It’s asbestos, not just RAAC that schools need to be concerned about
Written by Nick Garland on Friday September 1st 2023
The announcement from the government that multiple schools will have to close or partially close due to the long known presence of RAAC has further ramifications. Reinforced autoclaved aerated concrete or RAAC was used extensively in public buildings between the 1950s and the 1990s, for those of you that know your asbestos prohibition dates – this is the ‘heyday’ of asbestos use.
Asbestos is frequently hidden in the structure of the building, and can take weeks of planning and careful removal to find and address. In buildings of this vintage, such an issue will be highly likely. This additional delay could extend the school closures, potentially to months. But that is not even the main issue – the urgency of the RAAC question, might lead schools to overlook the asbestos question entirely.
The recent Department of Work and Pensions Select Committee report (April 22) highlighted the specific risk of asbestos in schools. ResPublica have recently stated that 80% of schools contain asbestos. The recent study paper by the National Organisation of Asbestos Consultants (NORAC) and the Asbestos Testing and Consultancy Association (ATaC) has similar figures, with 78% of the buildings they looked at having contained asbestos.
Following the select committee report, the HSE visited 421 schools to inspect their compliance with the regulations. 140 were considered to be falling short and received letters from the HSE instructing them on improvements that were needed in their management of asbestos. Of these, 27 received improvement notices (legal instruction for mandatory specific improvements), and one a prohibition notice (not to enter their boiler room until asbestos was removed). Whilst 33% non-compliance will not be a surprise to the industry, it should be seen as a worryingly high figure.
The Cliff Edge
I recently wrote about the cliff edge the country is heading towards in the race to net zero and the lifespan of system built buildings – deadlines a few years off. Now there is another ultra urgent deadline – repair or replacement of these RAAC structures so the schools can re-open. That is an awful lot of construction work that needs to be done immediately on buildings with clear potential to contain asbestos. The pressing and very public urgency to fix the RAAC problem might overwhelm other considerations – and in particular the asbestos risk.
HSE’s recent findings confirm what has been long suspected, that the model of manage-in-situ is not working well in schools. If the asbestos risk is overlooked now and not factored into the emergency, this latest crisis could be made even worse.
Approaching the cliff edge – unknown asbestos
Written by Nick Garland on Tuesday May 16th 2023
The Times recently carried a special report on asbestos (paywall). Steve Boggan’s excellent article was a rare example of a detailed, thoughtful, well-researched and intelligent piece of writing on the subject in the mainstream press. Without the unscientific scaremongering that is so often peddled out, this piece told the unvarnished reality – which frankly should be scary enough.
Boggan interviewed several sufferers and family members. These included Wayne: an HGV mechanic, Grace: a retired teacher, and Garry: who recently lost his wife Debbie to the disease. While their stories are all different in the detail of their unfairness and tragedy, they all share a central core – the fact that they didn’t know that they were being exposed.
The article discusses the recent Department of Work and Pensions Select Committee report, and focuses on the two main recommendations that would address this ignorance. These were a national register of asbestos, so we know where all of the material is, and a plan to remove it all. Both have been rejected by the government.
Boggan quotes the prominent campaign group ResPublica who state that 90% of hospitals and about 80% of schools contain asbestos. The recent study paper by the National Organisation of Asbestos Consultants (NORAC) and the Asbestos Testing and Consultancy Association (ATaC) has similar figures, with 78% of the buildings they looked at having contained asbestos.
I don’t know how accurate the ResPublica figures are, and I know the NORAC/ATaC piece was only a snapshot, but in part that’s the point: no one has an authoritative overall view of how big a challenge we have.
The Cliff Edge
As a country we are heading towards two impending cliff edges. The first is that many of the schools and other structures that contain asbestos have a light steel frame construction. These have a design lifespan of 40 years, and we’re at least 10 years beyond that now.
The second is Net Zero. If we’re going to achieve this, there’ll be an awful lot of building work required.
Between these two massive construction challenges, many of the buildings we currently use are either going to be demolished or heavily refurbished in the next few years. Without knowing how big the asbestos problem is or having a national removal plan in parallel, it would be human nature to lose sight of the issue.
Many still see asbestos as a problem we fixed long ago. It’s still there, though, just not widely known or understood. The climate emergency, by contrast, comes with a very pressing and public deadline. But if we don’t get the asbestos plan right, it seems inevitable that the rush to Net Zero will lead to an avoidable spike in asbestos exposure – and it could be centered on the schools and hospitals used by the most vulnerable in our society.
Sorry for the inconvenience – the HSE cracks down on site facilities
Written by Nick Garland on Thursday February 9th 2023
Site welfare is something that’s all too often overlooked on asbestos-removal jobs. We’ve all worked on sites with incredibly inadequate facilities, whether it’s too few loos, unsuitable washing facilities, or just nowhere to sit and take a break.
One of the main reasons it’s so common is that a lot of these projects are quite short term. Sometimes it’s just one or two days. Management can become too focused on the complexity of the job itself, which leaves welfare as an afterthought. Another issue is that these short-term jobs are typically in flats and houses, and by their very nature they prevent access to on-site facilities. For example, asbestos removal of the riser in a toilet might mean that the loo is available for the first couple of hours, but then it’s very much not for the rest of the day.
But while the management may forget to provide it, the Health and Safety Executive (HSE) views adequate welfare as a fundamental basic necessity for workers. In fact, during the COVID restrictions, Prohibition and Improvement Notices that mentioned COVID almost exclusively targeted inadequate welfare.
Management can also misinterpret the ‘so far as reasonably practicable’ (SFARP) exception, thinking along the lines of “It’s a one day job. What’s it reasonable for me to allow for?”. The law sets out a basic expectation of toilets, a supply of hot and cold (or warm) water for washing, changing facilities, drinking water, and somewhere to eat and rest. You’d have to have very significant reasons to not provide the minimum.
The HSE is reinforcing this with the release of some new guidance: Construction – Welfare Standards. I’m grateful to Graham Warren at ACAD for flagging it up in the latest newsletter. The guidance is actually for its own officers, not us, but understanding how the HSE will be looking at the subject is crucial: inspectors are directed to take ‘appropriate’ enforcement action to secure compliance.
The guidance makes clear that where toilets, hand basins, drying rooms etc. haven’t been provided, or they’re inadequate, an Improvement Notice (IN) is the appropriate response. There will be local exceptions that might even dial this up to a Prohibition Notice (PN), for example if there’s an imminent risk to health. But the guidance also states that prosecution should be considered for repeated offences – or even if the first offence is bad enough.
The penalties for getting it wrong are therefore significant. The guidance quotes multiple regulations and guidance documents, weaving together a framework for the inspectors to justify enforcement action. The most significant is obviously the Construction (Design and Management) 2015 (CDM 2015) regulations. Among other things, these introduced clear definitions for all parties in construction (including clients), removing the cloak of invisibility that had allowed some clients to claim ignorance.
In practice a client needs to create an environment where work can be carried out with the appropriate welfare facilities in place. If the works involve a specific fenced-off construction site, use of the client’s own facilities should not be the default option. The regs go on to say that where there isn’t such a specific construction site, clients are legally required to make their own facilities available for use.
Domestic clients are the exception. CDM 2015 and the HSE guidance both recognise that they don’t have legal duties, so it falls to the principal contractor (PC) and other contractors to ensure compliance.
Principal contractors have clear and unavoidable duties to provide facilities from prior to the start of construction work, all the way through to the end of the project. Contractors’ duties shadow those of the PC. If there are several contractors on a site, it’s a case of liaising and cooperating with the PC. If there’s only one, then all of the duties are yours.
That ‘so far as reasonably practicable’ get-out gets some clarification with regards to welfare. In essence it’s about weighing the measures needed against the sacrifices involved. Crucially, though, it’s weighted in favour of health and safety, i.e. it’s assumed you’ll provide the welfare, unless you can demonstrate it would involve ‘grossly disproportionate sacrifices’. Cost is not the primary focus and shouldn’t be considered ‘disproportionate sacrifice’.
Toilets are mandatory (i.e. you don’t get to say they’re not reasonably practicable), and there’s a hierarchy, with flushing toilets at the top and chemical Portaloos very much at the bottom. The guide states that for large or long-running sites the provision of ‘only portable toilets’ is considered insufficient – as it would very much be reasonably practicable to provide better.
All welfare facilities must also be ‘readily accessible’. What this means varies with the urgency: rest breaks can be planned, so the distance to travel can be greater. Toilet facilities, however, need to be much more convenient. The guide quotes BS6465(1) as stating that construction sites should provide WCs within 150 metres of the workplace. Arranging toilet use with a café that’s 10 minutes’ drive away would not cut it.
For the same reason the numbers of cubicles are also pre-determined:
|Number of people
||Cubicles (not urinals)
There are some other key requirements:
- Separate rooms for males and females. This HSE guidance is for the construction industry in general – it’s not specific to the asbestos industry – but it would have shown joined up thinking if inspectors were also directed to consider that most of our decontamination units are non-compliant with this.
- Washing facilities. Unlike toilets, washing facilities are qualified with SFARP. In other words, they should be provided except where this involves grossly disproportionate sacrifices. The HSE’s view is that suitable washing facilities (separate ones for toilets and rest areas) are easy to plan for and provide, and that justifiable exceptions are few and far between. Note – specific mention is made that cold water on its own is not sufficient.
- Drinking water. This must be readily available and – it nearly goes without saying – also fit for human consumption. Running water or sealed water bottles along with cups and mugs are specified.
- Rest rooms. These are another mandatory facility, like toilets. What constitutes a rest room is not clearly defined, but there are some pointers, which indicate something more significant than many of the welfare areas I come across. The Workplace (Health, Safety and Welfare) Regulations (WHSWR) state they must be equipped with an adequate number of tables, and adequate seating with backs for the number of workers likely to use them at any one time.
What I find particularly interesting about this guidance is the way that it details other regs and approved codes of practice (ACoPs) detailed in the guidance. It features them along the lines of ‘areas to be considered when considering enforcement and prosecution’. But to think of it another way, I always like to ask one of my favourite questions: ‘Why are we doing this?’ – as understanding why is often the lightbulb moment.
Of course, there’s the basic human dignity of providing somewhere to go. Not to mention hygiene 101: wash your hands before you eat. But as these often don’t seem enough reason, how about:
- First aid. Clearly things go wrong on site, and we are used to providing training for staff and first aid kits. The first day of First Aid school teaches you to wash your hands first, so a sink, soap, and hot and cold water is therefore a must.
- Hazardous substances. Washing requirements are often a key control measure when working with hazardous substances. For example, with lead paint it’s crucial to wash after work and before each break. That washing needs to be more than just the hands, covering the whole forearm up to the elbow. A small sink is therefore not suitable, and something else would need to be provided.
I’m sure you can think of more examples and, if they apply to the work you’re doing, the HSE inspectors will doubtless think of them too. Perhaps it’s time for those of us who design and commission work to stop treating facilities as so much of an afterthought, and start planning work around the comfort of the people who do, after all, do the work on the ground.
Female analysts and four-stage clearance testing – the need for change
Written by Nick Garland on Thursday December 9th 2021
I normally do a roundup of the FAAM asbestos conference, letting those that didn’t get to attend know some of the more important areas that were discussed by the leading thinkers in our industry. I will be doing that, but this piece is in many ways much more important.
** Warning, the content includes an upsetting personal revelation, and some readers may be affected by the issues raised.**
Colette Willoughby’s talk on the second day, Female Analysts and Four-Stage Clearance Testing, was the most raw and personal talk I have ever heard at a conference. The talk was split into two parts – the first a short history lesson on how things have changed during Colette’s distinguished career.
Having started out in 1982, Colette really was at the birth of the new world of asbestos analysis. She entered an industry where – astonishingly – a clearance just meant the contractor dropping a pump off at a lab. She witnessed it change to one where analysts started actually doing tests and – most revolutionarily of all – a visual, where the analyst actually checked the contractor had done what they said they would. My career started shortly after this, where people still talked about what it used to be like. Now this seems more like myth and legend.
The main part of the talk, though, related to Colette’s own experiences, and those of four other women she had interviewed. The interviewees were Jean Prentice, Joanna Parker, Sam Collins and an anonymous analyst still actively doing four-stage clearances (4SCs). The five women between them represent a huge amount of experience, gained from the mid-1960s to the present day.
Colette’s talk frankly and openly discussed the widest range of experiences, from the broadly positive (Sam and Jean), to the worst you can imagine. Colette, despite being one of the warmest and most professional people you could ever want to meet, has experienced some of the most unwelcome experiences possible. From initially not being allowed on site at all, to – after years of campaigning – being told: “OK, but we don’t think you’ll cope”.
What followed was a litany of sexist ‘banter’ from contractors, with comments such as: “You’re a woman, you’re just picky” and “You’re more used to cleaning: no wonder you can do it better.” Yet at the back of Colette’s mind, a traitorous voice insisted that now she’d convinced her bosses she could do the job, this was something she just had to put up with.
The ‘banter’ was shameful enough, but examples of criminal abuse followed. On numerous occasions, naked operatives have intentionally followed her into the decontamination unit (DCU) – the most recent occurrence being only four years ago.
Then came a horrific experience where she was raped on site by the supervisor. As Colette explains: “I was sexually abused and was raped on numerous occasions, but did not have the ability to go back and say anything because I was quite consistently told by him ‘Nobody’s going to believe you. You’re 23/24 years old, I’m a middle-aged man. I’m well respected, you were just asking for it. You’ve come into our environment [and] you’ve got to put up with it’.”
How Colette kept it together after that I will never know.
While spared the full horrors of Colette’s experience, Joanna and the anonymous, still-serving analyst both had multiple examples of threats of, or actual sexual abuse. And they both shared the belief that reporting it would be futile.
The hostile environment
Asbestos is of course part of the construction industry. To put some numbers to the hostile environment that women in our industry endure, Colette turned to a 2017 report, which found that four in 10 women had been on the receiving end of unwanted sexual behaviour, and that one in nine mothers had been dismissed, compulsorily made redundant, or treated so poorly that they left the post. The pay gap was 17.3%, to add insult to injury.
Colette is the chair of NORAC, Principle Examiner for asbestos at BOHS, and Director and Technical Expert at ACL. She is, quite frankly, one of the most impressive consultants in the industry, but the abuse and discrimination that she and other female analysts have experienced left me and the rest of her audience stunned. Speaking personally, I am ashamed of the ignorance that I had been labouring under.
How do we change?
Colette then moved on to what needs to change, and how. The distance we need to travel is vast – but at some levels utterly basic. For example, PPE must by law be fit for purpose and fit for use. But disposable overalls and underwear are all made for the male body shape and don’t fit women. Here, companies are effectively in breach for failing to provide the correct protective equipment.
The DCU poses a particular problem. Construction (Design and Management) regulations state: “Separate washing facilities must be provided for men and women, except where they are provided in a room the door of which is capable of being secured from the inside, and the facilities in each room are intended to be used by only one person at a time.”
DCUs are shared, yet their access is controlled by either a key or a combination lock, both of which are external. Again, this means they’re not compliant. I can only think that DCU manufacturers must be ignorant of the issue, or they would have changed this already.
Finally, Colette stressed two more areas where we need to do so much more. The first is the glaring need for simple respect. It should go without saying, but is clearly, sadly, very very lacking. Male colleagues must do all they can to help here – calling out even the borderline ‘banter’ – never mind the sexist abuse above.
Employers need to acknowledge the differences, and provide training so that female analysts are better prepared for the pressures. Crucially, they also need to offer support, so that analysts are comfortable and secure enough to report and get help when they need it.
As I said, it was a raw and eye-opening talk, and one which I profoundly hope will bring about change. Hearing the testimony were HSE officers, asbestos removal trade organisations, and consultancy business owners among others. It’s an oft repeated phrase that asbestos is the most regulated industry after nuclear – surely there were enough of the ‘right’ people in the room to make a change.
If you’ve been affected by this subject and wish to respond or raise similar concerns, email email@example.com. This is a totally confidential inbox that is monitored by Colette, Jean Prentice and Sara Mason, who are all on the working group set up in the wake of FAAM to address the issue.
The Contamination Expo, and the long road to events as normal
Written by Nick Garland on Thursday October 14th 2021
Cast your mind back 12 months and it was evident the pandemic was far from over. The government had introduced the three-tier system, and events were once again being cancelled and postponed. With this in mind, we should all be grateful that this year’s Contamination Expo was back at the NEC.
As probably the biggest event in our industry, the Expo is our major opportunity to come together, exchange ideas and information, and get a real feel for what’s going on. I was looking forward to being there but then, just a couple of days before, tested positive for Covid.
I’ve written loads about the ability – indeed the need – for firms to have technology that adds flexibility and remote-working capabilities, and it was interesting to get a chance to demonstrate first-hand. Our team leaped into action, helping me film my talk Demystifying the four-hour time-weighted average (4hr TWA) so that I could present it remotely to the conference – almost as planned!
Hopefully the talk still comes over well despite my not being 100% well – I’m happy to report that my symptoms were mild and I’ve recovered now. If you’re interested in reading more about the topic, this summer I wrote in depth about the HSE and personal monitoring, and took a deeper dive into the 4hr TWA.
Brilliant though technology is, and as much as it’s changing the industry we work in, there’s still no substitute for in-person conventions and events. Things will be more normal by this time next year, and the Contamination & Geotech Expo 2022 will no doubt be bigger and better. Mark out 14-15 September in your diaries!
We list the Expo and all the other occasions we know about in our regularly updated diary of asbestos and construction events. Aside from the regular ARCA and ACAD regional meetings, we’ll keep you posted on the various events and symposiums that accelerate the sharing of knowledge in our industry. Please let us know if you’re organising something so we can add it to the list.
Personally, I’m most looking forward to the next European Asbestos Forum (EAF) conference. Given the ongoing challenges with international travel this has been postponed until 2022, but I’m reliably informed next year’s event will be worth the wait. Given the quality of the 2019 conference, I don’t doubt it for a minute.
Want to see first-hand how Assure360 simplifies the 4hr TWA? Get in touch for your free demo!
“It’s only an asbestos enclosure” – why temporary works are a problem
Written by Nick Garland on Wednesday September 15th 2021
What on earth are Temporary Works? According to the Health and Safety Executive (HSE) they’re ‘the parts of a construction project that are needed to enable the permanent works to be built’. But this definition is a little misleading, and leads us to think only about major construction items, holding up partly built structures.
This over-simplified definition reflects a wider problem with how temporary works are perceived, and how the asbestos industry in particular deals with them. For the most part, we tend to ignore the whole issue as not applicable to us.
On the HSE’s side, there’s some problematic guidance in which the definition is subtly different. Essentially, here temporary works are anything that ‘might or might not remain in place at the completion of the works’. And if you’re thinking that could apply to anything, you’d probably be right.
Let’s step back from this confusion and explore the founding principles for temporary works (TW). TWs are assigned design categories, which reflect the complexity and innovation of their design. They also have a risk classification, which reflects the consequences should they fail.
The design categories are officially 1-3, but there’s an unofficial extra one – ‘0’:
0 – Standard solutions. Essentially off-the-shelf systems that have been previously judged or tested as safe.
1 – Simple designs. Some thought has been put into creating the solution. Examples might include simple formwork and propping.
2 – More complex designs. These would usually include piling and excavations.
3 – Complex, innovative designs. These are departures from the usual to solve novel problems or achieve an innovative result.
Depending on the category, the design requires a greater or lesser degree of extra checks.
Once we’ve established the appropriate design category, we determine the classification of risk by asking, ‘What are the consequences of failure?’ This often changes how temporary works are regarded. For example, temporary (i.e. Heras) fencing might be design category 0 – tried and tested. Put it next to a busy dual carriageway and it remains design category 0, but it becomes high risk. This raised level of risk means we undertake more stringent site checks to make sure the solution has been built as designed.
We’re actually very familiar with this kind of concept, as an asbestos enclosure is a great example. Enclosures are typically built to a very standard design, making them design category 0. But the consequences of failure will vary. In an open field there may be minor, manageable consequences. In a busy school they’d be very serious. Consequently, you may include additional checks for the latter.
Understanding risk categories
The obvious examples of TWs that we all think about are trenches, concrete formwork, and the propping up of partially constructed structures. But with the above definition in mind (anything that ‘might or might not remain in place at the end of the project’), they also include scaffolding, towers, hoarding, fencing and asbestos enclosures.
Essentially all the things we build in the asbestos industry are temporary works. So what do we need to understand about the rules?
Nearly everything that we do has a standard solution, and will have a design category of 0. Speedframe Airlocks, internal timber enclosures, Heras fencing, simple scaffolding, towers: it’s all off the shelf, so no specific design is required. However, there are times when we do something a little extra, and that changes things dramatically.
If instead of the standard Heras fencing we put up timber hoarding, the support and foundations for these are firmly in the category 1 arena. Adding logo sheeting to Heras fencing would also move it into category 1, with the associated changes in how it needs to be managed.
Many other common adaptations will modify category 0 structures in this way. If the existing site scaffolding is a standard design covered under the National Access & Scaffolding Federation’s TG20:21 guidance, great. But when we construct a full enclosure on this we’re adding a huge sail to a multi-ton structure. That’s very definitely no longer a TG20 scaffold!
If a temporary works fails, the consequences could be serious – and the HSE will certainly be investigating. Say for example that high winds topple the soffit enclosure scaffold, the scaffold company could well be in the clear – the reason it fell was because we added the sail. If we have specified category 1, 2 or 3 temporary works, but then not had them properly designed, it’s us in the dock.
Managing risk, avoiding disaster
So if everything we build is a TW, and mostly it’s category 0, but occasionally it’s not, what should we be doing? It’s unfortunate that there’s no official guidance. Instead, everything is effectively governed by the British Standard BS:5975. This document outlines the best practice you should be following. And in our industry we know that while we don’t have to follow guidance, we can’t ignore it, and we must do something equivalent or better.
BS:5975 states that you must have a procedure for TWs. This could simply be an extension to your existing standard procedures, essentially laying out what standard designs you use and what you will not do. You must also appoint certain roles. These include a designated individual: a senior person in the organisation responsible for establishing and maintaining the TW procedure. The designated individual must also appoint the temporary works coordinator: a competent person to manage the temporary works.
All temporary works must be designed by a competent person, or be to a standard (i.e. off the peg) design. And there may be a need to double-check aspects of the designs depending how complex they are. Anyone who designs a TW is a TW designer. They have exactly the same duties as any designer under the Construction (Design and Management) Regulations 2007.
All temporary works must be checked on site to ensure they have been installed or built as per the design. As we mentioned before, the degree of checks required depends on the risk.
How might this work in practice? The appointed roles might be shared out as follows:
- Health and safety lead takes on the designated individual role, as they have existing responsibility for the standard procedures.
- The contracts managers are appointed as temporary works designers. They design the job, and ideally they only select standard solutions.
- Supervisors are your eyes on the ground, ensuring that whatever you design is implemented correctly. After all, that’s their normal day job.
The first and second of these have to be formally appointed, and accept the position.
There’s excellent training available for temporary works coordinators – you can find much of it through Easybook – but it’s not compulsory. In the low-risk category 0 world we inhabit, you might choose to send one person, then have them cascade the information to all of the TWCs.
In any event, make sure your contract managers know what constitutes a standard solution – give examples in your procedures. Few licensed asbestos removal contractors (LARCs) have anyone in-house competent at designing scaffolding. If you’re using scaffold as the basis for a soffit enclosure, make sure the scaffolder knows it is unlikely to come under TG20, and that it will need a design. Similarly, don’t embellish Heras fencing with branded sheeting. If necessary, use the (expensive) netting designed for this purpose.
The supervisors, as usual, are the checkers. They need to confirm that the operative built, installed or erected the item correctly. Recording these checks can be time consuming, but it’s something we’re all used to. That’s exactly why we designed the Assure360 Paperless solution, which slashes supervisor administration time by up to 80%.
So in summary, the things that LARCs build or erect are always temporary works, and you ignore that fact at your peril. By following some simple steps we can repurpose the activities we routinely do anyway, ensuring that the job gets done properly, checked appropriately, and that we’re observing the proper guidance throughout.
Want to see first-hand how Assure360 Paperless streamlines routine safety checks, and makes the data available for insight and analysis? Get in touch now for your free demo!
Talking Asbestos – Nick appears on the Asbestos Knowledge Empire podcast
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!
Reviewing 2019 – a year of change in asbestos management
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.
Licensed to ill
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.
- “It’s saving me hours and hours and hours of going through paperwork.” – Jonathon Teague, project support manager, Armac Group
- “Instead of going backwards and forwards to my site folder I can now just do it all on the app. Paperwork is all done unbelievably quickly and I can go out and help with the sheeting up.” – Gary Meads, senior supervisor, Sperion
- “When it comes to the licence assessment, Assure quickly enables you to extract the information which will help prove that you are complying with the HSE’s licencing criteria.” – Clinton Moore, director, Sperion
- “Paperless has helped us build smooth processes around our critical site checks and record keeping, and the app will be a fundamental part of helping us maintain quality and efficiency as we scale up.” – Tony Loughran, managing director, Amianto Services
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.
Beyond Grenfell – Welcoming the Hackitt review
Written by Nick Garland on Wednesday July 18th 2018
The Grenfell disaster was, among many other things, a failure of building regulations to protect residents. It’s clear to me that the Hackitt Review had to re-learn the lessons of work health and safety, and with Dame Judith a previous head of the HSE, I awaited her review with some optimism. Here’s why I believe she has grasped the opportunity. (more…)