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 You can find the ACAD draft guidance page here (you’ll need to be logged in).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
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 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 Tuesday March 10th 2020
We’ve long been admirers of the Asbestos Knowledge Empire – a series of podcasts run by Acorn Analytical Services’ Neil Munro and Ian Stone. Speaking to a cross section of health and safety and asbestos experts, the series is helping play an important role in spreading awareness and fostering asbestos expertise. So when Acorn asked if I’d like to participate I jumped at the chance.
In a wide-ranging hour-long chat, we covered subjects as diverse as how I got my start in the industry, the one-time ubiquity of asbestos, and the importance of analysts and removal contractors ‘wearing lots of hats’. We also talked in depth about the Health and Safety Executive’s new licensing regime, the problems it’s solved and the new challenges it’s created.
If you’re interested in what I had to say, or if you’d just like to hear from the industry’s other leading lights, head over to Asbestos Knowledge Empire. There you’ll be able to listen to the latest episode, and find links to follow the series on popular platforms including Apple Podcasts and Spotify.
I hope you enjoy listening as much as I enjoyed taking part!
Written by Nick Garland on Wednesday February 12th 2020
The Health and Safety at Work Act underpins everything we do in the asbestos sector, yet within it – and in copious Health and Safety Executive (HSE) guidance – you’ll find unnerving phrases like ‘so far as reasonably practicable’. These create room for interpretation, with the result that people can be unclear how far they should go when removing asbestos. Even the way that some of the direction is framed can lead us into tricky territory: I’ve lost track of the number of times I’ve been told ‘it’s only guidance’.
So after a recent thread on the HSE’s forum, I thought it would be worthwhile analysing how the regulations are structured, and what we should be doing when designing a job. Particularly, if ‘perfect’ isn’t possible, what do we prioritise?
First let’s look at the ideal conditions for asbestos removal. We have an enclosure that is small, but big enough to allow efficient and safe removal of the asbestos. The air in and out is sufficient and balanced. The enclosure is perfectly sealed, and it’s designed in such a way that there’s no working from height. The combination of method, suppression and local exhaust ventilation (LEV) ‘eliminates’ all fibre release at source.
Obviously it’s a rare job indeed where we can get all of our controls by-the-book, so often there’s a need to find compromise. First up, I should stress that compromise should only come with need – you can’t just miss out controls. Where there are good practical or safety reasons why a control isn’t possible, you need to design others to mitigate.
To track back and answer that common response when people depart from the direction, it is not ‘guidance’; it is ‘Guidance’. Project design should be in line with the ‘Guidance’, or be equivalent to or better than it.
The Health and Safety at Work Act is not a tick box set of regulations. It’s written with an understanding that no two jobs are identical, and is specifically designed to harness our imagination as professionals in ensuring safe working practice in all circumstances. To that end we need to really understand the hazards, the resultant risks, and the controls we implement to eliminate or minimise them.
We, as asbestos professionals, are also guilty of being rather blinkered. We’ve got our specialist subject, so asbestos risk is all too often the first and last thing we think about. But take a step back and reappraise our typical work environment: while asbestos is complex, many other risks such as height or electricity pose a more immediate threat. In other words, we have to think of the whole project.
The particular example raised in the HSE forum was a small-to-medium metal frame shed with an asbestos insulating board (AIB) ceiling, and asbestos cement roof. Roof, frame and AIB were pinned together with J-bolts, and the building was in close proximity to neighbours.
The conundrum posed was whether you would build a full enclosure – with the high cost and the risk from crosswinds – or crop the bolts and remove the cement and AIB at the same time with no enclosure, but with perimeter air monitoring. Because of the breakage, removal of the AIB alone was discounted as an option.
Consider the first option. A full scaffold enclosure would create a rather large working at height issue. Just constructing the canopy has a risk, but then sheeting internal ranch-boards would involve working above a fragile roof. This risk is difficult to control and can have an immediately fatal consequence. And if the winds get up, it could all be for nought.
My argument is that the overall risk is lower if we build the enclosure internally, and control the increased asbestos risk that we create. Controls in this case should include strongly over-specifying the negative pressure ventilation (or over-neg if you’re in the industry) . The considerable breakage of AIBs needs to be mitigated with surfactant, shadow vacuuming and increased respiratory protective equipment (RPE) provision, for example air-fed RAS masks. As Paul Beaumont pointed out, there would be the potential of AIB fibre / fragments to become trapped within the corrugated sheeting, too.
The four-stage safety clearance certificate would identify this likely residual risk, mandating further controls when removing the cement sheets. As this is now a small asbestos risk, we may be able to approach the remaining stages of the project with a roofless enclosure, bringing the cement sheets down into the building.
This example distills a common problem, where we are faced with a choice between one or more risks that are potentially controllable, or another that is very difficult to control. I would go with the former – and this extends into all other areas of asbestos removal where we are too used to controlling the asbestos risk at the expense of ignoring or exacerbating others.
There are other examples. A classic is working in a loft in the summer. The new confined space guidance makes it clear that the heat makes this a confined space, yet often what I see when auditing is a cube at the bottom of the loft access, a three-stage air lock, and a negative-pressure unit (NPU) with roving head passed up through the single access point. This gives excellent control of the small AIB debris risk, but massively increases the risk of death from heatstroke.
What to do instead? You won’t find it in the books, so again it’s down to our professional creativity. Why not dispense with the roving head, harness the natural leakage of the tiled roof and over-neg the enclosure? Even in winter, this might be a good idea as the common setup would hinder an emergency evacuation, for example if there’s a fire in the building.
My argument is that the asbestos risk is complex and difficult to control, but we can’t let it blind us to the rest of the job. It must be properly balanced against the other risks of the working environment: addressing one risk in isolation may leave the site team in danger, or raise their overall risk. Training and refreshers for managers should therefore cover all construction hazards and how to control them. It’s important to remember this at the time of auditing or assessing performance: peer reviews must look at all hazards, rather than just how well the manager has dealt with the asbestos.
Indeed, if asbestos is the only hazard that a contracts manager understands, are they truly ‘competent’? I’m sure that being ignorant of other construction hazards would not be seen as a defence.
As professionals we are responsible for looking at the whole project, and balancing the hazards and risks against each other. Our controls should then be crafted to mitigate all of them. Some controls may elevate the risk from other hazards, which then have to be looked at again. Designing safe working environments and procedures requires the application of knowledge, experience, and imagination. As no two jobs are the same, the latter is not only crucial – but demanded by the Health and Safety at Work Act.
Written by Nick Garland on Tuesday December 10th 2019
2019 marked the 20th anniversary of the UK’s total ban on asbestos, and – perhaps – the first tentative signs that asbestos deaths have peaked. Much to celebrate, then, but the year also saw upheaval in asbestos management, with the HSE’s long-overdue overhaul of the licensing regime becoming a talking point for the wrong reasons. Here’s our review of the year.
Back on 24 November 1999, the UK’s ban on importing and using asbestos finally came into effect. This year marked the ban’s twentieth anniversary, but sadly our use of asbestos is far from a historic problem. For a start, it’s endemic throughout our built environment, so in February we asked various industry experts: Is an asbestos-free world possible?
As we discovered, the reality is that there is neither the capability nor the budget to remove asbestos from the entire built environment, but is there a case for selectively removing it? In particular, more than 85% of the UK’s schools contain asbestos. In April we asked whether in this unique environment the current ‘manage in situ’ approach was good enough – read our asbestos in schools article here.
Within the asbestos-removal industry, the ban’s anniversary was undoubtedly overshadowed by the Health and Safety Executive (HSE)’s plans to overhaul the licensing system. This permissioning regime controls who can perform most asbestos-removal work, and there’s no question that it needed an update – back in 2016 I was one of many calling for a move to a single, three-year licence term, backed up by formal reviews.
In March the HSE made a bold move, introducing a three-year only licensing system in which the onus is placed more fully on the would-be licensed asbestos-removal contractor (LARC) to prove their competence. Instead of inspections, there’s a detailed online form comprising 14 sections – you can read my analysis of it here.
While there were positive elements to the new system, it quickly became clear that LARCs had little guidance on how to complete the form, resulting in huge time overheads as they dug around for information that could be relevant. For the HSE, the form’s open-ended nature meant that no two applications were alike, and LARCs quickly reported a processing backlog in which renewals were taking many weeks to complete.
From the start, I’m proud to say that Assure360 could help LARCs retrieve the proof they needed to demonstrate their competence. We moved quickly to develop a custom module, specifically designed to provide the exact information the HSE needed for each section of the form – at the touch of a button. We’ve now helped multiple clients through renewal under the new regime, and as it begins to mature and improve we’re working with the HSE to further develop our support.
2019 was the first full year for the Assure360 Paperless app, and it’s a pleasure to hear from clients how it continues to help them work more efficiently on site, and eliminate paperwork back at the office. Below we’ve highlighted just some of this feedback below – for each you can click the link to read the full case study.
Already, some 15% of all LARCs use Paperless, and more than one in ten licence applications to the HSE are submitted using the Assure360 system, but we’re not sitting still. Unique to Paperless, we’ve introduced a new Personal Monitoring feature that helps LARCs develop real strategies for personal monitoring that reflect operatives’ true exposure levels. Aside from ensuring that monitoring is effective, it ensures that monitoring programmes adapt to reflect what’s actually happening on site, helping minimise and manage exposure risks.
And what of 2020? There’s already a packed event schedule for the year ahead – you can see many of the key dates in our frequently updated events calendar. We’ll be rolling out further improvements to Assure360 and, I’m delighted to announce, introducing Android versions of all three Assure360 apps: Audit, Paperless and Incident. There’s much to look forward to, but for now let me wish you a merry Christmas, and a happy and safe new year.
Written by Nick Garland on Thursday June 13th 2019
For some years, there’s been a question mark hanging over the Health and Safety Executive’s licensing regime for asbestos removal. With variable licence periods creating confusion among clients and an unintended hierarchy being created within the industry, attempts to overhaul the system are to be welcomed by everyone.
For those who don’t know, the existing system is a permissioning regime. Would-be licenced asbestos-removal contractors (LARCs) and those who want to renew must demonstrate to the HSE that they have the necessary skills, competency, expertise, knowledge and experience of work with asbestos, together with excellent health and safety management systems. The outcome is either no licence, a three-year licence, or any period between. Additional conditions are sometimes attached.
It sounds simple enough, but there are multiple problems. While nobody is meant to infer anything about competency from a company’s licence term, in practice customers choosing a LARC often treat the full three-year licence as a prerequisite. In addition, LARCs can’t notify a project that extends beyond their licence period – that means that bidding for complex, two-year-plus jobs is effectively restricted to the 35% or so of LARCs with a three-year licence.
Against this, in recent years the HSE has been less inclined to give out three-year licences. Among other things, that’s resulted in an increased workload for inspectors as they conduct more regular licence inspections. There’s a burden for LARCs, too, as there’s a considerable cost and administrative overhead to each licence application.
It’s no surprise that the HSE wants to shake things up. It’s already started to pilot a new regime that shifts the onus away from licence inspections, and more onto LARCs to provide evidence of their competency. In the new system, first-time applicants still get inspected, whereas existing LARCs re-apply via an electronic form.
A couple of years ago I called for an end to the fixed-term licence, and the introduction of monitoring visits. Essentially if you’re good enough, you get a licence. If not – you don’t. it’s recently emerged that in the pilot scheme the HSE are moving towards just that. As ACAD’s Graham Warren explains in a LinkedIn blog post:
“Some eagle-eyed people have been asking ACAD why all renewals [under the electronic pilot scheme] seem to be issued the full three-year term. HSE have confirmed this is not some chance occurrence, but actually how the new system works.”
At renewal, companies either won’t get a licence, or they’ll be licenced for the now-standard three-years. This doesn’t necessarily mean that LARCs that would previously have received a one or two-year licence will be turned down. In all cases where a company is judged competent, the HSE will issue a three-year licence, but it may require a formal review to ensure any improvements are fully implemented. Crucially, this review period will remain confidential, unless the LARC fails to make the required improvements, so it won’t affect the LARC’s ability to compete for contracts.
The change is virtually what I called for, and it’s a vast improvement. By settling on a single, three-year period, the HSE will reduce the confusion among clients who see one and two year licences as less of a vote of confidence. Moving the major work of re-licencing onto a three-year cycle will reduce the burden for LARCs, allowing them to concentrate on making the improvements the HSE wants to see at the review meeting.
For the HSE, it means less licence inspection work, and a relief from the commercial pressures to grant three-year licences to the biggest contractors, who may previously have needed them to bid for the most complex works. A more centralised approach by the HSE (all applications are reviewed by a single team) will mean much more consistency, too.
As Graham points out in his post, there may be some interesting consequences. With clients no longer able to select LARCs by licence duration, they’re likely to look for other ways to determine which companies are working to deliver the highest standards. Being able to demonstrate fastidious record keeping, management and analysis – for example through membership of a trade body such as ACAD – will become more of a competitive edge.
Assure360 can really help here, too. Our data-based system makes it easier not only for LARCs to manage asbestos removal, but for them to demonstrate the high quality of their training, competency, and analysis of key safety factors such as exposure monitoring.
In fact the new regime fits seamlessly with the Assure360 ethos. Being a health and safety system, specifically designed by asbestos industry experts for the asbestos industry, Assure360 has always allowed you to showcase your expertise. Vast quantities of evidence are now required in advance of the licence assessment, and Assure360 customers can simply provide it by running a series of reports. The database presents all the proof that the HSE could ever ask for. And with the new Paperless solution, even site files can be viewed with real date and time stamps on the certification.
We’ve got a great track record of helping clients prepare for, and excel at licence renewal: under the existing scheme our customers have consistently proven far more likely to achieve three-year licences. Under the new regime Assure360 will streamline the process even further, as our reports are mapped against the questions the HSE are asking.
So if you’re applying for a first-time licence, or preparing to renew an existing one, why not get in touch and see how we can help?
Assure360 will be at the Contamination Expo on the 11th and 12th of September – stand J7, directly opposite ACAD. So if you’re looking for guidance and insight into the new process, pitfalls to avoid and strategies to help – there couldn’t be a better first port of call.
I will also be speaking on the first day – 12:30 – 13:00 at Theatre 21 The subject – you guessed it is the only one that matters right now, the New Asbestos Licencing system and how electronic solutions can help.
Written by Nick Garland on Wednesday May 29th 2019
We’re not alone in having wondered whether the HSE’s asbestos licensing system was entirely fit for purpose. With three possible licence durations and multiple conditions that can be attached, clients often use a LARC’s licence as a shortcut to judging competence. Re-inspection as frequently as every year creates lots of work, both for the LARC and the HSE, and doesn’t necessarily result in raised standards.
A couple of years ago, founder Nick Garland called on the HSE to settle on a standard three-year licence, backed up with formal reviews. It’s recently emerged that’s exactly what’s happening in the HSE’s electronic licensing pilot – in this article, Nick explains some of the benefits and consequences.
Note: The post below was originally published by Nick Garland on LinkedIn in 2016. You can click here to read the original post.
The licence terms awarded to asbestos contractors have reduced year on year. I examine the latest data and offer an opinion on a better way forward.
A phrase every LARC will be familiar with, as it seems to be in all letters written by the HSE. One of the principle purposes of such a regime is to:
“…maintaining and improving standards of health and safety”
The Health and Safety Commission permissioning regime policy statement
Maintain and improve standards of H&S, presumably by weeding out the incompetent and promoting best practice. But why then are average licence terms shorter now than they were? I have been in the asbestos industry since the early 1990s, and I’ve definitely noticed the change. Can we infer that the HSE’s opinion is that the industry is less safe and less competent than it was?
Licence assessments can be a very unpredictable time. All of the companies that I work with have heard of, or experienced extremely intense assessment interviews, but at the same time hear of laissez faire ones with very little detailed examination. Requests (demands) from the ALPIs is often insightful but can also be bizarrely arbitrary, with little practical application. One licence assessment ended up insisting that filing cabinets be used (rather than the perfectly acceptable system the LARC already had) – resulting in the conversion of the one and only meeting room into an archive room.
We all know anecdotally that it has become harder and harder to get the ‘full’ three-year licence from the HSE, but the latest figures are quite stark.
ALG figures, supplied by ACAD.
ALG figures, supplied by ACAD.
Excluding new licences (always one year) there has been an alarming drop of 23% in three-year licences issued in that period.
ALG figures, supplied by ACAD.
In my experience the industry, whilst there are some bad eggs, is getting much better. When I think back to the beginning of my career, where it seemed everyone had a three-year licence – the differences are remarkable. Now projects consider the wider job and recognise non-asbestos hazards. In fact, it seems a different industry with most of the stories of astonishing individual poor practice in the past.
So, if we are not getting any worse and the principle aim of a permissioning regime is to drive standards, why are the licence terms going down?
Could it simply be that there are less licensed contractors out there and the HSE want to exert more control. A tighter leash if you like? Certainly, the tone of some licence assessments and HSE visits indicate this.
The HSE tell the wider construction industry (and clients) that they shouldn’t use the licence term as a tool for selection. If the company has been given a licence (any licence) that indicates that they (the HSE) are satisfied and this should be good enough. The clients however (quite reasonably) take the view that well if you are concerned enough that you won’t give them a 3-year licence, then we are concerned too.
A licence holder can’t notify a project that extends beyond the licence expiry date.
We add then that the HSE publish the expiry date of licences – so if you track these things, you can plot a company’s standing. A client also instantly sees which companies can notify the project that they are considering. This might not seem a big concern, but very complex major works, might require 2+ years to complete – knocking out 65% of contractors.
With this in mind – are the HSE less inclined to reduce the term for a huge company? Do they back away when a downward tweak might stop a multi-million £ job in a power station? Certainly ‘the word’ is that they do.
The licence term is certainly a commercial driver.
In my opinion the HSE should remove the fixed term licence. The HSE should assess a company and give, or withhold a licence based on the interview and past performance during site visits. These licences should not expire (I hear howls of outrage).
What should replace it is a tailored review schedule for that specific contractor. Essentially, ‘Yes we are content for you to work with asbestos, but we want to see you again in 6 months, or 12 months or 3 years, just to make sure things stay on track’. A structured plan could therefore be put in place on what improvements must be implemented before the next monitoring visit.
The monitoring schedule would not be published and would not appear on the licence itself. This therefore could not be used for contractor selection. The pressure would be released from the HSE to grant 3 year licences for commercial reasons. There would be no issue of notifying jobs beyond the end of the licence expiry date – as there won’t be one. The HSE can concentrate on maintain and improving standards and do so in a much more structured way.
As I say this is an opinion piece, and I would welcome everyone’s thoughts and feedback.
I have been in the asbestos industry since the early 1990s, helping licensed asbestos removal contractors stay at the forefront of the industry.
Written by Nick Garland on Friday October 5th 2018
Here are some dates for your diary – Nick Garland has put together his list of upcoming events for asbestos and construction safety professionals. We’ll update this page regularly.
27 February 2019
Join our February webinar and find out why more and more supervisors and managers in the asbestos removal sector are using our latest Paperless app to streamline on-site paperwork. Created by our expert team, Nick Garland will take you through everything you need to know about the system and demonstrate how it saves teams time and money. If you’d like to register for our February webinar simply sign up and we’ll send you more information.
18 February 2019
University of Reading, Agriculture Building, Whiteknights Campus
In this free evening event chaired by IOSH vice president Michelle Muxworthy, the IOSH addresses the role and significance of asbestos in workplace cancer.
1-4 April 2019
Hilton Brighton Metropole
Occupational Hygiene 2019 is the leading conference in the field of worker health protection in the UK, focusing on occupational hygiene and the prevention of occupational ill-health and disease. The conference programme combines inspiring and thought-leading plenary sessions with scientific and technical sessions, as well as a range of interactive workshops and case studies. The conference will bring together researchers, practitioners, regulators and other experts from around the world to discuss the very latest in issues that affect health at work.
9-11 April 2019
The NEC, Birmingham
The Health & Safety Event provides the perfect networking and educational opportunity to anyone responsible for running a safe and efficient workplace, anywhere in the UK. The CPD-accredited seminar programme will feature over 130 speakers from across the world of safety, fire and facilities.
6 June 2019
Location to be confirmed
Save the date for the annual ACAD golf day and awards dinner.
11-12 September 2019
The NEC, Birmingham
Registration for the Contamination Expo Series 2019 is now live. Claim your complimentary tickets to the Hazardous Materials Expo with seven events making up the Contamination Expo Series. The Assure360 team will be on stand J7, opposite ACAD.
If you’re hosting or attending an event you’d like us to list here, please get in touch.
Written by Nick Garland on Thursday September 27th 2018
The data collected by Assure360 gives us unique insight into the issues our peers in the safety industry tackle during site audits and tech reviews.
Assure360 is the only community audit and compliance tool available for the asbestos removal and construction industry. With over a hundred safety professionals using the system – so far they’ve completed 4,355 audits – we are developing real insight into the challenges and issues our clients and peers face and overcome. As a result, Assure360 has the power to genuinely improve the construction industry.
It’s been a great year so far. More than 10% of all licensed asbestos removal companies now benefit from our system. The 4,000th audit was completed by one of our Gold subscribers, and in July we hit a record of 159 audits and competence assessments in a single month.
If you’re familiar with these posts, and the Assure360 system in general, you’ll know that the data not only incorporates site audits, but records tech reviews during the planning stage. This allows managers to learn from common issues picked up by their peers – before the project goes live.
We regularly share the community’s findings with our army of independent auditors through our customer newsletter (scroll down to sign up). Let me walk you through highlights from the most recent findings, covering audits and site reviews in June and July.
If we look at the overall top 10 we see that it is very much method statement focused. However, if we look a little deeper I think there are some interesting trends developing, notably around risk assessments – both during the planning and on-site phases.
The top 10 looks like this:
I’ve long championed thorough risk assessment, and the latest results see a comparative surge of issues around them. Appearing mid-table, Risk Assessments (detailed in method proper) relates to assessments at the project planning stage. Risk Assessments are all-too-often an afterthought in the asbestos industry, where in fact they should be the first thing written. Logically if you have identified, say, that there’s a noise and vibration issue involved in a asbestos removal project, the method should detail precisely how all three of these challenges are to be overcome.
A familiar example might be where asbestos insulation removal is detailed, with the detail for the actual cutting restricted to “…cut out with reciprocating saw to 1m lengths.” Methods should state the trigger time, task rotation, and when to wear hearing protection.
Risk Assessment (live services) continues to get the attention it deserves. Interestingly this relates to the site level, i.e. where site teams have not followed procedure, rather than where issues haven’t been considered in the plan.
Happily, there’s a new Assure360 development that will help supervisors. All existing Gold subscribers now get access to our new Paperless solution free of charge.
Quite simply the holy grail of the asbestos removal industry, Assure360 Paperless is a secure and powerful system for recording checks. It’s designed to save time for the supervisor, allowing more time in which to actually supervise. Why not contact us to arrange a demo?
Assure360 is not a dumb ‘smart form’ or isolated tablet application – it’s linked to a powerful cloud database. Its sophisticated system of automatic reminders and dashboards, ensures the right people deal with the issues at the right time. Meanwhile, the system encourages you to always examine the data to ask ‘what could we do to prevent this happening again?’. Everything is dealt with – root and branch, and this month’s results suggest that the approach is working.
How does this data compare with your own audits? Do you have a tool that can help you monitor and tackle these issues, saving you time and money and keeping everyone on the project up to speed?
Let us know what kind of data you’d be interested in seeing, and if you’d like a demo, please get in touch.
Written by Nick Garland on Wednesday March 28th 2018
Finding asbestos contamination on a site or building project can feel paralysing. But there’s no need to panic. Here’s a simple guide to help.
The words ‘asbestos’ and ‘contamination’ are probably two of the things you least want to hear. Whether you’re involved in commissioning or designing a construction project or just occupying a building, asbestos can lead to worry, cost and delays.
Outside of the nuclear industry, the management and safe removal of asbestos is the most regulated process you can be involved in. And regulation invariably means expense – particularly if there’s regulatory infringement.
What is asbestos? As far as day to day practicality is concerned – ‘asbestos’ refers to the actual product that has been installed into a building. Because the ‘benefits’ of asbestos were so far reaching and its production relatively cheap – the type of products it was used in were virtually unlimited.
Asbestos can be found in:
And many other materials and structural elements.
Tony Rich, a respected asbestos consultant in the US, has taken and collated a vast collection of photographs of examples of materials and locations where asbestos has be found from roofing to cigarette filters
With the number of different products so extensive it’s no wonder that properties constructed before the early 1980s almost certainly contain asbestos. As the ban only came into force in 2000, even those built as late as 1999 could have some.
As we increasingly look for asbestos in soils we are finding more and more. Even if we ignore fly tipping and re-burying on site, there are several reasons why the ground we stand on can become contaminated.
Alas for many years we were not very good at finding asbestos in buildings. In defence of the surveyor, the proliferation of asbestos is huge (especially in the UK) and progressive refurbishments can cover over and conceal it. But the approach to intrusive pre-demolition surveys used to be quite weak.
The guidance on what you needed to do with asbestos once found in buildings about to be demolished was not always in concert with the hazardous waste rules. For example, it was widely accepted that Textured Coating had low asbestos content, was bonded to the surface it was painted on, and when demolished, did not constitute hazardous waste.
Buildings could be demolished without even looking for asbestos, either intentionally (we don’t want to know) or as an incompetent oversight.
Whatever the reason, if a building is demolished with asbestos still in it, that asbestos will find its way into the ground. The site itself could become contaminated and / or the subsequent rubble could be converted into secondary aggregate for other sites.
Whether you find asbestos in a building, or find it contaminating land you’re going to be building on, I’ve created a simple acronym to help remember the useful steps to take:
R – Respond calmly
2 – Two important questions to assess risk
D – Decide what you’re going to do next
2 – Two trade organisations who can help you find a licensed asbestos professional to help
If you discover asbestos, in the first instance – do not panic. As the HSE’s Martin Gibson has said – in the UK we have a long history and genuine expertise in managing the risk from asbestos. This does not always mean remove it.
With the proviso that you shouldn’t touch or disturb asbestos – the best rule of thumb when assessing the risk of asbestos in a building is to ask these simple questions:
For example, if the asbestos material is a corrugated garage roof: this is out of reach (or at least not easy to knock into) and clearly quite hard. So the risk is low.
If it is low level pipe insulation, it’s easy to touch and relatively soft. The risk is high. Simple.
You need to have as much knowledge as possible to answer these questions. And when it comes to asbestos that means a survey. This will tell you where any asbestos is and what the risks are.
The very nature of ground contamination makes the ‘problem’ an entirely different beast.
By being in the ground the material is buried and therefore hard to find. It degrades – breaking down and dispersing the asbestos fibres. Surveys have to follow a different pattern and are detailed in the HSE’s asbestos analyst guide (read my recent summary for more information). On the positive side, (especially in the UK) the ground is damp – important as wet asbestos does not get into the air too easily.
The risk assessment for ground contamination though remains essentially the same. Ask yourself two questions:
Loose insulation at the surface is high risk. Buried cement is low risk.
The next step is decide what you are going to do about it.
For asbestos in a building, providing that the material is in good condition there are plenty of options that do not include costly removal. In fact this is the HSE’s primary recommendation. If you can avoid touching, damaging or in any way disturbing the asbestos – then it is safer to manage it in situ. Even this is relatively straightforward – it involves a periodic check to make sure that its condition has not deteriorated.
If you do leave asbestos in the building – anyone who could come into contact with it should know it is there. If they could damage it through their work, they should have Asbestos Awareness training. These courses are so widely available that it is almost certain that there is a company near you that provides them. Check out the IATP or UKATA website to find a provider.
If however the asbestos is in poor condition, or it is in such a position that it could get damaged in the future, action may need to be taken. This still doesn’t necessarily mean removal but it does mean that you will need professional assistance. Options other than removal could be to protect the asbestos – help ensure it doesn’t get damaged. This can range from covering it up, painting it or to simply close and lock the door.
Again with ground contamination, we are faced with different challenges. We often only know of the existence or the contamination because digging is planned. But it could be something as simple as buried broken cement coming to the surface on a walkway. In either case some form of action is usually required. Just like asbestos in buildings though, that action could be ‘close the door’. In this case it would be to install a capping layer above the problem to seal it off. If however digging is unavoidable then some form of controlled removal will be required.
The rules on where this material goes is simple, but has huge implications:
If either of these are the case, then the material is ‘hazardous waste’ and therefore expensive to dispose of. If not at these levels, but still present, it is not ‘hazardous’, but must be disposed of at a landfill site that has an ‘asbestos cell’. Significantly less expensive, but still onerous.
Therefore a single fragment of visible asbestos can render a whole load contaminated. Careful early planning, screening and segregation becomes critical.
I have always recommended that a licensed contractor is used for any work on asbestos. This is (strictly speaking) not always legally required, as some low risk asbestos (the cement sheeting I mentioned earlier) does not need a licence. It does however need special equipment, training, medical supervision and insurance. In my experience you are much more likely to get it done right first time with a licensed contractor.
There are two main trade organisations: my one: ACAD, and ARCA. Both can offer lists of members that have passed their audit scheme. However, I would counsel that you would need more than this. Any company that operates an internal competence scheme like Assure360 gets a gold star in my opinion. Beyond that – personal recommendation (if your procurement will allow) is always the surest way to a happy outcome.
Land remediation is a specialist, complex skill that most (even licensed) contractors don’t have. The approach does not normally include enclosures, but could in the most serious of cases. Careful selection is therefore vitally important.
The final piece of advice I always offer is to become an educated client. Asbestos removal is expensive, complex and scary. Going ignorant into a contractual relationship in those circumstances is brave indeed. What’s more, CDM15 no longer allows clients to say ‘I didn’t realise’, or ‘that’s not my area’.
So, either get someone in your organisation that understands the subject (e.g. the BOHS course P405), or appoint a consultant independent of any of the asbestos project team who can be your expert advocate.
There is even help in selecting the right person: FAAM is the new faculty for asbestos professionals and commits its members to a level of expertise and an ethical code of conduct. Ask are they full members of FAAM (MFAAM)?
Expertise in asbestos land remediation is unfortunately less widespread. Whilst asbestos in the ground is a problem that has been with us for nearly as long as asbestos has, it’s been somewhat under the radar for most professionals.The introduction of the comprehensive document CAR-Soil has allowed training course to be developed often by CL:AIRE. CL:AIRE also publish a list of their members, but I don’t believe there is a formal auditing or vetting process.
Either your in-house expert or the external advocate would then be able to directly check that the project is being run safely according to the plan. In other words audit. Assure360has been specifically designed to help clients like the Royal Mail to monitor asbestos projects whether in the built environment or in the ground (no apologies for the shameless plug).
Whilst asbestos is a scary word – the Brits are world leaders in managing the risk. Get the right people around you and don’t panic.
Written by Nick Garland on Friday February 2nd 2018
Britain was the first country in the world to have an industrial revolution, and we were the first to start importing asbestos. We have imported the most asbestos of any country in the world. In fact in the ‘50s, ‘60s and ‘70s we imported 40% of the world’s capacity to produce amosite / grunerite.
We have so much asbestos that we can’t remove it all – we have to manage it.
These startling facts were shared by Martin Gibson (HSE) speaking at the European Asbestos Forum in September. They perfectly crystallise the unique situation that the UK finds itself in. The reality that we can’t remove our asbestos – only manage it – is also the foundation of all of our legislation. In essence: assess the risk and design solutions to keep people safe.
This takes a special kind of professional – one who is expert in the regulations, but who can see beyond the guidance to the purpose. They need to be able to design practical solutions rather than gold-plate and over specify.
How do you know you’re working with someone with these professional skills? Who can you trust? Asbestos is the biggest occupational health problem the UK has ever seen, yet anyone can claim to be a consultant or expert.
“We are a highly qualified asbestos consultancy firm”
“We are specialist consultants to survey and test any asbestos”
“Leading accredited asbestos management consultancy”
These are all genuine marketing lines promoting the skills and qualities of asbestos consultancies. Do they mean anything? How do we know, what confidence do we have?
The two existing professional asbestos management bodies have never been quite right. IOSH is focused on Health and Safety and BOHS has the whole breadth of Occupational Hygiene to consider. Being chartered in either does not speak to your asbestoscompetence, but there hasn’t been any real alternative
Until now.
Finally, there is a home for the asbestos professional. BOHS, with it’s shiny new royal charter has created a new faculty – Faculty of Asbestos Assessment and Management (FAAM). The launch event was back in October last year and the first few full members – myself included – were accepted into the faculty over Christmas.
https://www.youtube.com/watch?v=dLIgwq5sEL8
Now for the first time we have a home. One that insists on the maintenance of professional standards and where failure to maintain those standards will have consequences.
FAAM’s stated principles are:
FAAM will support members with
To be clear – FAAM will not be claiming that non members are incompetent, only that those who are members, have demonstrated competency, maintain that level and operate to an ethical code.
The levels of membership and the qualifications you need are:
Technician
• Level 4 – (one of P401 to P404), S301, W504, RSPH L4, or • Level 3 – RSPH Level 3 (plus written bridging exam) – OR…
Associate
• P405 or P407, or
Three from P401, P402, P403, P404, S301 or W504
Licentiate
Certificate of Competence (Asbestos)
Member
• CV, professional experience portfolio (or PEP) and personal interview
Fellow
… to follow … significant contribution to the profession
Whilst BOHS as a whole has a royal charter the new faculty does not – but there is the tantalising possibility that it might in the future.
The whole concept has excited me since it was first mooted – but I must say getting my acceptance documents through was a thrill and for the very first time there are letters I will be proudly using after my name – MFAAM. I urge all like minded professionals to apply.
Written by Nick Garland on Friday February 2nd 2018
I’m always fascinated by the insight the data gives us into the issues our peers in the safety industry tackle during site audits and tech reviews.
Assure360 is the only community audit and compliance tool available for the asbestos removal and construction industry. Over a hundred and sixty safety professionals use the system, completing, to date, more than 3500 audits. Assure360 is developing real insight into the challenges and issues all our clients and peers face and overcome. As a result, we have the power to genuinely improve the construction industry.
The system not only incorporates site audits, but records tech reviews during the planning stage. This allows managers to learn from common issues picked up by their peers – before the project goes live.
We regularly share the community’s findings with our army of independent auditors through our customer newsletter.
This time the issues that the Contracts managers faced mirrored the overall top 10:
The top 10 list looks like this:
If we look at the numbers – three of these are clearly related:
· Risk Assessment – generic assessments
· Risk Assessments – whether the identified controls are reflected in the method
· Risk Assessment (vibration)
If we also consider that electrical isolation not being in place could also be connected to a lack of adequate risk assessment – we can see the attention to detail with respect to non-asbestos hazards is by far the most common issue at 27 instances.
Improved general H&S awareness and training for the contracts managers should be considered.
The most common issues for supervisors
Assure360 allows us to drill down and identify issues faced by supervisors. This allows the teams to address targeted issues within supervisor meetings, rather than allowing company-wide concerns to cloud the issue:
The top 10 for supervisors looks like this:
1. Access Routes
2. Housekeeping
3. Tied (scaffold)
4. COSHH Assessments
5. Double hand rails (scaffold)
6. Scaffold (Fans)
7. Signing in
8. Method Statement (briefing)
9. Scaffold (Boards)
10. Scaffold (Design)
Two main issue stand out for the site teams – housekeeping / safe access routes and scaffolding. Again, these are non-asbestos general construction issues.
Assure360 is not a dumb smart form or isolated tablet application – it is linked to a powerful cloud database. Its sophisticated system of automatic reminders and dashboards, ensures the right people deal with the issues at the right time. As Assure360 always asks – ‘what could we do to prevent this from happening again?’ everything is dealt with – root and branch.
How does this data compare with your own audits? Do you have a tool that can help you monitor and tackle these issues, saving you time and money and keeping everyone on the project up to speed?
Written by Nick Garland on Saturday September 23rd 2017
In my regular feature, I take a look at the data collected by Assure360 to understand the issues our peers in the safety industry tackle during site audits and tech reviews.
Assure360 is the only community audit and compliance tool available for the asbestos removal and construction industry. With over a hundred safety professionals using the system – so far they’ve completed nearly 3000 audits and competence assessments – we are developing real insight into the challenges and issues our clients and peers face and overcome. As a result, Assure360 has the power to genuinely improve the construction industry.
The system not only incorporates site audits, but records tech reviews during the planning stage and . This allows managers to learn from common issues picked up by their peers – before the project goes live.
We regularly share the community’s findings with our army of independent auditors through our customer newsletter. Here is a taster of the most recent findings we shared covering audits and site reviews from August 2017.
If we look at the overall top 10 we see predominantly paperwork issues, that either are, or can be identified during peer reviews:
The top 10 list looks like this:
Whist the no. 1 spot is still held by the appropriateness of the method statements – there is a dramatic increase in the frequency (up nearly 40%). This may be an indication that new auditors are focusing more in this area due to these Top10s.
The next two are new to this month’s Top10 and reflect current forum threads. The former was an alarming situation:
A client of mine recently enquired why the hired DCU did not have a CO monitor in the clean end of the DCU. I think I suspected that they would say balanced flue, separate sealed unit, not needed… but they actually came back with ‘we took them out because they don’t work due to the humid conditions and the rapid airflow’.
Heres a summary of what they said:
Following an investigation into a CO poisoning case (2 operatives overcome by CO fumes within the shower system), the conclusion was that the CO alarm did activate using the test button but failed to activate when CO was emitted into the system. This malfunction was caused by the water ingression to the sensor field and simply blocked the sensor.
The BS 50292 (5.2.3.1) apparently states that alarms should not be installed next to doors, window, extractor fans or air vents – where significant air movement prevents the alarm from detecting CO.
Obviously a concern – a clear hazard (2 operatives overcome by fumes), but the detectors don’t work due to the configuration of the units. Just taking the alarms out doesn’t seem to be a solution.
Assure360 allows us to drill down and identify issues faced by supervisors. This allows the teams to address targeted issues within supervisor meetings, rather than allowing company wide concerns to cloud the issue:
The top 10 for supervisors looks like this:
Several new areas have been focused on this month with DCUs receiving significant attention. Double hand rails – whilst they have dropped a spot – actually went up in frequency (up 20%).
Similarly, contracts managers can focus on their challenges
The top 10 issues for contracts managers are:
Obviously the method statement issue dominates here – but if we look in more detail, there are three Welfare questions that are clearly linked. If we take Welfare – general facilities, canteen and provision of water together – they are in a clear second place with 16 instances. I think we are seeing evidence of our construction colleagues teaching us what to look for.
Written by Nick Garland on Wednesday August 23rd 2017
The data we collect through the Assure360 app gives us unique insight into the issues our peers in the safety industry tackle during site audits and tech reviews.
Assure360 is the only community audit and compliance tool available for the asbestos removal and construction industry. With over a hundred safety professionals using the system – so far they’ve completed nearly 3000 audits and competence assessments – we are developing real insight into the challenges and issues our clients and peers face and overcome. As a result, Assure360 has the power to genuinely improve the construction industry.
The system not only incorporates site audits, but records tech reviews during the planning stage and . This allows managers to learn from common issues picked up by their peers – before the project goes live.
We regularly share the community’s findings with our army of independent auditors through our customer newsletter. Here is a taster of the most recent findings we shared covering audits and site reviews from July 2017.
The top 10 list looks like this:
Changes from last time is that accuracy of the drawings has dropped lower as has double handrails. Dropping out of the top 10 completely COSHH assessments, electrical isolations and firefighting equipment. A new observation – at number 1, is the appropriateness of the method. This is a new question in the App – where the auditor makes a judgement of whether a better, safer, more efficient method could have been designed.
Assure360 allows us to drill down and identify issues faced by supervisors. This allows the teams to address targeted issues within supervisor meetings, rather than letting company wide concerns to cloud the issue:
The top 10 for supervisors looks like this:
The two interesting additions to the list is double hand rails and housekeeping. Both are traditional H&S issues rather than asbestos specific, and might indicate widening expertise or awareness from the auditors. Also a new question in the system is Method Statement Briefing. This is where a supervisor has had to be moved or replaced – has there been sufficient hand-over and has the new site management taken full charge of the site?
Similarly, contracts managers can focus on their challenges:
The top 10 issues for contracts managers are:
HAVS and the associated vibration risk assessments seem to be an issue at the moment. Also the refining of the question set, with more options with regard to how a method statement is being written – has changed how issues are being recorded. This will help with more detailed root cause analysis.
Written by Nick Garland on Tuesday August 1st 2017
In the second part of my summary of the Asbestos Analyst’s Guide from the HSE – I’m concentrating on asbestos testing (both bulks and air).
This is a stand-alone article, but you may also want to read the first instalment published earlier this year – New analyst guidance: appointing the right asbestos analyst.
This is a review of the ‘draft for consultation’ – there may well be changes before final publication. We still don’t have a release date for the final publication of the guidance, and we are already at the end of the promised June. However, the consultation was a surprise when it was issued over Christmas, so stand by your beds.
Whilst I am writing this for the layman – this instalment reviews some dramatic changes that all professionals will need to prepare for. It comes with my usual health warning – this is obviously a summary and clearly not intended to replace the Guide. The appendices contain a lot of important detail and should still be studied to gain the fullest picture.
The first section I will deal with in this instalment is analysis in bulk materials – or ‘bulks’ for short.
Simply put, this is where a small amount of a suspect material is collected on site and taken to a laboratory. Powerful microscopes are used along with special techniques to investigate the sample. This is the only sure fire way of determining whether a material contains asbestos and ultimately what risk it presents.
Bulk Sampling and asbestos surveys are required under the duty to manage (CAR 2012, Regulation 4) and under the current Construction Design and Management (CDM) Regulations.
Whilst HSG264 – Asbestos: the survey guide remains the best practice manual, the new analyst guide overlaps and takes things further in some areas. Both will need to be understood to remain compliant.
The guidance on single surveyor working has been significantly altered. It is now ‘strongly recommended’. The guide goes further by stating that some situations make it essential:
We should take note – as this is much more forceful phrasing than the ‘ideally’ in the Survey Guide. The need to work from height in most or all surveys would seem to preclude solo working completely. Clearly, if single ‘man’ teams are now officially frowned upon, it will have an impact on prices.
The guide gives specific direction on sampling strategy for some ACM types. Mostly the advice is consistent with HSG264, but again with some exceptions. The first significant change is in the recommended strategy for pipe insulation.
HSG264 tells us:
“In general, one sample should be taken per 3m run of pipe with particular attention paid to different layers and functional items (valves etc). ”
Whereas the Analyst Guide says:
“Valves or hatches or repaired areas near access routes are less likely to contain asbestos but discretionary sampling may be necessary.”
Clearly a totally different approach, which I am not convinced about. Only the other week I attended a site where all the asbestos had been removed, except near the valves.
Another key change in guidance is in dust sampling, which should be avoided except in ‘rare and specific occasions’. Dust sampling should not form a routine method or approach when surveying. Low numbers of asbestos fibres in dust are to be expected in buildings which contain or have contained ACMs. Due to the sensitivity of the method, very low levels of fibres can be detected. However, the guide tells us the random presence of low numbers of asbestos fibres in dust is not significant and represents “inconsequential risk”. It also tells us – in the absence of any ‘visible’ suspicious asbestos debris and fragments, extensive cleaning or abatement works will not be necessary
This is very welcome guidance indeed. Asbestos occurs naturally in the air of all our industrial cities. The sensitivity of the bulk analysis process is likely to find even the smallest trace. Because such testing merely determines presence and not risk, it is too blunt a tool. Random swab samples, where there is no visible evidence of contamination have caused no end of issues to clients. A report containing such information can cause considerable alarm and remediation costs, where the reality might be a single isolated fibre posing little or no risk. See the section towards the end of this article on SEM and ‘Real Risk Assessments’.
In traditional surveys, the number of samples taken will depend on:
The guide states that the number of samples should not be restricted by cost or contractual arrangements as this could lead to poor choices and false assumptions. This is much stronger guidance than previously published. I must stress that I fully support the increased emphasis, but it should be recognised that it will have an impact on costs.
Help can be obtained from original architect drawings, but will depend a lot on experience. The guide suggests ‘tells’ that will give a clue to a change in material:
None of the above can be used for positive identification, but they can give a strong indication as to when to take additional samples.
Consideration should be made where access makes sampling or post sampling clean-up impractical or hazardous. These areas should be discussed with the client. This is a continuation of the plan, plan, plan mantra of the survey guide.
On the sealing of the sampling point, the guide raises some important considerations. Specifically, it recommends that the chosen technique should be agreed with the client. Some issues to bear in mind:
Safety alert!
On this last issue, there was a serious safety alert on the asbestos forum where some foam sealant used in an enclosure spontaneously ignited via static electricity.
Spray coatings The guide suggests pre-injected with surfactant around the sampling area. It cautions against sampling damaged areas that show evidence of previous repair – whilst easier and safer, it may not be representative.
Pipe/thermal Full depth samples using a core sampler, but placing a wipe inside the tube before sampling and withdrawing the sampler through another wet wipe. This creates a plug at either end.
Insulating board/tiles The guide warns of proximity to live electrics, where pre-spraying might be hazardous. It also warns that a large sample is needed if the water absorption test is planned to determine AIB or cement (see below).
Asbestos cement Large samples are recommended (at least 5cm2) or where the water absorption test is required (9cm2). Asbestos cement is defined by CAR 2012 as a material, which is predominantly a mixture of cement and chrysotile and which when in a dry state, absorbs less than 30% water by weight. This leads to the Water Absorption test which is detailed in Appendix 3 of the draft guide.
Textured coatings Again large samples are recommended as asbestos is typically non-uniform (at least 20cm2). Areas of thicker material and/or ridges should be targeted. Two samples per surface or one per 25m2.*
Dust samples Avoid, but where they are taken to assess spread of a specific incident a minimum of one tablespoon of dust (not debris) should be collected. Scraping the dust layer into a pile and transferring into a suitable labelled container. Wipes, adhesive tape and filters should not be used.
* I have served my time in the bulk lab and can testify to how irritating small samples of textured coating are. However, I am not sure how a client would take to two 20cm2 sample from every ceiling. Certainly, something to discuss in the pre-survey planning.
In layman’s terms, air testing. For asbestos, it is the collection of a measured volume of air (litres) through a filter. A specific area is examined (number of ‘graticules’ – see below), and the number fibres counted. This allows the calculation of the concentration of respirable (again see below) fibres in the air.
As the guide was intended for the use of clients as well as analysts and the above is likely to mean nothing to most readers – I will start by explaining a few terms:
Respirable
In this case means not only breathable, but small enough that they can reach the lowest levels of the lungs where they can do the most harm.
Volume
Results are quoted in one of two ways – the first is by far the more dominant. f/ml or f/cm3 – i.e. number of respirable fibres counted for every millilitre or cubic centimetre of air drawn through the pump. 1ml is the same volume of air as 1 cm3.
Limit of Quantification (LoQ)
This is an oft used phrase that is little understood outside the analytical world. Results are often stated as less than the LoQ (e.g. <0.01f/ml). LoQ is a statistical way of determining what would be “fair to say”. E.g. if a given room had 100 fibres floating about and you sampled a small amount of the air – it would be pot luck whether you captured any of the fibres, but it wouldn’t be ‘fair’ to say that the air was asbestos free – just you didn’t detect anything. Similarly, if there were 1 million fibres floating about – you would be near certain of catching some. Therefore, LoQ is a statement that:
we don’t really know exactly how much asbestos is in the air, but it is less than ‘this’
Any clearer?
Graticules
This is the round ‘target’ that the analyst can see when analysing the filter through the microscope. The target is moved randomly a set number of times and the number of fibres falling within that target are counted. The graticule is a specific area, and so if we know how many targets have been inspected, we know the precise area of the filter that has been analysed. Clearance tests would include 200 of these random movements, personals can have less. Therefore, if only 100 graticules are used this means ½ the time to analyse the sample but double the LoQ.
The guide details the two main types of air testing – personal and static.
Where we test the fibre levels near to an individual’s face. The asbestos approved code of practice tells us what we should use this type of test for.
Whilst measurement against the control limit requires a 4-hour sample, there is allowance for shorter activities. It must be noted that when the time to access the enclosure and decontaminate following completion of a morning’s shift is factored in, a 4-hour task is a rare beast indeed.
In my opinion, all the above are important, but the last three have the most practical use. The removal contractor should be aiming for higher standards than the control limit to help drive performance. But only a test with a low LoQ can have any real utility. Therefore, the 10-minute test should be avoided in favour of one that can give a LoQ of 0.05f/ml or better.
My Assure360 database is designed specifically to deal with these three critical areas.
Clearly high risk activities should be prioritised – this may be related to the ACM, its condition or the individual’s role in the method. So, if a single test is to be completed it should be the operative scraping the pipe, not the one doing general spraying duties.
The analyst must record detailed observations about the operative during the testing:
The guide specifically states that if any of this information is missing, the sampling will be deemed inadequate. Now this is a very strong statement indeed. I think it is intended to compel analytical companies to comply, rather than suggest to a contractor to ignore them.
Just like any asbestos worker, the analyst themselves should have personal monitoring conducted on them particularly:
A ‘summary’ of personal sampling should be kept for 5 years. There is no guidance on what this summary should contain. But the data should form part of the health records, which must be kept for 40 years.
My Assure360 database tracks the exposure, compares it against the anticipated level and allows the employer to review methods on a regular basis to improve standards. Whenever the anticipated levels are exceeded, this is treated just like any safety incident spawning an investigation and root cause analysis. These new-look certificates would come into their own at this stage – perfect evidence for the investigation. Upload them as a permanent link to the record. With nearly 4000 personals on the system now – it gives users a great deal confidence when setting and reviewing levels.
This is the large traditional air test, where we establish the fibre levels in a general area. Used in several different situations:
There is no specified flow rate for static tests, but total volume of air tested should 480litres or more. The number of graticules (targets) counted must be 200+. However, the recommendation is that high flow rates (e.g. 16L / min for 30 minutes be used to limit the effect of settling and increase accuracy. The exceptions to this are background and perimeter monitoring – where low flow rates and very long durations are preferred.
The guide gives some pointers on when not to test.
I have my doubts over the wisdom of the last two. We are mandated to reduce exposure so far as reasonably practical, therefore not testing because we don’t think exposure will be too high – or we already use good RPE – seems to miss the point. You should always conduct the test to ‘support current and future risk assessments’ and ‘check the effectiveness of control measure’.
This is the name of the standard technique used to calculate airborne fibre concentrations. Paragraphs 5.10 & 5.11 give a great deal of detail on this, which I do not intend to reproduce here.
The technique has its advantages and disadvantages. Probably the key plus is that the test is quick (within an hour or two when conducted on site) and by comparison to the alternatives – inexpensive. Disadvantages are that high dust environments (e.g. wire-brushing, ‘blasting’ or removal of ceilings) can overload the filter making it unreadable (occluded). As it can’t easily differentiate between asbestos and non-asbestos fibres, it can overstate asbestos concentration.
These must be recognised and factored in when designing the sampling strategy. Careful selection of sampling periods/volumes or sequential samples (i.e. multiple tests run after each other, adding the results) should be considered. Another important strategy (where results may be skewed by non-asbestos fibres) would be the retention of half the filter prior to standard analysis. In the case of a ‘high’ result from the first half, the duplicate can be sent for a much more accurate Scanning Electron Microscopy (SEM) test – see below.
Caution should also be observed when interpreting the results from post incident air tests. The time gap between the incident and the test will be affected by natural dilution.
Whilst the guide details the option of using SEM analysis. It does not suggest it as a first option, but only as a check if PCM fails. However, in the case of blasting, where occluded filters are near certain, or very low LoQs are desirable, SEM testing should be considered. SEM can obtain LoQs as low as 0.0005f/ml and are much less vulnerable to overloaded filters.
One interesting service that is beginning to be available is ‘Real Risk Assessment’. The phrase was coined by Charles Pickles of Lucion referring to long duration air tests in normal (occupied) areas. Analysis by SEM would give very low limits of detection. Results could then be directly comparable to the World Health Organisation lifetime risk levels. This would finally measure chronic low level exposure and allow a genuine understanding of the long-term risks. Such accurate results could validate existing management techniques and prove that occupants are not being exposed, or, used to improve the plan.
In the case of 4-Stage Clearances (4SC), the guide indicates that the original floor surface should not be covered at the time of the air test. It does say that there are exceptions, but the only examples given is scaffolding or when the floor is an ‘intrinsically dusty surface’. This could be interpreted as meaning – floors sheeted out before removal must be uncovered for the 4SC air test. Hopefully clarification will be in the final version as many simple projects may become more complex and costly if this is the case.
The guide states that daily leak testing is required where there are other personnel near the asbestos work. Key areas to be tested are:
Testing should be a combination of short and long duration – short just after removal commences, with longer duration following on after.
This is very clear direction that was lacking in the original 2006 analyst guide. Currently leak testing (certainly daily ones) is considered an optional extra. The new emphasis is unarguably a good idea – but the cost impact on projects will be significant.
Other than the PCM and SEM, two other sampling techniques are discussed in the guide:
In my next feature I’ll be looking at how we can start preparing for new legislation.
Written by Nick Garland on Friday June 2nd 2017
We’ve just released an updated version of the Assure360 app – here’s how it helps to turn auditing into meaningful improvements in safety.
Our app was born to help companies manage asbestos removal projects (the most regulated UK industry after nuclear), so compliance is critical. But the structure also encourages the auditor to examine ways to improve. The app identifies good innovation on site as well as allowing the user to record aspirational best practice identified elsewhere. The combination of the app and the cloud database, instantly links audit findings with actions. Whether the observation is something that has gone wrong, innovative best practice, or a lesson learned from external sources –the sophisticated workflow process makes sure no one forgets.
The audits completed on the free app are the most comprehensive available, developed by myself over the past decade. They are uploaded directly to a database in the cloud, where the system interprets them for you. Non-conformances are presented to the designated managers for them to close out. It even reminds them if the due date expires. The high-level dashboard not only shows the immediate information required to spot trends, track close-out and develop strategies for improvement, it also allows a structured walkthrough so that you can showcase how you go about managing H&S to clients and regulators. A warts-and-all approach, where ‘challenged’ sites are discussed, becomes real evidence of proactive management.
Multiple organisations can participate in the process. The company themselves will obviously take the lead – but customers and trade organisations can also complete audits on the free app. The cloud structure can be designed so these 2nd and 3rd parties can view their audits and relevant internal inspections too. As all the audits are on the same system, close-out of non-conformance and learning from best practice is streamlined.
With the help of the army of auditors who use it, Assure360 has been evolving since its creation. As findings are anonymously shared on the central cloud database – this means that users constantly and automatically learn from others in their own sector and beyond.
Assure360 now covers safety auditing in every workplace and is so flexible it can be tailored to any industry, language or country. This flexibility was a key demand from our users who have been an integral part of the research and development. Continuous feedback, active participation, innovation and plain bright spark ideas have allowed us to design the experience to match not just what users need, but what they want.
We are still very close to our roots, but now the asbestos industry can start to learn from other sectors.
Read my feature on LinkedIn to find out more about what needs to change in safety auditing.
Written by Nick Garland on Thursday May 25th 2017
Here’s Nick Garland’s summary of the draft of the new Asbestos Analyst’s Guide from the HSE and what it suggests for hiring the right analyst.
The HSE’s new Asbestos Analysts Guide is coming soon or so we have been confidently told for the past year. The current tentative publication date is June 2017, but I have heard that even this is likely to slip. When we do get it, it is designed to help both Analysts and their clients comply with the Control of Asbestos Regulations 2012 and its ACoP.
It’s the client I am particularly aiming this summary at, but those with technical backgrounds should also find it useful. It is also for this reason that I largely don’t cover the appendices – in of themselves a whopping 178 pages’ long!
This is obviously a summary and clearly not intended to replace the Guide. In particular, the appendices contain a lot of important detail and should still be studied to gain the fullest picture. A note of caution, this is a review of the ‘draft for consultation’ – there may well be changes before final publication.
The early stages of the guide cover the critical areas of how to appoint an analyst and what quality control measures should be implemented by the consultancy.
This is the first time we have been given strong guidance on this subject, though it has long been the perceived best practice. This contractual relationship is critical to ensure independence and the control you will need
With this starting point, the HSE then require you to discuss the project in detail with the consultancy. The aim is to ensure that the consultancy understands what you the client wants and for you understand what you are going to get.
Areas to address:
The wording for this last point is particularly interesting. Reports should be designed to satisfy the client’s needs, not just perceived UKAS requirements. The frustrating ‘our reports have to look like this, it is part of our UKAS accreditation’ or ‘no we can’t give the data in that format, because…’ should all be a thing of the past.
The whole appointment and subsequent planning phase is intended to mimic the changes first introduced in the Surveying Guide in 2012. Planning (especially between the client and the surveyor) has become the major route to success. It is intended to get around the issue of “why do I never get what I asked for?” – the answer normally being “you didn’t ask for it…”
Underlying everything in CDM15. Asbestos removal projects are covered by CDM, this is a long-accepted fact. However, the analysts guide gives us a new twist. Contrary to the wording in CDM15, the guide specifically states that the analyst will be treated as a separate contractor. This has dramatic implications, as all asbestos removal projects – even the smallest ones – will therefore require the appointment of a Principal Contractor (PC) and a Principal Designer (PD).
Many of the asbestos consultancies have upskilled to take on the PD role, but the smaller ones may not accept the additional liabilities. This then is another duty for the client – appoint a PC and a PD to the project – and be confident that they have the skills to do it. This could be an asbestos consultancy that can accept the wider duties or a specialised PD that has the expertise in asbestos.
A key client responsibility in CDM15 is to ensure that the project is being run safely. Without this engagement and contractual control, ensuring safety would be largely impossible. Even then, without some expertise, you replace ‘ensure’ with ‘hope’.
The advice I always give clients is simple – become an educated one. Either train someone in your organisation or appoint a consultant independent of the asbestos project teams to be your expert advocate.
Employers must prevent or minimise exposure and as with all guidance, the phrase ‘so far as reasonably practicable’ is used. It also suggests that ‘live’ enclosure entry should be avoided – as this could lead to exposure above the Control Limit and with it, mandatory asbestos medicals.
I take two things from this: firstly, the pre-visual, much loved by contractors, is being officially frowned upon, and secondly the guide is suggesting that not all analysts need medicals. In my experience, site analytical work (clearances, leak air testing and so on), inevitably leads to exposure above the Control Limit at some point. I have two examples from my past, both seemingly very low risk that led to high personal exposure. The first, a contractor was removing a cement flue with hidden pure fibre in the flanges – a surprise failure at stage 3. The second was a straightforward Asbestos Insulating Board (AIB) job, where the High Efficiency Particle Air (HEPA) filter failed in the Negative Pressure Unit (NPU). Consequently, I believe all analysts should have medicals.
The guide makes clear that two copies of the Certificate for Reoccupation (CfR) must be issued – the building controller and the licensed contractor.
Personal exposure for analysts should be air tested (personals rather than static). The purpose of personal monitoring is not ‘merely’ duty of care and the data must be used for:
It gives direct guidance that personal monitoring should be performed in ~10% of case, targeting:
Whilst the control limit is highlighted, I find the other element more interesting. Minimise so far as reasonably practicable, risk assessment and effectiveness of controls drives the responsibilities of the employer much, much lower than just the control limit. There is therefore no ‘good enough’ and we should be striving for ever lower exposure. This has an impact on how long we run the tests for and what Limit of Quantification / Detection we set.
Whilst the number of required audits has stayed roughly the same, other checks to be recorded and studied have increased:
Approximately 5% should either be shadowed or blind inspected immediately afterwards:
During the consultation period, I know that there was some call for making the audits more specific – i.e. what type of clearance was it? This would bring it into line with survey audits.
The last bullet will be new to those that have not read the draft guide. The new 4-stage clearance process must include photographic evidence to support the decisions taken along the way. These will include such things as proof that the enclosure was free from gross contamination and dry before the visual inspection took place. The time and date stamp on the photos is intended to evidence the stated durations of each stage.
Maintain individual logs of all work completed by your analysts. These logs should record:
Six monthly auditing of Analysts’ performance (including a review of the above detailed logs).
Essentially the guide is calling for audits to record significantly more detail. Once we are collecting more we will have to do more with it. This will drive assessment of competence and training to new levels.
The difficulty is that a huge amount of data can be very time consuming to process. Just as the removal contractors found with the drive for competence on their side of the fence – the consultancies will have to develop new sophisticated systems to collect, analyse and present the data in meaningful ways.
The guide immediately highlights something that has been clear to me for a long time. What we ask of our analysts often strays from the standard UKAS requirements into other areas:
The guide also highlights the need for H&S training, in my opinion – critical basic training for any analyst.
We must also recognise that the very act of passing or failing a 4-stage clearance is a potentially stressful and intimidating situation. Consultancies should therefore provide support mechanisms and procedures to mitigate or eliminate. This will help ensure that analysts’ actions and decisions are impartial and independent. Personal qualities of ‘resilience’, ‘determination’ and ‘integrity’ will be required.
The guide covers the UKAS recognised proficiency training modules. Also highlighted is the requirement for sign-off by senior manager before any unsupervised work. However, the regulations tell us that Competence is not just a matter of a training certificate – we must ensure an employee is competent to do the job. But as I cover in my competence blog pieces – we can’t just leave it at that – just because I was signed off as competent last year doesn’t mean I still am.
The required participation of the client in the plan, plan, plan process is likely to expose a longstanding industry misunderstanding. When a client hears ‘Project Management’ they expect:
Initiating, planning, executing, controlling, and closing the work of a team to achieve specific goals and meet specific success criteria. The primary challenge of project management is to achieve all the project goals within the given constraints.
However, in most cases, Analytical Consultants mean:
Specify the project, review the method, supply an analyst to run air tests, provide a report after the clearance
The client sees the latter as a given, and assume that the asbestos consultancy’s definition of project management is the same as for other areas of construction. This disconnect from expectation and delivery leads to much of the dissatisfaction in the industry.
So how common are these skills:
It is a rare analytical company that even has these as categories on the skills matrix, never mind measures or audits them. They tend to be what we assume an analyst can do, without training. Managers have often described it to me as a ‘gut feeling’ about an analyst that leads them to promote them to a more senior role.
The guide’s focus on soft skills and project management presents a challenge to labs. Most companies currently do not even identify these soft skills in their competence matrix, never mind measure them.
The clear steer is that to be ‘competent’ (i.e. knowledge, skills and experience) an analyst needs to go far beyond just the ability to operate within a UKAS environment. We see far reaching implications for training and competence – a consultancy’s approach in this key area should form a key part of the selection process.
Get in touch with us to discuss how Assure360 can help with:
Written by Nick Garland on Friday October 21st 2016
Amazingly it is now a full week after the inaugural Contamination Expo – I don’t think any of us knew quite what to expect – and that included the organisers! 200 Exhibitors, 3000 registered delegates and rumours that the HSE were going to attend (I know at least one inspector was there, because he came to see us…).
Whilst I have been around the asbestos and H&S industry for nearly 25 years, the Assure360 solution is very new – so it did actually feel like the right place for us to be.
Not only did we exhibit, but I presented a seminar – ‘Competence Systems, the Good the Bad and the Ugly’. The 30-minute tutorial outlined what competence means within the asbestos industry and why we should care.
We were also up for the asbestos innovation award. Shortlisted from the 200 exhibitors – the judges came to the stand, and I had to convince them on the uniqueness of the system. We nearly got over the line first – but in the end still delighted to get the runners up slot.
For those of you that are not familiar with Assure360 – it is a solution for the asbestos removal, analytical and training community. It takes existing tasks that everyone does already, makes them easier and transforms them so that they solve multiple needs.
From the single audit application, the cloud database allows the user to comprehensively manage H&S from an HSE licensing or UKAS point of view. It provides Competence Assessments, TNAs and it even transforms exposure monitoring from just a duty of care exercise to a technique that actively improve standards. All at the touch of a button.
For the trainer – it provides incredibly detailed TNAs – ensuring that time is not wasted on the initial exam at the start of the course. Allowing a truly bespoke offering.
Our many customers extol its virtues with such comments such as:
“At our recent license renewal, the HSE inspectors were amazed by the power of the system and couldn’t believe everyone wasn’t using it.”
Ken Johnson, Managing Director, Delta Services
“Assure360 is now integral to how we work. Our BSI assessors were really impressed by the system, noting all of the improvements it allowed us to introduce.”
Steve Hannah, LAR
As I say – an exhausting but rewarding experience and we have already booked our stand for next year.
To learn more or book a demo call us on 0845 226 4318.
Written by Nick Garland on Tuesday November 17th 2015
This is a summary and critique of the brand new guidance produced by ARMI on Competence in the Asbestos Industry. I will try to reduce the 28 pages into something more concise and give my spin on the wording to help clarify. Reading this summary would hopefully allow you to fully implement ARMIs suggestions, and/or help navigate the full document if you want to read more (available at http://www.armi.org.uk/Download/ARMI_Competency_Guidance.pdf).
The guide starts with an explanation of what competence is and a statement that most contractors will be assessing it anyway. However this existing assessment may be entirely informal and subconscious (a vague understanding of – you wouldn’t ask John to do X because of Y).
‘The ability to perform a task to a specified standard’
‘The skills, abilities, knowledge and behaviours that lead to successful performance.
Understanding what skills are required, what skills are held by an employee and whether there is a gap between.
As the roles and duties you expect of an employee change, the skills (or Competencies) also change. Similarly Competencies also change if we change the way the job is to be done. Due to a variety of reasons, an employees’ Competence will change as time progresses – in either direction.
Consequently Competence assessment must be continuous to identify shortfall and inform training.
It must be remembered that training here does not mean set piece refresher courses, but a variety of tools to bridge the skills gap identified. It could be a formal training course, but equally it could be:
The guidance goes on to identify the clear regulatory basis that requires employers to conduct a structured Competence system. The document explains that you can get external assistance in performing some or all of these duties. However before you rush to an expensive external consultant – it states correctly that the duty can’t be delegated. Essentially what this means is that if a largely external system fails to deliver, it will be the employer in the dock.
As you are already at the Assure360 site – just click on Home tab to see how we can provide a simple, cost effective solution. Assure360 allows an employer to run an internal Competence system without creating extra work or recourse to expensive consultants.
Image taken from the ARMI Guide
Steps 1 & 2 establish the skill set required and agree the standards have almost certainly already been completed. Your company H&S Policy and Standard Procedures, if correctly written will be tailored to your precise circumstances, describing the precise duties you expect of those individuals.
The ARMI’s guidance document goes into some detail on what could be seen as a standard set of Competencies for the industry. However, unless we all rewrite our H&S Policy and Standard Procedure documents to match ARMI’s guidance they are unlikely to ever be the ‘standard’ Competencies. They do however broadly map out what you would expect.
The guidance raises two important points that I would wish to echo and highlight. Competencies are role based not title based, recognising the fact that employees are often a blend of roles. i.e. a senior Operative might have some Supervisory duties. Similarly in a small removal company a lead Supervisor might have key Management duties. This is a key point and useful to stress.
Secondly the guidance recognises how critical teamwork and communication is at all levels in the organisation, going some way to identifying what this looks like at different levels in the organisation:
Core duties – i.e. Competencies that everyone from the operative to the MD should have):
Supervisory duties – as above, plus:
Management duties:
This aspect of teamwork and communication as a Competency is largely overlooked by the majority of removal companies and could contribute enormously. Strategies on how to promote these should be sought, but the guidance does not help with this.
Step 3 (Collect Evidence) and to a lesser extend Step 4 (Produce Training Needs Analysis or TNA) are the ones that will cause most issues with Licence Holders. Unfortunately other than tell you of some sources for gathering the required information the guidance crucially falls short:
However, other than little more than these bullet points there are no clues on how to:
In fact just adding these tasks to an already full workload may be an ‘ask’ to far.
To be fair the guidance does repeatedly say, ‘many of these tasks are already being done by licence holders’, the problem is existing measures typically do not gather the kind of information needed to create a detailed understanding of an employee. The trick remains – to transform the tasks that are already being done into an exercise that automatically provides the competence assessment.
An employee must be deemed competent to do a task and until they are, they need to be supervised. This has most impact with new starters (including agency); whether this is an experienced supervisor/manager or someone fresh to the industry – they will have little idea on how you as an organisation do things and you will have no idea of their Competence. Induction into company H&S policies and procedures is therefore critical and a high level of supervision must follow.
Next on the cycle comes produce TNAs. TNAs are an old problem, and as most training organisations know actually getting a TNA for an employee is a rare event, getting one long enough in advance to plan appropriately has until recently been almost unheard of. Nowadays I do know of several companies that complete TNAs in advance and submit these to the training providers.
The guidance seems to suggest that creating TNAs is an additional exercise over and above Competence Assessments. It identifies who assessors should be and what competencies they should have. Essentially this comes down to Supervisors and Line Managers as the in-house experts best placed to do this. Having TNAs as an extra task, added to a busy workload, will have the almost inevitable result of it not happening at all.
Again the trick is to make the process automatic. Direct observation should produce a competence assessment, which by its nature (looked from the other side) is a TNA. But the guidance does not tell us this bit.
This is obviously the act of closing the gap. We’ve identified the strengths and weaknesses (competencies), we’ve developed the training requirements (TNA), and this is merely the delivery of that plan. What the guidance makes clear though is that training is not just the annual refresher and can take the form of toolbox talks, practical sessions and even informal chats.
Essentially what this means is that; once we know (in detail) what weaknesses an operative, supervisor or manager may have, we can be much more imaginative in addressing those needs:
Many of these are issues, which if we recognise them, can be dealt with internally.
A senior operative; if he excels in the skill to be imparted can deliver training. Supervisors can become key mentors, contracts managers can learn from each other.
Equally if you understand the weaknesses on site, you should know your strengths, the industry has an awful lot of expertise and this is by no means restricted to training organisations. Good ideas, innovation and excellent performance should be identified, reinforced and shared.
Increased supervision is effectively ‘on the job training’. An identified slip in performance in an experienced operative or a new starter can be tackled by mentoring. Just because a new employee comes to us qualified and experienced, we do not know their level of Competence. Equally we should be near certain of their lack of competence in our own company procedures. This support can be seen as simultaneous training and assessment.
Or rather – start again. It should be noted, though, that the guidance correctly identifies that ‘establish roles’, and ‘agree performance standards’, won’t normally need to be returned to on a regular basis. As the collection of evidence and consequent identification of training needs is continuous, the cycle should just keep rolling. The guidance document does note that infrequently completed tasks may need to be tested via simulations to ensure competence is maintained. A good example of this could be emergency procedures or fire drills.
There should also be a formal review (minimum annually) – or employee appraisal. The competence, and TNA assessments that have been completed throughout the year, should be used as part of this exercise. Events that should trigger reviews:
The guidance is an effective definition of what competence is and gives pointers to how Licence Holders (LHs) can design their own systems to fulfil the requirements. It also identifies many tasks typically already done by LHs that can provide evidence of Competence and therefore inform TNAs and training.
Essentially as a guide to creating a competence system it does work. However the process it describes is a colossal amount of work.
The ARMI guide starts by creating separate performance criteria and matrices for every role. In of itself, this could be a few weeks work. It then describes a host of evidence sources that (admittedly companies do at least some of). However it gives no guidance on how to streamline the process of analysing the ‘big data’ this would produce. All H&S managers in the asbestos industry know that a PDF audit report can be a dead end and is lucky to be closed out, never mind trends identified. iAuditor can produce Excel exports but these are incredibly labour intensive to analyse. Typically the ‘degree of granulation’ achievable is to supervisor level and no further, leaving the majority of the staff un-assessed. Essentially to administer the competence system as described would require a dedicated full time individual.
As I say the guidance does explain the concept, gives sound guidance on where to start. But it leaves us hanging with the slight echo of ‘pick the bones out of that’.
However, there is help beyond the guidance. New commercially available systems streamline this process into a ‘click-of-a-button’ solution – my assure360 database and app is one.
Written by Nick Garland on Monday June 1st 2015
The very first European Asbestos Forum conference was held in Amsterdam last week and I was lucky enough to attend. The stated aim was to improve professional networks and promote the exchange of knowledge. With the ultimate goal of helping our industry grow into a collaborative one.
I was asked to attend to share my expertise on Competence. My talk was entitled Using Technology to Deliver Competence with the case study of the Assure360 system as a demonstration on how it can be done – more on that later.
The highpoint of the morning session was a very powerful speech by the ex US Assistant Surgeon General Dr. Richard Lemen where he comprehensively debunked the claims from the asbestos producers that chrysotile is non hazardous.
Particular points from his speech to highlight would be:
The WHO figures just released indicate 125,000,000 people are exposed to asbestos every year. It is also estimated that 107,000 preventable deaths are attributable to asbestos. That is one person every five minutes. Even more shocking Dr. Lemen revealed that this figure is about to be revised UP to 194,000 per annum.
Very sobering.
The backdrop of his speech was the fact that many countries do not have a universal ban on asbestos (including the USA!). Some of this is down to commercial and political lobbying by the asbestos producers (notably Russia). Russia produces 2 million tonnes of asbestos annually, half of which it exports.
Whilst deaths from asbestos in the developed world appears to be plateauing, In developing countries it is skyrocketing. I read a stat the other day that India has overtaken China in GDP growth, add to that the fact that they are also the biggest asbestos importer.
He went on to debunk the myth that chrysotile is non hazardous, showing source after toxicological source confirming its carcinogenic nature. The final eye-catching proof was that over 30 times more chrysotile than amphibole fibres have been found embedded within mesothelioma tumours.
As I said, the reason for me attending was to share my expertise on Competence, in short the key points to any good competence system is:
If a scheme misses any of these pillars it will fall over.
This amount of direct observation takes a great deal of time. Obviously I went into more detail but the solution that makes this practical and achievable is a cleverly designed tablet application synching with a powerful cloud database.
Innovation and the asbestos industry for many years hasn’t seemed to sit side by side. However, the technology session in which I took part, was exciting. Inventions and developments showcased were:
There was also a comparative study on the pros and cons of EU national approaches to tackling asbestos. I will do a separate piece on this next week.
The aim of EAF2015 was to improve professional networks and promote the exchange of knowledge. Certainly Dr. Lemen’s speech set the tone – we’re all in it together. The collaborative approach of the subsequent sessions re-enforced this message.
Find out how we can help you with asbestos waste management – call us on 0845 226 4318
Written by Nick Garland on Monday March 16th 2015
Many in our industry mistakenly believe that the the Construction (Design and Management) Regulations do not apply to asbestos removal projects. Contradictorily, it is also often believed they only kick in when the notifiable triggers are exceeded. With CDM 2015 just round the corner, the following piece is a summary of the changes and how they pertain to the asbestos removal industry.
CDM either applies or it doesn’t. The extra duties imposed by notification, are just that – extra duties, for when the project is officially large. So the first question to answer is – do the new regulations apply to asbestos removal projects or not?
Regulation 2 states that:
“construction work” … includes:
(a) … de-commissioning, demolition or dismantling of a structure;
(d) the removal of a structure, or of any product or waste resulting from demolition or dismantling of a structure…’
These two clauses (incidentally also there in 2007), make it clear that asbestos removal projects are indeed covered and the duties it specifies flow from there.
CDM 2015 makes some sweeping changes, one role disappears, another arrives, client duties are expanded and some duties are taken on-board whether you like it or not.
There are five defined roles:
The main changes surround the Client and the new Principal Designer role. However, despite remaining largely unchanged the Designer might have the biggest impact on asbestos projects.
CDM 2015 takes implied responsibilities from the 2007 regs and adds liability significant phrases such as ‘must’ and ‘ensure’. The main changes are as follows:
With the exception of domestic clients**, the regs therefore no longer make the allowance that Clients don’t know what to do and now insist that they must, or employ competent advice so that they can.
** Note the duties of domestic clients are assumed by the Principal Contractor or in the case of very small jobs, the single Contractor.
Whilst this is not a new role and the duties are not tremendously different from before, it is worth understanding who a designer is and what duties they are committing to when they take it on. The regs tell us a Designer is an organisation or individual who
prepare or modify a design for a construction project (including the design of temporary works)
It goes on to say this includes, writing specifications, project management, drawings and anyone that design and modify work are included. It is therefore clear that the familiar role asbestos consultancies take on – is unarguably that of a designer.
The following key duty is therefore assumed by anyone in the role:
Must identify foreseeable risks to health and safety and apply the principles of prevention (avoid, reduce or where you can’t, control)
… identify foreseeable risks… this is where the problem comes in, whilst a good analytical consultant fully understands the issues presented by an asbestos job, our industry is often guilty of being blinkered to the host of other hazards that surround it. Therefore when specifying a removal technique, the Designer must consider if that manual handling issue can be tackled in any other way? Do the operatives really need to be exposed to vibration and noise to remove the last minuscule traces of asbestos (blasting techniques)? Does the average Asbestos Consultant have sufficiently broad H&S knowledge to identify all ‘foreseeable risks’ or the understanding of them to apply the principles of prevention? My guess is that most don’t even know what they are.
As an aside – an interesting sentence in the ACoP states that statutory bodies (e.g. the HSE?) who stipulate design changes outside of strict legal requirements, take on Designer duties.
Any project that involves more than one contractor e.g. LARC, Scaffolder, Electrician (for isolations) etc… must have both a Principal Contractor (PC) and a Principal Designer (PD). If the Client fails to appoint them, they assume the duties.
The two main changes for the PC is that the notification bar is higher. A project now needs to be notified if > 500 person days or if >30 working days AND >20 workers at any one time. The HSE believe this will halve the number of projects to be notified. However a Construction Phase Plan is now needed on ALL projects, not just notified ones. The significance of this on asbestos projects where the LARC is the PC or sole Contractor is that they must produce a Construction Phase Plan (CPP) as well as their method statement. For the small removal project most of the detail required in a CPP is already present in a good quality method Statement. But in any case the HSE are planning on providing a template.
Whilst the PC is largely unchanged, the PD is the new role on the block, replaces the old CDM Coordinator, takes on all of those duties and more. The duties are:
Remember, unlike the Designer where your can sleepwalk into the role, you can’t accidentally become a Principal Designer. Both a PC and a PD must be appointed in writing.
The role is essentially an organisational one, plus:
From experience I have found that next to nuclear, asbestos is by far the most complex hazard facing construction projects. It is therefore less of a challenge for a specialist in asbestos to up-skill in general H&S, than a generalist trying to master asbestos. In this, help and advice is available – the old CDM Coordinators are busily rebranding themselves as advisors to Designers. The asbestos consultant is therefore ideally placed to own this role. Rather than something to avoid, with the right skill set and advice this is genuine project management, which can be charged for appropriately.
In summary, it is not just the Contractor that should be concerned over high temperatures in a boiler house, or the introduction of unnecessary noise and vibration hazards (blasting techniques). We all need to become more educated and aware of areas outside our specialisms. Asbestos Consultants need to recognise the fact that they are Designers and the responsibilities that come with the role.
With Clients, the Designers have a duty that a project is completed without risk to those affected. They are mandated to get actively involved. Rather than just make design requirement, they must look at all of the implications. As this is the most liability significant duty and is automatically assumed by most consultants, the short hop to Principal Designer no longer seems onerous. But ignoring the issue will leave you badly exposed to regulatory and legal action.
Written by Nick Garland on Monday February 16th 2015
My experience is that personal monitoring is much misunderstood and therefore underused tool in the box. Often given lip service, ignored completely or done in a huge rush in the 6 months before license renewal. When it isn’t overlooked it is rarely used in a way that is of much practical use. Certainly the asbestos management databases that I have seen out there don’t seem to handle the data in any meaningful way.
Exposure monitoring should not be seen as another regulatory requirement that must be complied with, but rather an excellent way of auditing removal techniques and therefore designing better ones.
Other than ‘Error’ (test results representing something other than what was stated), measured exposure significantly above or below that anticipated indicates one of the following:
All of these events should be investigated – 1 & 2 as something went wrong, 4 & 5 because there is good practice to pass on. In fact 1 & 2 should be treated as an accident/incident and closed out as such. Measured exposure ‘at’ the anticipated level could be viewed as a near-miss.
A well constructed Excel sheet can process this data adequately, but a database would make the extraction and investigation a smooth joined up process.
Obstacles to the process that I have come across are – actually doing the personal monitoring with regularity and enough spread to cover all activities, the site team (‘we’d get in trouble if we gave them a high reading’) and the analyst themselves (too high limits of detection and vague/non-existent description of the activity tested). The last two can be solved by education.
Properly collected and collated data could then inform better research (at company or industry level) in areas that might make a big difference to the lads in the enclosure. This isn’t meant to be a shameless plug, but it’s worth mentioning that we designed the www.Assure360.co.uk system to help with this. We felt the most important elements to design in, must cover:
So that was our attempt at scoping a solution, aided by anonymous benchmarking tool to compare your results against the industry. That way, the exercise becomes a pro-active tool to improve standards, rather than just to predict exposure more accurately.
Written by Nick Garland on Tuesday December 9th 2014
What makes a good competence scheme – or indeed a bad one? What we first have to ask is ‘what is competence?’ and ‘what is a competence scheme for?’
The HSE state that competence is sufficient knowledge of the tasks to be undertaken and the risks involved and the experience and ability to carry out their duties. Competence develops over time. Individuals develop their competence through a mix of initial training, on-the-job learning, instruction, assessment and formal qualification.
Europe has a big influence on all things, not least H&S. The conclusions of the European Council in March 2000 shifted focus of education policy towards lifelong learning:
is no longer just one aspect of education and training; it must become the guiding principle for provision and participations across the full continuum of learning contexts
European Commission, 2000, p. 3
Lifelong learning is seen as the common umbrella under which all kinds of teaching and learning should be gathered and it calls for a fundamentally new approach to education and training.
To put it another way, Competence is the behaviour, skills and knowledge needed to undertake a task. A Competence Scheme is a mechanism that allows the employer to understand this framework as it applies to his employees. In other words define the behaviour, skills and knowledge (competence) required to undertake a set of tasks (a job) and measuring against it. This allows us to understand the difference between desired and demonstrated competence and therefore develop a plan to close the gap (training).
Therefore a good Competence Scheme has three pillars:
Conversely a bad Competence Scheme is one that misses any one of these.
If a scheme ignores behaviour (or any other founding element) it will not recognise the difference between an employee that knows what to do, but chooses not to (due to poor choices), one that is not aware of a weakness or is aware, but doesn’t have the skills to rectify it. Clearly the response to each of these would be very different.
If a Competence Scheme is a one-off exam – it might tell you the capabilities of that individual at that snap-shot moment, but it will tell you nothing of the evolving (and devolving) skill-set.
If a system does not quantify the skill gap – or put it another way, develop a Training Needs Analysis, it will not inform the training and all of the efforts to that point would be for nought.
After all of this – what do you do with it? The answer is train. When we say train – this no longer means just a classroom, but can be a combination of toolbox talks, classroom, practical training, mentoring etc….
Then, we start the whole process again…
Find out how we can help you with asbestos waste management – call us on 0845 226 4318
Written by Nick Garland on Thursday December 4th 2014
The Asbestos Liaison Group (ALG) have just released some draft guidance on how to design a competence scheme, and whilst it contains some sensible pointers, there are also several areas of inconsistency and blind allies. It also weighs in at a massive 24 pages, making accessibility difficult in our busy lives.
The document is still out for consultation for a little while longer, so in an attempt to improve it – here are some of the highlights:
It specifically casts doubt on the ability of the employer to conduct adequate competence assessments on temporary (agency) staff.
Rather than guiding us to all of the qualifications available, it only promotes two that are championed by the trade organisations.
In what appears to be a contradiction, it indicates both that there should not be degrees of competence and later that different levels of performance can exist (experienced vs newly qualified operatives).
The guidance states that competence is only achieved when ALL standards are met, partial competence – say excellent removal techniques but poor airlock construction would equate to ‘not yet competent’.
Despite it being a crucial part of the whole exercise, the guidance is very brief on actually how to produce and interpret Training Needs Analysis (TNAs).
Encouragingly it does recognise that the best assessments and assessors are first line managers or supervisors, conducting direct observation. Therefore internal continual monitoring systems are king and snapshot exams (e.g. ARICS) have a limited roll. The problem is how to do it. If you follow the guidance to the letter it leads inevitably to a new 100-200 page competence document that you would have to write.
There is hope however, competence schemes are available commercially and can be found either via ACAD, IATP or internet search engines (look for “asbestos Competence Scheme”). Good practical guidance on TNAs can be obtained at IATP, but the same commercially available competence systems by their nature produce TNA reports.
Find out how we can help you with asbestos waste management – call us on 0845 226 4318
Written by Nick Garland on Monday September 15th 2014
My experience is that personal monitoring is a much underused tool in the box, often given lip service, ignored completely or done in a huge rush in the 6 months before license renewal. When it is not overlooked it is rarely used in a way that is of much practical use. Certainly the asbestos management databases that I have seen out there don’t seem to handle the data in any meaningful way.
Exposure monitoring should not be seen as another regulatory requirement that must be complied with, rather an excellent way of auditing removal techniques and therefore designing better ones.
Other than ‘Error’ (test results representing something other than what was stated). Measured exposure significantly above or below that anticipated indicates one of the following:
All of these events should be investigated – 1 & 2 as something went wrong, 4 & 5 because there is good practice to pass on. In fact 1 & 2 should be treated as an accident/incident and investigated. Measured exposure at the anticipated could be viewed as a near-miss.
A well constructed Excel sheet can process this data adequately, but a database would make the extraction and investigation a smooth joined up process.
Obstacles to the process that I have come across are – actually doing the personal monitoring with regularity and enough spread to cover all activities, the site team (‘we’d get in trouble if we gave them a high reading’) and the analyst themselves (too high limits of detection and vague/non-existent description of the activity tested). The last two can be solved by education.
Properly collected and collated data could then inform better research (at company or industry level) in areas that might make a big difference to the lads in the enclosure.
Written by Nick Garland on Thursday July 17th 2014
Here at Assure Risk Management, we pride ourselves on being able to provide you with a number of differing services, all of which encompass health and safety, or the dangers of asbestos. We offer professional Health and Safety advice to the asbestos and construction industry.
We specialise in audit and competence schemes, outsourced health and safety management, legal expert witness services and asbestos consultancy and training.
Our risk analysis based approach to providing audits combined with the wealth of experience we have gathered over the years allows us to bring a unique holistic edge to our health and safety management schemes.
Having been in this industry for over 20 years, we are also extremely proud of the reputation we have gained from continually satisfying our customers and clients, whilst always hitting high standards with the quality of our work. This ensures you can be assured of not only expertise but a sound practical approach.
We do offer some services that may come in useful for you in your workplace setting, which we will inform you of here.
With changes to the licensed asbestos training environment, the asbestos industry will have to understand its workforce in much more detail. Our Health and Safety Management system gives you the correct understanding of the Asbestos Removal Competence Scheme.
A powerful online database, married with our Audit Scheme, allows the most comprehensive analysis of the asbestos removal process available. Uniquely, the system allows you direct access to the data and all of the reports.
We also have an iPad application that allows you to compete internal audits independently, which means you don’t need to rely on any external consultants. However, it does allow you to use third party auditors to expand your coverage. This synchronisation of both internal and external audits allows for a larger data set, and therefore more accurate data analysis.
Our ability to provide both generalist health and safety expertise and detailed forensic understanding of the asbestos hazard gives all of our clients the assurance they need.
We provide specialised expert advice in support of licensed contractors either applying for their first HSE licence or at the time of renewal.
We can also provide the following services – amongst others – to many licensed asbestos removal clients, aiding them to build a streamlined, well managed company:
And these three are just examples of what we can do, there are other areas we get involved in.
Here at Assure Risk Management we understand that training is not just presenting facts to a group of delegates; asbestos awareness training is about saving not only the lives of the staff you are responsible for but also safeguarding their families. It also ensures work stoppages are kept to a bare minimum allowing you to meet your deadlines
Our training is tailored to each client, offering operative and management focused courses to ensure you have asbestos competence. We also provide duty to manage bolt-ons for managers with a responsibility for buildings.
Our final bespoke training service is the provision of high quality e-learning packages for larger clients. These interactive presenter led courses incorporate broadcast quality filming and innovative techniques to deliver the most effective e-learning experience.
If you have any questions or would like to find out more about how we can help you, call us on 0845 226 4318 or email us enquiries@assure360.co.uk