Written by Nick Garland on Thursday June 27th 2024
It’s important to us that every Assure360 user gets the best from our system and apps, so our account director, Rick Garland, is starting up quarterly support webinars. In these free sessions, Rick will be bringing customers up to speed with recent developments in the system. Each session will also feature a Q&A, which will include time for users to suggest future development ideas.
I’m delighted to announce that the first session will be on Tuesday 16th July at 10am. We’d love for as many customers as possible to join us, but the webinars are also open to anyone who’s interested in seeing how Assure360 could benefit their business. Just use the form below to sign up!
Written by Nick Garland on Monday June 24th 2024
May and June have been very busy for the Dev team at Assure360.
Hand Arm Vibration Syndrome (or HAVS for short) is often the subject of questioning from visiting Health and Safety Executive (HSE) inspectors, with under-pressure supervisors trying to explain how they measure and record exposure. Often the maths is too much, and the contractor gets a letter.
This brings us to the first new feature from our tech gurus: a brand new module for supervisors using the Paperless app. Our long-awaited HAVS solution is fast, efficient, accurate, and above all simple for anyone unsure about technology.
The system is based on our unique exposure solution, that has led to nearly 20,000 personals being added to the biggest database in the UK. In a nutshell, the office develops a library of vibrating equipment with its associated vibration magnitude. The contracts manager assigns the correct kit to be used on a project, and the supervisor just picks from that list in the app. Our system does all the maths, warning the supervisor if the lower action level has been breached – and again if we are getting close to the upper limit.
Simple – like all the best solutions.
The next new release is another in our suite of exposure hacks. The new Exposure Target by person report allows you to check whether you have targeted your individual operatives with enough personal monitoring.
One of the requirements of the new Asbestos Network guidance is that, while you need to monitor all operatives, some need to be targeted with more testing than others. Anyone with less experience – or a more ‘hurried’ approach to removal – gets extra attention. The new report tells you immediately if you’re on target for your own monitoring strategy, using data you’re already collecting in the Paperless app.
That’s what you see on the surface, but beneath the water there is a great deal of paddling. We take your existing targets for high risk activities, and work out the average. Next the system tots up the number of exposures for each person, and the number of personals that they have had in those activities, and compares this with the average. This gives you a percentage-of-target score.
If the person has been tagged with Enhanced Supervision, then the target is doubled – i.e. we demand double the personals as they are higher risk individuals. I know I get carried away on this subject, but this is the only route to compliance without hours of Excel data mining. Our neat solution gives you 100% compliance with 0% extra work.
Finally we have completed the second phase of our People module, giving you a 100% flexible training matrix. You decide what job roles exist in your company and what skills are required, and assign those to your employees. We then track what you’ve selected and tell you what’s in date, what’s not in date and what’s about to be out of date.
What’s more we can even track the difference between role-required skills, and those that the employee has that are above and beyond. In this way, you can choose to maintain these additional skills if you want.
Written by Nick Garland on Monday June 24th 2024
You might remember the gel-cut asbestos pipe removal technique that I wrote about in October last year. This brand-new approach is aimed at an age-old problem: how to make the removal of asbestos pipe insulation safer than existing methods. Last month, in my capacity as a FAAM Committee member, I had the great pleasure of attending a site on Guernsey to conduct a further FAAM and BOHS investigation into the method.
By way of a short recap, when faced with having to remove an asbestos-insulated pipe, licensed asbestos removal contractors (LARCs) conventionally have two options. The first is full removal, the second is wrap and cut. Both involve injecting the asbestos-containing material (ACM) with surfactant and carefully removing the now wet insulation. Full removal, as the name suggests, involves taking away and cleaning all of the insulation, leaving a bare pipe to be reused. It’s a laborious process that clearly involves risk of exposure.
If the pipe itself is redundant, you can use wrap and cut. Here you inject and clean short sections of insulation to reveal bare metal that can be cut. Intact sections of still-insulated pipe can be wrapped and disposed of. This process is much safer than full removal as it disturbs only a fraction of the asbestos material. But it’s still laborious, as you have to inject and carefully remove the insulation from the point to be cut. As with full removal, you must always stay vigilant for a dry spot that could lead to significant exposure.
This is where the new technique comes in. With gel cutting, workers fix gel pouches to pipes that have already been wrapped, then simply cut through the gel, the asbestos, and the pipe. The innovation is that the gel reforms over the blade, so that the operative is always separated from the asbestos. The gel captures the dust and the team simply seals the cut end of each section with a waste sack and moves to the next cut point.
Our earlier investigation in Somerset with Horizon Environmental gave very encouraging results. Both wrap and cut and the new gel-cut technique gave similar air test results of 0.03 fibres per millilitre (f/ml). But importantly, the new technique was twice as quick, so the operatives’ total exposure was halved.
Last month FAAM appealed for suitable projects on which we could repeat the exercise. We wanted to see whether the technique could easily be adopted by a new team, in a different setting, and still deliver the big safety benefit we observed in the first test.
Paul Knight, of the Guernsey-based removal contractor ASR, quickly suggested his site at the old vineyard at A’La Fin. This was a redundant greenhouse plant room with 10 linear metres of asbestos-insulated pipes. As with the first trial, we were dealing with hard-set insulation including all three of the commercial types of asbestos: amosite, chrysotile and crocidolite.To make it more challenging, the material was in poor condition.
All of the pipes were wrapped in polythene and seven cuts were planned. The whole exercise – from selecting the cut points, affixing the gel packs, making the cuts and sealing the redundant pipe sections after removal – was completed in around 45 minutes.
This seems very fast – and it is in comparison to the traditional approach, which might have taken most of the day – but the whole process was in reality unhurried, and completed with increasing confidence. The exercise was witnessed by me (representing FAAM and BOHS), Graham Warren and Craig Binge of ASESA (ASR’s trade association), and Matthew Coggins of the Guernsey Health and Safety Executive.
Watch the footage of the cutting in action.
As with the Horizon Somerset test, the air test measurements were very encouraging. The new technique returned results of 0.015f/ml and 0.018f/ml – in line, or even better that what we’d expect from well-controlled wrap and cut removal. But again, with the work completed so much more quickly, worker exposure was significantly reduced.
This test showed that the technique is easily picked up by new teams, in different situations, who can work more quickly and in greater safety than they might expect from wrap and cut. I’m indebted to the site team, who committed to the investigation so enthusiastically.
The removalists were Paul Knight senior and Paul Knight junior, Darren Wain and Mathew Wakeford from ASR, while the air testing was expertly delivered by Daniel Klassen of Survey Safe. It was great to see their work subsequently covered by Guernsey Press, in which Paul senior was able to highlight the gap between the asbestos regulations in Guernsey and the UK.
Written by Nick Garland on Thursday June 6th 2024
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 2024 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.
“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 2024), 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.”
Written by Nick Garland on Thursday April 18th 2024
Last month, the Health and Safety Executive (HSE) unleashed absolute chaos. For those that don’t know what happened, I’ll summarise…
The HSE has become concerned about the quality of some training – and very concerned about the effectiveness of some RPE (respiratory protective equipment) face-fit testing (FFT). The regulator suspects even that in some cases, training and FFTs were not actually being done – just the certificate issued. Due to the criticality of a good FFT, it instructed the Asbestos Network members to share this concern with the world.
Where this got highly controversial is that the HSE issued a statement naming two training organisations of which it was particularly suspicious. And even worse, the first of these two was misnamed: the organisation’s acronym didn’t match its full name, which in turn was completely wrong – and a totally different organisation. No evidence was provided, so there was little for the relevant accrediting bodies to investigate.
From the outside, it didn’t seem like the appropriate way for the HSE to raise or deal with its concerns. But a colleague of mine more involved summed it up more directly: ‘It’s a proper screw-up’.
But as the dust settles, it’s important not to lose sight of the core concern here. For a very long time there have been rumours that training, FFT, mask maintenance certificates and even medicals can be and routinely are ‘forged’. I’ve personally not seen any hard evidence to this effect, but I’ve heard the suspicions of supervisors: “he’s never been trained in his life”, and “remote training sessions are too easy to pass – so what value is there in them?”.
The other week I came across a medical certificate for an operative who had been working on site all week in the south of England, but who had somehow managed to pop up to the North-East for his medical without missing a shift. Was this evidence of fraud? Actually no, as with some digging it turned out that the occupational health centre was providing medicals over the phone. This approach was brought in as an emergency measure in COVID and was withdrawn years ago. Not fraud, but certainly shocking.
Despite the naming issue, the HSE has not withdrawn its statement, so certificates from the two named organisations (and presumably the misnamed one too) should continue to face additional scrutiny. What this translates to is that a licensed asbestos removal contractor (LARC) must conduct extra competence assessments on employees with these certificates. The press release didn’t offer suggestions on how we should approach the FFT, but I understand that the labour supply agencies themselves are ensuring all staff under their wings are being re-tested.
This event should serve as a catalyst for the industry to reexamine testing more thoroughly, and ensure it’s delivering the high standards of protection that asbestos removal demands. For even when training is actually done – and done to a high standard – it’s fair to ask whether a three-day, new operative course should be enough to allow someone to work under challenging conditions with a carcinogen. In fact I think you’d struggle to find anyone to enthusiastically support this idea.
For those that can remember, labour supply agencies used to be licence holders, and were effectively employers for a stable of workers. Maintaining a licence is not an easy thing – it takes care, attention to detail and commitment. A good agency would be seen as a partner for a LARC and, if they could provide reliable staff that were competent, they would be able to command loyalty from their customers. Their licence would be precious, and they would have an incentive to train, assess and generally look after good staff.
This all changed in 2013, when they were removed from the licensing regime, and anyone could start up a labour supply agency without any checks and balances. The HSE’s argument was that they didn’t care where a LARC got its staff, providing the LARC ensured their competence. No thought was put into how the LARC might do this, particularly for workers who might only be with them for a couple of days. This has led to a lot more labour supply agencies, but the same pool of short-term workers (STW), who are self-employed people in their own right.
There are good, dedicated agencies out there that endeavour to provide top quality staff, but there are also some that are very, very poor. The pay rates for all site staff are historically low, and therefore a bump of £5 per day has become enough for a worker to move. When demand outstrips supply, it also becomes a seller’s market. Desperate employers and desperate agencies need bodies on site, and sometimes that’s achieved no matter the competence.
We have created a market where the individual worker is the customer, and loyalty to the LARC or the agency is for mugs.
For the trainers, RPE Face Fit providers, and mask maintainers, the customer is now often the individual STW, and time has become a huge premium for these self-employed people. Anything that keeps them off-site for a shift can represent a significant loss of income. The incentives are obvious, and help explain the rise of the online refresher course, rather than face-to-face training.
If we think a little on how this incentive could twist the market it is a short leap to questions such as: ‘how quick can the training be?’, ‘do I need a FFT every year?’, ‘this second hand mask looks alright – how do I get a maintenance certificate?’, ‘have you heard that NE doctor is still doing medicals by post?’. It’s the result of the pure free market meeting safety-critical requirements – and we are where we are.
Online and remote training became essential during the pandemic, and it seems they’re here to stay. In the right circumstances, they can be exactly what is needed. My understanding of the HSE’s current position on it is that such refresher courses can be suitable for experienced workers, if supported by the employer’s training needs analysis (TNA), i.e. an employer, having thoroughly assessed their worker, deems that they only need a light-touch refresher. This seems eminently logical to me. However, the obvious implication of this is that it is not suitable for self-sponsored, self-employed agency staff, as they don’t have an employer to assess them and perform a TNA.
Things are about to get a lot worse. On many major construction sites, individuals need Construction Skills Certification Scheme (CSCS) cards to demonstrate a basic level of safety training and awareness. These are backed up by NVQs, and these qualifications have lots more checks and balances. Evidence of a candidate’s competence is recorded, and there’s auditing of both the individual assessor and the training provider by the awarding body. They also represent a huge time commitment for both the worker and their employer.
As NVQs were initially a new concept in the asbestos industry, temporary red ‘trained’ cards were made available for workers who had no NVQ and only the traditional three-day training course. Fifty thousand of these non-renewable cards have been issued, and all of them will expire by the end of 2024. The only route for these red card holders to get black or gold cards is to complete an NVQ. That’s quite a commitment even for a full-time employed worker, and seemingly inconceivable for the self-employed.
If I try to look at this impending cliff edge with some optimism, the only thing I can come up with is that, once we’ve fallen off, the few employees available might at least be of a high standard. What it could mean for the already tight labour situation hardly bears thinking about.
Whilst the HSE’s intervention seems ill thought through, it has forced us to look at the current situation, which is dire. What’s the solution? I’m not sure anyone knows, and certainly I don’t, but something clearly needs to be done.
Graham Warren of the Asbestos and Environmental Safety Association (ASESA) has called for a complete reset of the training environment. In his vision, all of the training organisations (ASESA, ARCA, ACAD, IATP and UKATA) would get together and collaboratively decide what training and competence should look like. This agreed competency framework could then be followed by all. This kind of fundamental action seems to me like an excellent place to start.
It does seem inescapable that remote training will have to be part of the mix – but it is not suitable for everyone. That is one of the many fundamental questions such a collaborative re-assessment has to answer. What does training and competence look like for our sector? What is the right training for a given individual? How do they learn? What will they engage with?
If online refreshers aren’t suitable for the self-sponsored worker, then how do we make the new environment work for this critical pool of staff? Should we consider bringing back licences for labour supply agencies, and so recreate trusted ‘employers’ with skin in the game? Again, I don’t know, but we desperately need to look at the whole problem with honesty.
Wherever there is money, there will be bad actors prepared to cut corners for profit. But the new system should at least be designed so that most of the human nature levers are pushing us in the right direction. It is, after all, a fundamental matter of workers’ safety.
Written by Nick Garland on Thursday March 14th 2024
For the past few years I’ve been writing about personal monitoring and exposure guidance. It’s an area that the entire asbestos industry has struggled to grasp. By ‘the industry’, I include everyone: licensed asbestos removal contractors (LARCs), analysts, and the Health and Safety Executive (HSE). And frankly if these last two have struggled, what chance did the LARCs have?
In a continuation of our focus on the issue, I thought I would highlight the main points from the guidance. Here I’ve listed the most important issues raised, along with their implications, and how you can make sure you’re in compliance.
My first takeaway is that the guidance exists at all. It’s always been amazing to me that an area of the industry so important has been overlooked for decades. But it is here now, and what’s more it’s pretty good guidance. It’s clear, as concise as it could be, and it’s muscular – as in it goes slightly beyond the why and how to help address some of the blockers.
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.
Takeaway number two would be that it demands a much improved strategy. The old approach to personal monitoring was that 40% of asbestos insulation board (AIB) jobs, 60% of pipe insulation, and 100% of ‘flock’ jobs would get a personal monitoring test. The obvious flaw with this approach is that both a one-day AIB boiler cupboard job, and a one-week AIB ceiling project with 10 operatives, count as one job.
I appreciate this might have been the best we could do before widespread use of Excel and computers, where everything was locked away on paper, but we’ve been able to do much better for decades. Now that we have access to databases, and Excel is commonplace, the guidance takes us to another place entirely.
Our monitoring strategy now needs to be risk based. So – other than what asbestos-containing material (ACM) we are dealing with – what makes one activity higher risk, and therefore one we should target with personals?
All of these will need to interact, so that Barry the new starter is targeted more than 10-year veteran Tom when removing a one-off AIB panel. Similarly, 10 operatives removing panels for seven days straight are targeted – and in particular Barry.
You need to collect data in much more detail to be able to work all this out. And that means your exposure record sheets need to be expanded to include all of this data:
You also need to create categories of people, breaking employees down into trusted, experienced workers, and those you need to focus on. Ultimately you need to cover everyone doing all of the activities. And once you start collecting this data, you need to process it.
There are only two ways you can unpick the meaning behind this very very large amount of information: a spreadsheet like Excel, or a database. If you go down the first route, you will need to build a sheet that can take all this data and automatically calculate the implications of your strategy. You need to build this out into a tool that allows you to commission the right personal test at the right time.
The first of my apologies, is that Assure360 does, of course, already do all of this for you. I’ve been talking about the subject for years, so it’s only right that I have built it into our system. The Paperless app takes data that the supervisor records (faster than they could have done on paper), automatically slices it up, and tells you who and what to test. This decision is based on up-to-the-second data and is not only easier than a spreadsheet, it’s actually admin-free, representing no additional effort whatsoever.
The guidance recognises that this is new, and that you might effectively be starting from scratch, so there’s a bit of humanity built in. It stresses that you should prioritise high-risk activities first, and back-fill to lower risk ones when you have sufficient data.
The next takeaway is the huge elephant in the room: it doesn’t matter what you want them to do, the analysts and the clients won’t do it.
Understandably, the big drive for some time has been for clients to employ the analyst directly. This removes a potential conflict of interest, but introduces others. As the client is paying, they’re more interested in leak tests and the four-stage clearance (4SC), so personals get forgotten.
The guidance directs the client to consider their duties under the Construction, Design and Management Regulations 2015 (CDM duties), and makes it clear that personals help them discharge these. After all, a series of personals is evidence that the work is being conducted safely.
The next issue here is that the analyst often thinks that the data they record is ‘owned’ by the client, and therefore can’t be given to the LARC. This has been very firmly put to rest, as the guidance states:
“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.”
And
“Failure to supply this information might be a breach of the analyst organisation’s duty H&S at Work Act 1974.”
The guidance also tells us that – whoever is paying for the test – the LARC should specify what and who is to be tested.
I have never seen guidance clearer than this!
The guidance lists the four tests you could do, but it focuses us on two:
It also explains why.
The SSDA is the workhorse test. It focuses on a specific activity, that is, not “AIB removal and fine clean”, but one or the other. With that restriction in mind, it is still hugely flexible and will provide you the data you need to answer a whole host of questions:
It can even help you with assessing respiratory protective equipment (RPE) suitability and the 4Hr TWA, if you design it correctly. The only thing an SSDA will struggle to cover is the old 10-minute test (but the guide effectively acknowledges those as being a bit niche these days).
The HSE sees this test as equally important to the SSDA, and there is an element of ‘just do it’ in the guidance. But at least it does tell you how to do it. I won’t go into too much detail here, but in broad strokes here’s what you need to remember.
Where the SSDA is looking at one activity, the 4Hr TWA is looking at one person, and it can (and should) encompass everything they do. The result of the test will therefore indicate the average exposure in a working day. This might give rise to two questions: why is this important, and why only four-hours if we are talking about a working day?
The 4hr TWA relates to the Control Limit, and the CL relates to decades of known occupational excess mortality data – i.e. how many people will die – if exposed above a certain figure per day over a 40-year period. We need to be as far on the right side of this figure as possible.
The average in a day is important, as the fact that no exposure was experienced at lunch, or when travelling to the enclosure and back, is relevant. It allows us to ‘calculate’ the likely total exposure in a working lifetime. Therefore whilst the SSDA helps us get better at what we do, the 4hr TWA is the ONLY risk assessment for asbestos exposure.
The second question? Well that’s a bit niche. Back in the day, pumps weren’t capable of testing over an eight-hour working day, so the asbestos community went for four hours instead. That might sound like a cop-out, but in fact if you target the high-risk activities as you’re supposed to, calculating exposure over four hours imposes a stricter limit.
The maths behind the 4Hr TWA remains difficult, but the guidance goes into some detail on how to do it. In essence, we’re back to the Excel spreadsheet again.
That said, It would be really remiss of me not to include 4hr TWA calculations in Assure360. I have, and it does. The system automatically identifies whether the test follows the strict rules. If it does, Assure360 will do the sums for you automatically and instantly. Again, our system solves a mandatory, time-consuming task, helping you focus on your work.
One of the most common questions from LARCs over the past 20 years must be: “Why do we always get ‘useless’ short-duration air tests?”
Well, at least part of the reason for not getting the right answer is that we typically don’t ask the right question. Normally we would instruct the analyst “can you do a personal whilst you are there?”. They would look to the (old) analysts guide, where they had four options.
As I have said earlier, analysts – along with the rest of the industry – have been scratching around in the dark. Without a deep understanding of the subject, their thought process might be: “I can’t do option one, because that’s four hours. The Action Level doesn’t exist anymore, and it’s nothing to do with RPE. So the only personal I can do is a 10-minute”.
The new guide is a huge improvement, as it introduces the SSDA, but we are still working in a subject area with precious little competence. To ensure you get the data you want, be clear in what you want.
Don’t ask for ‘a personal’. Ask for “an SSDA test on Tom, removing AIB on Monday. Please make sure the flow rate is two litres per minute, and that you run it for at least two hours.”
The specificity is important, and the last two parts particularly so. If you can get most of your personals to follow this pattern, they qualify for 4hr TWA calculations and you kill two birds with one stone.
As many of you will recognise, I’ve seen it as my mission to help address the competence gap in this area. That’s why one of the first features of Assure360 dealt with exposure, and it’s why I’ve returned to write about it again and again. It’s why we recently ran a webinar to help the industry understand and implement the new guidance.
It’s one of my proudest achievements that Assure360 is so ahead of its time, its users were compliant with this guidance more than four years ago. If you want to see how our system solves the issues raised here – and much more – please do contact us for a demonstration.
Written by Nick Garland on Wednesday February 7th 2024
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.
9-13 June 2024
Dublin, Ireland
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.
19-20 June 2024
Melia Barajas Hotel, Madrid
After London and Brussels, the third Asbestonomy conference comes to Madrid this summer. There’s little information at the time of writing, but expect an event that takes more of a political and social approach to asbestos management, taking in ideas, policy and points of view from around the world. You can see what I thought of the first Asbestonomy conference, or click here for full details of the 2024 event.
27 June 2024
Leonardo Hotel East Midlands Airport, Derby
June also sees the UKATA Asbestos Conference, which is aimed at anyone involved in asbestos management and health and safety. This year’s theme is ‘Confronting asbestos together: pathways to progress’ – the conference will explore the latest research, new technologies, patient perspectives, and strategies for asbestos safety and welfare. It’s free for UKATA members, and £100 ex VAT for anyone else.
27 June 2024
Coventry Building Society Arena, Coventry
In an unfortunate clash of dates, the second Health and Safety Matters Live conference takes place on the same date as UKATA’s Asbestos Conference. HSM Live will feature leading industry figures, sharing best practice case studies and legislative updates, among other things. For those who can’t make it, the Health and Safety Matters team is planning a second event in Edinburgh on 27 November (see below).
2-3 October 2024
Farnborough International
Safety, Health and Wellbeing Live is split into two events in the North and South of England. Both follow a similar format, so workplace safety and occupational health professionals can expect sessions delivered by industry and regulatory experts, panel debates, and multiple opportunities to network.
8-9 October 2024
Mercure St Paul’s Hotel, Sheffield
This year the FAAM conference moves a little further north, with an in-person event in Sheffield. Expect a gathering of researchers, academics, practitioners and regulators, and a focus on scientific topics around the assessment, control and management of asbestos. This is certainly one of the year’s unmissable events!
27 November 2024
Edinburgh International Conference Centre
This will be the first time Health and Safety Matters brings its conference to Scotland. The team is promising a free-to-attend event featuring CPD-accredited seminars and a mock-trial based on Scottish legislation. It’s running alongside a sustainability conference hosted by NEBOSH.
2-4 December 2024
ExCel London
The Safety & Health Expo’s December 2024 dates come 18 months after the 2023 show, so there should be plenty to catch up on.
This year the Safety & Health Expo is merging with three other co-located events, under the branding ‘Anticipate London’. It will still have a core focus on workplace health, safety and staff wellbeing, but will now reflect the rapidly evolving smart technology landscape and how it impacts on keeping people safe.
12-13 December 2024
Marriot Grand Palace Hotel, Brussels
The EAF conference again takes up its year-ending slot, in mid-December. There aren’t yet many details beyond this year’s theme, ‘Asbestos: The Legacy’. Doubtless, event organiser Dr Yvonne Waterman will put together another deeply inspiring event, bringing together a diverse range of experts, campaigners, victims and policymakers. If you have a professional interest in asbestos, this conference is simply essential.
22-23 January 2025
Manchester Central
Safety, Health and Wellbeing Live is split into two events in the North and South of England. Both follow a similar format, so workplace safety and occupational health professionals can expect sessions delivered by industry and regulatory experts, panel debates, and multiple opportunities to network.
If you’re hosting, postponing or cancelling an event you’d like us to list here, please get in touch.
Written by Nick Garland on Wednesday January 24th 2024
The Asbestos Network (AN)’s new guidance on personal sampling and exposure is very welcome, but it also contains a lot of detail, and requires some significant changes to the way things have traditionally ‘been done’. That’s why we organised our recent webinar, in which I aimed to give attendees a practical guide.
I’m delighted by how well it was received, and I’d like to thank everyone who turned up and took part in such an engaging Q&A session at the end. We were joined by nearly 50 attendees, comprising many old friends, but also some new faces. It was great to also welcome two members of the Health and Safety Executive (HSE), and representatives from our trade associations.
This guidance covers a very important topic that as an industry we have struggled with. It’s the first official guidance that the AN, and therefore the HSE, has provided to licensed contractors on the subject. Crucially, it contains some major departures from how LARCs traditionally approach personal sampling, which is why we wanted to offer the industry our support.
Our webinar explored practical steps on how to implement the guidance, and demonstrated how Assure360 can be used to achieve full compliance – at the same time as saving hours of work both for supervisors and the admin team. Although, like the guidance, it was focused on the needs of licensed contractors, we hope it was also helpful to analysts and end-clients.
Many of those who joined us later asked if they could have access to a recording, and we’re happy to share it again here. Please feel free to watch, and share it to anyone else who needs support or guidance.
As always, if you do have any further questions, or you’re keen to know more about how we can help you achieve full compliance, please do get in touch – we’re only too happy to help. If you’d like to go ahead with a free demo, book here.
Written by Nick Garland on Thursday January 11th 2024
We’re just two weeks into 2024, and 2023 already seems like a distant memory. It was an important year, though, so we’ve put together a quick look back at some of the key things that happened.
For me, one of the key themes of the year was a renewed focus on innovation and research. From FAAM taking an active role in researching working methods and techniques, through to the excellent and highly promising product development and fresh thinking presented at conferences, 2023 showed a lot of promise.
In March, FAAM held a unique workshop on the four-stage clearance (4SC), bringing together analysts and licensed asbestos removal contractors to examine the purpose of the 4SC, its potential conflicts, and how the two sides of our industry could learn from each other.
In October I was delighted to also be involved in a second FAAM project, investigating a new gel-pack removal technique for asbestos-lagged pipework. Both were featured in November’s FAAM conference, where my colleague Cat Holmes reported on the findings and actions from our 4SC workshop.
The summer brought some welcome news, as the government climbed down on the sunset clause initially contained within the Retained EU Law Bill. Had this made it into law, might have seen vital legislation – including the Control of Asbestos Regulations – struck from the statute books at the end of the year.
On a more personal level, July saw Assure360 hit the 15,000-audit milestone – an incredible achievement, underlining the wealth of data and experience behind Assure360 and its user community.
The summer holidays also saw a last-minute announcement that multiple schools would not reopen, while long-standing reinforced autoclaved aerated concrete (RAAC) was assessed. Many schools are still fully or partially using temporary buildings while they wait for affected structures to be made safe. It’s an awful scenario, compounded by the high proportion of school and other public buildings that also still contain asbestos.
The end of the year brought the shock announcement of ACTA – a new trade association with the potential to shake things up – and two highlights of the events calendar: the aforementioned FAAM conference, and the European Asbestos Foundation (EAF) conference. For 2023, another excellent EAF was given even greater credibility by stronger government buy-in – the Dutch state acted as co-sponsor. The presence of policy makers from across Europe added further weight to EAF’s uniquely brilliant approach.
As I say, a year of much promise, but in 2024 we need to continue building and improving. Changes driven by the Asbestos Network’s new personal monitoring guidance require us all to adapt – that’s the focus of our free webinar on 16 January.
Beyond that, the EU’s Asbestos at Work Directive, and by the more general push to renovate and refit Europe’s ageing buildings, will require us all to be open and receptive to new ideas. As I reflected at the end of last year, there’s a real danger that we in the UK could be left behind as Europe pushes ahead with better protection for its workers, and continues to be the driving force behind the innovation needed to make that happen. We in the UK must be sure to keep pace.
I couldn’t end without also mentioning our dear friend and inspiration, Mavis Nye, who very sadly passed away in November. I’ll always remember Mavis as one of the warmest people you could ever wish to meet. She led a seemingly miraculous life, being in remission for many years from the hideous disease mesothelioma following immunotherapy treatment. She leaves an incredible legacy in the Mavis Nye foundation, and all she and her husband Ray have accomplished in their campaign for an asbestos-free world.
Written by Nick Garland on Thursday January 11th 2024
Savana Environmental is an asbestos removal contractor, operating nationally out of its base in the North East. It’s a familiar name for many, but in late 2021 the company was taken into new management. Under managing director Craig Robson, it has relaunched with a mission to deliver the highest quality projects, with exemplary levels of service.
Savana’s new management team benefits from more than 40 years’ experience in the industry, so it knows full well the complexity of managing asbestos removal jobs, and the people, resources and expertise needed to ensure safety and compliance. The fast-growing company offers a full suite of investigation and removal services, and already has a track record of successful outcomes for clients including construction and demolition contractors, government bodies and local housing authorities.
Savana was relaunched from the ground up. This approach allowed its experienced management team to start from scratch, implementing best-in-class solutions to the common opportunities and challenges of running a licensed asbestos removal company. With the usual administrative demands, plus the challenges of managing, training and supervising many new staff, it was quickly evident Savana would need an advanced software solution to help with all the key aspects of its operations.
While some Savana staff had previous experience of an in-house system designed to minimise on-site paperwork, the team wanted a purpose-built solution that would help them manage and optimise all aspects of their asbestos-removal operations. In particular, they wanted a solution that included personal compliance monitoring, to help them comply with the long-awaited Asbestos Network (AN) guidance on personal sampling and exposure.
In late 2022, the company started discussions with Assure360, and in early 2023 it became a customer, rolling out the Assure360 Paperless app to its supervisors. Assure360 was able to move quickly, rapidly onboarding the company and initially providing essential training to contracts administrator Benjamin Eckford and three supervisors. Like all Assure360 customers, Savana has also benefited from the extensive how-to guides and videos in the Assure360 Help Centre, along with unlimited free support from its in-house specialists.
Savana quickly began reaping the benefits of the Assure360 system. Using the Paperless app, its supervisors were able to cut the time spent recording essential safety checks and completing paperwork, leaving them with more time to supervise and support project work. The office team gained direct visibility of projects and were able to gain insight in near-real time, rather than potentially waiting weeks for site paperwork that would need to be processed manually.
Assure360’s inbuilt support for compliance monitoring, which includes features such as automatic calculation of four-hour time-weighted average exposures, has already proved invaluable. The system has been designed to support the practical uses for personal monitoring as described in the AN guidance, including exposure estimation, and maintaining exposure records, test records and health records.
Through ongoing support from the team, Savana has been able to optimise Assure360 for its purposes, while exploring and getting the most from additional features. This has further improved the company’s return on its subscription, helping it deliver the exceptional quality and value it aspires to.
There was only a very short period between us deciding to use Assure360 to us actually being up and running, and now quite a few months down the line I couldn’t imagine my job without it. With our initial training session completed, we could just dive straight in. Rick from Assure360 had reassured us that we would quickly get the hang of it, which is definitely true, but we’ve had his support via some Teams meetings, which has also helped us tweak a few things for our purposes.
Assure360 has made many, many aspects of our job – particularly for me as the administrator – so much easier. It’s a lot less labour-intensive than paper forms, and a huge timesaver. It’s really helpful for us retaining records of jobs that we’ve done, and all their different aspects – such as helping us identify training needs, and then keep the records of that training.
A major benefit is that it gives me more time to get on with the rest of work. I’ve always got loads of work that isn’t related to Assure360 or reported on Assure360, so the fact that the Assure360 stuff isn’t that time-consuming helps me achieve more.
It hasn’t just been a time-saver for me, it’s been a time-saver for our supervisors who are actually out on site. All our site supervisors have a tablet, and they have the Paperless app. We’ve recently taken on another contract manager who was already familiar with Assure360 from his previous employer, so that saves time too.
Client name
Benjamin Eckford
Contract Administrator
Written by Nick Garland on Thursday December 14th 2023
Many readers will know that the sixth European Asbestos Forum conference took place in Brussels on 1 December. We enjoyed a fabulous event – founder and president Dr Yvonne Waterman really pulled out all the stops for this occasion, making it the best EAF yet.
EAF is different from other conferences: more policy-focused than FAAM, less showy glitz than some, yet it retains a level of friendly warmth and classy delivery.
There were two reasons it was so different this time round, the first was that it was a joint event, co-hosted by the Dutch state. The conference’s USP was even stronger and more obvious this year, with policy maker after MEP after government minister lining up to talk. But EAF is also collegiate, with Martin Keve of the Dutch Ministry for Infrastructure and Water Management also putting a lot of personal effort into making sure the event was a success.
It will come as no surprise that the morning session was devoted mostly to the EU’s new Asbestos at Work Directive, which actually was published on that very day. I’ve written before about the main changes this will bring about, but they bear repeating:
European Union member states have two years to implement these new rules, but there are bigger changes down the line. In six years’ time, analysts need to start counting fibres as narrow as 0.2 microns (two ten thousandths of a millimetre). That’s much too fine for optical microscopes, or even most scanning electron microscopes (SEMs), and thus beyond the effective limit of today’s widely used techniques.
The directive allows for an alternative: don’t count these super fine fibres, but drop the OEL even further to 0.002f/ml. What this essentially means is that if you want to continue to operate at 0.01f/ml – transition electron microscopes (TEM) are really your only answer.
We often talk about political will, and that quality was personified by two people in particular: Zuhal Demir (Flemish Minister of Justice and Enforcement, Environment, Energy and Tourism) who ensured that the Flemish Asbestos Safe policy became a reality, and Nikolaj Villumsen MEP, the architect of the directive, and opening speaker on the Thursday – which already felt like an age ago.
I’ll come back to the directive at the end of this piece, but I wanted to try to sum up everything else that happened or was discussed at EAF – and it’s a lot. One highlight to mention from the morning is that Frederica Paglietti, senior researcher at Italy’s National Institute for Insurance against Accidents at Work (INAIL), was able to give us hints about a completely new style of respirator they’re working on that will rise to the challenge of the new lower OEL.
In the afternoon I had the honour of hosting session B, where we examined innovation. EAF’s afternoon sessions are pretty whirlwind affairs, with each talk lasting only 20 minutes. The ideas and discussions came thick and fast: Sean Fitgerald on defining asbestos – and whether we can, Thomas Muller of Eurofins talking about using AI and automation to help with TEM analysis, Wayne Bagnall on discovering asbestos cement in poured reinforced concrete, Stefan Kempeneers on his project to harness AI analysis of high-res aerial photography to map the extent of asbestos roofs in a whole region. And all of that before the first break!
After the break Sven de Mulder gave us an update on the incredible progress that Flanders is making in its Asbestos Safe policy. To finish off we had Graham Gould and Inez Postema both talking about asbestos eradication from different angles. Graham made the case for the thermal destruction of asbestos rather than burying it in landfill. In the second, Inez focused on her use of water and the natural alkali pH of cement to denature the material.
Whilst Graham did indeed touch on his own thermal approach, his main thrust (echoed by Inez) was a call for action. It’s much easier to commercially destroy asbestos when there is still lots of it in the built environment. If we continue to bury it, it will create a problem that’s far harder and more expensive to solve.
While it was a frenetic afternoon, full of ideas and innovation, two different uses of AI stood out for me. Thomas Muller gave a review of the lab group Eurofin’s project to harness robotics and AI. The way it’s being used to address ergonomic hazards for its analysts, at the same time as reducing the time spent by 70%, is impressive. The timing of this work is ideal: we need to massively increase the productivity of TEM analysis to implement the new directive.
The second was the use of AI to study photographs of huge acreages of roofing. This would allow analysts to understand the likely extent of asbestos roofing in a given town or region. It’s been shown by numerous reports now that asbestos cement roofing is not nearly as safe as we have historically thought in the UK. When we do finally start to do something about it, this seems like the perfect way to get a handle on the problem.
The format of the EAF is always to come back together to conclude the conference, and this time it was particularly special as there was an award. This was in recognition of Tony Rich – a jobbing analyst by day, but also a spectacular photographer. Based in the US, his nom de plume is Asbestorama, and you can find his work here on Flickr.
To return to the directive, we in the UK can of course ignore it. But we do so at our peril.
I recall going to my first EAF in 2015. Back then there was a feeling that the UK was pretty good at managing asbestos, and that we could in fact teach our European cousins a thing or two. Over the years, though, it’s become increasingly obvious to me that we’ve been static and have become complacent.
The approach in many EU countries is already outstripping us. I can point to recent European innovations including a fully automated robotic disassembly plant for asbestos-contaminated train rolling stock, AI-driven TEMs that are three times faster than the manual equivalent, gel technology to capture asbestos dust at source, and brand-new respiratory protective equipment (RPE) concepts – rather than the converted WW2 gas masks we essentially use.
Now we can even put a number on how far we risk falling behind – if we ignore the directive (or at least its intention), we would be offering our workers 50 times weaker protection.
In the past, when writing about the Asbestos at Work Directive, I’ve been sceptical as to whether it has been thought through sufficiently. Particularly, I wondered whether the practicalities had been fully considered. Current removal methods are nothing like good enough to meet the new exposure limits. Current RPE doesn’t perform well enough, so essentially everything we do would have to change.
Now as I leave the conference, I realise that it’s the way we think that needs to change. The new directive is the law that should make us reimagine everything.
Written by Nick Garland on Wednesday December 13th 2023
I’ve written several times about the Asbestos Network (AN)’s personal sampling and exposure guidance, which was published in August. Both ARCA and ACAD have spent a good percentage of their recent regionals taking members through the details – of which there are lots.
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. 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.
This is the first official guidance that the AN (and therefore the Health and Safety Executive) has provided to licence contractors on the subject. And there are some major departures from how contractors traditionally approach it.
That’s why we’re hosting a 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.
So whether you’re an Assure360 customer or not, please join us on January 16, 2024. To book your place, please just fill in the details below. We hope to see you there!
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.
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:
Asbestos Register
Management Plan
Staff and Contractors
The second summed up key messages to all schools:
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.
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?
Of course, there’s already wrap and cut, a similar method which works as follows:
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.
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:
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 –
Lee Woodward
Jacob Rowley
Jamie Hewings
Matthew Hewings
G&L Site Team
Jim Scholes
Archie Charles
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.
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:
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:
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.
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:
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:
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:
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.
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. |
| Exposure Records | 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. |
| Health Records | 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.
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.
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:
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.
Phased removal
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:
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 asbestos@sundaytimes.co.uk.
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:
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:
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 enquiries@assure360.co.uk
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 enquiries@assure360.co.uk
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.”
Phil Neville
Operations Director
Asbestech
“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.”
Dave Philips
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.”
Paul Beaumont
BIACS
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.
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.
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.
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.
Richly awarded
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:
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.
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.
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?
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:
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:
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.
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:
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:
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.
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.
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.
HSE action
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.
Contractors’ duties
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) |
| 1-5 | 1 |
| 6-25 | 2 |
| 26-50 | 3 |
There are some other key requirements:
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:
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.
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:
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.
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.
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:
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.
Conference day
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.
Breakout
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.
Stay Alert
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.
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:
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 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.
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.
Day two
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:
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: concerns@norac.org.uk and concerns@itsnotacceptable.co.uk.
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.
Wrapping up
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.
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.
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.
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
Waste
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.
Fibre release
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.
Water vapour
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.
Other considerations
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.
Written by Nick Garland on Wednesday September 14th 2022
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.
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.
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.
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:
Photographs
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.
Assigning points
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.
Safety Tour
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.
Site return
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.
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:
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.
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:
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.
Asbestos Safe
“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:
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.
Technical focus
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
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.
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.
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:
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
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:
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.
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
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):
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:
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:
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.
Digital Register
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.
Research
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.
Increased Enforcement
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.”
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.
Everyday 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.
Standard risks
These are incredibly routine, every-job situations that can be dealt with using a standard company approach. Examples might include:
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.
Site-specific risks
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.
Anything New?
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 |
| Confined space | 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).
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.
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.
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.
Going further
In fact, my personal preference is to go a step further. I believe all such projects should be broken down like this:
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 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.
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:
Please RSVP via our LinkedIn events pages or by email to enquiries@assure360.co.uk so we can confirm numbers for catering.
Other events
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.
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:
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.
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.
The guidance here pretty much summarises existing standard guidance. In brief, the gas bottle(s) should be:
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:
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.
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:
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.
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.
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.
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 concerns@norac.org.uk. 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.
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:
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.
Day two
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.