrestricted hours of work.
Needle guns used to be known for their huge vibration levels, but recent pneumatic variants are much improved. The one I am familiar with is the Trelawny VL303, whose manufacturer claim it has a noise level of 109.5dB(A), and vibration of 2.3m/s2. However, there does seem to be some question marks about this very low figure. Not least because normal operation is to use two hands… Clearly, unlike with blasting, whatever the HAVS (hand-arm vibration syndrome) data is, it is not negligible. If you plug 2.3m/s2 into the HSE’s HAVS calculator, you get a remarkable nine hours and 27 minutes to reach the lower exposure action value (EAV). However, worst case vibration data from the manufacturer indicates something nearer to 90 minutes or below. I understand Trelawny are conducting some independent HAVS testing and the report will be out soon.
Whether blasting or needle guns are selected, then effective hearing protection will be mandatory. Vibration needs to be looked at, and hopefully accurate data will be available soon
There’s no avoiding the issue, blasting will add waste to the project. Quill states there’ll be 0.5-1.1kg of material created per minute of use. You’ll need to consider the increased manual handling issues that this will create for the project. These may be exacerbated if you have to lug waste up from the basement – especially if there is any restricted access involved.
Both techniques are high-impact, high-disturbance methods that should only be used on trace residues. Both techniques use different approaches to keep dust and fibre levels down. As the name suggests, wet blasting uses water – which atomises as it hits the substrate with the blast media. This will probably be most effective when removing chrysotile residues, as amphibole fibres such as amosite or crocidolite are hydrophobic (they repel water).
Needle guns use the shadow vac technique, and come with dedicated vac cowls. The H-Type vacuum is attached at point A in the diagram, providing effective local exhaust ventilation (LEV) at the point of disturbance (B).
As with any asbestos-removal technique, you’ll need to test that exposure is as low as practicable, and investigate any elevated results.
The real problem for wet blasting comes with all that water; Quill states that you’ll be using 2-4 litres per hour. Water vapour plays havoc with air testing – whether that is standard optical or electron microscopy – occluding the filters so they can not be read. The default position seems to be that you should assume a high fibre release, and use supplied-air respirator (RAS) masks.
By contrast the needle and shadow vac technique is relatively easy to test. The results I’ve seen are favourable, with an average of 0.06f/ml (fibres per millilitre of air), highest reading of 0.12f/ml, and lowest of 0.01f/ml.
The high humidity of blasting creates two more issues that you need to allow for. Water does not play well with a negative pressure unit (NPU)’s HEPA filter. To counter this, Quill provides moisture vanes that work along with the standard pre-filter to protect the HEPA.
Another impact – especially in the cooler atmosphere common to basements – is that we often hit the dew point and visibility falls dramatically. Neatly, Beacon’s recirculating NPU incorporates an in-line heater to prevent this. You cannot underestimate the impact of low visibility on supervision – vision panels and especially CCTV will both become very limited, and you’ll need to identify enhanced supervision techniques to combat this. You may consider having a deputy supervisor in the enclosure to be the eyes of the lead supervisor outside.
There’s a rather unfortunate, nebulous bag of additional issues that you will need to factor in. As we’ve established, both blasting and needle gunning are very, very noisy, clearly requiring hearing protection. The follow on effect of that is that operatives will not be able to hear you when you try to communicate with them, whether routinely or in case of an emergency.
This is further compounded by the visibility issue discussed above – i.e. you can’t see them, and they can’t hear you. You might consider flashing beacons, activated externally, at the point of work, which will allow you to stop work quickly and easily. The extra internal supervisor would also help with this.
You also need to consider that needle guns are quite heavy, in addition, large-bore compressor hoses and metal coupling will add markedly to this. You should always step down to the narrower whip lines to minimise this manual handling issue. Generally, you should also consider fatigue as a hazard.
Another consideration with blasting is that the media obviously goes somewhere. Predominantly this will be the floor, but if operatives are working near the enclosure wall it could damage the sheeting and lead to a breach. A less obvious risk is that the media can be blasted into inaccessible voids, resulting in a spread of asbestos. Your design process needs to include careful planning of how and when to use the technique to avoid this.
Finally, while it’s not really part of the risk assessment, needle guns are much more mechanical than blasting equipment. As such they have moving parts, and need to be maintained through periodic stripping down, cleaning and oiling. They are also vulnerable to icing up where the weather outside is cold. For both cleaning and good maintenance, Trelawny recommends ISO22 low viscosity anti-freeze oil.
It’s hard to argue against a client’s wholly understandable desire for an asbestos-free boiler room, and these two techniques are the only options that get close to achieving it. As with all asbestos removal methods, however, they bring a range of issues that have to be individually and collectively assessed. It’s our job as professionals to understand the complexity, and ensure that we manage all of the risks.
Vertex Asbestos Removal
Written by Nick Garland on Wednesday September 14th 2022
Construction health and safety management case study
Peter Cooper is surely one of the most experienced site workers in our industry, having begun his career aged 18, shortly after leaving school with few qualifications. During Pete’s 35 years at the coalface, the rules and guidance surrounding asbestos removal have changed markedly. Pete had already been in the industry a decade when asbestos was finally banned in the UK. And like all of us working with the material, he’s still dealing with its legacy.
Today Pete works as an asbestos supervisor for Vertex Asbestos Removal. Providing nationwide coverage from its base in Essex, Vertex provides a full range of asbestos management solutions to schools, hospitals and commercial premises, together with the offshore and marine industries.
After a couple of years working for a different licensed asbestos-removal contractor, Pete returned to work at Vertex. During his time away the company had rolled out Assure360 and begun to use the Paperless app. Not being particularly familiar with computers and technology, Pete was concerned that he may struggle to adjust to recording safety checks and managing other site information on a digital system.
Along with Vertex’s other supervisors, Pete received an introduction to the system from the Assure360 team. Supported by the growing library of instructional videos in the Help Centre, he quickly found himself learning the Paperless app and growing in confidence.
Today, Pete is an enthusiastic user and advocate for Assure360. Remarkably, through using the system, he has become more comfortable with technology in general. His new confidence has helped him adopt other solutions such as OneDrive, allowing him to work completely paper-free on site – and benefit from having more time available to actually supervise.
What the client said
In the years when I first started there wasn’t any personal monitoring as such. I never had that for probably the first 10 years of my career. There were no face-fits, you just got a full mask that could have holes in it, or cracked pipes. It just wasn’t regulated like it is now.
Wherever I’d worked before we’d used paper to record checks and manage the work. Apart from maybe having a couple of certificates on your iPhone it was all paper.
I’m not the best on computers and things, and I was a bit nervous about using Assure360 at first. We got a trial of the system, and Nick [Garland] came out and showed me how to do it, and from there I just got better and better at it. When you ring Nick he answers his phone straight away and helps you out with it. I’m clued up on it, but I’m still progressing with it – getting into all the things.
I’ve got used to Assure360 now, and it’s kind of turned me on to other things; it’s moved me over to working out how to use things like OneDrive as well. It’s done me a favour really; it’s got me used to doing things on iPads that I never thought I could have done.
I seem to have got better with technology now that I’m using it every day. I haven’t got any paperwork on my site whatsoever!
Paperless is better because you don’t worry about people spilling things on your paperwork, or the wind blowing it away, it’s always just there whenever you go back to it. And it’s quicker. When you went to fill your paperwork out it could take four or five hours, whereas with 360 it could take 20-30 minutes in the morning, then you just go back to it during the day.
I can use the free time to actually help my team: carry things and sheet up with them, whereas before I’d be sat here with my glasses on with my paperwork. It’s even better for the analysts with four-stage and signoffs and everything; no messing about with bits of paper to get the sign off – it’s all on there.
It’s a good system and I’d recommend anybody to try it. If you keep tapping at it it will come naturally to you – even for somebody who hasn’t got GCSEs or other qualifications. I prefer it to the old systems. It’s quicker, easier – everything’s better with it. You haven’t got to sift through lots of paperwork, or worry about something stupid happening to it. When I first came to work at Vertex I was handed a large hard file for every job. Assure360 is much better.
- Peter Cooper
- Asbestos supervisor
We’re really happy with how it is going – it’s much easier to plan projects and get the information to and from site. The transition over has also helped us to comply with our ISO 14001 requirements when it comes to carbon footprints etc.
- Glen White
- Managing director
Audit 3.0 – our latest health and safety auditing app
Written by Nick Garland on Monday July 18th 2022
It gives me a huge amount of pleasure to announce that our latest app – Assure360 Audit 3.0 – has been finished! You can already download this third release of our essential health and safety auditing app to your iOS or Android device: find Assure360 Audit on the Apple AppStore, and Assure360 Audit on Google Play.
We had big ambitions for this release of the app, and we’ve spent the last year or two on a long development road, guided by the suggestions of our fellow safety professionals. This isn’t some lightly tweaked update: Assure360 Audit 3.0 is packed with new features and functionality, designed by and for auditors.
The app is now much smarter – it talks to our other solution, Assure360 Paperless. If you’re auditing a site that is being run with our industry leading Paperless solution, then the Audit App already knows all the details from the job – including the address, and who is on site. Another new feature is that you can promote a site ‘operative’ to a Deputy Supervisor. This will automatically adjust the competency questions to correctly reflect their management role.
The app’s improved intelligence has also allowed us to build in more flexibility. Assure360 Audit has always supported bespoke audits, but now the process is incredibly streamlined. A brand new audit can be designed, rolled out, and shared across the community within just an hour or two.
We’ve added specific improvements and extra functionality all-round. Some examples include:
One of the most common requests from auditors was ‘can we take more photos?’. We’ve done away with the previous limit – take as many as you need to describe the situation.
We’ve revamped this system to add much more flexibility, allowing 10% increments, rather than the previous 25%. You can also double up. Imagine the example of a severe trip hazard. Obviously the supervisor should have resolved this before you got there, but say three operatives also ignored it. The app now allows you to assign the issue to all four of the site team, without overstating its overall seriousness.
This isn’t a new feature, but with the improvements in the latest release, it’s well worth discovering if you don’t already use it. Activate it, and the app strikes out every question with ‘N/A’. You can then dip into the audit and record only the particular areas of interest. It’s ideal for senior managers visiting the site for a meeting, for example.
Now, if you’re returning to a site you already audited, you can copy the original audit, rather than starting from memory or scratch. This allows you to directly comment on progress, and it helps ensure more thorough follow-up.
What else is new?
All our apps are built from personal experience, but Assure360 Audit in particular is the app I use almost every day. Among its new features, our new search facility is my personal favourite: just type in a key word for what you are looking for (e.g. ‘Trip’), and the app will filter the menu to show the most relevant bits. As a quick way to find the best home for your observation it’s an obvious time-saver, but it’s also a big bonus in other situations:
- Safety Tour feature – Start off with a clean sheet as above, and Search allows a Contracts Manager to find and record the few observations they have in seconds.
- Translating ARCA and ACAD audits – Want to manage all of your external audits using the incredibly powerful analytical tools in Assure360? Start with a safety tour and add the one or two observations from the auditor. Now this is a simple process taking maybe five minutes per audit.
- HSE visits – Treat these as above to manage closeout in the most efficient way. Every observation will also contribute to your trends and training needs analyses.
- Audit Prep – I use this feature all the time now, especially in conjunction with Paperless. Before you even get to the site you can get a good idea as to what is going on, for example by reading the latest set of RAMS to understand what you might need to follow up when you get there. Studying the site paperwork stored in the cloud also shows you what the supervisor has or hasn’t recorded. And all the while you can use Search to make notes for later follow up, tagging them as a non-conformance so they’re easy to find again.
All wrapped up
The final major improvement is to the upload process. Now all you do is tap Sync when finished, and the audit will upload directly from your app to the cloud, assigning any actions within seconds of you leaving the site.
It’s been a long development road, but we’ve arrived at a redesigned health and safety auditing app that further simplifies and improves the auditing process. It’s full of expanded functionality, and enhanced to further streamline data collection and synchronisation. We’re delighted with the outcome – and we hope you will be too.
Want a demo of the new Assure360 Audit app, and how to get the most from it? Curious to see what Assure360 and its apps can do for you? Why not contact us? We’d be delighted to show you around the system.
The Asbestonomy conference – fresh thinking on a problem that hasn’t gone away
Written by Nick Garland on Monday July 18th 2022
It’s a brave move to launch a new event when Covid 19 is still loitering about, so it was great to be at the first Asbestonomy conference in London in mid-June. Even better was the fact that this refreshingly interesting and worthwhile event was a real success. While owing much to other conferences among leading thinkers, Asbestonomy is aiming to carve out a different identity: despite high calibre speakers and delegates, it’s less academic than, for example, FAAM – and much more about ideas, policy and different points of view from around the world.
The conference was kick-started with a video presentation by the Danish MEP Nikolaj Villumsen. As you might expect, his talk focused on the policy changes coming down the line in Europe, particularly focusing on where the ‘green deal’ intersects with the problem of our asbestos legacy. As legislators and our industry are increasingly aware, the drive to insulate homes and make them ready for net zero is likely to clash dangerously with the reality of our ageing, asbestos-insulated building stock.
Nikolaj’s talk highlighted many recommendations that also featured in the recent Department of Work and Pensions (DWP) Committee report:
- Strategy for removal
- Public asbestos registers
- Financial framework to support removal
- Financial support for strengthening enforcement
But he also discussed a mooted EU-wide rule to mandate asbestos surveys before the renovation or sale of a home – an eminently sensible idea for any property that predates the banning of ACMs in construction.
Other parts of Nikolaj’s talk highlighted areas of potential disagreement. The EU is keen to introduce an occupational exposure limit (OEL) of 1,000 fibres per cubic metre (f/m3), or 0.001 fibres per millilitre (f/ml). However, we have a very real concern in the UK about setting any OEL for asbestos, and especially setting the wrong one – which 0.001 f/ml almost certainly is.
However, discussing an OEL does raise the question of whether we should be looking again at reducing our clearance indicator (CI) – the level below which an analyst can declare an area ‘cleared’ of asbestos. As a community I personally think we need to open this discussion, look at the objections, and work out whether they’re good enough to outweigh the advantages.
For example, would lowering the CI lead to other benefits, such as eliminating pressure on analysts to clear an area? Would it eliminate borderline passes that perhaps shouldn’t be passed, e.g. an area that’s visually ‘clean-ish’ with an air test result of 0.008f/ml? It’s probably time we discussed it.
“The asbestos bans gave people a false feeling of safety as it made them think it was yesterday’s problem.”
This stand out quote came from Flemish policy maker Sven de Mulder, in his presentation regarding Flanders’ drive to become asbestos safe by 2040 – an initiative in which he remains the driving force. It rings all too true: I can’t say how many times I’ve heard comments like “Asbestos? I thought that was all sorted years ago…”.
I was familiar with the Flemish initiative, but de Mulder made clear something I hadn’t fully understood: the policy is to be asbestos safe, rather than asbestos free. How this translates is that all accessible asbestos in poor condition is to be removed by 2040, not all asbestos. Again, this calls to mind the DWP committee’s headline recommendation to remove all asbestos – is the Flemish goal more realistic, and would it be as effective?
The Flemish approach is very much risk-based, therefore starts with buildings where the users can’t be expected to manage their own risk, such as schools. The timescale looks like this:
- 2018 – Government action plan
- 2019 – Legislation in place
- 2022 – Asbestos survey required when selling
- 2032 – Asbestos survey of all buildings (database of registers to measure progress)
- 2034 – Removal of all external asbestos cement
- 2040 – Removal of all accessible asbestos in poor condition
What appears to have helped the success of the campaign so far is that it started with getting all stakeholders on board. Since then there’s been years of coverage and discussion, which seems to have allowed the removal industry to plan appropriately.
Asbestonomy’s middle section was quite technical, and I won’t recount it in too much detail here. Notable speakers included ITGA technical director Martine Chouvet, who explained why the French government has decided to pursue a transmission electron microscopy (TEM) approach to fibre analysis, rather than phase light or scanning electron microscopy. Sean Fitzgerald also gave a more academic talk, bringing some of the audience up to speed on asbestos, geological considerations, and his work in testing for asbestos in talc and makeup.
The afternoon session explored four different approaches to communicating survey findings to users. ITGA IT director Benoît Lanlard, UKNAR CEO Andrew Paten, Victorian Asbestos Eradication Agency CEO Simone Stevenson, and ACM manager of Aléa Contrôles, Santiago Jimenez, all gave impressive presentations, discussing cloud-based asbestos registers for entire geographic regions.
The French, Australian and Spanish versions all make heavy use of building information modelling technology. In contrast, UKNAR’s simplified approach is very appealing – it’s effectively a repository for existing registers, which seems very cost effective. I particularly like UKNAR’s innovative approach of using QR codes to give workers easy accessibility to a site’s asbestos records.
The final session was on asbestos removal and waste disposal, where it was interesting to again hear from Thermal Recycling (UK) chairman Graham Gould. When he spoke previously at FAAM, one concern I had was that burning asbestos at 1,400oC was a potentially questionable solution in a net zero world. However, when I challenged Graham on this, he made the point that the end product of the heat recycling process is a concrete replacement. When fed into that product stream – which itself is responsible for high carbon emissions – the material saves as much carbon as was used in the asbestos destruction process. In other words, the overall carbon footprint remains unchanged. What’s more, the kilns are already compatible with hydrogen, when it becomes commercially available.
Graham also made the point that now in the UK we still have quite a lot of asbestos waste to deal with, so plants like his are commercially viable. If we wait until more of that asbestos has been buried in landfill we may have missed the opportunity.
So: will construction clients pay more to denature asbestos rather than bury it? Graham feels that many socially and environmentally aware end clients would pay the premium if they had the option, but it strikes me that public opinion might have an important role to play here. The current understanding may be that asbestos ‘was all sorted years ago’, but greater coverage as net zero refurbishments get under way might shift the sentiment, and help nudge developers towards doing the right thing.
Rise of the robots
Finally, I was fascinated to hear from Mickael Place of French asbestos removal specialists, DI Environmental. At a cost of €10 million, they have built a processing factory for recycling asbestos-insulated railway rolling stock. It uses robotic arms, operated from a separate control room, to completely remove all asbestos. The blasting techniques employed use iron shot, which can be cleaned and reused. Once cleaned (and tested), the carriages are broken down and recycled on site.
There’s no worker exposure in this very efficient, ‘futuristic’ process: it’s an astonishing semi-automated solution. While the specific use case might not be relevant to the UK, it’s a great example of what’s possible with the application of technology and imagination.
Significantly, knowing that processes like this can be achieved helps to unblinker us when we are considering our own intractable problems. Over the next decade and longer, we’ll see the growing need for asbestos management expertise coupled with an increasing demand for permanent solutions – rather than just burying fibres for future generations to deal with.
For me, DI Environmental’s plant highlights both an opportunity, and a real danger we face in the UK. We think that we are very good at managing asbestos – and with some justification. But if we don’t broaden out who we’re listening to, we could get trapped in an echo chamber where we keep reinforcing how great we are, rather than innovating to get better. With some embarrassment, I can easily imagine how we might have attempted to solve the rolling stock problem.
All in all then, Asbestonomy was a success: informative and thought-provoking as all good conferences should be. Yet in style and substance it very much felt like a homage to the European Asbestos Forum Conference. I look forward to Asbestonomy when it returns, but I strongly recommend you also make the effort to go to November’s EAF conference in the meantime.
Written by Nick Garland on Thursday June 16th 2022
Construction health and safety management case study
Since 1962, Clifford Devlin has been providing specialist services to the construction industry. Now celebrating more than 60 years, the business has grown to become a leading provider of demolition, construction and asbestos management services.
Demolition has been at the core of Clifford Devlin’s business since its inception. Today the firm offers a full range of demolition services, on buildings ranging from schools and residential buildings, through to medium-rise office blocks. The business’ building division – originally established in the 1990s to support complex demolition projects – is now a multi-disciplined, stand-alone service capable of delivering complex schemes in its own right.
For nearly 40 years, Clifford Devlin has also been providing asbestos remediation to support the construction sector. A corporate member of ARCA for the last 30 years, Clifford Devlin typically works to support reactive and planned maintenance programmes for local authorities and housing associations. Today, its asbestos division numbers more than 20 highly trained operatives. The firm’s attention to detail extends to its fleet of custom-built site vehicles, with air-tight waste compartments for asbestos-containing materials (ACMs), ensuring fibres aren’t released during transit.
Clifford Devlin’s asbestos management division faced much the same challenges as other leading contractors. Legacy systems revolving around paper-bound site and project management were reducing the efficiency of its field teams. The delays in processing paperwork from its sites limited the usefulness and timeliness of the information being gathered there. And the recording and processing of mandatory safety data had grown to become a significant drain on time and resources.
With teams tasked to multiple sites and clients, Clifford Devlin needed a system that would streamline the gathering, recording and sharing of information between its site and management teams. And rather than sifting through folders of paperwork after the end of a job, it wanted the ability to generate meaningful insights during a project, allowing it to act on safety and quality issues as they arose.
In 2020, Clifford Devlin became an Assure360 customer. Assure360’s secure, cloud-based system provided the business with a modern, digital alternative to slow and onerous paperwork. The Assure360 Paperless app allowed the company’s site teams to ditch paper in favour of streamlined and efficient record keeping. The app’s ease of use has allowed supervisors to complete their mandatory checks more quickly, and freed them from the need to process and submit reams of paperwork afterwards.
Clifford Devlin also moved to the Assure360 Audit app for completing site audits. As with Paperless, Audit’s cloud data synchronisation means that information gathered on site now appears near-instantly on the office team’s web dashboards.
With no need to wait to recover site folders after a project, managers have gained a real-time view of what’s happening on their projects, allowing them to react to safety or quality issues before it’s too late to fix them. The Assure360 system also allows the business to demonstrate this better site management to the Health and Safety Executive (HSE). It makes it easy to evidence that site issues are being recorded, and that appropriate actions are taken to prevent recurrence.
What the client said
For our site teams, it makes jobs easier, there is considerably less paperwork and the system is reasonably easy to use. From an office point of view it collects all the data we require and streamlines what our admin team have to do. Where we are not using paper, we are not printing out hundreds and hundreds of Permits to Work that subsequently have to be scanned for saving into our electronic post completion records, so it’s cost-effective and time-effective for both our contracts managers and our administration team. All of our project information is in one place and allows us to access what we need almost immediately.
From our dashboard in the office we can see what has written in the site diary or when a work area has been completed, without making that phone call to the site team – we can just look at the Assure job record file. We can see in real-time what’s happening on that particular job. If, for example, the personal monitoring comes back with an elevated reading, we get an email, which allows us to react straight away, identify the possible reason and take immediate action so that operatives don’t continue to work at raised levels, as opposed to finding out there has been an elevated reading after the work has been completed.
The feedback from the guys is that it’s a lot better than working with all the vast amount of paperwork they used to do. One, it’s streamlined the paperwork that they have to do on site and two, it lets them add time stamped diary entries, so that if the client raises a question or there is any other issue, we can refer back to exactly when and what happened on the job, on a particular day.
When it comes to licence renewal, the system provides us with the information to demonstrate to the HSE that where issues arise, or we have identified a problem, we have taken action to resolve it immediately. We can physically demonstrate performance, corrective action and trend analysis, as the data collected from Assure is provided to our management team at our monthly compliance meetings.
- Steven Greenhalgh
- Compliance Manager, asbestos division
Asbestos Network guidance on personal monitoring, health, and exposure records
Written by Nick Garland on Thursday June 16th 2022
It feels like we’ve been talking about personal monitoring a lot lately, and rightly so. It’s a critically important part of ensuring the safety of people working in asbestos management, and yet to date there has been a lack of official guidance on it.
However, since 2019 the Asbestos Network (formerly Asbestos Leadership Council) has been working on creating some. It’s my understanding that this summer is the targeted release date. It can’t come too soon, particularly given that some recent licence applicants have been hauled over the coals for supposed failings – which seems unfair when there’s no definitive guidance to go by.
I want to examine the new guidance based on the latest draft. I’ll lay out the main points of it, but I strongly suggest you also give the original a read, and provide your feedback through your trade organisation. You can find the ACAD draft guidance page here (you’ll need to be logged in). ARCA doesn’t seem to publish draft versions of AN minutes on its guidance page, but you will be able to provide feedback through comments.
The first very welcome news is that the guidance is broad. By this I mean it recognises that personal monitoring is a means to several ends. Rather than focusing just on the initial testing, the guidance examines why you are doing the testing, and how you use the results for the practical ‘ends’.
As it stands, the guidance starts with those ends, and what it says is pretty much straight out of existing documentation:
- Establish that the four-hour control limit is not liable to be exceeded (after all controls including respiratory protective equipment)
- Check the effectiveness of control measures to ensure worker exposure is reduced as low as is reasonably practicable
- Select or confirm that the RPE in use is capable of providing the appropriate degree of protection
- Ascertain whether the exposure is sporadic and low intensity, and that the short term (10-minute) limit has not been exceeded
- Support current and future risk assessments. This is an extension of the second bullet, i.e. if the controls were not as effective as you anticipated, re-check any improvements you make.
- Provide medical surveillance records
My understanding is that this part of the guidance might be trimmed further, with more emphasis placed on health records (largely the four-hour time-weighted average) and the effectiveness of controls. This interpretation is reinforced by the choice of tests currently selected from the Analysts’ Guide for further detail:
Specific short-duration activity (SSDA) Monitoring
This is the workhorse test that you will use most of the time. It is used to test a specific activity (i.e. to satisfy goals two and five above). The guidance talks about the importance of really focusing on the individual task. To this end it stresses that it is no longer good enough to, for example, talk about removal of asbestos insulation board (AIB) – now you need to detail the fixing too. An example given is breaking out a single AIB panel, followed by fine cleaning. This should be viewed as two separate tasks, and either you should test them separately, or prioritise the high-risk element.
The guidance doesn’t yet state what parameters you should follow for this type of test (but it will in later drafts). As the purpose of the test is to examine an activity, you are allowed quite a bit of licence. The flow rate (how hard the pump is working) should be between two and four litres per minute, and the minimum volume tested should be 120 litres. These recommendations are very much intended to ensure you get a decent limit of quantification (see below).
Four-hour time-weighted average (4Hr TWA)
The second test that the guidance highlights is the dreaded 4Hr TWA – although hopefully these will be far less opaque if you’ve read my previous articles on the subject.
Not in the guidance yet is an explanation as to why on earth we should be doing these tests, beyond ‘it’s for the health records’ or ‘the HSE says so’.
Here’s my understanding. If an employer causes an operative to be exposed to asbestos, we should be able to tell them accurately how much they have been exposed. If we all pick different rules for these tests, it will be a mass of confusing numbers that could be interpreted in a whole host of ways. If however, we all follow an official internationally recognised method, proven to give good results, we have more of a chance at telling the real story.
Back to the guidance. The first thing it makes clear is that these tests are less about the activity, and more about the person exposed. If an operative is building an enclosure in the morning and then removing asbestos in the afternoon – it is the afternoon’s work that you would want to test. If the operative is removing nailed AIB for two hours, and then fine cleaning for one hour before exiting the enclosure, we don’t need to worry too much about splitting the testing down to capture the different activities – but you definitely need to catch that initial peak exposure.
Compared to other parts of the document, this section seems to be in need of a lot more work. Hopefully it will use plain English to detail that we are looking at four hours of activity, but that you are allowed to make some assumptions. Crucially, the guidance needs to underline that it’s NOT a four-hour test – it’s a four-hour calculation.
To understand this, look again at the example above. The operative is exposed for a total of three hours, so you could therefore assume nil exposure for the rest to make it up to four hours. It’s also worth remembering that if you test for two hours, but the activity runs for four, you are allowed to extrapolate the result to give you figures for the full four hours.
Again, the test parameters are not detailed yet, but these would be a flow rate of one to two litres per minute, and a minimum volume of 240 litres. Meeting this volume is crucial, given that there’s some flexibility in the testing parameters.
Keen observers will note that there is some overlap here. If the standard test you commission is two litres per minute for two hours, this will give you the minimum volume you need to qualify for the 4Hr TWA and also the SSDA. It’s therefore an opportunity to greatly increase how many of these ‘tests’ you complete. Whether the guidance will explicitly spell this out is yet to be seen.
Confused? Read my deeper dive into the 4Hr TWA
Unpicking the language
The personal monitoring guidance will also unpick some of the arcane language used by the Health and Safety Executive (HSE) and analysts. In particular, it tries to explain the following:
Limit of quantification, calculated results and reported results
The limit of quantification (LoQ) is a calculated level of asbestos found, above which the analyst can be confident of the result. Below the LoQ, the counted fibres are so few and far between that some could have been missed. The guidance explains this, then goes on to tell you how to calculate the LoQ, which is probably too much detail for the purpose of the document.
Calculated result. This is effectively the analyst’s ‘workings out’. It is never the final answer, and should be taken with a grain of salt. The reason? It’s often below the LoQ, which we already know is the lower limit of confidence. You, as the user of the data, should always refer to the reported result.
Reported result. This is the analyst’s answer to the question – ‘what was the exposure?’ It will either be equal to or above the LoQ (i.e. the analyst has confidence in reporting it).
It might help to look at a couple of simple examples:
LoQ stated as 0.05
Calculated result 0.01
Reported result <0.05
As the analyst I can only be confident if the result is above 0.05. This is below that, so all I can be sure about is that it is less than my LoQ.
LoQ stated as 0.05
Calculated result 0.06
Reported result 0.06
I can only be confident if the result is above 0.05, and this is above that, so I am comfortable reporting 0.06.
Next, the guidance looks at what level of detail you need to record. The short answer is: ‘more’. The guidance recognises that historically, licensed asbestos-removal contractors made fairly simple records such as ‘AIB removal’, ‘pipe insulation removal’ etcetera. This is now considered insufficient for the obvious reason that removing nailed-on AIB is a very different job to screwed AIB, never mind glued AIB. The minimum parameters you should be detailing are now: activity, the nature of the asbestos-containing material (ACM), and the fixing used to install it.
The final point I listed right at the beginning of this review was health surveillance records, and it does look like the guidance will give a very good steer on what this entails.
Outside of the asbestos industry, employers need to keep employee records for up to six years after the employee leaves the business. In our industry, however, employee health records have to be kept for a very long time – specifically, 40 years after the last entry, or until the employee would be (or would have been) aged 80: whichever is longest. For example, if you employ a 22-year-old for three months, you should keep their health records until they turn 80. If an employee retires at 55, you must keep their health records until they turn 95.
Health records are formed from the exposure records that we have been discussing up to this point, and in particular the 4Hr TWA data. In addition they include:
- Employee personal details
- The average duration of exposure in hours per week
- A record of any asbestos work an employee did before their employment started
- Dates of medical examinations
- The system you used for ensuring medicals are planned and undertaken
These can all be from separate records or systems. Records one and three will come from your HR data. Four and five are more related to your personnel certificate management system.
The second one is a little more tricky. The approved code of practice (L143) requires the recording of exposure duration and fibre levels, but it doesn’t require these to be multiplied together to provide a measure of dose in fibre hours; that requirement was retired in 2006. What your system does need to do is give the individual worker a breakdown of their actual exposure against your company’s anticipated levels.
It’s important to remember this remains draft guidance – and it could be some months off being issued formally. What’s more, the HSE is not in the market of giving you a specific solution. Instead, its guidance makes clear your duties and – if written well – should give you a steer as to what they mean in practice. The actual solution is up to you.
Say you implement an extensive system of Excel spreadsheets that you religiously maintain, and data-mine for the answer to different questions. As long as you already record all of the information that the new guidance demands – and your Excel skills for reports, charts and queries are up to the task – there will be little extra work here.
For the rest of us, the presence of guidance brings a very real problem: when it is out, your performance can be measured against it.
Fortunately, I’m able to offer some reassuring news to the Assure360 community. All of our users are already covered, as the ‘new’ three-tiered approach (activity-ACM-fixing) has been in place since I created the system. Also, our comprehensive suite of reports provides all the required detail you’ll need for employee health records, 4Hr TWA calculations and much, much more.
If you’ve got concerns around the guidance and the changes you’ll need to make, or simply if you’re yet to see what Assure360 can do for you, why not contact us? We’d be delighted to give you a demo, and set up a free pilot of the system.
Positive changes to improve personal safety in the DCU
Written by Nick Garland on Wednesday May 11th 2022
At last year’s FAAM conference, Colette Willoughby delivered a raw and personal presentation about the personal safety of female analysts. It was eye-opening and shaming, and it focused the minds of all who heard it on the urgent need for change.
Colette herself set out what needs to change in our industry, and with the support of many colleagues I’m encouraged to see things moving in the right direction. Asbestech – one of the UK’s leading asbestos management companies – has announced that it is retro-fitting locks to all of its decontamination units (DCUs).
Asbestech contract manager Alessia Gilbey commented that “it’s a simple method to provide an additional reassurance to myself and other women that may be required to use a DCU”. And it is simple – a quick, inexpensive change to make existing DCUs safer workplaces.
I’m also encouraged to see that DCU manufacturers themselves are paying attention. I’ve recently been invited to meet with SMH to discuss potential design changes that would improve personal safety in the DCU, and I’m hopeful they’re able to put something effective in place.
It’s heartening to see that the bravery of Colette, and the other female analysts who spoke to her, is resulting in real change. It’s up to everyone now to keep the pressure on, and continue making the improvements to equipment, training and behaviour that our female colleagues demand and deserve.
Read more here about Colette’s talk, Female analysts and four-stage clearance testing
The Work and Pensions Committee asbestos report: five key recommendations
Written by Nick Garland on Wednesday May 11th 2022
As you’ll no doubt all be aware, the Work and Pensions Committee has been conducting an inquiry into the Health and Safety Executive (HSE)’s approach to asbestos management. In its report, published in April, the committee calls for a raft of changes, including a proposed 40-year deadline for the removal of all asbestos from public buildings.
Predictably, I’ve already seen people commenting that 40 years is far too long, while others say the reverse and wonder how we’ll ever pay for it! But the asbestos management report is a substantial document, and I wanted to look at the changes and recommendations behind the headline. The committee has heard many opposing views from industry experts, campaigning groups, charities, victims groups, government ministers and the HSE itself, and to its credit has produced a well-balanced set of proposals that deserve greater scrutiny.
The balance of evidence
Like most in our industry, I’ve been following the progress of the inquiry and the evidence presented to it. Everyone has their own opinion, but there were a couple of witness testimonies that I took issue with. In December, Professor Julian Peto of the London School of Hygiene and Tropical Medicine suggested caution over the mandatory removal of all asbestos, pointing out research in the 1980s showing that airborne asbestos levels in buildings were higher six months after removal than before.
I’ve no reason to doubt that research, but I have first-hand knowledge of how comparatively poor asbestos-removal techniques were when I started my career in the 1990s. In the 1980s it must have been even worse, as analysts weren’t even doing independent clearances back then. I’d be astonished if the equivalent research, conducted today, didn’t reach a very different conclusion.
In February, HSE chief executive Sarah Albon claimed that the 60% drop in asbestos enforcement notices over the last 10 years was evidence of better compliance. However, when we compare 2012/13 with 2019/20 (the most recent pre-pandemic period for which figures are available):
- Visits by the HSE dropped by a huge 40%
- Prohibition and Improvement Notices (combined) dropped by 48%
- The number of Improvement Notices dropped by 67%
- Yet the number of Prohibition Notices dropped only by 16%
What this suggests to me is that the HSE targeted the companies it thought would be the worst offenders, and pretty much saw what it expected, giving it a much higher hit rate of Prohibition Notices.
If that’s the case, then the figures rather undermine the suggestion of improved compliance. Instead, they suggest to me that some companies are simply avoiding having their collar felt, and I’m not alone. As Darren Evans of Asbestos Training and Consulting (ATaC) told the committee: “There are lots of people out there taking an informed view that they are unlikely to be visited, and therefore corners are cut.”
Let me stress that I’m not blaming the HSE here. Over the 10 years to 2019/20 the organisation experienced a 46% drop in funding – it did well not to cut visits even further.
Regardless of the details, the committee has managed to distil a mound of evidence and come up with some well considered proposals. The report’s key recommendations are:
- The HSE should develop research to measure asbestos exposure in non-domestic buildings, and in particular schools and other public buildings. This came with dates – it should have a plan by October 2022, and then provide regular reports on its findings. The committee goes on to clarify that it doesn’t believe there’s a need to increase routine air monitoring, but research into the highest risk scenarios would be very beneficial.
- There should be a deadline to remove all asbestos from non-domestic buildings within 40 years. The government and HSE should develop a strategic plan to achieve this, starting with the highest risk asbestos and the highest risk settings such as schools.
- That more research is urgently needed to establish whether the historic view that it is safer to leave asbestos alone and manage it, rather than remove it, remains the case. This is especially urgent because of the likely huge rise in accidental disturbance that the race to Net Zero will bring.
- There should be increased guidance to dutyholders and trades on their obligations. The committee suggests that lessons could be learned from the use of digital technologies in building management and in the health response to the pandemic. This should be a sustained campaign across a range of media. What works and doesn’t work with regards to getting the message over should be robustly evaluated.
- A central, digital register of asbestos in non-domestic buildings should be developed, beginning with schools and hospitals.
- There should be a sustained increase in inspection and enforcement activity by the HSE, targeting compliance with the Control of Asbestos Regulations. The HSE should establish from this whether it needs to specify a minimum level of competence for dutyholders.
- Consolidation and simplification of the approach with regard to Licensed, Non-Licensed and Notified Non-Licensed work should be part of the ongoing 2022 review of the regulations.
- There should be mandatory accreditation for all surveyors by a recognised accreditation body.
- The HSE should assess the impact of making it a legal requirement (rather than the current strong recommendation) for building owners or occupiers to employ analysts directly and, by extension, make it illegal for asbestos removal contractors to do so.
- The HSE should keep a watching brief on Europe’s move towards more stringent asbestos occupational exposure limits. It should carefully consider this in the context of Great Britain and what the costs and benefits of a similar move would be. The committee added a stern warning “It should ensure that the extent of the asbestos legacy in Great Britain is not seen as reason to tolerate poorer health standards.”
As I said, these are all well-balanced proposals. It’s hard to argue against any of them, but I can see a particular subset with the potential to bring the fastest, greatest benefits. Five particular points would have an obvious, immediate impact on safety and good management:
- Minimum competence for duty holders
- Central digital asbestos register
- Mandatory accreditation of surveyors
- Research into the real risk of management in situ versus the risks of removal
- Increase in enforcement
Just these five, if acted upon, would have the potential to transform our knowledge and our ability to act appropriately. Let me explain further.
Competence of dutyholders
We are long used to the absolute requirement for access to competent health and safety advice – why should it be any different for asbestos? This has always been something I care about, in all my work with clients – the central pillar is to ensure that they end up more capable of asking the right question at the right time. For large organisations, having this requirement might mean having someone on the books who is P405 qualified. For smaller companies it might be having the right health and safety consultant on retainer.
Whatever we are doing, we’re likely to be more diligent and careful if we know our work is going to be checked. We see the evidence of this all the time in asbestos management: there’s a difference between an unannounced audit and one where they knew you were coming, or a visual inspection with the UKAS assessor in attendance. If organisations know that they’ll be uploading their asbestos survey to the HSE, they’ll do it better. Just the very fact that a survey or register could be independently checked at any time will benefit standards hugely.
Accreditation of Surveyors
It’s always been unexplained why asbestos analysts must be accredited, but it’s only advisable for companies conducting a survey. It’s very costly to get and maintain accreditation, so it’s only really accessible to established organisations. But being un-accredited doesn’t necessarily mean bad – smaller firms and individuals may be unwilling or unable to go down that route.
Regardless, we currently have a situation where UKAS accredited companies must compete commercially against non-accredited companies and individual surveyors – that’s not a level playing field.
Interestingly the recommendation in this regard is that accreditation should be compulsory for the individuals conducting surveys, not the firms employing them. This change would immediately level things out: large and small firms along with individual surveyors should be able to demonstrate competence.
I’d expect that surveyors would welcome this professionalisation of the industry, as the employment power would be devolved down to them. The change wouldn’t allow companies to shirk their responsibilities, as it will remain their duty to ensure competence of the workforce.
If the priority is to focus on schools and hospitals, just how big is the problem there? The short answer is that nobody knows, as very little research has been done. What we do know is that some schools have a good deal of asbestos-containing materials in them. We also know that young lungs are much more susceptible to damage from asbestos, and that youngsters are practically (and legally) considered not to be competent. This latter is crucial as ‘competent workforce’ is an important pillar in the current approach to managing in situ.
I’ve discussed the unique problem of asbestos in schools before, and the risks faced by teachers and pupils alike. As with other public buildings, UK policy has been to manage asbestos in place, but what little research this is based on is now well and truly out of date. Before we settle on any change in policy, we need to know for sure that removal is the safer option.
I’ve said it before, but the 1974 Health and Safety at Work Act is a beautifully written piece of regulation. If you render it down to a couple of sentences, it essentially says: “The employer must be an expert in their field, must understand the risks, and must eliminate them as much as they can. And if they don’t there will be dire consequences.”
The author was very cleverly identifying that proscriptive legislation would never be able to keep up with the best and safest way to operate across multiple industries in a changing world, but that a regulator would be able to use the power of hindsight to identify if something could have been done better.
And that’s where the HSE comes in. It’s vital that they are out there making checks and serving up enforcements to ensure things are done better. To recall Darren Evan’s point, companies need to know they cannot cut corners, because they will be caught.
Will it happen?
I’ve focused on these five very positive recommendations, because together they would improve our knowledge of the problem, make the scale of the issue visible, and leave dutyholders in no doubt that they need to act appropriately. However, they would also represent an increase in costs to business, an increase in health and safety regulation, and an increase in funding for a public body (the HSE).
None of these things have been particularly popular with the UK government for a decade or more. For several years there has been an effective ‘one in one out’ rule for new regulations. Consequently, much of the HSE’s excellent guidance of late has had to be be sneaked out as appendices to Asbestos Network meeting minutes – not exactly the ideal situation.
I would like to end, though, on a point of optimism, from Charles Pickles from the campaign group Airtight on Asbestos. Responding to the report, he told me it was a rejection of the existing line that asbestos was “yesterday’s problem: nothing to see here”.
Instead, he said, it’s a move to acknowledge that “we have a problem with current exposure, and we need a plan to deal with it”. The Work and Pensions Committee has asked the HSE for its plan, and soon. And as Charles put it: “That really is a significant move.”
The HSE’s new risk assessment guidance, and where it misses the point
Written by Nick Garland on Wednesday April 20th 2022
The Health and Safety Executive (HSE) – or rather its Asbestos Network – is about to release some new guidance on non-asbestos risk assessments. Regular readers will know that this is an area very close to my heart. However, as the guidance stands I’m concerned that it will actually set back the industry’s understanding of the process.
The Asbestos Network starts well, explaining that risk management is about taking practical steps to protect people from real harm and suffering, rather than just bureaucratic back covering. It also states that risk assessment should focus on reducing significant risks, and not creating a totally risk-free situation.
The guidance goes on to identify the difference between everyday risks, standard risks and site-specific risks.
These are those areas that we all experience all of the time. Examples would be getting in or out of the van, driving to the site, preparing lunch and so on. If the task at hand will not change the risk associated with the hazard, then we can ignore these for the purposes of a risk assessment.
These are incredibly routine, every-job situations that can be dealt with using a standard company approach. Examples might include:
- Manual handling – waste transportation to the skip via a wheelie bin
- Working at height – building a two-metre tall enclosure, requiring short step ladders
- Biological hazard (e.g. leptospira bacteria) – wearing of gloves, no smoking on site, hygiene and welfare
These standard approaches can all be detailed in the standard operating procedures (SOPs), and need not be re-assessed with every project.
Take as an example the removal of a one-metre squared asbestos insulating board (AIB) panel, from eye level in a social housing bike store, 10 miles from your HQ. This incorporates some standard everyday risks – a manual handling hazard, working at height (building the enclosure), and Leptospirosis – but we don’t need to spend much time thinking about it as they’re all entirely routine.
This is the area that we should be focusing on. Site-specific risks fall into two categories: everyday and standard risks that have somehow been increased or changed because of the job, and new hazards introduced because of the task or location.
By just revising a couple of aspects in the above example, we can see how site-specific risks might completely alter the nature of the job. Imagine we’re removing the same AIB panel, but now at four metres above ground, and 300 miles from the office. Several things change. Driving that kind of distance towing a decontamination unit (DCU) is no longer round the corner, obviously. You’ll also need different methods to physically get to the panel, which may well affect the physical handling.
These changes must be assessed and new control measures designed. Breaks for the driving? A two day job with digs? What’s certain is that working at height now means you need a scaffold tower, and operatives with PASMA training. The manual handling (lifting equipment up to height, and the AIB down to the ground) will also be much more complex, and require appropriate controls.
This guidance confirms the relatively common aspirational goal of returning to the site just ahead of the official start date as best practice. Wherever reasonably practicable you should re-assess the hazards – has anything changed? Is the location of the DCU still appropriate? Are there any new hazards?
To underline the importance of recognising that things change, the guidance also stresses that the supervisor should be conducting their own daily risk assessments. Essentially, a competent experienced supervisor should not blindly follow an out of date method, just because that’s what was written. You may know this practice as point of work risk assessment – in their wisdom, the Asbestos Network terms it ‘dynamic risk assessment’.
To be clear, I fundamentally agree with all of this approach, but I have some relatively minor objections to a couple of specific examples:
|Working at height
||Mobile tower required to access asbestos-containing material (ACM) for removal. PASMA trained operatives (named) to erect, with hold point in plan of work (PoW) and checked by supervisor to ensure this is correctly built prior to removal activity
||Purging air to be introduced to facilitate works with trained site team, escape set provision and continuous gas monitoring in place throughout confined space (CS) working
My problem with the first example is on a practical point – the chances of knowing that Steve the PASMA-trained operative will be assigned to a particular job in a number of weeks’ time is remote to say the least. Naming the specific operative shouldn’t be necessary.
The second is a lazy example that encourages a very poor attitude to confined space. It falls into the trap of taking a standardised approach that fails to recognise the specifics of why a space is confined, and what the exact risks are. In some cases, rolling out these standard controls would make matters worse, as I’ve previously explained in my analysis of the Confined Spaces Guidance.
This is the example they should have given:
|Confined space (due to risk of reduced oxygen levels)
||Purging air to be introduced to facilitate works with trained site team, escape set provision and continuous gas monitoring in place throughout CS working
There is also a final paragraph on quantitative risk assessments (i.e. risk assessments (RAs) with numbers), which states that they are not needed. The logic is that they are ‘only required to prioritise the controls’, and that because it’s a licensed activity you will be doing all of the controls. It is difficult to argue against this, but there may be a practical issue, as many PC clients will not recognise a RA without the quantification element.
What is the purpose of a risk assessment?
Other than these ‘minor’ points, the guidance contains sound advice. But I have a more fundamental issue with this as a standalone separate piece of guidance.
A simple way to think about risk assessment is that it’s like an exam. There is the question, and an answer – but you will also have your workings out. In the world of construction and asbestos – the method statement (how you’re going to do the job) is the ‘answer’, and the risk assessments are your workings out.
The answer is crucial, but the only way you can be sure to get the ‘right’ answer is after you’ve done the workings out. Far too many people make the mistake of seeing risk assessments and method statements as two separate exercises – or even worse two separate documents – and that’s exactly the trap that the current guidance as written is ushering us into.
Instead, the biggest section of the guidance should be focusing on how to translate the identified controls into the method itself. This ‘lost chapter’ in your method statement should have a work area set up section talking about using the hoist to lift the negative pressure unit (NPU) into position. It should be detailing the bagging of the AIB on the scaffold, and then the lowering of it to an operative on the ground. If indeed there is a confined space due to oxygen depletion, it should detail exactly how and when you will be introducing purging air (before you even start building the enclosure, I would presume).
What the current document tells us to do is complete a site-specific risk assessment (good), streamline it so that readers can focus on what is important without the fog of the mundane (great), and check regularly that it’s still valid (brilliant). But not once does it mention the reason we are doing this in the first place – writing a method that the employees can follow that will get them home safely (fail).
Nominations open for the FAAM Committee
Written by Nick Garland on Thursday March 10th 2022
Earlier this year the British Occupational Hygiene Society (BOHS) announced multiple vacancies on its board, along with its two faculty committees. Of these important bodies, regular readers will know well the Faculty of Asbestos Assessment and Management (FAAM) Committee, which is expanding with the addition of five new members.
I’m excited to have been invited to run for election to one of these new positions on the FAAM Committee. I’m especially honoured given the calibre of the others in the list of nominees – I’m standing alongside many highly respected names, and very grateful to Sam Collins and Yvonne Waterman for putting me forward.
I wanted to serve up a brief reminder of the role of FAAM, and how the Committee and its members shape its direction and decision making. The faculty exists as the professional home for all of us who deal with asbestos as part of their work in the UK. Its key focus is on supporting and ensuring the competency and expertise of its members, with the goal of reducing the ongoing issues – such as mesothelioma and other cancers – that relate to historic asbestos use in the UK.
The FAAM Committee exists to steer this work. In FAAM’s own words, it’s there to “act as the guardian of professional standards and ethics in the profession of asbestos assessment and management.”
In practice, this means regular meetings at which the FAAM Committee works towards developing and maintaining standards for the profession. Committee members take part in discussions around qualifications and faculty membership, participating in disciplinary matters, and generally helping to ensure that the Committee continues to deliver against its objectives and satisfy its overall purpose.
It’s an exciting and important role, for a vitally important faculty, focusing on one of the biggest ongoing health and infrastructure challenges faced by this country. As I say, I’m honoured to even be in the running, and I wish all the nominees the very best of luck in the forthcoming election.
If you’re a FAAM member, you should already have received an email inviting you to vote, sent on behalf of Alex Wilson, BOHS Honorary Secretary. If you haven’t seen it, please do check your junk mail folder, as my own invitation landed there.
The European Asbestos Forum (EAF) conference returns
Written by Nick Garland on Thursday March 10th 2022
While the pandemic has presented us all with very real challenges, it has also meant many missed opportunities. In a specialist industry like ours – where face-to-face knowledge sharing and training are crucial – it’s been hard to maintain momentum and drive things forward. That’s why I’m more than delighted to share the news that the European Asbestos Forum (EAF) conference is returning this year, with a two-day event in Amsterdam.
It’s great to see the conference return after its Covid-enforced hiatus – it was last held in 2019. EAF traditionally brings together many of the world’s preeminent experts on asbestos, its health risks, and its removal and disposal. It’s a place where professionals and asbestos victims alike can go to share their experiences, enjoying networking and social events to help build a close asbestos ‘family’. Together, the goal is that we’ll help develop the new approaches that will ultimately reduce harm for everyone.
Not the least of the experts attending the event will be EAF founder and president Dr Yvonne Waterman MFAAM herself. This year Yvonne is putting together a conference programme on the theme of ‘Asbestos and the State of the Art’. Expect a first day comprising workshops, and an exclusive excursion to visit a metal foundry that denatures and recycles asbestos-contaminated steel.
The second day of the conference will feature a variety of top speakers from across the globe, profiling new science, developments, innovations and insights. I’m also delighted to be chairing one of the two afternoon breakout sessions. It’s a real pleasure to be involved in such a highly regarded – not to mention enjoyable event!
I look forward to sharing more details in the future, but for now you can find more information on the European Asbestos Forum website. Please be sure to save the date:
10-11 November 2022
Van der Valk Hotel Oostzaan (Amsterdam)
I very much look forward to seeing you there.
When to visual in the four-stage clearance
Written by Nick Garland on Thursday February 10th 2022
One of the main objectives of the new analysts’ guide is to reduce analyst exposure, by clarifying what is licensed work, and what falls under the analyst’s remit. But the HSG 248 document is now massive, running to 238 pages. In cases where it hasn’t been fully read and understood there’s the potential for misunderstanding.
I’ve been thinking about this after a recent project, in which a difference in understanding created the risk of costs spiralling out of control. The project in question related to a wall that had sporadic asbestos insulation spatters underneath an imperfect layer of paint. The job was to scrape the wall back and then encapsulate the residues – so far so normal.
However, in this case the analyst was unwilling to enter the enclosure prior to encapsulation. This created the potential situation that, if the analyst wasn’t happy with their visual after encapsulation, the licensed asbestos removal contractor (LARC) would have to strip all the paint off and start again. The analyst’s view was that the project was not yet finished, the enclosure was therefore live, and that in line with HSG 248, ‘they do not do live enclosure entry’. For the LARC it represented a very expensive project risk.
So what does the guidance suggest? On the surface of it, HSG 248 is fairly ‘clear’:
The nature and extent of exposure will depend on several factors including the activity, the type and condition of the ACM and the effectiveness of any controls. For example, all entry into asbestos enclosures carries a risk of exposure to airborne fibres. Analysts should avoid as far as possible entering ‘live’ enclosures while removal or remediation work is still being carried out. If entry into a ‘live’ enclosure does occur there will be potential exposure to asbestos fibre concentrations above the control limit or short-term exposure limit.
Para 1.6, Pg 11 HSG248
However, if we look deeper (and when I say deeper, I mean we have to read to page 193) there’s more guidance under the section “Clearance for specific situations” – the bold is mine, for emphasis:
Inaccessible or impossible to remove asbestos
Spray-applied asbestos is often found in crevices or holes through walls where pipe work or girders run. These may leave asbestos residues that are impossible to remove. In these cases, the analyst may permit the use of non-flammable sealant such as foams or plaster to fill the hole and seal the asbestos within it. Before the sealant is applied the analyst must be satisfied that as far as reasonably practicable the asbestos has been removed.
Para A5.78, Pg 193 HSG248
Use of encapsulant or sealant
Where asbestos has been sprayed on to porous surfaces (e.g. breeze blocks, bricks, plaster and concrete), it is almost impossible to obtain an asbestos-free surface. The analyst should satisfy themselves that further removal is not reasonably practicable, and should advise the contractor and/or building client to seal the residual asbestos with a permanent proprietary sealant. The visual inspection can restart once the sealant has been applied and dried. In these circumstances encapsulation of asbestos should not take place before the analyst has seen the residual asbestos. A note should be made on the CfR and recorded in the asbestos register and management plan for the premises.
Para A5.80 Pg 194 HSG248
This second paragraph matches my example situation perfectly, but in fact both paragraphs make clear that the analysts must complete a visual before the LARC encapsulates any remaining asbestos to make sure (essentially) they are not hiding anything. While the general guidance in paragraph 1.6 says that analysts should avoid live enclosures ‘as far as possible’, this subsequent guidance takes us to the heart of the issue – a live enclosure is one where removal work is ongoing. In these situations, the enclosures are not ‘live’ as all possible removal has been finished.
In fact, my personal preference is to go a step further. I believe all such projects should be broken down like this:
- LARC cleans the enclosure
- Supervisor is satisfied that the surface is completely clean and no more dust or debris can be removed
- Analyst does visual and agrees or rejects the supervisor visual
- Reclean or not as appropriate
- Stage 3 air test:
- If it passes – optional encapsulation in half-masks after the enclosure comes down as an extra reassurance to the client
- If it fails – reclean. Encapsulate and repeat the air test
With either option after the stage three air test, the client gets valuable extra information that they wouldn’t get with the traditional approach. Based on what happens, they know to what degree they need to be cautious about the wall.
This is my personal preference, and I’d be interested to hear opposing views on it, so let me explain my reasoning. First, read this rather long paragraph from the Analysts’ Guide:
There may be occasions when some asbestos is to remain in situ in the enclosure. It may be that only damaged asbestos lagging is being removed from pipe work, and that undamaged material is to remain; or it could be that only a proportion of asbestos ceiling tiles is being removed. The analyst should have been made aware of this in the discussion on the scope of work as part of stage 1. The contractor should have checked the condition of the remaining ACMs as materials in poor condition could lead to a failure in the four-stage clearance when the analyst checks. If the analyst does find asbestos materials in poor condition these will need to be dealt with (eg repaired, encapsulated or removed, all of which actions are likely to need agreement of the building client and the involvement of a licensed contractor. The four-stage clearance should stop at this point and the contractor/building client should be informed. The four-stage clearance should not restart until the matters have been rectified. Any remaining ACMs in good condition should be recorded in the CfR so that the building client can update the asbestos register and management plan accordingly.
Para A5.76 Pg 192 HSG248
My logic is that if we are working on a wall that only ever had occasional splashes of debris – the risk starts at low. If:
- the project is actually to remove all exposed asbestos, and leave any that is concealed by a stable paint layer;
- the walls have been rigorously scraped and cleaned (possibly several times over the years);
- the thorough visual inspection(s) cannot locate any asbestos / dust / debris / loose paint (or it would fail and a re-clean would be demanded), all that remains is the possibility of asbestos under some remaining stable paint.
The selection of the scrape and vac technique is therefore intentionally leaving some asbestos in by design, and paragraph A5.76 is the reference that we should be looking to. This allows the analyst to make a judgement that all loose paint has been removed, and the asbestos left in by design would be noted on the four-stage clearance (4SC) certificate.
While we haven’t 100% removed the asbestos-containing material (some is being left in by design), stage two has passed, and there is no absolute need for encapsulation. But if the air test subsequently identifies a problem then we must encapsulate. On the other hand, if the whole 4SC passes, and we still want to encapsulate, well, that’s an ultra risk-averse decision that can be completed as a non-licensed activity.
I appreciate this is possibly a left field opinion, but I believe it addresses what we are trying to do which is understand and mitigate risk, rather than blindly follow what we’ve done before.
A look ahead to 2022
Written by Nick Garland on Wednesday January 19th 2022
We’re already a fortnight into 2022, the schools are back, and our focus is well and truly on the year ahead. It’s a sad reality that we’re all still living with the risk and disruption of Covid-19, but it does seem likely that this will be the year we move towards living with the virus. And as the policy shifts away from trying to contain it, it’s likely that in some ways this will be a more normal year than 2020 or 2021.
So what can we expect in the construction and asbestos industries? First and foremost, it seems that we’ll see a return of more in-person events. As it stands, most major industry events in 2022 seem likely to go ahead in person, which should bring more opportunities to network and catch up with colleagues we may not have seen for some time.
At Assure360, we’re seizing the opportunity, and kicking the year off with the return of our popular breakfast meetings. If you’re not familiar, these serve as a warm up to selected ACAD regional meetings, and provide an opportunity for existing customers to discuss the future direction and evolution of the Assure360 system. It’s our community’s biggest opportunity to help shape the next stage of Assure360 development.
The meetings aren’t just for existing customers, though. Me and my brother, Rick Garland, will be happy to provide all comers with an overview of the system. We’ll be able to answer any questions and give demonstrations, all while you enjoy a light breakfast. So please do come along to one of the following:
- 1st March, 8:00am – Cardiff Arms Park, CF10 1JA
- 2nd March, 8:00am – Meeting Point, 26 & 28 High St, Kegworth DE74 2DA
- 3rd March, 8:00am – Novotel Manchester West, M28 2YA
Please RSVP via our LinkedIn events pages or by email to firstname.lastname@example.org so we can confirm numbers for catering.
It’s hard to predict exactly how the rest of the year will pan out, but among the big events likely to go ahead, the Hazardous Materials Expo is set for 14-15 September at the NEC. Assuming the situation allows for it, expect a return to a much bigger event than has been possible for the last two years.
We also hope that the improving situation lets the 10th international symposium on modern principles of air monitoring and biomonitoring (Airmon 10) go ahead. Originally scheduled for last September, it’s now planned for 7-10 November. As always, we’ll be trying to keep our regular events listing updated as more events are announced or confirmed.
Finally, a reminder that the Work and Pensions Committee is continuing its examination of how the Health and Safety Executive manages the continued presence of asbestos in buildings. After a call for evidence and the first oral evidence sessions last year, the committee will continue its work of examining the risks, how the HSE manages them, and how UK practice compares to the rest of the world.
As we said, it’s hard to predict exactly how the year will pan out, but we can hope that things return more closely to normal as vaccination and other measures help bring Covid under control. However things develop, we wish you all the best throughout 2022 and beyond.
There’s more to DCU safety than gas and electrics
Written by Nick Garland on Wednesday January 19th 2022
I originally wrote this review of the Asbestos Network technical committee’s upcoming guidance on DCU safety two years ago, and in some ways not a great deal has changed since. The guidance is still in draft, still imminent, and still missing some of the more practical direction on safety that I identified.
Part of the issue is that the scope of the guidance is limited to gas and electrical installations, but in reality the DCU represents a wider range of risks. In particular, I feel it’s now important to revisit the draft guidance in the light of Colette Willoughby’s raw and emotional testimony at FAAM last year. With the benefit of Colette’s experiences and insight, it’s clear that we must also consider analysts’ personal safety.
We all know that the job of asbestos removal is dangerous – that’s why it’s so tightly regulated. But while the most serious risks are often found inside the enclosure, they don’t stop there. The decontamination unit (DCU) presents its own hazards, including:
- personal safety and security for analysts
- exposure to asbestos
- electrical and gas hazards
- crush injury when setting up or decamping
So what guidance is available, and how can it help keep analysts and operatives safe?
For the last two years the Asbestos Network technical committee has made time in several meetings to discuss DCU safety. Unfortunately they’ve made slow progress in producing guidance, and the final version hasn’t been issued.
I wanted to revisit what there is so far. For the most part it’s good stuff, but the way I perceive our workplace changed at the 2021 FAAM conference. Colette opened my eyes to additional risks faced by female analysts, which can and must be addressed. In this light, DCU guidelines that focus only on electrical and gas safety are missing a major opportunity to protect our colleagues.
Personal Safety and Security
Colette’s FAAM talk has shone a light on what should have been blindingly obvious for decades – decontaminating in the DCU represents a very vulnerable moment for a female analyst.
The Construction (Design and Management) regulations state: “Separate washing facilities must be provided for men and women, except where they are provided in a room the door of which is capable of being secured from the inside, and the facilities in each room are intended to be used by only one person at a time.”
As we know, DCUs are shared, yet their access is controlled by an external lock. Obviously this isn’t compliant. What has also become obvious, given the experiences detailed by Colette and the other female analysts she has spoken to, is that it’s simply not appropriate protection for our colleagues at a vulnerable time.
I am sure that the makers of DCUs can and should implement better solutions that give the occupant of the DCU control over entry and exit. But in the meantime, adding a simple bathroom-style bolt to all of the doors would seem like a very easy and quick solution. Clearly, there would also need to be a revised DCU procedure, as the unit would not be accessible from the time the analyst leaves it secured, until the point they leave the enclosure and fully decontaminate. During this time it would effectively become a one-person unit, but this is not that different to current, Covid-era practice, where operatives’ exit from the enclosure is staggered so as to be one at a time.
Another significant issue raised by Colette is that disposable underwear is simply not available for women. Laundering services for contaminated clothing don’t seem to be commercially available, either. Employers need to find an acceptable interim solution – such as using standard underwear or swimsuits and disposing of them after a single use.
The following is predominately unchanged from my review a year ago and concentrates on the physical issues covered (or not covered) by the guidance.
The gas safety guidance starts predictably enough, instructing that gas boilers should meet the required BS EN standards, that they should be installed by an accredited gas fitter, and that each appliance should be fitted with an isolating valve and flame failure device. However, it then goes on to say that all boilers situated in the clean end – rather than a sealed cupboard – should be of the balanced flue type.
For those of us who aren’t gas engineers, in a balanced flue (also known as room-sealed) boiler, the entire combustion circuit is sealed off from the room that the boiler’s in. The fresh air supply, combustion chamber, heat exchanger and exhaust gases are open to the atmosphere only, meaning that if something goes wrong, any toxic or flammable gases should be vented out of the DCU.
Insisting on this type is wise, as they’re much safer than open flue boilers which draw their combustion air from the room they’re in, but following the guidelines might mean an expensive upgrade for any older DCUs.
There are some other issues to pick up on. If the boiler is mounted in a separate sealed cupboard it is best practice for that boiler to be room-sealed anyway, but regardless the cupboard door must be closed and sealed at all times. Many times I’ve seen cupboard doors left open, sometimes for convenience, but sometimes because there is otherwise insufficient ventilation in the cupboard for the boiler to work. If the boiler only works when you leave the cupboard door open, then it’s effectively in the clean end, and must be room-sealed.
It’s important to understand that a room-sealed boiler doesn’t guarantee that combustion products like carbon monoxide (CO) can’t leak into the room. Seals can fail, so there should always be a CO alarm fitted in the clean end, adjacent to the vent to the shower compartment. Correct positioning is important – I’ve seen random locations, not all of which will be effective according to the guidance.
Gas Bottle Storage
The guidance here pretty much summarises existing standard guidance. In brief, the gas bottle(s) should be:
- External to the DCU
- Vented to the outside
- Labelled as carrying flammable gas
- Positioned vertically
- Propane rather than butane (which has issues below 5°C)
Note, too, that there should be a maximum of two 16kg bottles, and that nothing spark-generating should be stored with them.
So far, so standard, but then we get to areas where I’m not sure we have much compliance. Gas bottles should be:
- Ventilated top and bottom, with a minimum area of 50mm2, or 1% of the floor area (whichever is greater)
- Separated from the clean end by a barrier with a half-hour fire rating
- Secured rigidly top and bottom
- Connected to a date-stamped, British Standard-compliant low-pressure regulator and hose
- Kept in the bottle compartment during use
Gas Safety Certificate
There’s some welcome clarity here: DCUs require mandatory 12-monthly gas-safety certificates. Some HSE inspectors are still referring to a very old note that mandated six-monthly inspections for open-flued units. This detailed guidance supersedes and clarifies this.
In day-to-day use, the gas pipework needs to be checked daily and at the end of the project – not a job that I’ve seen on many supervisor checklists. There should also be emergency procedures to follow if gas is smelled. The advice states that gas should be isolated at the end of the shift, but it then goes on to contradict itself, suggesting that if there’s no oil-filled radiator the pilot light should be left running in cold weather. Presumably, this will be cleared up in the final pre-publication checks.
All vents, clearly, need to be kept clear. If you have an open-flue boiler in a sealed cupboard, that cupboard needs to be kept closed and the seals must be in good condition. In all cases the CO alarm must be checked at least weekly.
Electrics & Earthing
This is usually the area that gets the most attention when a job is audited, but the justification for this seems patchy at best. To my knowledge there has never been a DCU electrocution, so the previous guidance has clearly been serving us well.
This guidance states that all DCUs must regularly be electrically inspected and tested – we rarely see units that haven’t been. In fact, the biggest risk is likely to come from using the client’s mains supply if it turns out to be faulty. The moment of greatest risk is brief – when an individual is standing on the floor, but touching the metal frame of the DCU.
The guidance offers some pointers on how to eliminate electrocution risks:
- DCUs should be protected by a residual current device (RCD)
- Earthing should be independent of any client supply, via copper rod. This should be driven into the ground for some distance, which itself raises hazards that should be protected against
- You should investigate the maintenance of the client’s electrical supply
- Power sockets used as a source should be checked with an ‘advanced plug-in socket tester’
However the guidance really calls for better design of DCUs to ensure better electrical separation, along the lines of a bathroom. Generally there should be layers of insulation between electricity and people, and the power for recharging masks should come from two-pin, low-voltage sockets. Where there are concerns about the quality of the source electrical supply, it’s perhaps wisest to use a single-phase generator rated below 10kVA, which doesn’t need earthing at all.
Movement and positioning
As I laid out last year, another pressing DCU safety issue relates to the risks when positioning them. DCUs are heavy beasts. Moving them using a vehicle presents multiple hazards, and manoeuvring them by hand typically takes more than one person. Both approaches require coordination and well-designed procedures to prevent workers from being trapped or injured, yet these are all too often overlooked.
I personally know of one serious injury that has occurred due to lack of concentration when manoeuvring a DCU. The following is the safe working procedure that was created after the event:
When positioning, re-positioning or removing a DCU from site it is critical that it is done so safely. DCUs are heavy pieces of plant. They can cause injury by trapping operatives against fixed structures and can become unstable if moved over rough ground.
- The route that the DCU will be moved over must be checked. It must be level and clear of obstructions. Hazards must be removed/corrected prior to moving the DCU
- One operative is to hold the hitchcock and handbrake to steer. This operative oversees the manoeuvre and will instruct all those assisting
- A maximum of three operatives will position to the rear of the DCU, and will be instructed when to push and stop as the DCU is being moved. At no point is anyone to use the two front handles on the DCU for pulling the DCU from the front
- The DCU will be guided to the van and hitched onto the van
- Driver to check electrics before moving away
Where necessary – a traffic marshal will use a barrier to stop traffic when the DCU is to be moved into the road to be hitched onto the waiting van.
It’s important to reiterate that the scope of the DCU guidance was limited to gas and electricity issues. As such, I know I’m being slightly unfair in expanding my analysis out to other issues such as personal safety and manual handling. However, both are important issues, and as we’re not likely to get more guidance on DCUs for the foreseeable future, this seems an ideal time to provide something comprehensive whilst the bonnet is up.
Female analysts and four-stage clearance testing – the need for change
Written by Nick Garland on Thursday December 9th 2021
I normally do a roundup of the FAAM asbestos conference, letting those that didn’t get to attend know some of the more important areas that were discussed by the leading thinkers in our industry. I will be doing that, but this piece is in many ways much more important.
** Warning, the content includes an upsetting personal revelation, and some readers may be affected by the issues raised.**
Colette Willoughby’s talk on the second day, Female Analysts and Four-Stage Clearance Testing, was the most raw and personal talk I have ever heard at a conference. The talk was split into two parts – the first a short history lesson on how things have changed during Colette’s distinguished career.
Having started out in 1982, Colette really was at the birth of the new world of asbestos analysis. She entered an industry where – astonishingly – a clearance just meant the contractor dropping a pump off at a lab. She witnessed it change to one where analysts started actually doing tests and – most revolutionarily of all – a visual, where the analyst actually checked the contractor had done what they said they would. My career started shortly after this, where people still talked about what it used to be like. Now this seems more like myth and legend.
The main part of the talk, though, related to Colette’s own experiences, and those of four other women she had interviewed. The interviewees were Jean Prentice, Joanna Parker, Sam Collins and an anonymous analyst still actively doing four-stage clearances (4SCs). The five women between them represent a huge amount of experience, gained from the mid-1960s to the present day.
Colette’s talk frankly and openly discussed the widest range of experiences, from the broadly positive (Sam and Jean), to the worst you can imagine. Colette, despite being one of the warmest and most professional people you could ever want to meet, has experienced some of the most unwelcome experiences possible. From initially not being allowed on site at all, to – after years of campaigning – being told: “OK, but we don’t think you’ll cope”.
What followed was a litany of sexist ‘banter’ from contractors, with comments such as: “You’re a woman, you’re just picky” and “You’re more used to cleaning: no wonder you can do it better.” Yet at the back of Colette’s mind, a traitorous voice insisted that now she’d convinced her bosses she could do the job, this was something she just had to put up with.
The ‘banter’ was shameful enough, but examples of criminal abuse followed. On numerous occasions, naked operatives have intentionally followed her into the decontamination unit (DCU) – the most recent occurrence being only four years ago.
Then came a horrific experience where she was raped on site by the supervisor. As Colette explains: “I was sexually abused and was raped on numerous occasions, but did not have the ability to go back and say anything because I was quite consistently told by him ‘Nobody’s going to believe you. You’re 23/24 years old, I’m a middle-aged man. I’m well respected, you were just asking for it. You’ve come into our environment [and] you’ve got to put up with it’.”
How Colette kept it together after that I will never know.
While spared the full horrors of Colette’s experience, Joanna and the anonymous, still-serving analyst both had multiple examples of threats of, or actual sexual abuse. And they both shared the belief that reporting it would be futile.
The hostile environment
Asbestos is of course part of the construction industry. To put some numbers to the hostile environment that women in our industry endure, Colette turned to a 2017 report, which found that four in 10 women had been on the receiving end of unwanted sexual behaviour, and that one in nine mothers had been dismissed, compulsorily made redundant, or treated so poorly that they left the post. The pay gap was 17.3%, to add insult to injury.
Colette is the chair of NORAC, Principle Examiner for asbestos at BOHS, and Director and Technical Expert at ACL. She is, quite frankly, one of the most impressive consultants in the industry, but the abuse and discrimination that she and other female analysts have experienced left me and the rest of her audience stunned. Speaking personally, I am ashamed of the ignorance that I had been labouring under.
How do we change?
Colette then moved on to what needs to change, and how. The distance we need to travel is vast – but at some levels utterly basic. For example, PPE must by law be fit for purpose and fit for use. But disposable overalls and underwear are all made for the male body shape and don’t fit women. Here, companies are effectively in breach for failing to provide the correct protective equipment.
The DCU poses a particular problem. Construction (Design and Management) regulations state: “Separate washing facilities must be provided for men and women, except where they are provided in a room the door of which is capable of being secured from the inside, and the facilities in each room are intended to be used by only one person at a time.”
DCUs are shared, yet their access is controlled by either a key or a combination lock, both of which are external. Again, this means they’re not compliant. I can only think that DCU manufacturers must be ignorant of the issue, or they would have changed this already.
Finally, Colette stressed two more areas where we need to do so much more. The first is the glaring need for simple respect. It should go without saying, but is clearly, sadly, very very lacking. Male colleagues must do all they can to help here – calling out even the borderline ‘banter’ – never mind the sexist abuse above.
Employers need to acknowledge the differences, and provide training so that female analysts are better prepared for the pressures. Crucially, they also need to offer support, so that analysts are comfortable and secure enough to report and get help when they need it.
As I said, it was a raw and eye-opening talk, and one which I profoundly hope will bring about change. Hearing the testimony were HSE officers, asbestos removal trade organisations, and consultancy business owners among others. It’s an oft repeated phrase that asbestos is the most regulated industry after nuclear – surely there were enough of the ‘right’ people in the room to make a change.
If you’ve been affected by this subject and wish to respond or raise similar concerns, email email@example.com. This is a totally confidential inbox that is monitored by Colette, Jean Prentice and Sara Mason, who are all on the working group set up in the wake of FAAM to address the issue.
FAAM conference review – useful, compelling, and more thought-provoking than ever
Written by Nick Garland on Thursday December 9th 2021
FAAM 2021 was held virtually on the 17th and 18th of November, and was broadly a very interesting and engaging conference again. I say ‘broadly’ in no way intending to underplay it, as all of the talks were fascinating. However, Colette Willoughby’s day-two presentation on female analysts and what they have to endure was so raw and personal that it quite unavoidably dominated the whole event.
I have written about Colette’s talk separately, as it deserves to be considered separately and seriously by us all. However there were many other thought-provoking and informative talks throughout the programme: here are some of the highlights.
The conference started with a fascinating, deep look into the marriage of cutting edge new technologies to tried and tested Phase Contrast Microscopy (PCM) techniques. Frontier, Ethos and xRapid all had slightly different takes on enhancing PCM with artificial intelligence and robotics, to improve consistency, accuracy and speed.
That today’s PCM process is quite straightforward probably shouldn’t be surprising, given that it’s a technology that predates WW2. For asbestos, the analyst looks down the microscope and carefully looks for any fibres that follow the accepted rules as to what qualifies as asbestos. They count the number that fall within a defined area in the middle of their view (or field), then move this view randomly and make another count, adding to the total. This is repeated a given number of times to give a total number of asbestos fibres in a given number of fields.
The weakest link
That’s the process, but it’s important to look at the problems humans bring to it. I can testify to the first flaw, which is that the mark I eyeball is of varying quality – and my eyes are not what they were. So our ability to see the very fine fibres will vary. The rules as to what ‘counts’ as a fibre are straight forward, but we have to apply them correctly every time.
In addition, humans get tired, and tend to be less competent later in the day. We’re also flawed in that we have desires, and that we can be influenced by persuasion or threats that may consciously or otherwise affect which fields get counted. Add in the time pressures we all need to work under, and you will understand that the accuracy of on-site analysis is different to the work done in a lab with a nice cuppa to hand.
The application of AI and robotics has the potential to eliminate nearly all of these issues. Random is random, the rules are the rules, a calibrated eyeball mark II is accurate to a known degree – and it doesn’t get tired.
Automated analysis is also a lot quicker, at less than five minutes per sample. All of this really does promise a fascinating and exciting change for our analysts. Supported by AI, they will be able to concentrate on the really crucial visual inspection. And when that passes, the computer says no (or yes).
Ethos, based in Scotland, has taken the technology a step further with a kit that can take the sample as well. Currently the size of a pedal bin, the technology incorporates a very powerful pump, cartridges of filters, slides and a robotic microscope. Essentially you position it in the enclosure, press go and it takes the sample, mounts the slide and starts reading it. You can then move it to a new location whilst the analysis is ongoing and repeat.
Ethos says the turnaround for the first sample is only 20 minutes, but the current model is an advanced prototype and has limitations. Not least the fact that it looks heavy – making it a potential challenge for some analysts to heft around.
Rolling moss uncovers the stone?
The next really fascinating talk was a case study of a project being led by Colette. The site is a vast military storage facility, with 60 acres of asbestos cement roofing! All of it is past its anticipated life expectancy, but still, asbestos cement: what’s the problem?
In fact, one of the main issues is moss. As it turns out cement is not some inert binder – but an ideal source of nutrients. Here you can see how enthusiastically the site has been colonised.
There is some greenery, but there is also a lot of dead moss that eventually drops off. And with the dead moss comes pure asbestos fibre.
This material has contaminated walkways, roads and the nation’s fighting vehicles, and potentially exposed serving personnel. It’s an ideal nesting material for birds, who may have carried it away to contaminate nearby houses. Over the past two and a half years the project has evolved from assessment, to imaginative decontamination techniques.
The ECHA chamber
The afternoon of the first day was devoted to the European Chemical Agency (ECHA) subcommittee’s research report on a potential for a new occupational exposure level (OEL) for asbestos.
Just to rewind a bit, the report’s terms of reference were to:
- Assess the different types of asbestos fibres and their corresponding health effects
- Assess the appropriateness of different limits for different asbestos types (currently there is just one control limit set at 0.1f/ml)
- Review or propose revised OELs
It’s an important area for legislation, as different types of asbestos fibre are known to pose widely differing levels of threat. For example, there’s a nearly 500:1 jump in mesothelioma risk with exposure to crocidolite (blue) compared to chrysotile (white) asbestos.
However, the committee seems to have gone off-piste, and has instead chosen to answer entirely different questions with dubious scientific justification. Andrey Korchevskiy and Garry Burdett’s presentations laid bare the problems that would be encountered if the report was accepted.
Its first fundamentally flawed assumption is to assume that operatives won’t know which type of fibre they’re working with. Given that the ‘O’ in OEL stands for occupational, it’s a very sound argument that people working with asbestos rather should know its type. Assuming that, just because there’s a Europe-wide ban, all exposure will be a mixture of fibres will lead to a significant unnecessary exposure risk.
Yet despite this, the committee elected to average out the danger and assume a single risk for all fibre types. The result of this crude approach is to set the level of risk far too high for chrysotile, and far too low for amosite and crocidolite.
Unasked for – the report also discards proven PCM technology in favour of expensive and cumbersome electron microscopy. All the existing lifetime risk assessment data is based on PCM science, and it would be a stretch to apply the new technology to old data. Moreover, if this recommendation were adopted, it would likely also prove unachievable for poorer EU nations.
As I said, for me day two was dominated by Colette’s talk Female Analysts and Four-Stage Clearance Testing. I had expected this presentation to cover the practical issues that our female colleagues experience, but it was so much more disturbing and worrying than that. Focusing on her own experience and the testimony of four other analysts, Colette left her audience pretty stunned and speechless. I have covered her talk and the issues it raises separately, to give it the attention it deserves.
To sum up, the FAAM conference was yet again incredibly useful and informative. More than ever it was also thought-provoking, and demanding of self-reflection. The overall impression it gave was that change was coming – both due to the positive impact of new technologies, but also I hope in response to the now public darker side of our industry.
FAAM conference preview – don’t miss it!
Written by Nick Garland on Thursday November 11th 2021
After the roaring success of last year’s virtual FAAM conference, the team made an early, risk-averse decision that this year, FAAM Asbestos 2021 would also be online. We will all be ‘gathered’ for the 17th and 18th of November for an intense and varied programme of speakers that includes industry experts, doctors and academics.
So what ground is the conference covering this year? It starts with a deeper look into the use of AI in reading asbestos slides. You may remember that I wrote about Marvin the robot after Frontier Microscopy’s presentation at the 2019 European Asbestos Forum conference.
We were told how it was used in Australia, where getting analysts to remote places was a huge challenge. Instead, samples are sent to a central lab for analysis, where Marvin uses AI to analyse the samples more quickly and accurately than humans. At FAAM we’re going to hear from Frontier, Ethos and xRapid on where the technology has gone in the last couple of years.
After the morning break, we will be looking at more traditional approaches. But even here there’s a new slant – discussing how certain changes to how we take the sample can give us the opportunity to improve the limit of quantification.
The rest of the first day – with one notable exception – will be focusing on the European Chemical Agency (ECHA) Assessment for Asbestos. You may not be aware, but the ECHA produced a substantial report back in February, seeking consultation on its recommendation that the occupational exposure limits (OEL) be dramatically reduced.
You’d wonder who would argue against this kind of proposal, but in fact it seems that the science behind the move may be flawed, and the recommendations impractical. Andrey Korchevskiy, Robin Howie and John Hodgson are all speaking on the subject then, after the break, Gary Burdett will present the ECHA opinion.
Outside the ECHA chamber
The ECHA exception I mentioned is Dan Barrowcliffe, who will be presenting on the exposure study that he led on removal operative exposure during licensed work. Dan has been very present at FAAM conferences, but has recently taken up a post at the new Building Safety Regulator. I’m sure he’ll be at future conferences, though: we all know there is no real escape from the asbestos industry!
Day two kicks off with a series of talks on the UK’s asbestos legacy, with a focus on mesothelioma and treatment advances – a subject that is ever present in our minds. Before lunch we look at the law, and the role of the expert in asbestos claims. After the gripping mock trial last year I expect this will be a compelling examination of what can happen when it all goes wrong.
We round up the day with site-based issues, ranging from communication between clients and LARCs, and Sara Mason’s talk on the challenges to site analysis. Several talks here sound promising. I’m eager to hear from Dale Timmons of further advances in thermochemical asbestos destruction – a technology that could hold the key to preventing landfilling.
I’m also interested in Graham Warren’s look at the implications of ‘net zero’ for the asbestos industry. And finally, given that the four-stage clearance (4SC) is a topic close to my heart, I’m hopeful that Colette Willoughby will be telling us about some practical solutions to the additional challenges faced by female analysts during the 4SC.
It’s a packed programme, and my experience from last year suggests that – despite the virtual format – the event remains unmissable. You can sign up for FAAM 2021 via the BOHS website. I hope to ‘see’ you there!
Relicensing, and the importance of external audits
Written by Nick Garland on Thursday November 11th 2021
With the HSE’s electronic licence assessment process now nearly three years old, the original pilot companies are going through the process again. The promise for the new system was that licensed asbestos removal contractors (LARCs) would feel the pain only on their first time through, with all subsequent renewals being much more straightforward. Only time will tell whether the HSE’s view of simplicity matches ours.
But assuming the process has bedded down into an initial, intense assessment, followed by more of an ongoing ‘light touch’, what is certain is that the regulator will be focused on what’s new. This will range from any changes you have made internally, through the findings of any HSE visits, and crucially the results of your own audit programme.
And as anyone that’s been through the licence process will know, while the HSE values a well-managed internal audit programme, external audits are near-mandatory – and huge store is put on their findings.
When internal audits do more harm than good
First off, it’s important to explain that I’m a huge supporter of internal audits. Without looking for yourself, it is easy to fall into the trap of running your company with blinkers on. This wilful blindness will lead to poor practice through ignorance, and a degree of shock when others – such as the HSE – see something that you haven’t.
The key is that these internal audits need to be effective. Significant pitfalls to avoid would be:
- Always using the same auditor
- Contracts managers auditing their own jobs
The weaknesses in both come because it is human nature to see what you expect to see. If you always have the same auditor, they’ll always spot the things they’re great at spotting. The things they’re not so good at spotting will always get missed. When marking your own homework it is difficult to spot your own mistakes!
Contracts managers (CMs) who audit their own jobs will be particularly vulnerable to this. The takeaway is not necessarily to (as some would say) avoid CM auditors, it is rather to ensure that you’re aware of their limitations, and that you look for these in the results. Whether audits are conducted by a CM or a regular internal auditor, if they typically don’t find anything wrong, it’s unlikely to mean there isn’t anything to find. In fact, it should be seen as a warning. A blend of auditors makes for a healthy system. A LARC can benefit most from the eyes and interpretation of the CMs, the MD, and even supervisors themselves.
This last group is often underused for auditing, but while they don’t realise it, supervisors audit every job. Often they even record their findings – for example your supervisor’s pre-start check is an audit of the RAMS (risk assessment method statement) against the reality they are faced with.
It’s important to use this data, and so recording it needs to be easy. Assure360 is specifically designed to streamline all aspects of construction safety, so we allow supervisors to complete pre-start checks digitally – with the data automatically contributed to the internal audit system.
Assure360 also allows safety tours, so any time that the CM and MD complete a site visit they can record any issues they see. Again, this flexibility helps record and highlight issues that typically get resolved there and then, and would otherwise be forgotten by the time an audit rolls around. Finally – uniquely to Assure360 – we help avoid the ‘snow blindness’ sometimes caused by over-reliance on internal audits. All our users get to see benchmark data from the many thousands of audits already completed on the system – letting you learn from other people’s lessons.
External sets of eyes
It’s clear that a well-managed internal audit programme is crucial for health and safety. So what does an external expert add? Their key role is to provide a check and balance on your own observations – allowing you to recalibrate.
The HSE knows all too well the limitations of internal audits, and approaches them with a pinch of salt. For the purposes of licence assessment, it needs some sort of external verification of the evidence submitted. In the past this would have been HSE visits – and lots of them. But with budgets as they are, we’re not seeing the dramatic step up in inspections that would be needed. In fact the numbers are down again – continuing the trend of the last four years:
||HSE Annual Report 2017 / 2018
||HSE Annual Report 2019/2020
||HSE Annual Report 2020/2021
|Proactive inspection visits
To supplement its own visits, the HSE will therefore be focusing its attention on what other external eyes have spotted – and that means the finding of external auditors.
The first round of the new licence assessment required LARCs to submit three internal and three external audits conducted in the six months before application. With the HSE’s licence assessment now focused solely on what’s new and what’s changed, these audits will take centre stage.
All of which brings us back to a subject I wrote about earlier in the year – the increasing importance of the external auditor. In any healthy auditing ecosystem – and explicitly in the three-and-three minimum outlined by the HSE – the independent auditor presents a vital, fresh perspective on the otherwise closed feedback loop of internal audits.
Fundamentally, external auditors improve the overall quality of an audit system in multiple ways:
- A fresh pair of eyes – external auditors are fresh to the project, increasing the chances they’ll spot problems that have fallen into your blind spots
- Different experience and approach – the best auditors have a broad range of experience that may extend beyond yours, helping provide richer or complementary insights
- They see many different approaches – by auditing multiple companies they will be able to form a view of best practice and pass that on
- Independence – the external auditor has no skin in the game, and this lends them greater authority
Independent audits should always be seen as a vital check, regardless of how we’re licensed, but the HSE’s increasing reliance on them may well be about to drive up demand as the industry begins its second rotation through the new system. To the handful of existing quality auditors, we need to add other skilled and experienced professionals, able to help protect and improve the safety standards to which we all aspire.
If you know my history, you’ll know this is an area I feel strongly about. Through Assure360 I’m determined to help improve auditing standards in our industry, which is why we’re continuing to offer Assure360 as a free-of-charge service to suitably qualified independent auditors. Whether or not the end client is using Assure360, this means the auditor will benefit from:
- Big efficiency savings on site – speeding up note taking
- Elimination of manually drafting a PDF report
- Access to all the benchmark data from the 10,000+ audits recorded in Assure360
- Dashboard and reporting tools that allow the auditors to offer sensible, data-driven advice to their clients.
The system is even more appealing if the client happens to be an Assure360 customer. In these cases, all audits will automatically read across to the client’s slice of the system, allowing:
- Smooth close out of actions and prevention of recurrence
- Population of client’s trend analysis
- Population of the client’s individual competence assessments
We’re keen to expand the group of selected, quality auditors who use Assure360 to simplify their audits, and improve the depth and clarity of their reporting. If you’re interested in joining them, why not get in touch to understand more about how Assure360 can support you?
“Assure 360 auditing software has made my auditing process seamless, and provides a quality audit for my clients in an easy-to-read format. The system is very stable. Nick and the team are on hand to provide support when required. It is very rare to find such experts in the field running and operating great software.”
Craig Ablett, Consulo Health & Safety Ltd
“I just find it so, so easy to use, so simple. It doesn’t take up half the time of my own audit system – where I’m uploading photos, copying and pasting information. It’s none of that, it’s quick. It’s a great app really.”
Chris Pedley, CP Safety
“It’s the benchmark we should all be working to. It covers just about everything you could want on an asbestos audit, along with general health and safety.”
Dave Philips, D&N Asbestos Advisory Services
“I’m an absolute fan. When I turn up on site, I’m not carrying pens, paper and clipboards. It’s just user friendly, it’s so easy.”
Paul Beaumont, BIACS
“My clients aren’t just getting a box-ticking exercise, they’re benefitting from my expertise and feedback, and the software’s ability to help produce actionable information.”
Chris Pedley, CP Safety
Written by Nick Garland on Thursday October 14th 2021
Construction health and safety management case study
Originally founded in 1965, the Breyer Group has grown to become one of the UK’s leading principal contractors. Still owned and managed by the Breyer family, the group now has more than 400 employees, and specialises in roofing, construction, responsive repairs and maintenance.
Breyer’s success is founded on its reputation for customer service, environmental care, and commitment to health and safety. Its management systems are ISO 9001:2015 and ISO 45001:2018 accredited, underlining its focus on delivering satisfaction and ensuring the wellbeing and safety of everyone on site. To this end, it has a dedicated Health, Safety and Environmental team, which works to performance targets set by the board.
As a large company comprising hundreds of staff, working on multiple sites for many different clients, Breyer faced the challenge of effectively monitoring and maintaining health and safety. Historically the company had audited its sites with a bespoke software tool, but this didn’t extend to tracking accidents and incidents. The cost and complexity of maintaining separate systems had begun to mount, and were becoming an obstacle to improvement. In addition the internal system’s support contract was due to expire, adding urgency to the need to find its replacement.
Breyer became an early customer for the Assure360 system, and the Assure360 Audit health and safety auditing app. The company now also uses Assure360 Incident to track and act on all accidents, incidents and near-misses.
Assure360’s configurable cloud database delivered the flexible approach that Breyer had been missing. Quickly implemented to work ‘out of the box’, the system was further customised to provide bespoke auditing questions. Not only did it replace and build on the functionality of the previous auditing tool, it combined accident and incident tracking into a single, integrated solution.
Enhanced by the specialised Audit and Incident apps, Assure360 provided Breyer with a single, centralised platform for the effective monitoring and management of health and safety throughout the group. Reporting observations and incidents became quicker, while the system provided ready visibility to all who needed it – from site managers and clients, all the way up to the board.
Today, Assure360 plays a vital dual role within the Breyer group. Most importantly, it’s fundamental to the group’s ability to inspect sites and ensure compliance with best practice. The system’s granular approach to data, and cloud-based synchronisation between site and office, ensures that the management team is immediately provided with audit and incident data.
Secondly, Assure360’s powerful reporting and analysis features help the business demonstrate its legislative compliance and exemplary track record – whether that’s to internal managers, the Health and Safety Executive, or to potential clients.
What the client said
It’s fundamentally important to us as a business that we bring our staff home safely every day. Only the very highest health and safety standards will do.
More than this, our customers only want to work with contractors who can demonstrate exemplary standards. It’s important for winning new business and building long-term partnerships that we have the track record and the figures to back up our strategic commitment to safety.
And while safety is our overriding focus, there are other advantages to constantly striving towards the safest working environment. By minimising injury, we pay less on insurance, for example.
Assure360 has been a breath of fresh air since we started using it. It allows us to quickly and easily audit sites, and to report, track and investigate health and safety incidents. The cloud database lays all of the information I need to do my job on a plate. I can instantly understand what our findings are telling us. Reporting to the board is no longer something I have to take weeks to prepare for: everything is at the touch of a button.
And that’s what you want. You don’t want to trawl through loads of paperwork and information. That’s not relevant today. Assure360 is easy to use and has helped us get rid of all that. What’s even better is that the system is so easy to use, it is no longer me and my team that ‘do health and safety’ – all of the contracts managers and directors participate.
It makes safety proactive rather than reactive. With the Assure360 Incident app – because everyone loves an app – something that people look at as a boring chore in fact becomes interesting because you’re looking at a mobile phone. They haven’t got to fill a form in, or go to the table we used to have.
They just get out their phone, answer six or seven series of questions, upload a photo, send it off to me and it goes into my stats. So I can see efficiency, and near-misses like “Tiles left on footpath” or “Skip not closed”. It’s good for myself, but also clients: they always ask “How do you report near misses?”. With Incident I can show them.
One of the things I like about Assure360 Audit is that it doesn’t just highlight non-conformity, it creates an action for what you’re going to do to close it out. So for example you might sit down with the contracts manager and say, “Handrail missing from scaffold.” You’d resolve it by assigning the action to contact the scaffold company, with a three-day timeframe. Then the contracts manager or site manager, when they’ve rectified it, will go in, upload a photo, and then they’ve closed it out.
So it’s not just there to show people’s failings, it’s there to put an action plan in place. A lot of apps just go out and mark everything as bad news – “That’s wrong, that’s wrong, that’s wrong, that’s wrong” – but not how you’ve closed it out or how you’ve made it safe. Whereas Assure360 produces a trail that shows how you’ve made it safe. You can record best practice, too – highlight the good stuff that’s on site.
That’s useful not only because it means that things get resolved, but also because you can demonstrate good practice to clients, contractors, borough councils, or for things like our ISOs and accreditations.
- Andy LeMarie
- Group Head of Health and Safety
The Contamination Expo, and the long road to events as normal
Written by Nick Garland on Thursday October 14th 2021
Cast your mind back 12 months and it was evident the pandemic was far from over. The government had introduced the three-tier system, and events were once again being cancelled and postponed. With this in mind, we should all be grateful that this year’s Contamination Expo was back at the NEC.
As probably the biggest event in our industry, the Expo is our major opportunity to come together, exchange ideas and information, and get a real feel for what’s going on. I was looking forward to being there but then, just a couple of days before, tested positive for Covid.
I’ve written loads about the ability – indeed the need – for firms to have technology that adds flexibility and remote-working capabilities, and it was interesting to get a chance to demonstrate first-hand. Our team leaped into action, helping me film my talk Demystifying the four-hour time-weighted average (4hr TWA) so that I could present it remotely to the conference – almost as planned!
Hopefully the talk still comes over well despite my not being 100% well – I’m happy to report that my symptoms were mild and I’ve recovered now. If you’re interested in reading more about the topic, this summer I wrote in depth about the HSE and personal monitoring, and took a deeper dive into the 4hr TWA.
Brilliant though technology is, and as much as it’s changing the industry we work in, there’s still no substitute for in-person conventions and events. Things will be more normal by this time next year, and the Contamination & Geotech Expo 2022 will no doubt be bigger and better. Mark out 14-15 September in your diaries!
We list the Expo and all the other occasions we know about in our regularly updated diary of asbestos and construction events. Aside from the regular ARCA and ACAD regional meetings, we’ll keep you posted on the various events and symposiums that accelerate the sharing of knowledge in our industry. Please let us know if you’re organising something so we can add it to the list.
Personally, I’m most looking forward to the next European Asbestos Forum (EAF) conference. Given the ongoing challenges with international travel this has been postponed until 2022, but I’m reliably informed next year’s event will be worth the wait. Given the quality of the 2019 conference, I don’t doubt it for a minute.
Want to see first-hand how Assure360 simplifies the 4hr TWA? Get in touch for your free demo!
Events – Update Autumn 2021
Written by Nick Garland on Wednesday September 15th 2021
Asbestos, construction, and safety events calendar
Covid-19 is still with us, but with few restrictions in place, most in-person events are back.
Here’s our list of all the other essential meetings, briefings and other dates for your diary.
ACAD Awards and Golf Day
16th September 2021
Celtic Manor, Newport
This year’s awards and golf day will be a long-awaited opportunity to safely meet up with old friends and industry colleagues. Assure360 will be sponsoring the Audit awards. We look forward to seeing you there!
Find out more
Rearranged for November 2022 – see below.
Contamination & Geotech Expo
22-23 September 2021
The NEC, Birmingham
Like most other leading events, the 2020 Expo couldn’t run because of the pandemic. This year it’s rebranded to acknowledge its importance to the Geotech industry. As before, the event is composed of a series of child events that includes the Hazardous materials expo. Keynote speakers include Yvonne Waterman, founder and president of the European Asbestos Forum foundation.
At 2pm on 23 September, our own Nick Garland will be giving his talk on the four-hour TWA and the HSE’s new focus on personal monitoring. Nick will also be at the ACAD stand during most of the two-day event.
Find out more
ARCA Annual General Meeting
8 October 2021
Lords Cricket Ground
ARCA returns to Lords for its 2021 general meeting. Full details are yet to be announced, but the HSE’s Sam Lord has been confirmed as a speaker. The event usually includes updates from the leadership team and other staff, along with lunch and ample opportunities to network. As in previous years, there’ll be an after-lunch speaker to wrap things up with a smile.
Find out more
Asbestos Virtual Conference 17 & 18 November 2021
2021 sees the fourth annual asbestos conference organised in conjunction with the Faculty of Asbestos Assessment and Management (FAAM) and for the 2nd year running it is virtual.
The event will bring together researchers, academics, practitioners and regulators, through various plenary talks and technical sessions with a programme that will include UK and international speakers, dealing with scientific topics covering key areas regarding the assessment, control and management of asbestos. Click here for further information and the preliminary programme.
ARCA Regional Meetings
4-30 November 2021
ARCA will be returning to face-to-face meetings for its autumn regionals, which take place at various locations throughout November. However, it’s providing an additional date for a remote meeting. Find more details on the link below, or email firstname.lastname@example.org to learn more.
Find out more
7-10 November 2022
Bristol Marriott Hotel
Airmon is the leading international forum for air monitoring. The tenth instance of the event was previously scheduled for September 2021, but has now been rearranged for November 2022. It will build on previous conferences, providing an exciting programme. Thought-provoking keynote presentations will be combined with oral presentation sessions. Presentations from students or early-career researchers are warmly encouraged, and short training courses, delivered by experts in their field, are an integral component of this event.
Find out more
If you’re hosting, postponing or cancelling an event you’d like us to list here, please get in touch.
“It’s only an asbestos enclosure” – why temporary works are a problem
Written by Nick Garland on Wednesday September 15th 2021
What on earth are Temporary Works? According to the Health and Safety Executive (HSE) they’re ‘the parts of a construction project that are needed to enable the permanent works to be built’. But this definition is a little misleading, and leads us to think only about major construction items, holding up partly built structures.
This over-simplified definition reflects a wider problem with how temporary works are perceived, and how the asbestos industry in particular deals with them. For the most part, we tend to ignore the whole issue as not applicable to us.
On the HSE’s side, there’s some problematic guidance in which the definition is subtly different. Essentially, here temporary works are anything that ‘might or might not remain in place at the completion of the works’. And if you’re thinking that could apply to anything, you’d probably be right.
Let’s step back from this confusion and explore the founding principles for temporary works (TW). TWs are assigned design categories, which reflect the complexity and innovation of their design. They also have a risk classification, which reflects the consequences should they fail.
The design categories are officially 1-3, but there’s an unofficial extra one – ‘0’:
0 – Standard solutions. Essentially off-the-shelf systems that have been previously judged or tested as safe.
1 – Simple designs. Some thought has been put into creating the solution. Examples might include simple formwork and propping.
2 – More complex designs. These would usually include piling and excavations.
3 – Complex, innovative designs. These are departures from the usual to solve novel problems or achieve an innovative result.
Depending on the category, the design requires a greater or lesser degree of extra checks.
Once we’ve established the appropriate design category, we determine the classification of risk by asking, ‘What are the consequences of failure?’ This often changes how temporary works are regarded. For example, temporary (i.e. Heras) fencing might be design category 0 – tried and tested. Put it next to a busy dual carriageway and it remains design category 0, but it becomes high risk. This raised level of risk means we undertake more stringent site checks to make sure the solution has been built as designed.
We’re actually very familiar with this kind of concept, as an asbestos enclosure is a great example. Enclosures are typically built to a very standard design, making them design category 0. But the consequences of failure will vary. In an open field there may be minor, manageable consequences. In a busy school they’d be very serious. Consequently, you may include additional checks for the latter.
Understanding risk categories
The obvious examples of TWs that we all think about are trenches, concrete formwork, and the propping up of partially constructed structures. But with the above definition in mind (anything that ‘might or might not remain in place at the end of the project’), they also include scaffolding, towers, hoarding, fencing and asbestos enclosures.
Essentially all the things we build in the asbestos industry are temporary works. So what do we need to understand about the rules?
Nearly everything that we do has a standard solution, and will have a design category of 0. Speedframe Airlocks, internal timber enclosures, Heras fencing, simple scaffolding, towers: it’s all off the shelf, so no specific design is required. However, there are times when we do something a little extra, and that changes things dramatically.
If instead of the standard Heras fencing we put up timber hoarding, the support and foundations for these are firmly in the category 1 arena. Adding logo sheeting to Heras fencing would also move it into category 1, with the associated changes in how it needs to be managed.
Many other common adaptations will modify category 0 structures in this way. If the existing site scaffolding is a standard design covered under the National Access & Scaffolding Federation’s TG20:21 guidance, great. But when we construct a full enclosure on this we’re adding a huge sail to a multi-ton structure. That’s very definitely no longer a TG20 scaffold!
If a temporary works fails, the consequences could be serious – and the HSE will certainly be investigating. Say for example that high winds topple the soffit enclosure scaffold, the scaffold company could well be in the clear – the reason it fell was because we added the sail. If we have specified category 1, 2 or 3 temporary works, but then not had them properly designed, it’s us in the dock.
Managing risk, avoiding disaster
So if everything we build is a TW, and mostly it’s category 0, but occasionally it’s not, what should we be doing? It’s unfortunate that there’s no official guidance. Instead, everything is effectively governed by the British Standard BS:5975. This document outlines the best practice you should be following. And in our industry we know that while we don’t have to follow guidance, we can’t ignore it, and we must do something equivalent or better.
BS:5975 states that you must have a procedure for TWs. This could simply be an extension to your existing standard procedures, essentially laying out what standard designs you use and what you will not do. You must also appoint certain roles. These include a designated individual: a senior person in the organisation responsible for establishing and maintaining the TW procedure. The designated individual must also appoint the temporary works coordinator: a competent person to manage the temporary works.
All temporary works must be designed by a competent person, or be to a standard (i.e. off the peg) design. And there may be a need to double-check aspects of the designs depending how complex they are. Anyone who designs a TW is a TW designer. They have exactly the same duties as any designer under the Construction (Design and Management) Regulations 2007.
All temporary works must be checked on site to ensure they have been installed or built as per the design. As we mentioned before, the degree of checks required depends on the risk.
How might this work in practice? The appointed roles might be shared out as follows:
- Health and safety lead takes on the designated individual role, as they have existing responsibility for the standard procedures.
- The contracts managers are appointed as temporary works designers. They design the job, and ideally they only select standard solutions.
- Supervisors are your eyes on the ground, ensuring that whatever you design is implemented correctly. After all, that’s their normal day job.
The first and second of these have to be formally appointed, and accept the position.
There’s excellent training available for temporary works coordinators – you can find much of it through Easybook – but it’s not compulsory. In the low-risk category 0 world we inhabit, you might choose to send one person, then have them cascade the information to all of the TWCs.
In any event, make sure your contract managers know what constitutes a standard solution – give examples in your procedures. Few licensed asbestos removal contractors (LARCs) have anyone in-house competent at designing scaffolding. If you’re using scaffold as the basis for a soffit enclosure, make sure the scaffolder knows it is unlikely to come under TG20, and that it will need a design. Similarly, don’t embellish Heras fencing with branded sheeting. If necessary, use the (expensive) netting designed for this purpose.
The supervisors, as usual, are the checkers. They need to confirm that the operative built, installed or erected the item correctly. Recording these checks can be time consuming, but it’s something we’re all used to. That’s exactly why we designed the Assure360 Paperless solution, which slashes supervisor administration time by up to 80%.
So in summary, the things that LARCs build or erect are always temporary works, and you ignore that fact at your peril. By following some simple steps we can repurpose the activities we routinely do anyway, ensuring that the job gets done properly, checked appropriately, and that we’re observing the proper guidance throughout.
Want to see first-hand how Assure360 Paperless streamlines routine safety checks, and makes the data available for insight and analysis? Get in touch now for your free demo!
Written by Nick Garland on Friday July 23rd 2021
Asbestos management case study
The Horizon Environmental group was founded in 2011 to deliver comprehensive asbestos removal and land remediation services to the construction and public sector across the UK. Focusing on consistent high quality work and exemplary health and safety practice, the business has grown rapidly.
Today the business has expanded beyond the UK, delivering international asbestos removal services to British government sites overseas. It has also worked across Europe, Africa, Asia and in the Middle East. Horizon remains dedicated to maintaining the highest standards, upholding practices that create long-term value and enhance the firm’s reputation for honesty, integrity and safety.
As a large asbestos services company, Horizon Environmental is typically responsible for multiple asbestos-removal projects at any one time. With major clients including several NHS hospitals, projects can often be complex, and last for many weeks. In order to maintain the very high standards to which it aspires, the company uses a system of internal auditors who visit sites on a round-robin basis. In addition, an external auditor is contracted to provide regular independent audits.
Operating a business of this scale, with this level of oversight, in such a heavily regulated industry, requires a huge amount of record keeping and organisation. This is hard enough to achieve using paper-based systems, but such traditional approaches also have the effect of ‘locking up’ valuable data and insights.
Additionally, businesses using many auditors face the challenge of ensuring consistency. While multiple auditors provide a broad base of insight and experience, differing auditing approaches and report formats can make it harder to identify trends, or produce and act on consistent training needs analysis.
Horizon Environmental has long been mindful of these challenges, and aware that emerging technology could provide solutions. In 2014 it became one of the earliest adopters of the Assure360 system, leveraging the Audit app to manage audits and generate insight. In 2018 Horizon was involved in the design of Paperless, Assure360’s digital supervisor support tool, and the company became one of the launch customers for the app..
Horizon’s use of the Assure360 platform has become fundamental to its ability to manage the high volume of audits it conducts. Assure360 Audit provides a framework through which Horizon can ensure a high level of consistency between auditing approaches, obtaining meaningful and comparable results between auditors. In addition, the app helps Horizon to track and report data, providing insights that help contract managers deliver high quality outcomes on time.
Horizon was already familiar with many benefits of Assure360 Paperless. For example, the system has helped the business liberate critical safety data from site folders, allowing it to respond to process or training issues at the time they arise, rather than when the paperwork finally comes back. Under the coronavirus restrictions, however, the system proved its worth in other ways, such as by helping support remote-working staff, and showing live on-site progress to contracts managers working from home.
Most recently, Horizon benefited from Assure360’s help during its early 2021 licence renewal. By drawing on the licensing modules built directly into the database, the company was able to streamline and accelerate its application by providing high-quality reports in the required format. In addition, the Assure360 team was available to provide support and advice based on its experience with guiding other customers through the process.
What the client said
“Our internal auditors picked up the process very quickly.
“With Paperless, myself and the contracts managers really like the real-time monitoring that’s available. With your archaic, traditional site folders, you wouldn’t really get to see the bones of the project until completion – or on a longer project when we did a changeover of the paperwork. The Paperless system allows us to have that real-time monitoring and see that all the checks and everything have been done in real time.
“In Covid, where we obviously had a lot of staff working remotely, we were able to tap into the Paperless system and have a real live feed of activity on site and how things were progressing. And with the picture functionality that’s been rolled out in the latest version, that’s really, really helped in that respect as well.
“Rolling out Paperless has reduced the strain on the administrative side of the business, which obviously allowed us to allocate staff to other projects in the business, which has been massively beneficial.
“When it came to re-licensing (in early 2021), using Assure360 we could directly generate reports from the vast amount of data in regards to exposures, personal monitoring – all that kind of really technical stuff. We used those as part of our submission, our supporting evidence. We had a very good experience of the new licensing process.
“I would highly recommend the whole Assure360 system. The auditing side I think is fantastic: it allows us to have a real in-depth understanding of how our sites and staff are operating. We’ve got the training needs analysis feeding into that, which once again is extremely helpful.
“The whole system – from Audit and Paperless to the cloud-based database and what you can pull from that – I think is a really useful tool. I would highly recommend it to other licensed removal companies.”
- Tony Baker
- Operations Manager
Probing the subtleties of the new Analysts’ Guide
Written by Nick Garland on Thursday July 15th 2021
As you’ll almost definitely know by now, in April the Health and Safety Executive finally released its new Analysts’ Guide. I say finally, because as you’ll also know, the update was previously in the works for more than five years.
It’s been a very long road. The original consultation document was optimistically called ‘Asbestos: The Analysts’ Guide 2016 HSG248’. Like many others, I originally sent in my return to the consultation in November 2015. In 2017 I drafted my white paper, which summarised, analysed and commented on it. At the time, I anticipated that I’d be updating that promptly, but the real thing didn’t appear for more than another three years.
Despite this long gestation, the guide still has a few niggles – not least of which are a number of typos, some of which need clarification. I won’t be concentrating on these here, but I do think it’s likely the HSE will be targeting them in a minor revision before too long.
The big changes – and a typo
I’m not intending to focus on the big changes, in part because the majority of them were telegraphed in the original draft doc and then subsequently ‘leaked’ – we’ve had a long time to talk about them. The biggest example of this is the Supervisor Handover Form, which has been in wide but not universal circulation for a while.
However, now that it is in the guidance, for all practical purposes it becomes mandatory for the supervisor to hand one of these, fully completed, to the analyst before they can start on the four-stage clearance (4SC). This will also be something that the United Kingdom Accreditation Service (UKAS) will be checking when they do their visits to the labs. Assure360 was an immediate adopter of this, so if you’re already using the Assure360 Paperless app you don’t need to do anything.
Discover how Assure360 Paperless helps keep you within the guidelines.
If, however, you haven’t started using the now ‘mandatory’ form, be aware that the template on page 202 of the guide contains a typo. The form asks ‘Has the NPU been switched off and new pre-filter inserted?’ Of course, we all know that this is done by the analyst after they are satisfied that stage two has been passed and they are ready to start the air test.
The asbestos enclosure handover form widely shared by ACAD had this typo rectified – you could contact your trade organisation to get their corrected version. If you do use the one from the guide, be sure to brief your teams on the correct way to use it.
Getting into the subtleties
As I say, I don’t want to focus on the typos, but rather I want to pick up some of the less obvious changes that people might have missed.
Throughout, the Analysts’ Guide stresses the client’s responsibilities with regard to protecting the health of people who work in or on their building. The underlying subtext is that this includes the analyst and the asbestos removal operative. Clients also have fairly extensive duties under the Construction (Design and Management) Regulations (CDM) to ensure that a project can be carried out without risk – so far as is reasonably practical. The combination of these factors could be that the client’s duties extend to cover previously grey areas.
It seems curious that the HSE is effectively extending the well known position that the client and not the licensed asbestos removal contractor (LARC) should appoint the analyst. The reason for this is that the analyst’s four-stage clearance is the final quality control audit prior to handing back for normal occupation, and any conflict of interest at this point is bad.
So far so normal, but the change comes with the highlighting of less formal conflicts in paragraphs 1.23 and 1.24:
“…where the contractor is a major source of work…” and;
“The analyst should not perform site clearance certification where such shared links exist. However, if shared links are unavoidable, the building client should be made fully aware of them. This should be in writing.”
Any such links would therefore generate a UKAS-verifiable paper trail. It will be interesting to see what kind of an impact this will have on the industry.
Regardless, the inevitable conclusion that strikes me is that if personal monitoring is mandatory (it is), and the HSE is giving out a very strong steer that the client should appoint the analyst directly, then the client-appointed analyst should be conducting the LARC’s personal monitoring. It would then be inevitable that if they do, it will form part of the health records of that individual, and must be shared immediately with their employer (the LARC).
This might not seem controversial to those of you removed from the coal face, but the reality is that in many cases client-appointed analysts are refusing to share this crucial data with the LARC on the grounds that ‘the client has paid for it – so we can’t hand it over.’ It is my understanding that the HSE’s position on this will be made crystal clear in upcoming guidance on personal monitoring.
Personal monitoring, again
The most significant of the subtle changes in the new analysts’ guide centres around personal monitoring. I first wrote about these based on the final draft version of the guide. In short, a new type of personal sample has been added: the Specific Short Duration Activity (SSDA) test.
It’s this test that most contractors have tried to use in recent years as it has the most immediate, practical effect – i.e. they use it to test the effectiveness of their methods and make changes as appropriate. The problem has been that as it wasn’t listed in the guidance, analysts were tending to only do the 10-minute version, which is useless in all but a few cases.
Now the HSE has given the optimal test a name, LARCs should immediately adopt the terminology, and request ‘SSDA Personals’ whenever they book personal monitoring tests.
There are dark arts involved in the calculation of four-hour time-weighted average (4hr TWA), and LARCs can take another step that will increase the utility of any personal monitoring air testing. Where possible the go-to or standard test should be at least two hours long, and run at a sample rate of two litres per minute. The full 200 fields/graticules should be counted, too. This single test will then qualify for calculating a SSDA, RPE suitability, and the 4hr TWA. Of course, there may be more complex situations, as I explained in my recent deeper dive on the 4hr TWA.
Finally, those of you who have read my earlier posts may remember I pointed out a typo in the late draft of the guide. It specified a four-litre per minute minimum flow rate for the SSDA tests, but this has been corrected in the final version to specify up to four litres.
Want to simplify exposure monitoring? Book a demo today, and see how Assure360 automates the 4hr TWA.
Written by Nick Garland on Wednesday June 23rd 2021
Asbestos management case study
Asbestos Essentials was founded in late 2017 by a leadership team boasting more than 50 years of industry experience. With offices in Milton Keynes and London, the company has expanded rapidly to offer comprehensive, UK-wide asbestos surveying, removal and remediation services.
The foundations of Asbestos Essential’s growth come from its twin commitments to customer service, and best practice safety and environmental standards. In addition to a highly experienced management team, the business is certified to ISO 9001, ISO 14001 and ISO 45001, and licensed by the HSE and Environment Agency in asbestos management and disposal.
The asbestos industry is highly regulated. As Asbestos Essentials’ business gathered pace, it faced many of the common administrative challenges posed by mandatory record keeping. With site records completed on paper and held in large binders on site, managers didn’t have easy access to information that would help them improve the performance on safety of ongoing jobs.
Additionally, the team faced the headache of processing large quantities of paperwork once it returned to the office at the end of an audit or project. With huge files, containing hundreds of sheets of paper, the task was taking up valuable office time that could be better dedicated to improving standards and growing the business.
In spring 2020, Asbestos Essentials became an Assure360 customer. It chose to deploy the Assure360 Paperless app, in the process equipping its site supervisors with iPads. Asbestos Essentials took advantage of the Assure360 rollout to provide supervisors with other support for remote working, installing Dropbox to allow the easy sharing of plant and equipment paperwork, along with policies, licences and other useful site documentation.
Asbestos Essentials quickly began to benefit from Assure360 Paperless’ ability to streamline and simplify asbestos management paperwork. While some of its less technical staff initially needed extra guidance, the team could call on Assure360’s technical support and assistance to help ensure that everyone quickly understood the new system.
Assure 360’s granular data capture and cloud database meant that critical site and employee information could now be gathered and stored electronically, dispensing with the need for bundles of paper. Additionally, with essential reference documents now provided electronically, project teams no longer needed large folders to hand while they worked.
Aside from streamlining on-site record collection – and allowing supervisors to concentrate on supervising – the move to Paperless brought major benefits to the office. With information gathered and shared in near-real time, the management team could see at a glance what was being done on site – and whether anything had been forgotten.
The ready availability of site data has also freed office staff from the chore of processing large volumes of paperwork as it returns from site. And with automated analysis of the data, the team has easier access to insight that can help them drive safety and environmental standards still higher.
What the client said
“The amount of paperwork, audits and so on that we produced was astronomical. Having a cloud-based system like this, it allows us to see in real time what’s going on on site. Plus all of the paperwork that had to get done and sorted when it got back to the office, that’s now done on the system – rather than having big huge files which we then have to archive.
“It means as well that I don’t have to pull out files and show auditors: ‘well, that’s this file. That’s this file.’ and so on. Now I just need to find a job on the system and pull it up and it’s there.
“Our work in this industry is very much process-driven. A really good thing about Assure360 is you can’t move on to the next bit until you’ve done the bit before. It won’t let you close the job at the end of the day until you’ve done all the checks and all the things you’re supposed to do.
“Also, if we have jobs going on where we’ve got multiple supervisors, you can actually hand it over to another supervisor and it appears on their iPad instantaneously. If an HSE inspector turns up and says ‘you only started working at four o’clock today; what happened during the rest of the day?’, you can run through all of the things that have been done on the previous shift because it’s all there for you.
“When we first took on Assure360, we met with some initial scepticism on our supervisors’ part. All that they had known was paper, so their concerns were understandable. However, with support from myself – and directly from the Assure360 team, they have really taken to the system.
“The Paperless app is so easy to use and intuitive, it cuts out nearly all of their admin tasks. They love it – even if I wanted to go back to the old ways, they wouldn’t let me.”
- David Wilson
- HSEQ Director
The four-hour time-weighted average – a deeper dive
Written by Nick Garland on Tuesday June 15th 2021
I’ve had a lot of very positive comments on April’s article about personal monitoring and the four-hour time-weighted average. I thought it might be a good idea to take another look – but this time take a deeper dive into the exposure geek pool. In this post I’m going to really focus on the challenges of the four-hour time-weighted average (4Hr TWA), and give a few more examples of how to do it.
What’s the point of the 4hr TWA?
It’s important to start with a quick refresher on the point of the 4hr TWA. Sam Lord of the Health and Safety Executive (HSE) recently summed it up neatly: the point of 4Hr TWA control limit testing is to really look at compliance, not just nod to it.
I discussed the wider context of the testing and explained the terminology in my previous post. The key point is that the four-hour control limit test is a duty-of-care test, intended to really examine whether we have complied with our duties as an employer.
To recap, the test specifications are:
||Sample Rate (litres/min)
|4-hour Control Limit
The control limit is 0.1 fibres per millilitre of air (f/ml) over four hours – measured inside the mask.
The newly (finally) published Analysts’ Guide specifies a simplified version of the World Health Organisation method – an attempt to increase the frequency at which these tests are being completed.
Despite referring to it as a ‘test’, it is better to think of the four-hour TWA as a calculation. It is intended to represent what happened to that person over a continuous four-hour period – it tells a story, if you like. The simplified rules are:
- Sample rate must be 1-2 litres per minute
- The total volume of air sampled must be 240 litres or more
There’s a very important point to make here: you don’t have to do a single four-hour air test to calculate a valid 4hr TWA. What you do need is a record of what happened over those four hours, with test results that support the ‘story’.
The HSE’s simplified approach to this is to require a minimum total air volume of 240 litres. If you do the maths, that means you need at least a two-hour (120-minute) test at two litres per minute.
However, now the analysts’ guide is out, it’s clear that how you get to those numbers is a bit more flexible. You could conduct three individual tests one after the other. Importantly, certain assumptions can also be drawn.
Let’s go through some examples of how you do these calculations by hand. The calculations for all of these examples are taken directly from the new analysts’ guide. Please note that the HSE works in hours and fractions of hours, rather than minutes.
Also, before I start, I should point out that while the sums are straightforward, the calculations are yet another burden for asbestos professionals. Later on I’ll explain how Assure360 can do it all for you.
Example 1 – a series of tests to paint a picture
Consider this shift inside the enclosure:
- Removal of asbestos insulating board (AIB) tiles for 30 minutes (0.5hrs), with a result of 0.15f/ml
- Boring out of fixing holes for 45 minutes (0.75hrs), with a result of 0.1f/ml
- Fine cleaning of the enclosure for two hours and 45 minutes (2.75hrs), with a result of 0.06f/ml
Because we know the sample rate was at least one litre per minute, and the total test duration is four hours, we know that the total air volume exceeds the magic number of 240 litres. In this case we can tell the story of the whole four hours.
This is where the ‘time-weighted’ bit comes in – we multiply each of the measurements by the duration of that specific activity to calculate total exposure. Then we divide by the total duration to produce an effective average exposure rate for the entire duration of the tests:
Example 2 – what if the work lasts more than four hours?
An activity will often carry on beyond the tested period. In this case, the guidance says you can assume that the exposure continued at the same rate, provided the minimum flow rate and sample volume are met. Consider this activity:
- Removal of nailed-on AIB for six hours.
- Tested at two litres per minute, for three hours and 20 minutes, with a result of 1.2f/ml.
Here, the test duration and flow rate ensure the total sample volume is well over the minimum 240 litres. Accordingly, you can assume that the last 40 minutes of the four-hour window would be same as the result of the actual testing:
Example 3 – what if the work lasts less than four hours?
Similarly, where the work (and the air test) last for less than four hours, we can extrapolate. Consider this morning’s work:
- Removal of asbestos pipe lagging for two and a half hours.
- Tested at 1.6 litres per minute, for two and a half hours, with a result of 2.5f/ml.
- Operative exits the enclosure and no more exposure happens (e.g. lunch)
Again, as the sampling rate was 1.6 litres per minute for 150 minutes, this means that the total sample volume meets the 240-litre minimum. Accordingly, we can calculate a four-hour TWA:
Of course, if you’ve got the computing skills, you can create a spreadsheet that will do all of that for you. Alternatively it can be done by hand every time. But while the former is bad enough, the latter is quite soul destroying – and either could be prone to mistakes.
Making it simple
Happily we’re able to offer Assure360 customers an alternative. I’ve long sought to simplify personal monitoring for licenced asbestos removal contractors (LARCs), and I want to support the HSE’s renewed push to improve it. We’ve added a new TWA tool to the Assure360 platform, allowing the system to do the heavy lifting for you – and saving hours.
Last month our Paperless app was enhanced so that, along with the test result, it will collect three more data points:
- Flow rate
- Duration of the air test
- RPE worn
Now that this data is being collected, the Assure360 database reports will, over the coming weeks, give you more and more power to do TWA calculations.
We’re already providing the original simple time-weighted result for every compliant test. We also calculate it for every situation where it is known that exposure continued for the full four hours. Next month we will be adding a system to pool multiple results together, to complete the suite of tools.
By automating calculation of the four-hour TWA, I hope that we can help ensure that more four-hour tests are carried out, and fewer mistakes and misunderstandings made. More than anything, we want to help the HSE improve the depth and quality of personal monitoring, and improve the safety of everyone who works in our industry.
Want to see first-hand how Assure360 Paperless simplifies the four-hour TWA? Why not get in touch to book a free demonstration?
Stay safer with Assure Incident 2.0
Written by Nick Garland on Thursday May 20th 2021
We’ve said it before and it remains true: the construction industry is an inherently dangerous business. According to 2019/20 figures, the sector recorded the highest number of fatalities of any industry, and the second highest rate of injury.
However, focusing on the top-level statistics overlooks a fundamental truth: that comparatively few workplace accidents happen truly without warning. All too often they’re the end result of a trend, or they become possible thanks to a blind spot in safety culture or supervision. Each year, lives could be saved and life-changing injuries avoided if we could better identify the conditions, oversights and company cultures that allow people to get hurt.
Without doubt, the most important pillar in driving down workplace accidents is to fully record and investigate them, along with the incidents and near-misses that often precede them. As we’ve written before, the accident triangle theory suggests that any near miss could be a warning of a potential accident. It’s essential to capture and analyse data – and act on the insight to prevent something worse.
The construction industry takes this seriously, and many employers do it well, but the same is less true in the specialised world of asbestos management. Historically, it’s something we’ve been rather poor at.
Across all industries, a culture of continuous improvement demands that any accident, incident or near-miss is recorded so that lessons can be learned. Recording should be mandatory, and any barriers to it should be removed: that’s the philosophy behind Assure360 Incident.
Incident exists precisely to minimise the barriers to recording safety incidents in the workplace. Providing a simple and intuitive interface, it improves record keeping. With the Assure360 dashboard, it helps provide the analysis and insight that organisations need to improve.
Now, we’ve improved the app itself, with a refreshed interface and a raft of other features. Chief among these is that, like Paperless before it, Assure360 Incident 2.0 is now available on Android.
Other major improvements include:
- Multiple photographs – a full picture of an incident can be recorded for later review and investigation
- Close out notes for action taken on site – encourages proactive site behaviour to prevent the near-miss from becoming an actual incident
- Record of the PPE worn at the time of an incident – completing the picture for senior management
- Instant upload to the Cloud Compliance system
- Actions automatically assigned to the safety team. Email alerts notify the team so actions can be reviewed, and health and safety investigations undertaken if needed
Above all, we’ve focused on making Incident 2.0 as streamlined as possible. By making incident and near-miss reporting easy, our aim is to help you make it quick and comprehensive. Why not download Assure360 Incident now, and start strengthening your health and safety culture?