Written by Nick Garland on Wednesday May 27th 2026
The Health and Safety Executive (HSE) has published its policy position on Great Britain’s asbestos Control Limit (CL). The decision was telegraphed ahead of time, but after a full evidence review the limit will stay at 0.1 fibres per millilitre (f/ml), measured as a four-hour time-weighted average.
It’s always been tempting to look at the EU’s occupational exposure limit (OEL) – 10 times lower than our CL – and imagine the UK is falling behind. However, the OEL was always a permitted ceiling, the totem of a very different approach to our own. Set with reference to estimated cancer risks across a working lifetime of constant exposure, an OEL tells an employer that, provided they’re within it, the legal duty is broadly satisfied.
The Control Limit does no such thing. It is not a safe exposure level – in fact the UK does not have any safe limits. The CL is a trigger that defines licensable work under the Control of Asbestos Regulations 2012, bringing with it notification, the four-stage clearance procedure, personal exposure monitoring and medical surveillance. Beneath the CL, the duty to reduce exposure as low as reasonably practicable (ALARP) still applies in full. There is no permitted dose.
So it was that our CL and the EU’s OEL were always doing fundamentally different regulatory jobs, and as such they couldn’t be compared. But all that is changing fast, with the risk that the UK is being left behind.
From 21 December 2025 the EU OEL fell to 0.01 f/ml. By 2029 member states must reduce again to either 0.002 f/ml, counting wider fibres only, or 0.01 f/ml counting narrower fibres too. But there’s also been a change to the EU’s approach, and that’s what fundamentally changes the comparison.
The amended Asbestos at Work Directive, consolidated on 20 December 2023, has reshaped the EU position. Three articles do the work. Article 6 requires employers to reduce asbestos exposure to as low as is technically possible – note that’s ‘technically possible’, not ‘reasonably practicable’.
This change strips out the financial element of the cost-benefit analysis, and sets a stricter enforcement bar than ours. Article 8 fixes the interim limit value at 0.01 f/ml, with further reductions scheduled for 2029 depending on the testing methodology Member States adopt. Article 10 makes the limit value operate as the trigger for a hierarchy of precautions, with respiratory protective equipment (RPE) as the last line of defence.
In other words, the EU limit now functions in much the same way as the GB Control Limit. Same architecture. Tighter number. Stricter duty. Now there is no permitted dose on either side of the Channel.
The HSE’s review still has force. The principle of ALARP already drives exposures well below the CL on most jobs, and lowering the figure in isolation would sweep lower-risk work, such as cement or floor tile removal, into the licensed regime at significant cost. But now the EU has a similar requirement to drive exposure down to the minimum, reinforced by a lower permitted baseline than us.
The EU’s 0.01 f/ml figure is not a response to a step-change in the science. The toxicology of asbestos has been settled for years. What changed was that the bloc gained the political appetite to apply existing evidence at a tighter threshold. Now in the UK, “below the CL” is doing less reassuring work than it used to, especially given the EU benchmark is 10 times lower, and the duty above it is stricter. The UK’s four-stage clearance procedure remains more rigorous than the EU equivalent, but we’ve otherwise ceded our leading regulatory position.
The message for dutyholders is unchanged. The Control Limit is not a target. Air monitoring strategies, RPE selection and method statements should be built around ALARP, not the figure on the certificate. But the benchmark for what ALARP looks like now sits in Brussels.
Written by Nick Garland on Wednesday May 27th 2026
The 2026 FAAM Asbestos Conference returned to Birmingham at the end of April, bringing together researchers, regulators, consultants, analysts and practitioners from across the sector. Together they examined some of the biggest scientific and technical questions facing asbestos management today. As regular readers will know, I believe the conference is the most important forum in the UK for challenging assumptions, sharing emerging research and debating the future direction of regulation and practice. This year’s programme covered everything from exposure modelling and disease trends to AI, fibre analysis and the hidden consequences of low-level environmental exposure.
Three presentations in particular stood out for me. Not because their presenters agreed, but because together they painted a far more complicated picture of asbestos risk than the industry is perhaps comfortable with. Andrew Curran, Director of Science at the Health and Safety Executive (HSE), presented a measured and cautiously reassuring view: mesothelioma deaths appear to have peaked, historic exposure has reduced significantly, and the overall trajectory broadly follows the models that the regulator predicted years ago.
Professor Daniel Murphy then challenged whether we are interpreting those statistics correctly at all, arguing that asbestos-related lung cancer, particularly linked to chrysotile exposure, may be dramatically underestimated. Professor Jukka Takala widened the lens further still, arguing that global and UK asbestos mortality remains persistently high, with trends among women potentially revealing something deeply uncomfortable about how we understand low-level exposure.
Taken together, the talks left me thinking that the central issue may not be whether the asbestos problem is improving or worsening. It may be that we are using the wrong framework entirely to understand what modern asbestos exposure now looks like.
Andrew Curran’s presentation was an important reminder that the HSE’s position is not complacent. The regulator continues to invest heavily in asbestos research, and Curran described the considerable effort going into understanding changing exposure patterns, non-licensed work, asbestos degradation over time, behavioural factors and predictive modelling.
Some of the data he presented was genuinely reassuring. Mesothelioma mortality overall appears to have passed its peak – particularly among men historically associated with heavy occupational exposure. Lung burden studies examining asbestos fibres in tissue samples also indicate that exposure has reduced significantly over time.
But even within this broadly positive picture, Curran highlighted several warning signs that the HSE now believes warrant closer examination. Cases are appearing in occupational groups not historically associated with direct asbestos handling, including teachers, nurses and administrative staff. More worryingly, there appears to be a small but noticeable uptick in mesothelioma cases among people born between 1980 and 1984. The numbers remain small and require cautious interpretation, but they are sufficient to justify further research.
Curran left us with a single obvious thought: asbestos is a complex problem. Exposure, regulation, behaviour, building management, removal practice and health outcomes all interact in ways that are extraordinary. That systems-thinking approach became increasingly important as the later talks unfolded.
Daniel Murphy’s presentation was probably the most provocative of the day. He accepted that male mesothelioma mortality appears to be declining overall, but argued that population-wide statistics are potentially masking important underlying trends. Looking at specific occupational cohorts rather than the population as a whole, statistically significant increases remain visible in several groups, particularly construction-related trades among men, and educational, professional and secretarial occupations among women.
Murphy’s central argument was that the continued presence of asbestos within buildings remains an active exposure source, both directly and indirectly. Maintenance workers disturbing asbestos-containing materials are one part of the picture. But he also pointed towards long-term passive exposure within occupied buildings, and situations where occupants remain present during maintenance activities despite asbestos disturbance taking place nearby.
His most striking argument concerned chrysotile asbestos. Historically, chrysotile has often been treated as less dangerous than amphibole fibres in relation to mesothelioma. Murphy did not dispute that distinction entirely, but argued that chrysotile’s role in lung cancer may have been significantly underestimated. Given that chrysotile represented the overwhelming majority of asbestos imported into the UK, this matters enormously.
Murphy highlighted an important technical problem: chrysotile fibres are far harder to identify reliably in post-mortem tissue analysis than amphibole fibres. Unlike the straight, needle-like amphiboles, chrysotile fibres curl and fragment. Murphy argued that this may have created a misleading impression that chrysotile “disappears” harmlessly from the lungs, when in reality it may simply be much harder to detect.
From there, Murphy introduced what I found one of the most compelling analytical approaches of the conference. Rather than trying to estimate asbestos-related lung cancer using fixed ratios against mesothelioma cases, he instead treated mesothelioma geographically as an indicator of asbestos exposure intensity. Looking across Scottish health boards, areas with high mesothelioma incidence also showed high lung cancer rates. Areas with low mesothelioma rates showed lower lung cancer rates. Other cancers did not show the same pattern.
Murphy’s argument was not that asbestos alone explains all lung cancer. Rather, it was that the geographic relationship between mesothelioma and lung cancer strongly suggests asbestos is contributing far more substantially than current official figures recognise.
My own view increasingly aligns with elements of this thinking. The traditional approach of treating mesothelioma and asbestos-related lung cancer as existing in a broadly fixed ratio may simply no longer be the right way to understand the disease burden. In the UK, this approach broadly underpins the familiar estimate of around 5,000 asbestos-related deaths annually. But if chrysotile fibres are inherently difficult to identify post-mortem, and real-world UK exposure has almost always involved mixed fibre exposure rather than neat laboratory categories, then any rigid ratio starts to become highly questionable.
A much more meaningful approach may be to treat mesothelioma itself as a geographic exposure marker. If areas with elevated mesothelioma incidence also consistently display elevated lung cancer rates, then that relationship may tell us far more about the true burden of asbestos disease than attempting to force the problem into fixed mathematical assumptions.
In that sense, mesothelioma stops being viewed solely as the disease of concern, and instead becomes a marker for wider asbestos-related harm across populations living and working within asbestos-containing environments over long periods of time.
Jukka Takala’s presentation then took this thinking even further. His argument was blunt: asbestos-related disease globally remains substantially underestimated, particularly lung cancer. Mesothelioma may be the most recognisable asbestos disease, but lung cancer is the larger burden numerically, and often disappears statistically because smoking dominates the clinical narrative.
Takala repeatedly returned to the interaction between smoking and asbestos exposure. The two do not simply add risk together; they multiply it. Yet once a patient is identified as a smoker, asbestos exposure is often no longer properly explored.
What I found particularly striking, however, was his focus on women. Takala showed that while male trends may flatten or slowly decline, female asbestos-related disease continues to rise in several countries, including Sweden and the UK. His explanation centred on long-term environmental exposure from buildings and urban environments rather than traditional heavy industry exposure.
My own reflection is that the female statistics may actually be telling us something broader than female exposure alone. Historically, women were less likely to experience the heavy industrial exposures that dominate historic asbestos datasets. As a result, female cases may effectively provide a cleaner signal for understanding long-term, low-level environmental exposure.
If that is right, then this is not fundamentally a “women’s issue” at all. It may instead represent the clearest evidence yet of what prolonged low-level exposure looks like across whole populations: women, men, children and adults exposed over decades through the continued presence of asbestos within the built environment.
Viewed through that lens, the apparent rise in female cases becomes deeply significant. It suggests that once the statistical “noise” of historic high-dose occupational exposure begins to fade, a different exposure model starts to emerge beneath it. And that possibility fundamentally challenges the comforting narrative that the asbestos problem is now simply winding down with time.
None of this means that Andrew Curran’s reassurances were wrong. Historic heavy occupational exposure probably has reduced substantially. Mesothelioma among traditional high-risk male cohorts may indeed have peaked. But Murphy and Takala’s work strongly suggests that this may no longer represent the whole picture.
The possibility exists that we are transitioning from one asbestos epidemic to another: from visible, high-dose industrial exposure to diffuse, low-level, long-duration exposure embedded within ageing buildings and infrastructure. If so, the real challenge for the next decade may be recognising that the shape of asbestos exposure itself may already have changed.
For me, the presence of these three speakers – and the ability to evaluate their positions against each other on the day – underlines the value of the FAAM Conference. Going back to what I said at the start of this post, the conference is a place for challenging assumptions and stimulating debate. Those discussions, and the reflections that come afterwards, can be pivotal in forging links and building a deeper understanding that benefits us all.
Written by Nick Garland on Thursday March 12th 2026
Over the past 11 years, I’ve had countless conversations with contractors about how they manage their site paperwork and compliance. Some are drowning in paper. A few have cobbled together spreadsheets and smartphone photos. And some have tried other digital solutions that promised much, but ultimately couldn’t deliver.
That’s why I wanted to set out clearly what makes Assure360 different – and why nearly a quarter of the licensed asbestos removal industry now uses it.
Let me start with a number that I’m genuinely proud of: approaching 23% of licensed asbestos removal contractors (LARCs) in the UK now use Assure360. If you include contractors using the ARCA portal (which runs on our platform), that figure rises to nearly a third of the industry. That’s a level of success I could have only dreamed of when I first started building Assure360 from my auditor’s spreadsheets.
To date, our users have created over 78,000 projects and 115,000 work areas on the system. We’ve recorded nearly 1.4 million individual exposure records. These aren’t just impressive numbers – they represent a big industry-wide shift towards better compliance, better records, and better protection for workers.
Assure360 makes site paperwork simple. We know that supervisors typically save one to two hours every single day using the Paperless app. That’s a transformation on site, liberating your most experienced staff member to support the team, and better ensure safety and compliance on the job.
But we don’t stop there. The real power of Assure360 comes from what happens with all the information we gather. Instead of sitting in a filing cabinet waiting for the job to finish, it flows directly through to the back office, giving management genuine visibility of what’s happening on site – in real time, from anywhere. Better still, our powerful reports and functions can generate insight – into training, equipment; everything – while the job’s ongoing.
Think about what that means. Contracts managers can check on multiple jobs without spending half their week driving between sites. Directors can focus on winning new work instead of chasing paperwork. And when licence renewal comes around, everything is already there, organised and ready.
I’m especially proud of our approach to exposure management. The regulations around recording and managing asbestos exposure are complex, and getting it wrong can have serious consequences – for your licence, and more importantly for your workers’ health.
Assure360 delivers 100% compliance with HSE requirements for managing asbestos exposure. Our exposure strategy tools are unique in the industry, and they’re essentially admin-free. The system does the heavy lifting, so you can be confident you’re meeting your obligations without adding to anyone’s workload.
The support we offer is a huge part of our appeal, and why our software proves so effective in practice. To help you get the most from Assure360 we provide:
In this way, everyone using Assure360 and our apps is supported to get the most from the system.
I understand that switching systems is a big decision. That’s why we offer a three-month free pilot with no obligation. You can see for yourself how our system and apps work on your jobs, with your team, before you commit to anything. And if you do decide Assure360 is right for you, there’s currently a 10% discount available.
But more than the commercial terms, what I’d really encourage you to do is talk to others in the industry who use it. Ask them about their HSE visits. Ask them how much time they’ve saved. And ask them whether they’d ever go back to paper.
I’m confident in what they’ll tell you.
If you’d like to discuss how Assure360 could work for your business, or if you’d like to arrange a pilot, please get in touch.
Written by Nick Garland on Thursday March 12th 2026
Enclosure air management is a critical part of controlling risk to workers during asbestos removal. Despite significant research by the Health and Safety Executive (HSE), however, it’s still an area that causes a degree of head-scratching among some asbestos professionals.
Our understanding of airflow in the enclosure is informed by two key pieces of HSE research:
This article aims to bring some clarity to the practical application and management of airflow: explaining why enclosure air management matters, and providing a practical way to think about it. I won’t be discussing the use of anemometers in this article, for my investigation on these devices and the underpinning regulations see my previous articles on enclosure airflow.
Let’s start with the basics.
An enclosure is constructed around the work area and one or more negative pressure units (NPUs) are installed. These draw air out of the enclosure, pass it through a HEPA filter that removes 99.97% of asbestos fibres, and then discharge the cleaned air to the atmosphere.
This extraction process has a second critical effect. By continuously removing air from the enclosure, the system creates negative pressure inside it. Nature abhors a vacuum – the principle was famously described by the ancient Greek philosopher Aristotle around 320 BC – but the physics is straightforward: if pressure inside a space drops, air will try to flow in to equalise it.
For asbestos removal, this is exactly what we want. If air is always moving into the enclosure, fibres cannot escape into the surrounding environment. Specifically, HSE guidance instructs us that a minimum level of negative pressure that we are looking for is five pascals (-5 Pa).
However, this creates another challenge. If air is being extracted, it must be replaced. If the enclosure were completely sealed its polythene walls would simply collapse inward. Controlled routes for incoming air therefore have to be provided. These usually take the form of:
There is also a second air management requirement. Enclosures must achieve at least eight air changes per hour (ACH) – although in practice the industry commonly designs for more than 10 ACH. This ensures that the air inside the enclosure is continuously cleaned and that airborne fibres are removed efficiently.
So the system has two simultaneous objectives:
If met, these objectives mean that outside the enclosure we remain protected from fibre release, while inside the enclosure the air is constantly being filtered.
At this level the concept is relatively straightforward.
The design target is a minimum of –5 Pa of negative pressure. HSE research — particularly RR988 and the associated enclosure ventilation studies — also gives us useful practical benchmarks. For example, the research shows that a standard one-metre airlock typically allows approximately 1,500 cubic metres per hour (m³/h) of make-up air to enter the enclosure, and that ~250mm of flap deflection in the airlock equates to approximately –5 Pa.
In simple terms this means that if an NPU is extracting around 1,500 m³/h, and the enclosure has a standard one-metre airlock, the system will usually sit in roughly the right operating range.
The complexity arises when we move from the research environment into the real world. Real enclosures are rarely perfect. They may:
At that point the air management problem becomes a calculation. We need to determine both the airflow required to achieve at least 8–10 ACH, and the amount of make-up air required to maintain stable negative pressure. Too much incoming air will reduce the negative pressure. Too little incoming air will throttle the NPUs.
A simple analogy helps illustrate this. Imagine sucking air out of a crisp packet. If there is no hole in the packet, it will get harder and harder to extract more air, eventually you cannot remove any more at all and the bag will collapse. The same thing happens with NPUs if insufficient make-up air is provided.
The HSE research gives useful approximate airflow values for common controlled air entry points:
These figures allow us to estimate how much air can enter an enclosure.
For example:
In practice, enclosure design also needs to consider airflow patterns within the enclosure. In the example below we can see several good design principles:
(Courtesy of Asbestech Ltd.)
Note in this example that the NPU is exhausted to atmosphere via trunking. This will reduce its efficiency markedly – HSE research indicates around 1% reduction in airflow per metre of trunking, and 2% per 90° bend. Another factor to consider when planning an enclosure is that the effectiveness of NPUs depreciates over time, so it’s prudent to allow for this when calculating airflow capacity.
Once the enclosure is built, the airflow balance may still require adjustment. To help with this, I’ve produced a spreadsheet that performs the airflow calculations. It also integrates neatly with the Assure360 Paperless App, which includes several tools designed to help prevent mistakes being made on site and double-check that supervisors are making the correct decisions.
Access the enclosure air management calculation spreadsheet here. Note that this is a read-only spreadsheet – make a copy, or download as an Excel spreadsheet via the FILE menu to use it.
The enclosure shown above is 50 m³, and the NPU is rated at 2,300 m³/h. Allowing for 20% depreciation, five metres of exhaust trunking and a couple of 90° bends, the effective airflow is reduced accordingly. In this case the ingress filter must remain open to ensure airflow passes through the kitchen area.
Ordinarily, the airlock, baglock and ingress filter would allow approximately 3,500 m³/h of incoming air. However, to balance the NPU we only require 1,674 m³/h of make-up air. This tells us the baglock will need to remain closed, and the airlock will need to be partially closed in order to restrict the amount of air entering the enclosure.
Airflow calculations are not based on everything physically present in the enclosure design. They are based on what is actually being used to achieve the required airflow balance. This is exactly what the accompanying spreadsheet tool is designed to help with.
Rather than simply documenting what appears on a drawing, the spreadsheet calculates the airflow configuration required to achieve the outcome we want: stable negative pressure and effective air cleaning inside the enclosure.
The role of the supervisor on site is to fine-tune the setup so it reflects reality – something that can rarely be achieved from the drawing board alone.
I hope you find this spreadsheet and its integration with the Paperless app useful. Feel free to get in touch if you want to know more about how to use the spreadsheet, or how it and Assure360 can work together to ensure compliance.
Written by Nick Garland on Thursday February 19th 2026
The Asbestos Network Technical Working Group met for the first time since Christmas, with leak testing guidance firmly at the top of our agenda. The document itself is now close to completion, but the current focus is on refinement rather than substance: simplifying the language, making it more direct, and ensuring it concentrates on what you actually need to know when deciding what to do, and where. Fingers crossed a final version will be ready at April’s meeting.
Alongside this, we’ve been asked to prioritise which other guidance documents should be progressed this year. There are currently nine draft appendices at varying stages of development, some entirely new and others revisions of existing material. The current proposed list includes:
Some of these are quick wins and might be produced relatively quickly. Others could be merged – here I’m particularly thinking of calculating NPU airflow and differential pressure measurement. Both of these are circling around Paragraph 395 of the Approved Code of Practice (ACOP), which states:
“Before starting work in the enclosure, a thorough visual inspection and smoke test must be conducted to check the enclosure’s integrity. The filtered air extraction equipment must be tested to ensure it is achieving negative pressure and the required air change rate.”
If you have any strong opinions as to which areas need guidance, please do speak to your trade association: they’re all represented on the Technical Working Group, and their regional meetings are happening around now. If you’ve missed the boat, or you wanted to speak to me directly, by all means get in touch to let me know your thoughts.
To find all the guidance produced by the Asbestos Network Technical Working Group, go to the CONIAC website.
Written by Nick Garland on Thursday February 19th 2026
I’m a strong supporter of the Health and Safety Executive (HSE), and its work is normally excellent. Last year, however, I raised a concern about its revised hand-arm vibration syndrome (HAVS) calculator, which you can download from the HSE website.
To recap the issue: the field for tool make and model includes a drop-down selector. You can ignore this and type in the precise device you are using, but drop-downs have a habit of drawing people in. If you use it, you are presented with a broad category of device (for example, a reciprocating saw) and a corresponding vibration magnitude range. This range is based on extensive HSE testing across a wide variety of tools and activities, and they have even calculated a “typical” vibration magnitude – the 75th percentile.
The intention is sound: this data allows users to critically assess manufacturers’ claims. So far, so good.
The problem is that the spreadsheet automatically selects this “typical” value and inserts it into the calculation – in the column labelled HSE. Unless you actively override it with a value based on your own assessment of the actual tool and task, the exposure calculation will be carried out using the HSE’s recommended figure. Without understanding why the dataset is provided in the first place, it would take a very confident user to select an HSE value and then deliberately replace it with their own.
That matters, because if the tool you are using happens to sit at the upper end of the range, the worker could be significantly over-exposed.
The image I use illustrates this with a worked example for a reciprocating saw. It shows what happens if the typical HSE-measured value of 18 m/s² is accepted, but the actual tool and task had a vibration magnitude at the top of the range – 27 m/s². On the calculator, a 30-minute trigger time would appear comfortably below the exposure limit value (ELV). In reality, it would represent a breach by almost a factor of two.
There has been a change since my initial observations when the spreadsheet first went live: the HSE now provides brief guidance on how to use it. The most relevant section states:
Click on the white areas and enter a representative vibration magnitude (in m/s²) and an exposure duration (in hours and/or minutes). You can do this for up to six different machines or processes. Information on tool types may be entered directly into the tools/process names columns, or selected from a drop-down list of common tools with HSE’s recommended initial value.
There is now at least an acknowledgement that the HSE figure should be treated as an initial value – a starting point rather than a definitive one. That said, the message is subtle rather than explicit, and it needs to be firmed up.
I don’t enjoy criticising the HSE, which, as I’ve said, usually does an excellent job. But this spreadsheet still feels like a well-intentioned tool that remains flawed in its execution. For now, I would recommend using it with a good deal of caution. The HSE’s measured values should be treated as a guide only – a way to challenge your own assumptions and the manufacturer’s claims, rather than a figure to be adopted uncritically.
Written by Nick Garland on Thursday December 11th 2025
This article has been co-authored with Jonathan Grant
The Health and Safety Executive (HSE) has launched a major public consultation on proposed changes to the Control of Asbestos Regulations 2012 (CAR) and associated guidance. These proposals aim to strengthen how asbestos is managed across Great Britain, and will have a direct impact on dutyholders, analysts, surveyors, removal contractors and anyone involved in maintaining or working within the built environment.
The consultation seeks views on three key areas:
The Notifiable Non-Licensed Work (NNLW) category has its roots in changes made when textured decorative coatings were moved from licensable to non-licensable work. Historically, removal of textured coatings had been treated as licensable, which created a substantial volume of licensed work despite the relatively low risk these materials present.
When the HSE revised the Regulations to classify textured coatings as non-licensable, parts of the removal industry challenged the change at the European Court, citing technical requirements in the EU Asbestos Workers Directive concerning notification and medical surveillance. The challenge was upheld, requiring the UK to amend its legislation.
To comply, the HSE introduced the NNLW category, applying the minimum necessary changes under the Directive: keeping textured coatings as non-licensed work, introducing a simple notification process, and requiring a level of medical surveillance that was proportionate but not as extensive as that required for full licensable work. As a result, the NNLW category emerged primarily as a compromise solution to meet EU legal requirements, rather than as a clearly defined or conceptually distinct risk category – something that has contributed to ongoing uncertainty in its interpretation. There is evidence to suggest that the current system has allowed asbestos insulation board (AIB), insulation and sprayed coatings to be treated as NNLW. Yet this is either a significant misunderstanding of the rules, or deliberate misuse. The HSE’s data suggests this accounts for around 10% of notifications – 2,400 or more projects annually.
Being able to remove NNLW is, in Jonathan Grant’s view, the only tangible Brexit benefit to date – though others may take a different view.
Nick Garland takes a different position: NNLW should be retained, but only for genuinely lower-risk materials. AIB, insulation and sprayed coatings should be explicitly removed from the category – ensuring these higher-risk materials are dealt with under the licensed regime.
This is not a particularly controversial area, and the HSE’s preferred option – that licensed asbestos removal contractors (LARCs) should not appoint four-stage clearance (4SC) analysts – is sound. There will be teething issues – domestic clients and small construction companies are likely to say to the LARC, ‘just tell me who to appoint’ – but largely the removal of a clear conflict of interest would be a great move. Alongside it, there must be client-focused channels for finding the right consultant – a point made in the consultation.
The HSE’s own evidence to the Work and Pensions Committee is revealing. It considered accreditation of surveyors in 2004, but opted instead for non-regulatory measures it viewed as less burdensome. The voluntary individual certification schemes that were attempted failed largely because uptake was low – an entirely predictable outcome when participation was not mandatory. Despite the HSE position and evidence, the Committee recommended mandatory accreditation.
For the past two decades, efforts to improve survey quality have relied on two main approaches: non-regulatory guidance for dutyholders, and accreditation that is encouraged but not mandatory. Yet significant issues with survey quality persist, which suggests that neither approach has been sufficiently effective.
The HSE’s own research shows that UKAS accreditation has improved survey quality, but it is not a complete solution – and therefore the regulator maintains that mandatory accreditation would not fully resolve the problem. But the preferred option of more guidance has demonstrably failed over the past twenty years.
Consistent feedback from across the sector points to the core issue being the competence of individual surveyors. The Committee’s recommendation was for surveyors – not survey companies – to be accredited, which is possibly revealing of their intent.
Unfortunately, the consultation document narrows the question down to just two options: mandatory accreditation by UKAS or improving guidance. If we have to pick between one that has some effect and another that has been shown to have no impact, then it has to be mandatory UKAS accreditation.
However, it is rather a shame that the opportunity was not taken to think around the subject, possibly picking up on the Committee’s use of ‘surveyors’ to look at an approach that directly tackles individual competence.
This consultation does offer quite a few yes/no, or multiple choice questions. But across all these areas there are opportunities for respondents to expand on what they think. There will naturally be a wide range of views – but what is essential is that all practitioners across the sector make their views heard. The consultation is open until 9 January 2026, but to find out more – including more views beyond Jonathan and mine, FAAM is running a very timely webinar on the 17th December at 10:00. Here’s a link to sign up. And once you’ve attended that here’s where you can respond to the consultation.
Written by Nick Garland on Wednesday October 22nd 2025
I’ve worked in asbestos and safety businesses now for some 30-odd years. I’ve been to more sites and contributed to more projects than I care to remember, and of course, I’ve worked alongside hundreds of colleagues. I’ve seen first-hand the challenges and dangers of asbestos removal, the methods we use to address them, and the work of regulators who hold us to exemplary standards. It’s a unique, fascinating, challenging industry.
Assure360 comes from this personal experience; its roots are in the spreadsheets I built when working as an auditor, and supporting LARCS through licence assessment. As they became more sophisticated, I realised the potential to create a product that could help keep my wider colleagues safe. And that’s been our mission at Assure360 for the last 11 years.
But I know that not everyone working in construction and asbestos removal went to college. Not everyone is comfortable with technology. And many of us struggle with conditions such as dyslexia. In our paper-bound, records-reliant industry, these can present skilled workers with real difficulties. Paperwork is a chore, yet technological solutions like our Paperless app can seem threatening and complex.
That’s why I wanted to pull together a few words from the people actually using Assure360, and in particular Paperless. Every day, hundreds of supervisors fire up the app to complete their critical checks and mandatory safety records. It helps them get more done, and gives them back time from their day to actively help and supervise the team. What do they say?
Some of the boys we work with have been in the game for 24 years and all they know is paperwork, so the new system is a bit of a jump for them. I wouldn’t say I’m the best at computers at all, really, but it is mega easy to get, really. And if there are problems you can text Rick [Garland] and he’ll get back to you in about 30 seconds.
Joe Cooksey, Supervisor
At first I was very daunted when I heard what was going to happen. I’m not very technical. I can use my iPhone but that’s about it. I have to say I was taken aback by how simple it was. I picked it up very quickly and now I much prefer it to paper.
Craig Toomer, Supervisor
I’m not the best on computers and things, and I was a bit nervous about using Assure360 at first. We got a trial of the system, and Nick [Garland] came out and showed me how to do it, and from there I just got better and better at it. When you ring Nick he answers his phone straight away and helps you out with it. I’m clued up on it, but I’m still progressing with it – getting into all the things.
Pete Cooper, Supervisor
I have been in the asbestos industry for 24 years and a supervisor for the past 19. I’m not a computer person at all – never owned one in my life – so I was a bit nervous when East Coast fully adopted Assure360. But now a few months in, I’m really getting the hang of it, and I can say I absolutely love Paperless. Just using it makes me feel a lot more professional, my spelling and writing is not great – the app takes care of that.
Mark (Penny) Ashcroft, Supervisor
Now it’s more being a supervisor than just doing the paperwork, because you can add pictures. It’s dramatically helped me time-wise, and also just the professionalism of it. Asbestos strippers aren’t known for their spelling or writing, but now if you have a visit from the Health and Safety Executive (HSE) or anything someone can always read what you’ve written. They can go through the site diary and you’ve just got everything there.
Joe Cooksey, Supervisor
The extra time it gives me to supervise [my team] makes my life so much easier. I have everything on an iPad rather than a huge site folder. Even on a short project it saves me a huge amount of time.
Craig Toomer, Supervisor
It’s definitely saving time, and especially after the first day when you load it all up with everything, then it’s just a matter of pushing the buttons after that – it’s all been stored. I do think it’s a very professional tool, there’s no doubt about it – and easier.
Adrian O’Neill, Supervisor
It’s quicker. When you went to fill your paperwork out it could take four or five hours, whereas with Assure360 it could take 20-30 minutes in the morning, then you just go back to it during the day.
I can use the free time to actually help my team: carry things and sheet up with them, whereas before I’d be sat here with my glasses on with my paperwork. It’s even better for the analysts with four-stage and signoffs and everything; no messing about with bits of paper to get the sign off – it’s all on there.
Pete Cooper, Supervisor
There are reasons why Paperless delivers this time-saving simplicity: years of personal experience and community feedback inform everything we do. I use our software professionally in my role as a consultant. And we’re always asking our users for feedback and input into our development pathway. This feedback loop is a fundamental part of what we do, typified by the quarterly client forums we introduced last year.
But what does all this mean for the back office: the contracts managers and directors who may not be using the Paperless app, but need to be sure that any business solution delivers value for money, and that any safety solution supports health and safety? We asked East Coast Insulations’ associate director Adam Lubach:
You don’t get anywhere quick in Norfolk. Instead of doing a site visit and making sure everything is alright, we can actually do that from our office, which saves us a bit more time. There are quite a few rural areas up here where it’s hard to get a signal, so we were a bit worried about how that could impact our operations. We did a trial period to check how that would work, and then we went with Paperless after.
It does save me a lot of time as a manager. For example, this week I’ve got three jobs running. I know I don’t have to run around to these sites because I can have a quick look on Assure360, I don’t have to go there and I can concentrate on seeing clients, preparing quotes. I can spend more time on the plan of works.
With a paper-based system you spend a lot of money on paper, then you’ve got to audit the paperwork; you’ve got to file it. There’s a lot of post-completion work after the actual removal job has been done.
[Paperless means the supervisors] don’t have to come down to the seating area, the welfare, or to the office to do paperwork – they can do it on the move. They’re loving it because it saves us a lot of time. The guys are more hands-on, so they’re better at managing the operatives, and it makes it easier for me to manage the jobs.
Assure360 Paperless does all that work for you as the job starts and progresses and finishes. So all I’ve got to do is just close jobs out in the end, then that’s uploaded and stored for the HSE’s audit for our licence renewals. So it saves us a lot of time with paperwork.
Adam Lubach, Associate Director, East Coast Insulations
I’ll leave the last word to Craig Binge, Managing Director at Westfield:
We have been using Assure360 for some years now and have always found that it makes running jobs so much easier. We have a particular supervisor that is extremely dyslexic but despite this he is able to use Paperless perfectly.
Just having the system puts the HSE’s mind at rest and visits go much more smoothly. I’ve often said it has been the single best investment we have made as a business – and that companies would be mad not to use it.
Written by Nick Garland on Friday September 12th 2025
This is quite a departure for me: talking about ingested, rather than inhaled asbestos. In fact it’s so much of a departure that, until last year, I hadn’t really considered it. With the shame that hindsight can sometimes induce, I also recall in my early career ridiculing the issue as being irrelevant. My road to Damascus moment came with the excellent talk at last year’s EAF by Professor Arthur Frank, from Drexel University in Philadelphia.
Professor Frank highlighted growing evidence that links ingested asbestos to cancers beyond the respiratory system. These include ovarian cancer, peritoneal mesothelioma, kidney cancer, and various gastrointestinal tract cancers (esophageal, stomach, and colorectal). All of this evidence is supported by epidemiological studies and meta-analyses.
Frank also identified that asbestos fibres have been found embedded in numerous body tissues, demonstrating migratory behaviour – for example, crossing the bowel wall, diaphragm, and even the placenta. He also noted that early-onset colon cancer was increasing, and an area of real concern.
There is an obvious source for these ingested fibres. When we inhale in a contaminated environment, some fibres are trapped by the natural defences of the body and swallowed. But while this would contribute to an exposure pathway, asbestos cement water pipes represent a very persuasive alternative angle.
Most in the UK probably aren’t even aware we have asbestos cement water pipes, and, again, it’s something that I firmly believed was a non-problem. But we do have them. When you consider that they’re typically 50-100 years old – and you see what a cement roof looks like after 50 years – ignorance isn’t really an option.
The USA tends to lag behind in asbestos regulations, but it’s way ahead on regulating asbestos in water. The Environmental Protection Agency (EPA) actually has a limit: seven million fibres per litre. They recognise that if this is a problem it is a genuinely big one, because as Frank revealed, there are more than 992,000km of asbestos cement water pipes in the USA alone.
This is a truly huge length – enough to stretch nearly 25 times round the world. Testing has shown fibre levels in drinking water ranging from hundreds of thousands to over a billion fibres per litre, clearly far exceeding the limits. But beyond the USA, I am not aware that much testing is done.
Julian Branch, an award-winning Canadian investigative journalist who has spent most of his career at The Canadian Press, is far from being behind the curve. He has been investigating this issue for around 10 years. While the USA has some sense of the scale of its problem, Canada is only beginning to study it, with data limited to isolated cities and districts.
The UK, by contrast, doesn’t even formally recognise the issue. Some global figures exist, but as one UK water utility told me, asbestos cement pipes were installed before legal requirements for asset registers, so their exact extent is unknown. Julian Branch estimates there are roughly 35,000 kilometres of asbestos cement pipes in the UK, 40,000 kilometres in Australia, and hundreds of thousands of kilometres across Europe.
It’s interesting to look at a couple of specific regions in the UK, which get their water supplies from Dŵr Cymru (Welsh Water) and United Utilities (broadly the NW of England). Freedom of Information requests reveal that in Wales, asbestos cement pipes comprise 13.1% of the drinking water network. But in line with our understanding of the life expectancy of these pipes, they are responsible for 43% of all the country’s breakages and repairs.
Where Dŵr Cymru seems to know to the kilometre how much asbestos it has in its network, United Utilities was much more uncertain:
Almost all asbestos cement pipework was laid before the legal requirement to keep an asset register for asbestos-containing materials. Also, as almost all of this pipework was laid in the mid-twentieth century and the pipes themselves are buried, our records are incomplete and only updated as work is carried out.
Having said that, we estimate that we currently have approximately six and a half thousand kilometres of asbestos cement main [sic], which is approximately 15% of our water network.
The condition of these pipes in the North West is clearly rapidly deteriorating, with the proportion of breakages relating to asbestos cement increasing 35% in the last five years:
| 2020-2021 | 2021-2022 | 2022-2023 | 2023-2024 | 2024-2025 | |
| Incidences | 1353 | 1625 | 1691 | 1895 | 1803 |
| % of total | 29.8% | 39.6% | 35.3% | 41.6% | 40.3% |
Similarly to what the figures show in Wales, it is notable that in 2024-25, despite asbestos pipes making up approximately 15% of the United Utilities network, they accounted for 40.3% of breakages.
The fact that the USA of all places is so far ahead of the rest of the world in regulating asbestos in water is uncomfortable, and deeply ironic given its reluctance or inability to ban the material. Julian Branch notes that the issue has been repeatedly highlighted in the US since the 1980s. A 1985 EPA study on the subject concludes: “Asbestos has a definite potential for human carcinogenicity by ingestion.”
Cast your mind back to Professor Frank’s assessment of the academic literature: there is growing evidence linking ingested asbestos to cancers beyond the respiratory system (including gastrointestinal cancers), and there is significant evidence of the migration of fibres. Now consider the alarming statistics highlighted by Julian:
So how does this affect us on this side of the pond? Just as there is no difference between UK, European and North American lungs, one would imagine that our gastrointestinal tract is going to react to carcinogens in a pretty similar way.
Cancer rates in the UK are widely available, and from them we can see that gastrointestinal cancers are on the increase here, too. If we look at colonic cancer in England we can see a 3% rise in the incidence, which compares with a 27% drop in rectal cancer (my understanding is that the former is linked to ingested asbestos more strongly than the latter).
If we look at Wales over a similar period we see a 17% increase in colon cancer. Why would we see any difference between these two neighbouring and largely similar nations? One reason could be because of the water.
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| Michal Hájek et al. | East Devon Water Softeners |
These two maps are quite revealing. The first is a map of the groundwater pH levels across Europe, with acidic (low pH) in red, and alkaline (high pH) in blue. Pick out Wales and you will see that it has strongly acidic ground water. You will also note that while the majority of England is quite strongly alkaline, the North West is similar to Wales. The second map shows how ‘hard’ the UK’s water is. Hard water is packed full of minerals that tend to leach out, hence the furring of pipes and appliances.
You can see the two maps show a broadly similar pattern, but why are either of these things relevant? For one, asbestos cement is itself alkaline, and therefore vulnerable to acidic attack. Secondly, soft water is less saturated by minerals, so it tends to do the reverse of hard water: dissolving minerals from the structure of the pipe, a process referred to as soft water attack.
For the century that some asbestos cement pipes have been underground, they’ve endured the natural friction of billions of litres of water flowing through them. However, in Wales and the North West of England, asbestos is also vulnerable to being dissolved through both direct acidic attack, and softwater attack.
This doesn’t just present a plausible explanation for the high rate of pipe failure in those regions, but it would also increase the likelihood of a high concentration of asbestos fibre being present in the water.
It’s interesting to compare a region with different groundwater qualities. Severn Trent supplies a broad stretch of central England – from the Bristol Channel up to the Humber – where the water tends to be more alkaline and harder. It told me that only 7.8% of its network is made up of asbestos cement pipes, and that those account for just 2% of total failures.
Julian Branch also highlighted an important factor noted in an article by Hu and Hubble in the Canadian Journal of Civil Engineering: heavy clay soils. While clay itself doesn’t directly affect water pH or hardness, it does expand and contract with very wet or very dry seasons. It would be fascinating to see how pipe breakage rates respond in a record-breaking year like the one we’ve just experienced.
Copyright Julian Branch
With all this in mind, places like Bellevue in Washington State would seem to have the perfect storm of conditions for high asbestos pipe failure rates and water contamination. Some 40% of its water pipes are asbestos cement, and it has particularly soft water. This catastrophic failure is not a rarity.
As all three UK water companies I contacted told me, testing for asbestos is not required, so they don’t do it, and I doubt they are actively filtering fibres. There is, therefore, a good chance that asbestos is present in much of the UK’s tap water. And even if ingesting this poses an uncertain risk, both Arthur Frank and Julian Branch raised another point: the millions of fibres in tap or shower water will be left as a residue when the water dries.
I’m only just becoming aware of this issue, and while the statistics are not yet 100% definitive, there seems to be enough evidence to take the possibility of a risk posed by water supplies very seriously. The precautionary principle, normally adopted in Europe and which the USA appears in this case to follow, seems an entirely sensible approach. If this is a problem – and the evidence suggests it might be – it could be a big one.
Special thanks to both Julian Branch and Professor Arthur Frank for their help with this article.
Written by Nick Garland on Thursday July 17th 2025
I thought I would return to this subject before the summer holidays – a period when, unlike the rest of the country, we become incredibly busy. It remains a live issue on site, with some Health and Safety Executive (HSE) inspectors from a few areas of the country insisting with fervour that it’s mandatory to measure air flow on a negative pressure unit (NPU) before any licensed job.
That’s at odds with my assessment (following my recent strawpoll) that only 40% of licensed asbestos removal contractors (LARCs) use hand anemometers at all – and most of those not because they see any value, but because their local inspector insisted on it.
In my last post on this subject, I went back to the Approved Code of Practice (ACoP), and asked “Why are we doing this, and why is it important?”. In my view, only when you understand this can you make the judgement calls that the real world forces on you, when reality doesn’t quite fit what someone wrote 12 years ago, hundreds of miles away.
This time I will summarise some of those thoughts, show how data from the coal face calls the tests we do into question, and discuss what we really should be doing.
To go back to the very basics, we’re talking about the enclosures that operatives use to safely contain asbestos fibres and other traces of the material when working on a licenced removal job. The requirements for these are that they contain the hazard, and that they minimise the exposure for the operatives working within. We all agree that NPUs are critically important, as they underpin most of the controls that keep asbestos operatives and those immediately outside an enclosure safe.
NPUs – negative pressure units – do exactly that. They apply negative pressure, so that any damage to the enclosure results in clean air leaking in, rather than contaminated air leaking out. Also, clean air rushes in to replace the contaminated air they suck out and clean, which means that the operative is protected by a constant dilution of the contaminated atmosphere.
To underline their importance, paragraph 395 of the ACoP states:
Before starting work in the enclosure, a thorough visual inspection and smoke test must be conducted to check the enclosure’s integrity. The filtered air extraction equipment must be tested to ensure it is achieving negative pressure and the required air change rate.
Note the word ‘must’ that I underlined. Guidance very rarely uses such strong words – and when it does, it indicates that something is mandatory. But while it tells us what we should be testing for, it doesn’t tell us what the test itself should be.
Let’s look at some of the other wording. We are testing to ensure ‘negative pressure’, and that ‘required air changes’ are achieved. Required air changes is a rough measure of the dilution I mentioned above. Elsewhere in guidance it tells us that in the UK we should get at least eight air changes per hour (ACH) – that means simply you need sufficient NPU power to replace all of the enclosure’s air eight times every 60 minutes.
Negative air pressure means that the atmospheric pressure inside the enclosure should be lower than outside. In fact, it should be at least five pascals (5Pa) lower.
As I mentioned above, some HSE inspectors are insisting that NPUs MUST be tested using an anemometer or an onboard airflow meter. Their interpretation of the above guidance is that ‘test’ means to test how powerful the negative pressure unit is, and that a handheld anemometer should be used to do this.
You’ll have to read my earlier article for my reasons why I think these are inappropriate devices for the rough and tumble of site life. In this post I wanted to add some interesting data to illustrate my point.
The data in the table below was provided by a skilled (specifically trained) engineer on various sites, using an expensive calibrated anemometer – significantly more high-end than the ones typically used by LARCs. The equipment has been calibrated within three months of the test – and kept carefully off-site in between. The tests were repeated more than once in each setting and using different techniques to compare.
| NPU Ref | DOP Certified Airflow * | Onboard Airflow gauge + | Standard 5pt Anemometer Reading ** | Exhaust Anemometer Reading ++ | Spread (overall) DOP vs Lowest Site Reading | |
| Difference highest and lowest value | % | |||||
| 001 (1st Reading) | 5860 | 5301 | 4278 | 3922 | 1938 | 36.56% |
| 001 (2nd Reading) | 5860 | 5180 | 4758 | 4490 | 1370 | 26.45% |
| 001 (3rd Reading) | 5860 | 5332 | 4490 | 4745 | 1370 | 25.69% |
| 002 (1st Reading) | 2085 | 1796 | 1848 | 2047 | 289 | 16.09% |
| 002 (2nd Reading) | 2085 | 1821 | 1833 | 1992 | 264 | 14.50% |
| 002 (3rd Reading) | 2085 | 1927 | 1748 | 1935 | 337 | 17.49% |
| 003 (1st Reading) | 2450 | 2076 | 1095 | 1315 | 1355 | 55.31% |
Notes to the table:
As you can see there is a massive range of values. Note that readings – whether the on-board flow meter, the standard 5pt anemometer test, or the exhaust reading – swing enormously from moment to moment.
It is arguable that the DoP-certified test should be the most accurate, as it is done on a test rig, but this consistently gives a higher reading than either the onboard flow meter or either of the anemometer tests. In one case the DoP-certified value was stating a performance:
The hand anemometer readings swung between 5-11% when repeated.
Speaking as a scientist, any test that gives us this kind of range in our results is close to useless. But importantly, in any case this is a test of how powerful the NPU is, not what the ACoP says we must test for – negative pressure and air changes achieved.
Why is that relevant? Even if we decide that we can accept a swing of 20% and we should just pick an average, all this result would do is indicate ample airflow. But if there is air getting in somewhere else (a leak in the enclosure, big or small) you won’t have adequate negative pressure. Similarly, while we may be drawing out and cleaning lots of air, a poorly-designed enclosure will leave pockets of still air that’s not being cleaned at all.
As I said in my previous post, by testing a feature of good enclosure design, rather than the outcome we’re trying to ensure, we have gone down an unnecessary rabbit hole. And a warren that is costly, time consuming and potentially very misleading.
Let’s look again at what we are trying to achieve:
Impose 5Pa of negative pressure
Good airflow is essential for negative pressure, but in isolation it tells us little about whether we have achieved it, so how can we test for it?
There is a ready reckoner for 5Pa of negative pressure. If you balance the enclosure (air in and air out is roughly equal), and the flap deflection on your main air lock is around 250mm, you will have achieved approximately 5pa.
However, if the word ‘test’ in the ACoP requires us to be more scientific than this, you can actually measure negative pressure easily. Dwyer pressure gauges that accurately state what the pressure is are inexpensive, very simple, and robust. Simply tape one to the side of the enclosure and it will compare pressure inside and out. And what’s more this doesn’t leave you with a single reading taken at the time of the smoke test – it gives you constant monitoring.
No dead spots
Remember we need to ensure there are no dead-spots, and therefore no highly contaminated pockets of air. Simply measuring how impressive the airflow is at the NPU tells us nothing about how successfully we are cleaning and diluting the air. The only way you can actually test for sufficient air changes is by the ‘old fashioned’ smoke test. You can actively see the smoke moving, and can redesign the enclosure to make sure there are no dead spaces.
Even if the mandated eight air changes per hour sounds like one change every 7.5 minutes, we shouldn’t think that all smoke will be gone within that timeframe – dilution just doesn’t work like that. When you can no longer see any smoke, you’re getting an indication that you’re heading towards a complete change of the air.
Nearly all contractors use a minimum of 10 ACH, and often quite a bit more. Is it tremendously important that you are achieving 8.2, 9.7, 10.4 or 15.1 ACH per hour? I would argue that it’s not. In fact my position is firmly that nominal ACH is not a useful test of the effectiveness of our controls at all. It’s more important that you know there are no dead spots, and that smoke does indeed clear from all areas.
As I said in my previous post, we can likely achieve all that we want by having NPUs that are capable of drawing air to the tune of about 10 times the total enclosure volume. But the only way to test we’ve actually met the requirements in a balanced enclosure is:
As I hope I’ve explained, this is an area of regulation and guidance that is poorly understood and often (in my opinion) blindly and incorrectly enforced. The tests some HSE inspectors are insisting on indicate some things, but they don’t specifically tell us if we’re meeting the requirements of the guidance. And as is always the case, if we’re falling short of the guidance, we could be exposing operatives and building users to risk.
As with my earlier post, I’m hoping to stir up a discussion about the fundamentals of enclosure airflow. You might agree or disagree, but please get in touch to tell me why, so we can all learn and get better at what we do.
Written by Nick Garland on Friday May 23rd 2025
For years the FAAM conference has been a mainstay of the autumn events calendar. This year it moved to new spring dates, and what a fantastic event it turned out to be. It’s hard to summarise such an excellent conference in one blog post, so I’m going to focus simply on the bits that blew me away. But first, a mention that next year’s FAAM is likely to be at the end of April – watch this space for updates.
The first day’s amazing morning session was kicked off by keynote speaker John Cherrie, who asked “how did we get here?”, and more importantly, “where do we go next?”. Drawing on his lifetime of work modelling asbestos exposure, he provided insight into where we should put our policy effort.
Professor Cherrie explained how the presence of asbestos and its removal are complex, but the resulting exposure can be modelled. This lets you compare likely exposure among building users, for example, in buildings that contain asbestos, when asbestos is being removed, or when this work has been finished. You can also of course factor in exposure in the asbestos workers tasked with removing the material.
Models also let us compare with the dangers of doing nothing (i.e. manage in situ), and only dealing with asbestos when the building is at the end of its life – typically when it is 100 years old.
John went into a huge amount of detail, exploring predicted exposure for groups including teachers, maintenance workers and firefighters. He looked in more detail at removalists wearing respirators, but also the potential risks to those nearby during and after removal works. The key takeaway? We can expect around double the asbestos exposure if we do nothing with a building, compared to what happens if we remove its asbestos.
Gillian Nichols of the Health and Safety Executive (HSE) presented insight from the Great Britain Asbestos Worker survey – an astonishing, unique resource. For 54 years the HSE has been following up with those exposed to the material. From the top, the survey tells an interesting story of shifting understanding and priorities: at first it tracked asbestos manufacturing workers, then insulators, and latterly those exposed through removals.
The UK regulators showed incredible foresight to introduce this only a few years after the UK started regulating asbestos and a full four years before the HSE even existed! The fact it has been maintained for more than 50 years is deeply impressive, and has resulted in a superb resource.
Gillian shared some highlights from the project. Over time, more than 120,000 workers have completed at least one of the questionnaires, and granted the HSE permission to follow up with the NHS and their health records. Interesting nuggets of information ranged from the time spent in an enclosure per week having doubled since the early 90s, to the fact that smoking among asbestos workers is nearly triple that of the general population.
When everyone in the asbestos industry knows how smoking has a multiplying effect on mesothelioma consequences, this last is a stark statistic, but it’s borne out by disease numbers. Asbestos workers are more than 13 times more likely to die from mesothelioma than the population at large. But they also seem more susceptible to a whole range of other cancers. Lung, stomach, kidney and rectal cancers are all from 1.5 to 2 times more common. If this isn’t a wake up call to asbestos workers to take removal methods more seriously, look after their respirators – and be more diligent even with shaving – I don’t know what is.
One last slide from Gillian really caught my eye, illustrating the unsurprising correlation between mortality and the length of time spent in this hazardous industry. But the statistics also show that our regulations are having an effect. Those who began in the industry since the 1990s (around the advent of wet stripping), have mortality rates 10-fold lower than those who started out in the earliest years of the industry.
With all that’s known about asbestos and asbestos use, you might think we have a definitive definition for what it is. It’s surprising when you explain to those outside of the industry that’s not strictly the case. Thus doctor Andrey Korchevskiy provided a though-provoking conclusion to the mind-blowing morning session.
Those of you who have experienced Andrey talking at FAAM before will know that the fast pace and sheer mountain of information that he presents is astonishing – and just before a break might have been ambitious for the organisers. But the clarity and inescapability of his argument was clear.
Dr Korchevskiy demonstrated how the bio-persistence (how long a fibre can last in lung fluids), rigidity and smoothness of fibres maps incredibly closely to the lifetime death stats that we have been measuring for decades. This correlation explains why we know that crocidolite and amosite (both very rigid) are significantly more hazardous than chrysotile.
More than that, it can be used to predict when non-asbestos fibres might become mesotheliomagenic (likely to cause mesothelioma). For example, fibre dimensions, bio-persistence and rigidity can be used to predict whether carbon nanotubes can cause mesothelioma.
For decades we have struggled and failed to absolutely and definitively define asbestos. Maybe in mesotheliomagenic we have a term that can be linked more to health outcomes, than the geological origin of the original fibre.
The afternoon commenced with a heart-rending talk by mesothelioma sufferer Sue Farrall, who provided a timely reminder of why so many of us choose to work in this field. She explained her experience: an incredibly slow diagnosis where the possibility of mesothelioma was just not considered, despite her having classic symptoms, because she didn’t fit the profile of an elderly man that has worked with asbestos.
Sue shared her story, from the huge operation she underwent to remove the entirety of her pleural membrane and diaphragm, to the quite astonishing 29-plus mile walked marathon she completed despite being out of breath after two flights of stairs. Amazing.Dr Yvonne Waterman of the Global Asbestos Forum gave us all an update on what is happening around the world – underlining why her organisation has changed its name to the Global Asbestos Forum, rather than ‘just’ being European.
Alas, there was not much in the way of good news. Yvonne explained the likeliness that the EPA in the U.S. would be reduced to a mere token organisation, and relayed how government funding for the South African asbestos cement removal programme was being embezzled. Even the excellent Flanders declaration that all asbestos in schools would be removed – and that the government would pay – has apparently merely led to a doubling of project costs. How depressing.
The bright spark in Yvonne’s talk was the launch of her new magazine. At 87 pages, this has been no small undertaking – and it has been completed in this same classy style that is the hallmark of everything she does. Filled with fascinating articles, from leading lights in the industry, and all with the amazingly beautiful pictures taken by Tony Rich. If you haven’t seen a copy yet I would get on the mailing list before they all go: [email protected].
The day’s final session was one I’d particularly been looking forward to. Phoebe Smith of the HSE managed to overcome what might have been considered the graveyard slot; the end of a very long day where your brain just can’t absorb any more. Her energy was astonishing, carrying her around the conference room while she involved everyone, blowing away all the cobwebs in no time.
Phoebe is a clinical psychologist, and the human factors technical lead for the HSE. I can almost hear you ask what ‘human factors’ is: it’s essentially why people do (and don’t do) what you and your procedures would ideally like them to. This is a constant complaint in the asbestos industry, and Phoebe’s talk gave me the beginning of an insight into where we have been going wrong – for probably 20 years.
I’m still reflecting on what I learned, but Phoebe turned much of what we do upside down by explaining the importance of when NOT to have a procedure. She explained the need to pick your moments, and only put the effort into a procedure where the risk and consequences warrant it, because to get it right is a much bigger task than you might think.
So, when the situation warrants it, how do you create the ideal procedure – one that people will actually follow? Phoebe showed how it must work:
Are all overlapping, and creating the ideal procedure means distilling them all down in a way that works for all groups. Phoebe’s work is insightful, and it feels like something from which we can all learn a huge amount. I hope I’ll have the opportunity to engage with her more in the coming weeks and months.
So many highlights, and as the more observant among you will note I’ve only got to the end of day one! Even then I haven’t had time to mention Garry Burdett and James Staff’s comparison between electron and phase contrast microscopy (PCM), and really how closely they can perform. Fortunately this is likely to be the subject of a FAAM webinar in the coming months.
You’ll notice I also haven’t had time to summarise day two, which featured a comparably stellar lineup of speakers, covering a similarly stimulating range of subjects. All in all this really was a fabulous conference. I’d like to extend a huge thanks to the FAAM conference committee for organising it, and most especially Sara Mason. Sara, long-serving chair of that group, and longtime FAAM committee member, is stepping down. As swan songs go, this was fantastic.
Written by Nick Garland on Thursday April 24th 2025
Leak testing is coming back on the Health and Safety Executive (HSE’s) agenda. That means if you’re a LARC, a consultant that manages projects, a client that commissions projects, or a principal contractor that controls sites with asbestos removal projects, it’s firmly back on your agenda too.
This is one of those tests that has always been a requirement. I recall running hundreds of leak tests in the early part of my career, but then we largely stopped. There was no regulatory change, no guidance to imply that we should stop; we just stopped. Well, mostly: they’re still done at some major sites such as nuclear, and in particularly well-managed NHS trusts, but elsewhere they’re vanishingly rare.
However, the rules are pretty clear.
Paragraph 316 of the approved code of practice (ACoP) states that, “where an enclosure is being used to comply with regulation 16 [the duty to prevent or reduce the spread of asbestos], employers should make sure that:
And then Paragraph 416 adds that, “air monitoring to reduce risks from spread of asbestos is required to:
There really is no wiggle room there. And it doesn’t just apply to internally vented NPUs; it means genuine leak tests adjacent to the enclosure.
Interestingly, paragraph 416 goes on to require that you “measure background fibre levels inside the enclosure when the asbestos work is complete, to ensure that it has been thoroughly cleaned and decontaminated before dismantling.”
This of course is the root of the four-stage clearance. The document goes on to talk about that type of test a lot more, but leak testing is given the same level of ‘mandatory-ness’ as the clearance air test – and yet, we just stopped doing it.
Why, you ask, is it coming back on the agenda now? Because there will be a new Asbestos Network (AN) guidance note on the subject. Thankfully this is going to continue in the new style, with clearer and more forceful language. There’ll also be a a genuine attempt to address the reasons why we stopped in the first place. The new approach isn’t so much ‘them’s the rules – get on with it’, but more ‘here’s why, and this is what you can do to address it’.
The guidance will also address some of the blockers, or rather the likely main blockers as to why we don’t do leak tests anymore:
As with other recent AN documents, there will be a box spelling out the Construction (Design and Management) (CDM) regulatory duties relevant for clients, principal contractors and designers. If the personal monitoring guidance is anything to go by, when considering leak testing – the language will be very firm.
In almost all circumstances, leak testing is required for asbestos enclosures. Testing must be daily if the vicinity is occupied, and ‘periodic’ if only the removal team are on site. We’ll get some guidance on what periodic actually means, but my understanding is it’s likely to be more than once per week. There’ll also be practical guidance, but short-term jobs (one-day) are not exempt, and neither are dusty demolition sites.
It’s potentially less clear-cut what constitutes vicinity. It’s a tricky subject, as it will always be site-specific, and must be considered as part of the project design. Examples will be given, but it is essentially connected areas. As such, enclosure walls, seals and negative-pressure exhausts are all obvious contenders.
Then we get to the less obvious and more challenging: connecting voids. Air conditioning could, for example, form a tunnel to lots of different areas. Removal of an asbestos insulating board in a bathroom riser on the second floor would be directly connected to the first and third-floor bathrooms.
In short, anything deemed as ‘vicinity’ must be tested.
I’m focusing on the leak testing guidance, but the document itself will be broader. It lines up the design of enclosure, air management, smoke test and leak test as part of the standard planning process.
In other words, we all design the enclosure layout and the air management of that enclosure. At the same time we must be planning how we are going to test the effectiveness of that by considering the smoke and subsequent leak testing. As a manager you will need to assess where smoke might leak from and into – and ensure that access is available to check those areas.
This means we’ll need to start asking questions like “Where does that riser go?”, and “How does the supervisor get access to check the second-floor bathroom for escaping smoke?” These will become your plan for the leak testing: the guidance will call for both of these to be documented in the risk assessment and method statement.
The very fact that the AN is producing a guidance note on the subject means that HSE inspectors will take notice, and enforcement will likely follow. This should also give the same responsible LARC some reassurance that it will be a level playing field.
Coincidentally, this completely lines up with the recent HSE summit on research priorities. One of the top contenders for HSE and industry-led studies was a comparison between fibre levels in buildings before, during, and after asbestos removal. It seems that if leak testing data – and the associated reassurance tests post-removal – were recorded in the right way, LARCs could contribute massively to this investigation.
There is time to plan. The guidance is still in draft, and you may very well already be compliant with the ACoP because you never did stop testing. But if this has fallen off your radar, now is the time to start looking at your policies and procedures so that you are ready to record the data and react appropriately to the results you get. This is especially the case with your site paperwork – can you even sensibly record the findings?
For those of you that use third-party software to record site paperwork, now is the time to ask the developer whether or not they will be ready to support you in this change that is not a change.
The Asbestos Network is always keen to get feedback on draft guidance, so if you can contact me HERE with any thoughts, recommendations or pitfalls to avoid it would be very much appreciated.
Discover more about Assure360 Paperless – read about the app here, or get in touch for a free demo.
Written by Nick Garland on Thursday March 27th 2025
I’m a huge supporter of the Health and Safety Executive (HSE), and its work is normally excellent. However I wanted to urgently flag a concern I have over its ‘new’ HAVS calculator, which you can download from the HSE website.
Instead of the space for the make and model number, It now has a drop-down selector for equipment, indicating a range of vibration for each. This range is based on extensive testing that the HSE has done on a wide range of tools and a wide range of activities. It has even calculated the typical vibration magnitude (the 75th percentile). The idea is that you can use this information to critically assess what the manufacturer tells you.
So far so excellent. But crucially, the spreadsheet picks this typical figure and slots it into the calculation for you. Unless you put your own figure in based on your own assessment of the actual tool you are using, the calculation will be done using the HSE’s ‘recommended’ value.
If your tool happens to be at the high end of the range, you could be massively exposing the worker.
The image I use is a worked example for a reciprocating saw. The typical value (18m/s2) was accepted – but the tool picked up (and the task undertaken) has a magnitude at the top end of the range (27m/s2). A ‘nice safe’ 32-minute trigger time was recorded ‘well away’ from the exposure limit value (ELV). The reality would be a breach by nearly double.
I don’t like to criticise the HSE which, as I say, is normally excellent. But it seems as though this spreadsheet has been broken by someone trying to be helpful, and I’d recommend using it with extreme caution for the time being.
Written by Nick Garland on Thursday March 27th 2025
I was talking to an industry professional recently. When asked “Why do we measure airflow?” his response was “Because the guidance tells us to”.
For me that said it all. We know it’s important, but not any of the fundamentals that underpin it. Airflow is really rather important, and for very sensible reasons. And the guidance tells us to test. But these are two very different things.
My approach to asbestos regulations, the Approved Code of Practice (ACoP) – and all guidance – is always to ask “Why are we doing this, and why is it important?”
Only when you understand this can you make the judgement calls that the real world forces on you, when reality doesn’t quite fit what someone wrote 12 years ago, hundreds of miles away.
Let’s start with the fundamentals.
Disturbing asbestos is very dangerous because inhaling fibres has a disease risk where there is no safe limit. Removal of asbestos inevitably liberates these fibres into the atmosphere where they can be breathed in.
We carefully design methods so that we minimise how many fibres are released. We build enclosures so that any fibres that are released are contained, and can only affect a small area. We apply negative pressure to the enclosure so that if there are leaks, then clean external air leaks in – rather than contaminated air leaking out. This is achieved by drawing air out of the enclosure using Negative Pressure Units (NPUs), and scrubbing it through HEPA filters.
So, we have created a hermetically sealed bubble that we are asking workers to enter to do the work, potentially exposing them to fibres. The methods should reduce the fibre release, and the workers have respiratory protective equipment (RPE). But as there is no safe limit, and respirators are the last line of defence, we have to do more.
Helpfully, those NPUs we were using to apply negative pressure have another very useful trait. They remove contaminated air, and replace it with clean air. If the enclosure is carefully designed there will be a constant flow of clean air to all areas, so asbestos fibres are drawn away from the worker and there are no stale air dead spots. The contaminated air is being constantly diluted.
So, airflow is critical, as it underpins all of the controls:
How do we ensure we get it right?
Paragraph 395 of the ACoP states:
Before starting work in the enclosure, a thorough visual inspection and smoke test must be conducted to check the enclosure’s integrity. The filtered air extraction equipment must be tested to ensure it is achieving negative pressure and the required air change rate.
There’s a need for some interpretation first. ‘Required air changes’ is a rough measure of the dilution I mentioned above. In the UK this is eight ACH – that means you need sufficient NPU power to replace all of the air, eight times every 60 minutes.
It doesn’t quite work that way – but that’s how it is sold. Think homeopathy and that’s how much it lines up with reality. The industry standard, though, is at least 10ACH, and often many more.
The smoke tests mentioned in the ACoP are fairly straightforward: fill the enclosure with smoke, and check outside to see if any of it leaks. If not, we have a sealed enclosure.
Now the last and most crucial bit: the NPU should be tested to ensure it is achieving negative pressure, and that it is achieving those air changes.
This word ‘tested’ has been taken to mean that we should actually measure how much the NPUs are ‘sucking’. Once we have established definitively that the NPUs are pulling at least eight times the enclosure volume, then all questions are answered.
Some HSE inspectors are even insisting that NPUs MUST be tested using an anemometer or an onboard airflow meter. An anemometer is a handheld device that is essentially a fan with an electronic read-out. Place the fan near the NPU head and it will tell you how fast the air is passing through it. Get several readings, take an average, and multiply by the area of the pre-filter and we have an answer.
Well not really, because:
And while it sounds easy, even measuring the area of the pre-filter is near impossible. The guidance says you should measure height by width, but the reality is that those pesky cross hatches will reduce it somewhat. If you look closer, you will see there are vertical veins – the matting actually increases the surface area dramatically. The veins also create turbulence, causing further uncertainty.
Image – Beacon International.
In any case, all NPUs are tested by trained professionals at the service company every six months, using equipment that is kept in lab conditions. Are we really saying that a supervisor on site with a one-year-old anemometer from the van is better than that?
I have seen data where two readings were taken on site by two different people on a single NPU (moments apart). One set differed by 14%, and a second pair differed by a whopping 30%. Even the guidance provided by the HSE says that handheld anemometers typically overestimate by 10%. If we’re measuring a critical value, overestimating is not something that we should be doing.
I’m not a fan, as you can probably tell.
Onboard flow meters are better, as they measure internally from a static position. But just like the hand versions, they are subject to being knocked and damaged by the rough and tumble of life on site.
Even without these concerns, does this testing guarantee we’re achieving what we want?
Not necessarily. You may have ample airflow from your NPUs, but if there is air getting in somewhere else (a leak in the enclosure, big or small) you won’t have adequate negative pressure. Similarly, while we may be drawing out and cleaning lots of air, a poorly-designed enclosure will leave pockets of still-air that’s not cleaned at all.
By testing a feature of good enclosure design, rather than the outcome we’re trying to ensure, we may have gone down an unnecessary rabbit hole. And a warren that is costly, time consuming and potentially very misleading.
Let’s look again at what we are trying to achieve:
Impose 5Pa of negative pressure
Good airflow is essential for negative pressure, but in isolation it tells us nothing about whether we have achieved it, so how can we test for it?
There is a ready reckoner for 5Pa of negative pressure. If you balance the enclosure (air in and air out is roughly equal), and the flap deflection on your main air lock is around 250mm, you will have achieved approximately 5pa. There are too many vague terms in this for my liking, but as it stems from an HSE research paper, it does have some authority.
You can however measure negative pressure easily, by using a magnehelic differential pressure gauge (often known by the company that makes a lot of them: a ‘Dwyer Gauge’). These are inexpensive, very simple devices, yet they accurately state what the pressure is. Simply tape one to the side of the enclosure and it will compare pressure inside and out. And what’s more this doesn’t leave you with a single reading taken at the time of the smoke test – it gives you constant monitoring.
No dead spots
Remember we need to ensure there are no dead-spots, and therefore no highly contaminated pockets of air. Simply measuring how impressive the airflow is at the NPU tells us nothing about how successfully we are cleaning and diluting the air. On the other hand, a smoke test, done well, tells us quite a bit about this. You can actively see the smoke moving and can redesign the enclosure to make sure there are no dead spaces.
Eight air changes per hour
We must also achieve eight ACH. Dilution is a complex mathematical problem; just having eight times the enclosure volume in NPU power in no way predicts that we’ll reach the necessary figure. It also doesn’t mean we’ll be refreshing the enclosure air once every 7.5 minutes – dilution just doesn’t work like that.
Eight ACH means removing 13.33% of the air and replacing it with clean air every minute. If we assume that there is perfect mixing within the enclosure (very difficult to achieve), some of that air will be dirty and some will be clean. Very roughly, with some rounding, we get a ratio of dirty to clean air pattern that looks like this:
| Elapsed time (minutes) | ‘Dirty’ air (%) | ‘Clean’ air (%) |
| 1 | 86.7 | 13.3 |
| 2 | 75.1 | 24.9 |
| 3 | 65.1 | 34.9 |
| 7.5 | 34.3 | 65.7 |
These figures show that after 7.5 minutes, the first of your supposed ‘air changes’, you are only down to about a third of the original ‘dirty’ air. In fact, only after about 30 minutes – or four ‘air changes’ – are you anywhere close to getting rid of it.
So let’s go back to the smoke test. When you can no longer see any smoke, you’re getting an indication that you’re heading towards a complete change of the air. But again, you’ll never actually get there, because that’s not how dilution works.
Nearly all contractors use a minimum of 10 ACH, and often quite a bit more. Is it tremendously important that you are achieving 8.2, 9.7, 10.4 or 15.1 ACH per hour? I would argue that it’s not, really. In fact my position is firmly that nominal ACH is not a useful test of the effectiveness of our controls at all.
Having NPUs that are capable of drawing air to the tune of about 10x the total enclosure volume is the means by which we achieve all that we want. But the only way to test we’ve actually met the requirements in a balanced enclosure is:
Why am I going over this? Well, it’s all too easy once we have guidance, to focus on meeting the letter of that guidance. But as I said at the start, it’s important to ask why we’re doing the tests we do, and what we’re actually trying to achieve.
I’m hoping to stir up a discussion about the fundamentals of enclosure airflow. You might agree or disagree, but please get in touch to tell me why, so we can all learn and get better at what we do.
Written by Nick Garland on Monday February 17th 2025
Two connected events have caught my attention over the past few weeks. The first one I wanted to talk about is the continuing series of excellent FAAM webinars following the broad theme of the EU’s reduced Occupational Exposure Limit (OEL).
As a reminder, the OEL is the equivalent of our Control Limit. It’s reducing from 0.1 to 0.01 fibres per millilitre of air, and in a few years it’ll reduce further to 0.002. The most recent FAAM webinar addressed respiratory protective equipment (RPE), and asked whether it can cope with the ambitious new target.
That’s a key question if we in the UK are going to adopt the reduced limits – something the Health and Safety Executive (HSE) is actively considering. Garry Burdet, previously of the HSE and now a pivotal member of FAAM, joined Nick Baxter, the HSE technical lead on RPE and the Vice President International Society for Respiratory Protection (ISRP). Together they addressed why RPE performance is based on a complex web of international agreement (or the lack thereof).
It’s worth taking a step back to look at the basics. All masks come with an Assigned Protection Factor (APF), which is the assumed amount of protection that the mask can achieve. This is how APF is supposed to work: contaminants outside the mask will be reduced inside the mask by a factor of the APF. This HSE example (diagram) shows an environment where the exposure is 20, and the APF 10, thus the wearer’s exposure is reduced by a factor of 10, to 2.
In the UK, half-masks are assigned an APF of 20, while full-face powered masks (the ones we use in an asbestos enclosure) are 40. The air-fed masks we typically refer to as RAS masks have a whopping 2,000.
However, how well the mask delivers its APF is based on a number of factors:
Bearing this in mind, a full face mask can achieve an APF of 40, but if you don’t look after it, don’t keep it clean, or it doesn’t fit you perfectly, it won’t be anywhere near that.
Many of us on the crusty end of the industry will remember where we were when the APF for the standard issue full-face powered mask was lowered from around 1,000 to the 40 we accept today. For me it was a night job, where they were blasting sprayed insulation firebreaks.
This horrific wake-up call was prompted by the 1996 Howie research for the HSE, but Howie’s wasn’t the only team looking at this issue in the 1990s. All of the studies were ‘as found’ – essentially workplace observations on actual workers in the field. Around the world, individual teams designed their own approaches, leading to variations in sampling methods, training in mask use, exercises the subjects were asked to do, and different methods of testing the fit.
This led to a huge range of APFs assigned to given mask types around the world. As I mentioned above, in the UK the standard powered full-face mask for enclosure work has an APF of 40. The exact same mask in Scandinavia has an APF of 1,000.
Astonishingly, not every country requires face-fit testing for individuals. Therefore we have a situation where there is no international agreement on how effective RPE is, and some countries don’t even mandate a well-fitting mask.
The Howie research led to the UK’s comparatively pessimistic assessment of full-face APF, but also indirectly to most of the wet-stripping innovations that we now take for granted. In fact, the UK’s cautious approach to APF possibly explains why we have driven innovations on how to minimise exposure at source. It also might explain why European colleagues are less concerned about how the new OEL will impact their removal projects.
In other European countries, everything (including cement window sills and floor tiles) is typically removed inside an enclosure, but dry-stripping is the norm. Essentially, it doesn’t matter what the operative does, he’s protected by equipment which is assumed to have a higher APF than we give it in the UK. This raises important questions about the poor folk outside the enclosure – I’ll come back to that in a minute.
In the UK, what do we see when we test asbestos removal activities inside the enclosure? Assure360, as you may know, is the best mass data resource on this subject, with approaching 20,000 personal monitoring results. In the last year, 95% of results were, when calculated with an APF of 40, below the new EU OEL.
This is clearly very positive news. If the operative follows the method perfectly, and the mask fits, and it’s looked after, UK removal methods are probably adequate to deal with any reduction in the limit. But – and it is quite a big but – all personal monitoring is observed behaviour, and therefore conducted when the operative is working perfectly to the method: slowly and methodically.
If all our assumptions on the efficacy of the mask in the UK were correct, what would we see if the method wasn’t being followed precisely? For example, what if asbestos insulation board (AIB) was being removed dry, as it is in many parts of Europe? Exposure would be much higher, and the existing OEL would be breached – never mind the new one! You would have to have a VERY good mask to deal with that.
There is a second ‘but’: if the mask doesn’t fit well, or if the assumptions made in the EU that the mask in peak condition provides an APF of 1,000 are wrong, or if the mask hasn’t been looked after perfectly, the poor operative is going to be repeatedly exposed. In the EU, that coud be to extremely high levels.
Nick Baxter helped put all this in focus by reminding us that all RPE fails to danger. That’s why regulation and guidance prevent us from using RPE as anything other than the last line of defence, and why it rightly sits at the bottom of the hierarchy of control:
Considering the differing APF figures for the same items, and all the variables regarding how it’s used and maintained, the UK approach has to be the right one: assume that the APF is quite small, and therefore do as much as possible to minimise exposure.
That brings me neatly to what’s going on outside the enclosure, and a heads up that the Asbestos Network (AN) Technical Working Group (TWG) is taking another look at leak monitoring. Around the time that I was getting the RPE-related shock of my life, leak testing was considered part of most or all jobs. But now it’s a rarity: the preserve of nuclear sites and some NHS trusts, it seems. But the regulations haven’t changed: it was mandatory on a virtually daily basis in 1996, and it remains mandatory now.
The next AN appendix to the minutes will be clarifying this: really laying out when you need to do leak testing outside an enclosure. Fundamentally, it’s nearly all jobs, irrespective of duration. That ‘one-day’ domestic job falls under the umbrella, just like the demolition site.
Thankfully the AN approach is now much more practical than it was even a few years ago, as the group increasingly tries to analyse the blockers to a policy and address those. It’s asking questions such as how you do leak testing on a dirty site like a demolition, the practicalities of leaks on a short job, and even where you consider the vicinity of the enclosure to be, given that air can move through risers, ducts and the like.
As we all know, clients can be one of the biggest blockers if they don’t pay for the tests. Again this is recognised by the AN, and there will be extremely clear instructions to those in charge of projects regarding their Construction (Design and Management) duties on the subject.
The new guidance is probably a few months away – I’m predicting early summer – so there’s plenty of time for you to start thinking about it. Of course, Assure360 is already working on the subject, and our solution is taking shape for a release in the spring. As with everything we do, it will be done in the right way. That means keeping things easy for the supervisor and not adding to their day. Instead, everything will be collected as data, so you get the maximum benefit in the office.
Written by Nick Garland on Thursday January 23rd 2025
With the start of the year on us, I thought I would return to my favourite subject: exposure monitoring. Specifically, how we can understand it better, and get better value out of the effort we put into it. In this article I’m going to discuss strategies for exposure monitoring, and provide some tips that will – hopefully – make it easier.
Exposure monitoring was one of the areas that was dramatically changed by the Asbestos Network’s guidance on the subject, released over a year ago now. Let’s remind ourselves of what it said.
There are four different types of personal sampling that you can deploy:
But rather than just picking at random, you should be considering what your goal is: what are you trying to capture? The goals for all monitoring are derived from the regulatory requirements. These state that you must:
Helpfully the guidance states that one or more requirements can often be met from a single sampling exercise – i.e. you can use one test to cover off several goals.
One simple trick
So, here’s the first tip – when requesting personal monitoring, try to ensure that the test parameters do not disqualify it from one of the other categories.
The tightest rules are around four-hour Control Limit testing (the 4-Hr TWA). This requires a minimum of 240 litres of air, and a flow rate of between one and two litres per minute. Therefore a two-hour test at two litres per minute qualifies, even though it is not actually four hours long.
The key question is: ‘Do you know what was happening outside of this test?’ Was there no activity (for example, a lunch break), or more of the same (for example, you tested for two hours, but the work lasted for four)? Either way, we are allowed to make assumptions.
This simple trick will allow you to use that single result for the first, second and fourth test type, and all the goals outlined above. In fact the only scenario it doesn’t cover is a method where short-term exposure might be very high, even if when measured over a full shift it will be more moderate. For these less common situations you will have to resort to a short air test.
The maths remains a little tricky for completing the 4hr TWA calculations – but not for Assure360 users. We analyse the data you put in, compare it to the rules, and provide all the four-hour Control Limit results for you.
Using a risk-based strategy
Now it starts to get a little trickier. The age old ‘rule’ where you test 40% of all asbestos insulating board (AIB) jobs, 60% of all pipe insulation work, and 100% of sprayed insulation jobs is out, replaced by a risk-based strategy.
You might say that the old way was broadly risk-based – AIB is, after all, less risky than sprayed insulation. True, but now we need to go much much further.
While AIB may generally present less of a risk, there are wide variations within AIB jobs. Nailed AIB is riskier than screwed, for example, as the chance of breakage is much greater. Further, it’s more challenging to remove nailed AIB from a crawl way than when your operatives are standing firmly on the floor. In recognition of these variations, the guidance now says we need to treat all of these (and more) differently, and have a strategy to measure each.
The bad news is that this is very challenging if you’re having to record and calculate everything in Excel – it’s possible, but it takes skill and time. However, the great news is that it’s easily achievable if you’re an Assure360 user.
In the admin-free Assure360 approach, the supervisor records all exposure information in the right way, first time round. We know how many times Tom, Dick or Harry has been exposed to the removal of nailed AIB in a duct, or screwed AIB in a bathroom, or anything else. We also know exactly how many times a personal test has been recorded against that activity. It’s therefore a matter of moments to do the calculation, giving you a live assessment of current performance against your strategy.
Cover all activities
Back to the guidance, which states that all activities should ultimately be covered. That’s not just the situations we’ve covered above, it’s also waste runs, enclosure construction and deconstruction, visual inspections, fine cleaning, and everything else. These all need their own strategy that you must measure.
The Health and Safety Executive (HSE) recognises that this is a big departure from what we were doing before. The regulator has indicated that you should focus on asbestos removal activities first and get good data, before broadening out to all the other lower-risk activities.
Which leaves new activities – or as the HSE puts it, ‘novel removal techniques’. These are new-to-you methods where you don’t have much or any data. Again, these need special attention. More protective RPE should be selected, and then you need to test, test, test.
Again, this is very simple when you approach the exercise activity by activity. And Assure360 makes it even easier – our users have access to unique benchmarking data, where you get to see the results of nearly 20,000 personals. Even the brand-new GelCut technique for wrap and cut features in our data, with an average exposure of 0.03 fibres per millilitre.
The final element of your strategy is that it should take account of people, because people have the biggest impact on your carefully designed methods. An inexperienced operative – whether they are directly employed or a short-term worker (STW) – should be viewed with suspicion. I jest, sort of, but the point is that everyone new to you – or inexperienced with your procedures – must be targeted with additional personal monitoring.
With Excel this would involve an employee log, some with flags against their name, so you can drag in a ‘number of personals’ figure from other spreadsheets. But as you might imagine, Assure360 makes this easy. All new employees (including STWs) are automatically tagged as needing increased supervision. This (again automatically) plays out with the strategy reports, measuring your performance with up to the minute, live data from your sites.
Simple – like all the best solutions should be.
Don’t miss out on a system that simplifies personals and so much more. Get in touch now to arrange your free demo!
Written by Nick Garland on Friday October 4th 2024
We’re absolutely delighted to announce that Assure360 and ARCA are partnering to deliver better exposure monitoring for licensed asbestos removal contractors (LARCs).
This year’s ARCA AGM was concluded by chief executive Steve Sadley announcing our exclusive offer to help all of the association’s LARCs. In short – all ARCA members will now get free access to the Assure360 system to record personal monitoring results using a simple-to-use module on our compliance website.
As with all of our solutions, our personal monitoring module comes with the confidence of absolute expertise in the science behind it. Assure360 has long been at the bleeding edge of best practice for exposure monitoring, four-hour time-weighted average (4hr TWA), and exposure strategies. In fact, we were compliant with the latest guidance four years before it was written!
We understand that if software isn’t easy to use, it won’t work for our users, and we build that understanding into everything that we do. Assure360 is simple, not simplistic. Not only is the system intuitive, it does all of the 4hr TWA calculations for you – and it even gives you handy tips if you get confused with the numbers.
Once you’ve added the data, we provide insight in the shape of powerful reports – such as the duty of care report covering your workers. This helps you understand how much your staff have been exposed: all you do is pick an operative and click go. You’ll get the results in under a second.
We’re committed to our relationship with ARCA and its members, so the 100% free ARCA/Assure360 exposure system will continue for as long as you want it to. If you are a member of ARCA, in the next few days expect an email from Steve explaining the deal, what you can expect from us, and introducing our team so that we can help you with configuration and training.
While all of this is great, there is one extra part to the relationship: Satish Patel and his team of trainers will also benefit from access to the unique benchmarking report, built from all the exposure data in the system. And when we say all, it really is a lot! Assure360 is used by around 20% of all LARCs, and consequently has the best personal monitoring database in the UK. With approaching 20,000 personals and well over a million routine exposures on record, it provides the kind of insight that will help ARCA training be the best it can be.
We look forward to helping you get started soon. But in the meantime, please don’t hesitate to contact us to find out more about the partnership, or our other products like Assure360 Paperless – the original, the best, and the most popular solution for LARCs.
Written by Nick Garland on Monday June 24th 2024
May and June have been very busy for the Dev team at Assure360.
Hand Arm Vibration Syndrome (or HAVS for short) is often the subject of questioning from visiting Health and Safety Executive (HSE) inspectors, with under-pressure supervisors trying to explain how they measure and record exposure. Often the maths is too much, and the contractor gets a letter.
This brings us to the first new feature from our tech gurus: a brand new module for supervisors using the Paperless app. Our long-awaited HAVS solution is fast, efficient, accurate, and above all simple for anyone unsure about technology.
The system is based on our unique exposure solution, that has led to nearly 20,000 personals being added to the biggest database in the UK. In a nutshell, the office develops a library of vibrating equipment with its associated vibration magnitude. The contracts manager assigns the correct kit to be used on a project, and the supervisor just picks from that list in the app. Our system does all the maths, warning the supervisor if the lower action level has been breached – and again if we are getting close to the upper limit.
Simple – like all the best solutions.
The next new release is another in our suite of exposure hacks. The new Exposure Target by person report allows you to check whether you have targeted your individual operatives with enough personal monitoring.
One of the requirements of the new Asbestos Network guidance is that, while you need to monitor all operatives, some need to be targeted with more testing than others. Anyone with less experience – or a more ‘hurried’ approach to removal – gets extra attention. The new report tells you immediately if you’re on target for your own monitoring strategy, using data you’re already collecting in the Paperless app.
That’s what you see on the surface, but beneath the water there is a great deal of paddling. We take your existing targets for high risk activities, and work out the average. Next the system tots up the number of exposures for each person, and the number of personals that they have had in those activities, and compares this with the average. This gives you a percentage-of-target score.
If the person has been tagged with Enhanced Supervision, then the target is doubled – i.e. we demand double the personals as they are higher risk individuals. I know I get carried away on this subject, but this is the only route to compliance without hours of Excel data mining. Our neat solution gives you 100% compliance with 0% extra work.
Finally we have completed the second phase of our People module, giving you a 100% flexible training matrix. You decide what job roles exist in your company and what skills are required, and assign those to your employees. We then track what you’ve selected and tell you what’s in date, what’s not in date and what’s about to be out of date.
What’s more we can even track the difference between role-required skills, and those that the employee has that are above and beyond. In this way, you can choose to maintain these additional skills if you want.
Written by Nick Garland on Monday June 24th 2024
You might remember the gel-cut asbestos pipe removal technique that I wrote about in October last year. This brand-new approach is aimed at an age-old problem: how to make the removal of asbestos pipe insulation safer than existing methods. Last month, in my capacity as a FAAM Committee member, I had the great pleasure of attending a site on Guernsey to conduct a further FAAM and BOHS investigation into the method.
By way of a short recap, when faced with having to remove an asbestos-insulated pipe, licensed asbestos removal contractors (LARCs) conventionally have two options. The first is full removal, the second is wrap and cut. Both involve injecting the asbestos-containing material (ACM) with surfactant and carefully removing the now wet insulation. Full removal, as the name suggests, involves taking away and cleaning all of the insulation, leaving a bare pipe to be reused. It’s a laborious process that clearly involves risk of exposure.
If the pipe itself is redundant, you can use wrap and cut. Here you inject and clean short sections of insulation to reveal bare metal that can be cut. Intact sections of still-insulated pipe can be wrapped and disposed of. This process is much safer than full removal as it disturbs only a fraction of the asbestos material. But it’s still laborious, as you have to inject and carefully remove the insulation from the point to be cut. As with full removal, you must always stay vigilant for a dry spot that could lead to significant exposure.
This is where the new technique comes in. Using EasyGel Protect, workers fix gel pouches to pipes that have already been wrapped, then simply cut through the gel, the asbestos, and the pipe. The innovation is that the gel reforms over the blade, so that the operative is always separated from the asbestos. The gel captures the dust and the team simply seals the cut end of each section with a waste sack and moves to the next cut point.
Our earlier investigation in Somerset with Horizon Environmental gave very encouraging results. Both wrap and cut and the new gel-cut technique gave similar air test results of 0.03 fibres per millilitre (f/ml). But importantly, the new technique was twice as quick, so the operatives’ total exposure was halved.
Last month FAAM appealed for suitable projects on which we could repeat the exercise. We wanted to see whether the technique could easily be adopted by a new team, in a different setting, and still deliver the big safety benefit we observed in the first test.
Paul Knight, of the Guernsey-based removal contractor ASR, quickly suggested his site at the old vineyard at A’La Fin. This was a redundant greenhouse plant room with 10 linear metres of asbestos-insulated pipes. As with the first trial, we were dealing with hard-set insulation including all three of the commercial types of asbestos: amosite, chrysotile and crocidolite.To make it more challenging, the material was in poor condition.
All of the pipes were wrapped in polythene and seven cuts were planned. The whole exercise – from selecting the cut points, affixing the gel packs, making the cuts and sealing the redundant pipe sections after removal – was completed in around 45 minutes.
This seems very fast – and it is in comparison to the traditional approach, which might have taken most of the day – but the whole process was in reality unhurried, and completed with increasing confidence. The exercise was witnessed by me (representing FAAM and BOHS), Graham Warren and Craig Binge of ASESA (ASR’s trade association), and Matthew Coggins of the Guernsey Health and Safety Executive.
Watch the footage of the cutting in action.
As with the Horizon Somerset test, the air test measurements were very encouraging. The new technique returned results of 0.015f/ml and 0.018f/ml – in line, or even better that what we’d expect from well-controlled wrap and cut removal. But again, with the work completed so much more quickly, worker exposure was significantly reduced.
This test showed that the technique is easily picked up by new teams, in different situations, who can work more quickly and in greater safety than they might expect from wrap and cut. I’m indebted to the site team, who committed to the investigation so enthusiastically.
The removalists were Paul Knight senior and Paul Knight junior, Darren Wain and Mathew Wakeford from ASR, while the air testing was expertly delivered by Daniel Klassen of Survey Safe. It was great to see their work subsequently covered by Guernsey Press, in which Paul senior was able to highlight the gap between the asbestos regulations in Guernsey and the UK.
Written by Nick Garland on Thursday April 18th 2024
Last month, the Health and Safety Executive (HSE) unleashed absolute chaos. For those that don’t know what happened, I’ll summarise…
The HSE has become concerned about the quality of some training – and very concerned about the effectiveness of some RPE (respiratory protective equipment) face-fit testing (FFT). The regulator suspects even that in some cases, training and FFTs were not actually being done – just the certificate issued. Due to the criticality of a good FFT, it instructed the Asbestos Network members to share this concern with the world.
Where this got highly controversial is that the HSE issued a statement naming two training organisations of which it was particularly suspicious. And even worse, the first of these two was misnamed: the organisation’s acronym didn’t match its full name, which in turn was completely wrong – and a totally different organisation. No evidence was provided, so there was little for the relevant accrediting bodies to investigate.
From the outside, it didn’t seem like the appropriate way for the HSE to raise or deal with its concerns. But a colleague of mine more involved summed it up more directly: ‘It’s a proper screw-up’.
But as the dust settles, it’s important not to lose sight of the core concern here. For a very long time there have been rumours that training, FFT, mask maintenance certificates and even medicals can be and routinely are ‘forged’. I’ve personally not seen any hard evidence to this effect, but I’ve heard the suspicions of supervisors: “he’s never been trained in his life”, and “remote training sessions are too easy to pass – so what value is there in them?”.
The other week I came across a medical certificate for an operative who had been working on site all week in the south of England, but who had somehow managed to pop up to the North-East for his medical without missing a shift. Was this evidence of fraud? Actually no, as with some digging it turned out that the occupational health centre was providing medicals over the phone. This approach was brought in as an emergency measure in COVID and was withdrawn years ago. Not fraud, but certainly shocking.
Despite the naming issue, the HSE has not withdrawn its statement, so certificates from the two named organisations (and presumably the misnamed one too) should continue to face additional scrutiny. What this translates to is that a licensed asbestos removal contractor (LARC) must conduct extra competence assessments on employees with these certificates. The press release didn’t offer suggestions on how we should approach the FFT, but I understand that the labour supply agencies themselves are ensuring all staff under their wings are being re-tested.
This event should serve as a catalyst for the industry to reexamine testing more thoroughly, and ensure it’s delivering the high standards of protection that asbestos removal demands. For even when training is actually done – and done to a high standard – it’s fair to ask whether a three-day, new operative course should be enough to allow someone to work under challenging conditions with a carcinogen. In fact I think you’d struggle to find anyone to enthusiastically support this idea.
For those that can remember, labour supply agencies used to be licence holders, and were effectively employers for a stable of workers. Maintaining a licence is not an easy thing – it takes care, attention to detail and commitment. A good agency would be seen as a partner for a LARC and, if they could provide reliable staff that were competent, they would be able to command loyalty from their customers. Their licence would be precious, and they would have an incentive to train, assess and generally look after good staff.
This all changed in 2013, when they were removed from the licensing regime, and anyone could start up a labour supply agency without any checks and balances. The HSE’s argument was that they didn’t care where a LARC got its staff, providing the LARC ensured their competence. No thought was put into how the LARC might do this, particularly for workers who might only be with them for a couple of days. This has led to a lot more labour supply agencies, but the same pool of short-term workers (STW), who are self-employed people in their own right.
There are good, dedicated agencies out there that endeavour to provide top quality staff, but there are also some that are very, very poor. The pay rates for all site staff are historically low, and therefore a bump of £5 per day has become enough for a worker to move. When demand outstrips supply, it also becomes a seller’s market. Desperate employers and desperate agencies need bodies on site, and sometimes that’s achieved no matter the competence.
We have created a market where the individual worker is the customer, and loyalty to the LARC or the agency is for mugs.
For the trainers, RPE Face Fit providers, and mask maintainers, the customer is now often the individual STW, and time has become a huge premium for these self-employed people. Anything that keeps them off-site for a shift can represent a significant loss of income. The incentives are obvious, and help explain the rise of the online refresher course, rather than face-to-face training.
If we think a little on how this incentive could twist the market it is a short leap to questions such as: ‘how quick can the training be?’, ‘do I need a FFT every year?’, ‘this second hand mask looks alright – how do I get a maintenance certificate?’, ‘have you heard that NE doctor is still doing medicals by post?’. It’s the result of the pure free market meeting safety-critical requirements – and we are where we are.
Online and remote training became essential during the pandemic, and it seems they’re here to stay. In the right circumstances, they can be exactly what is needed. My understanding of the HSE’s current position on it is that such refresher courses can be suitable for experienced workers, if supported by the employer’s training needs analysis (TNA), i.e. an employer, having thoroughly assessed their worker, deems that they only need a light-touch refresher. This seems eminently logical to me. However, the obvious implication of this is that it is not suitable for self-sponsored, self-employed agency staff, as they don’t have an employer to assess them and perform a TNA.
Things are about to get a lot worse. On many major construction sites, individuals need Construction Skills Certification Scheme (CSCS) cards to demonstrate a basic level of safety training and awareness. These are backed up by NVQs, and these qualifications have lots more checks and balances. Evidence of a candidate’s competence is recorded, and there’s auditing of both the individual assessor and the training provider by the awarding body. They also represent a huge time commitment for both the worker and their employer.
As NVQs were initially a new concept in the asbestos industry, temporary red ‘trained’ cards were made available for workers who had no NVQ and only the traditional three-day training course. Fifty thousand of these non-renewable cards have been issued, and all of them will expire by the end of 2024. The only route for these red card holders to get black or gold cards is to complete an NVQ. That’s quite a commitment even for a full-time employed worker, and seemingly inconceivable for the self-employed.
If I try to look at this impending cliff edge with some optimism, the only thing I can come up with is that, once we’ve fallen off, the few employees available might at least be of a high standard. What it could mean for the already tight labour situation hardly bears thinking about.
Whilst the HSE’s intervention seems ill thought through, it has forced us to look at the current situation, which is dire. What’s the solution? I’m not sure anyone knows, and certainly I don’t, but something clearly needs to be done.
Graham Warren of the Asbestos and Environmental Safety Association (ASESA) has called for a complete reset of the training environment. In his vision, all of the training organisations (ASESA, ARCA, ACAD, IATP and UKATA) would get together and collaboratively decide what training and competence should look like. This agreed competency framework could then be followed by all. This kind of fundamental action seems to me like an excellent place to start.
It does seem inescapable that remote training will have to be part of the mix – but it is not suitable for everyone. That is one of the many fundamental questions such a collaborative re-assessment has to answer. What does training and competence look like for our sector? What is the right training for a given individual? How do they learn? What will they engage with?
If online refreshers aren’t suitable for the self-sponsored worker, then how do we make the new environment work for this critical pool of staff? Should we consider bringing back licences for labour supply agencies, and so recreate trusted ‘employers’ with skin in the game? Again, I don’t know, but we desperately need to look at the whole problem with honesty.
Wherever there is money, there will be bad actors prepared to cut corners for profit. But the new system should at least be designed so that most of the human nature levers are pushing us in the right direction. It is, after all, a fundamental matter of workers’ safety.
Written by Nick Garland on Thursday March 14th 2024
For the past few years I’ve been writing about personal monitoring and exposure guidance. It’s an area that the entire asbestos industry has struggled to grasp. By ‘the industry’, I include everyone: licensed asbestos removal contractors (LARCs), analysts, and the Health and Safety Executive (HSE). And frankly if these last two have struggled, what chance did the LARCs have?
In a continuation of our focus on the issue, I thought I would highlight the main points from the guidance. Here I’ve listed the most important issues raised, along with their implications, and how you can make sure you’re in compliance.
My first takeaway is that the guidance exists at all. It’s always been amazing to me that an area of the industry so important has been overlooked for decades. But it is here now, and what’s more it’s pretty good guidance. It’s clear, as concise as it could be, and it’s muscular – as in it goes slightly beyond the why and how to help address some of the blockers.
You can get a copy from your trade association, from the AN’s new official home on the CONIAC website, or download it from our website.
Takeaway number two would be that it demands a much improved strategy. The old approach to personal monitoring was that 40% of asbestos insulation board (AIB) jobs, 60% of pipe insulation, and 100% of ‘flock’ jobs would get a personal monitoring test. The obvious flaw with this approach is that both a one-day AIB boiler cupboard job, and a one-week AIB ceiling project with 10 operatives, count as one job.
I appreciate this might have been the best we could do before widespread use of Excel and computers, where everything was locked away on paper, but we’ve been able to do much better for decades. Now that we have access to databases, and Excel is commonplace, the guidance takes us to another place entirely.
Our monitoring strategy now needs to be risk based. So – other than what asbestos-containing material (ACM) we are dealing with – what makes one activity higher risk, and therefore one we should target with personals?
All of these will need to interact, so that Barry the new starter is targeted more than 10-year veteran Tom when removing a one-off AIB panel. Similarly, 10 operatives removing panels for seven days straight are targeted – and in particular Barry.
You need to collect data in much more detail to be able to work all this out. And that means your exposure record sheets need to be expanded to include all of this data:
You also need to create categories of people, breaking employees down into trusted, experienced workers, and those you need to focus on. Ultimately you need to cover everyone doing all of the activities. And once you start collecting this data, you need to process it.
There are only two ways you can unpick the meaning behind this very very large amount of information: a spreadsheet like Excel, or a database. If you go down the first route, you will need to build a sheet that can take all this data and automatically calculate the implications of your strategy. You need to build this out into a tool that allows you to commission the right personal test at the right time.
The first of my apologies, is that Assure360 does, of course, already do all of this for you. I’ve been talking about the subject for years, so it’s only right that I have built it into our system. The Paperless app takes data that the supervisor records (faster than they could have done on paper), automatically slices it up, and tells you who and what to test. This decision is based on up-to-the-second data and is not only easier than a spreadsheet, it’s actually admin-free, representing no additional effort whatsoever.
The guidance recognises that this is new, and that you might effectively be starting from scratch, so there’s a bit of humanity built in. It stresses that you should prioritise high-risk activities first, and back-fill to lower risk ones when you have sufficient data.
The next takeaway is the huge elephant in the room: it doesn’t matter what you want them to do, the analysts and the clients won’t do it.
Understandably, the big drive for some time has been for clients to employ the analyst directly. This removes a potential conflict of interest, but introduces others. As the client is paying, they’re more interested in leak tests and the four-stage clearance (4SC), so personals get forgotten.
The guidance directs the client to consider their duties under the Construction, Design and Management Regulations 2015 (CDM duties), and makes it clear that personals help them discharge these. After all, a series of personals is evidence that the work is being conducted safely.
The next issue here is that the analyst often thinks that the data they record is ‘owned’ by the client, and therefore can’t be given to the LARC. This has been very firmly put to rest, as the guidance states:
“analysts must always provide full PM results directly to the LARC as soon as possible after the collection of the sample via either hard copy or electronic means.”
And
“Failure to supply this information might be a breach of the analyst organisation’s duty H&S at Work Act 1974.”
The guidance also tells us that – whoever is paying for the test – the LARC should specify what and who is to be tested.
I have never seen guidance clearer than this!
The guidance lists the four tests you could do, but it focuses us on two:
It also explains why.
The SSDA is the workhorse test. It focuses on a specific activity, that is, not “AIB removal and fine clean”, but one or the other. With that restriction in mind, it is still hugely flexible and will provide you the data you need to answer a whole host of questions:
It can even help you with assessing respiratory protective equipment (RPE) suitability and the 4Hr TWA, if you design it correctly. The only thing an SSDA will struggle to cover is the old 10-minute test (but the guide effectively acknowledges those as being a bit niche these days).
The HSE sees this test as equally important to the SSDA, and there is an element of ‘just do it’ in the guidance. But at least it does tell you how to do it. I won’t go into too much detail here, but in broad strokes here’s what you need to remember.
Where the SSDA is looking at one activity, the 4Hr TWA is looking at one person, and it can (and should) encompass everything they do. The result of the test will therefore indicate the average exposure in a working day. This might give rise to two questions: why is this important, and why only four-hours if we are talking about a working day?
The 4hr TWA relates to the Control Limit, and the CL relates to decades of known occupational excess mortality data – i.e. how many people will die – if exposed above a certain figure per day over a 40-year period. We need to be as far on the right side of this figure as possible.
The average in a day is important, as the fact that no exposure was experienced at lunch, or when travelling to the enclosure and back, is relevant. It allows us to ‘calculate’ the likely total exposure in a working lifetime. Therefore whilst the SSDA helps us get better at what we do, the 4hr TWA is the ONLY risk assessment for asbestos exposure.
The second question? Well that’s a bit niche. Back in the day, pumps weren’t capable of testing over an eight-hour working day, so the asbestos community went for four hours instead. That might sound like a cop-out, but in fact if you target the high-risk activities as you’re supposed to, calculating exposure over four hours imposes a stricter limit.
The maths behind the 4Hr TWA remains difficult, but the guidance goes into some detail on how to do it. In essence, we’re back to the Excel spreadsheet again.
That said, It would be really remiss of me not to include 4hr TWA calculations in Assure360. I have, and it does. The system automatically identifies whether the test follows the strict rules. If it does, Assure360 will do the sums for you automatically and instantly. Again, our system solves a mandatory, time-consuming task, helping you focus on your work.
One of the most common questions from LARCs over the past 20 years must be: “Why do we always get ‘useless’ short-duration air tests?”
Well, at least part of the reason for not getting the right answer is that we typically don’t ask the right question. Normally we would instruct the analyst “can you do a personal whilst you are there?”. They would look to the (old) analysts guide, where they had four options.
As I have said earlier, analysts – along with the rest of the industry – have been scratching around in the dark. Without a deep understanding of the subject, their thought process might be: “I can’t do option one, because that’s four hours. The Action Level doesn’t exist anymore, and it’s nothing to do with RPE. So the only personal I can do is a 10-minute”.
The new guide is a huge improvement, as it introduces the SSDA, but we are still working in a subject area with precious little competence. To ensure you get the data you want, be clear in what you want.
Don’t ask for ‘a personal’. Ask for “an SSDA test on Tom, removing AIB on Monday. Please make sure the flow rate is two litres per minute, and that you run it for at least two hours.”
The specificity is important, and the last two parts particularly so. If you can get most of your personals to follow this pattern, they qualify for 4hr TWA calculations and you kill two birds with one stone.
As many of you will recognise, I’ve seen it as my mission to help address the competence gap in this area. That’s why one of the first features of Assure360 dealt with exposure, and it’s why I’ve returned to write about it again and again. It’s why we recently ran a webinar to help the industry understand and implement the new guidance.
It’s one of my proudest achievements that Assure360 is so ahead of its time, its users were compliant with this guidance more than four years ago. If you want to see how our system solves the issues raised here – and much more – please do contact us for a demonstration.
Written by Nick Garland on Wednesday October 25th 2023
In late 2022 I attended the European Asbestos Forum conference in Amsterdam. This won’t come as a surprise – I wrote about it shortly afterwards, and anyway I’ve been going since the very first conference. In part inspired by EAF, I’ve regularly talked about how important it is for us to look beyond our shores to find new solutions to old problems.
I’ve also talked about how UK asbestos innovation seemed to stop with the introduction of wet injection. Don’t get me wrong: injection – and the huge safety benefit that comes with removing asbestos that is properly suppressed – was a huge improvement on what went before. But for 20 years we have been resting on our laurels somewhat.
That’s why at EAF 2022 I was so interested in BCL Invent, and their product Easy Gel. In layman’s terms, this is a range of shaped plastic pouches filled with gel. The application that sparked my imagination was for cutting cement pipes, where the pouch is secured to the pipe before being cut through. Rather than just suppressing the dust – which it appeared to do – the gel remained on the surface, forming a barrier – separating the worker from the activity.
This is a crucial consideration if we want to improve safety: how do we separate the worker from the activity? It will become increasingly important as and when the European occupational exposure limit (OEL) is reduced by 10- and 50-fold in the coming years.
BCL Invent’s new approach transformed a very direct and personal activity into one that was significantly more remote. The air test results that they were obtaining were also very impressive; less than 0.0048 fibres per millilitre (f/ml) for cutting a cement pipe and <0.0032f/ml when cutting fibreglass-insulated pipe. I asked myself – how would it perform with the very common challenge in the UK of asbestos-insulated pipes?
Of course, there’s already wrap and cut, a similar method which works as follows:
The bare section of pipe is then cleaned, the exposed edges of insulation sealed, and the pipe is cut. The whole process is repeated until the entire pipe has been removed.
Wrap and cut has an advantage over cleaning the whole pipe, as it’s safer: there’s less asbestos disturbance, and it’s quicker so there’s shorter exposure. As a bonus, it’s also cheaper.
It has downsides – in particular vibration and noise. Hand-arm vibration syndrome (HAVS) is particularly challenging. A reciprocating saw is so vibrating that the normal limit per person per day is just 15 minutes. There are also several points in the procedure where we expect the worker to stop, check and repeat. It’s therefore understandable that operatives tend to over-inject, reducing the possibility of coming across dry patches – but dramatically increasing the spread of contaminated water.
Easy Gel seemed much simpler, with very few ‘moving parts’. If its barrier approach worked, it could fall into that sweet spot that the original wrap-and-cut method occupied – safer, quicker and cheaper.
If it works – but who finds out whether it can? The Health and Safety Executive (HSE) doesn’t approve methods: that’s not its job and it never has been. Innovators should be those creating the hazard. But we operate in a fractured industry where licensed contractors have a lot to lose. And we as consultants have become very risk-averse, guilty of blindly applying and enforcing guidance.
Step up BOHS and FAAM, who are in the ideal position to investigate the safety or otherwise of innovative techniques. We designed a rigorous experiment to examine the hypothesis that the use of a barrier gel would be enough to suppress fibre release.
As a control, we first tested the traditional wrap and cut method. Three cuts were made, which took 57 minutes. The results of the two personals for the cutter were both 0.02f/ml.
Here’s a video of the cuts being made…
I intentionally held the video on the last frame with the cut end visible. If we were relying purely on wetting of the insulation – the clear dry spots would have led to significant fibre release. But we didn’t see this.
Five horizontal cuts were made in a 45-minute period using Easy Gel. The results of the two personals for the cutter were 0.02f/ml and 0.04f/ml respectively. The cutter achieved a further four vertical cuts in a 48-minute period. Here the personals were slightly higher at 0.03f/ml and 0.06f/ml.
Our results confirmed that the key quality of the gel-cut method was the formation of a physical barrier, which prevented fibre release. You can see this in this still frame, which shows the extent of (imperfect) wetting from the gel. Were we relying solely on the gel’s wetting properties, this would have resulted in high fibre release.
While the individual personal results with gel-cutting were slightly higher, we were able to make cuts more quickly, so total exposure was reduced. Another way to look at this is to ask what would happen if more cuts were made.Twelve cuts using the wrap and cut method would take approximately four hours. The same gel cuts would take less than two. Reducing exposure time by 50% would reduce total exposure.
For this test we also used an ALERT constant monitoring device, and the data we received gave us fascinating insight into the fibre release. We could see the distinct cut points as they happened. The wrap and cut method was particularly interesting – giving us peak exposure after the cuts, not during. You can see this in the chart below, where the pink trace shows fibre levels, and particles are shown in green.
So what did we learn? While the results for vertical cutting with gel packs were still low, it’s slightly more difficult to control than horizontal, so they were slightly higher than the horizontal values.
There’s a more significant, if subtle, difference when it comes to HAVS. With a quicker process, workers could make more cuts in a shift, increasing their exposure to harmful vibration. In addition, the cutting technique required the user to keep the foot plate away from the gel pack to avoid crushing it. This in turn leads to less control and more vibration.
There’s a narrower margin for error with gel cutting – effectively the width of the gel pack, rather than the 150mm you get with the wrap and cut method. When considered with the reduced cutting control, this reduced margin for error might be significant.
The increase of the already significant vibration hazard is particularly problematic for the method and must be addressed before it is used commercially.
We observed comparable air test results: wrap and cut at 0.02f/ml, and gel cut (horizontal) of 0.03f/ml. As wrap and cut resulted in an excess of injection liquid leaking out, gel cutting gave a higher degree of control – there was virtually no spread of contaminated gel.
The gel cut process is much quicker. If 12 horizontal cuts were to be made using the traditional method this would take approximately four hours. Using gel cutting would take approximately half this (meaning the exposure in the subsequent two hours would be zero) . Therefore, whilst the test results are comparable, a total exposure or four-hour time-weighted average (4hrTWA) calculation would be approximately 50% of the wrap and cut equivalent.
This increased efficiency could lead to shorter project duration – which would be commercially attractive to clients and licensed asbestos removal contractors (LARCS).
However, due to the commercially attractive nature of the method, the increased vibration and reduced control must be countered before the procedure is adopted. The following currently available solutions should be considered:
Whilst the picture shows an uninsulated pipe, these devices are equally usable on wrapped insulated pipes. This approach imposes a great deal of control on the cut and virtually eliminates vibration. This modification should be considered for all uses of reciprocating saws, and would be crucial when considering the new method.
This project shows what a fully functioning, joined-up industry can achieve. The innovators must be the hazard creators, but FAAM can provide the structure, independence and academic rigour to prove a method can work.
I’d like to extend our particular thanks to Ben Ives of Horizon Environmental, for tolerating a research project on an asbestos removal project, and to G&L Consultancy for the analytical work. Special thanks also to ALERT for providing the constant monitoring kit, and last but not least BCL, for modifying Easy Gel for the UK application.
Our thanks also go to the site teams:
Horizon Site Team –
Lee Woodward
Jacob Rowley
Jamie Hewings
Matthew Hewings
G&L Site Team
Jim Scholes
Archie Charles
Written by Nick Garland on Wednesday July 12th 2023
The Times is turning into a real champion for those of us who want to change the UK’s approach to asbestos. The paper has kicked off a new – and extremely welcome – campaign to eradicate asbestos from schools [paywall], launching it with another excellent article.
It’s fantastic to finally see the issue getting some mainstream coverage. You’ll probably remember that I’ve written before about asbestos in schools. I think it’s an issue that many of us in the industry feel increasingly strongly about.
It’s instructive to remind ourselves as to the Health and Safety Executive (HSE) advice to schools regarding asbestos. They must:
In a school setting, those most at risk of disturbing ACMs are tradespeople, caretakers and others who work on the fabric of the building. The school’s plan needs to contain provisions to ensure that they have information about the location and condition of ACMs. The duty-holder should also ensure that any staff likely to disturb asbestos are suitably trained.
As I’ve pointed out before, this is essentially the same advice that applies to any other employer, and any other workplace: manage the ACMs in situ. But schools are unique.
In law, a school is a workplace, but the majority of people using them are children – sometimes as young as three. Despite the known vulnerability of children to pollutants, contaminants and other environmental hazards, when it comes to asbestos, schools are treated like any other workplace: they’re subject to workplace asbestos fibre limits, regulations and management approaches. And that’s a problem – both for our children, and the professionals who teach them.
The Times’ article brings together lots of stats that, when read together, paint a very stark picture of the current situation. Figures gathered by the National Union of Teachers’ Joint Union Asbestos Committee (JUAC) reveal that, since 1980, around 400 British school teaching professionals have died of mesothelioma, the cancer almost exclusively linked to asbestos exposure. An average of 19 school teaching professionals now die each year from mesothelioma – up from three per year in 1980.
This is likely to be an underestimate, as occupation is not stated on the death certificate of those over 75 – which is the age group accounting for most victims of this horrible disease. To my mind, the real figure could even be double or triple this number.
Research by the US Environmental Protection Agency estimates that for every teacher that succumbs to the disease, a further nine pupils will go on to die from mesothelioma in later life. The JUAC estimates that as many as 10,000 pupils and staff have died to date due to exposure to asbestos in schools.
A unique challenge
Why is asbestos such a serious problem in schools? Aside from the particular vulnerability of pupils to the substance, the UK has a major problem with how widespread ACMs are – and also with the poor state of repair that some school buildings are in. More than this, schools are under budgetary pressure – heads are thinly spread as it is.
In 2018, the government asked schools to provide information on asbestos in their buildings, through the Asbestos Management Assurance Process. In 2019, AMAP reported that 80% of schools contained asbestos.
In addition to this, the National Audit Office has estimated that 24,000 school buildings are beyond their design life. Nearly two-thirds of these are the system-built buildings that so frequently contain asbestos. Last year the Department for Education revealed that there was a risk of the collapse of one or more blocks in some of these schools.
A recent Freedom of Information request by JUAC to 60 of these system-built schools revealed that nearly half did not have an “up to date” asbestos survey, and two-thirds had not identified where all of the asbestos was.
In an ordinary workplace, the HSE’s ‘manage in-situ’ advice can work very well. Surveyed, recorded and managed properly, ACMs should pose no risk – provided the management plan ensures that they remain undisturbed. Proper management starts with a management team that has the training and experience to properly understand the risk, and design and implement appropriate controls.
The Times’ article brings together a body of evidence demonstrating that, for schools at least, this is not working. Headteachers have been unreasonably forced into the role of duty holder, responsible for management of asbestos in their schools without adequate training, support or budget.
When you add in the fact that the majority of the school population can’t be considered competent around asbestos, and the complication that we don’t know the true scale of the problem, it is not surprising that the system isn’t working.
Phased removal
If management in-situ doesn’t work for schools, the only answer is surely the phased removal called for in the excellent Work and Pensions Committee investigation and report. As I have written before, the government rejected the report’s key recommendation to remove all asbestos from public and commercial buildings, and this is where the Times is taking up the banner for schools, with its five-point plan:
The paper’s campaign has already gained support from significant political figures including Nadhim Zaharwi , Alan Johnson and Matt Hancock, who between them have formerly held the roles of Chancellor, Education Secretary, Home Secretary and Health Secretary.
The Times clearly doesn’t want to let this lie, and I applaud it for that. Its launch article ends by asking if you have been affected by asbestos. If you have, email the paper at [email protected].
Written by Nick Garland on Thursday June 22nd 2023
I’ve previously written about the ongoing standoff between the European Parliament, EU member states, and the European Commission regarding the exposure limit for asbestos. Well, that standoff is set to enter a new phase at the upcoming interinstitutional talks with the European Council.
To recap, the Commission has proposed a reduction in the exposure limit of asbestos at work to 10 times lower than the current value. That would mean reducing it from 0.1 fibres per cubic centimetre (f/cm³) to 0.01 f/cm³. But for the European Parliament’s employment committee (EMPL), this is not enough – they are insistent on a 100-fold reduction, to 0.001 f/cm³, after a transitional period of four years.
In the UK there isn’t an exposure limit for asbestos, but it’s analogous to our Control Limit, which is also 0.1 f/cm³. We have another limit called the Clearance Indicator. That’s the level that an asbestos enclosure must pass before it can be handed back, and that’s set at 0.01 f/cm³.
The lines are fairly firmly drawn with the EU ministers of employment setting out their position in early December last year, which was to agree with the Commission’s 0.01 f/cm³ proposal. But Danish MEP Nikolaj Villumsen wants the Parliament to keep its stronger position.
“Sadly, we know that some member states are satisfied with a limit value 10 times as high as what we propose, with outdated methods of measuring and less stringent approaches to training and certification,” he said. “This is what we will be up against next.”
This matters to the UK because, if the EU reduces its exposure limit, it will be very difficult for us not to follow. But I’ve previously touched on a more fundamental problem if the limit chosen is 0.001 f/cm³. There’s currently no equipment or testing technique available that can do personal monitoring tests at these levels. The technology simply isn’t ready to support them.
Furthermore, the masks that asbestos removal workers use have a protection factor of 40. This would mean that to stay within the lower 0.001 f/cm³ exposure limit, any method used to remove asbestos must not release concentrations above 0.04 f/cm³. I’m not aware of any working method that would reliably achieve this.
There are two things at play here: what is safe to hand back to the normal users of the property, and what’s safe for the workers actually removing asbestos in enclosures. It’s concerning that the implications to asbestos removal appear not to have been thought through.
It’s vital to protect workers and other users of the built environment, and I can see a lower exposure limit is a positive move. More stringent cleaning and more accurate testing will be able to achieve this. But, how will these new levels affect the removal operatives themselves? Protection technology improves all the time, and perhaps the lower limit will force some kind of breakthrough, but in the absence of that it’ll be a hard limit for the industry to meet.
Written by Nick Garland on Thursday June 22nd 2023
You might have already read or heard my thoughts about the Retained EU Law (REUL) Bill, which is making its way through parliament. If you’re not familiar with it, it’s a piece of Brexit legislation that aims to bring into UK law regulation that has its origin in European law. While it’s seen as a crucial step by those who want a stricter interpretation of ‘Brexit’, the bill as originally set out had huge and manifest problems.
First of all, REUL covers a vast amount of legislation – the current count is that it affects approximately 5,000 laws, and (terrifyingly), nobody seems to know exactly how many. It includes such critical and effective regulations as the Control of Asbestos Regulations.
The biggest issue with this is that the bill contains a sunset clause, which would essentially provide that, unless an individual piece of law is ported over to UK law or re-written (a mammoth task), then it will disappear at the end of the year. If this clause survives unchanged, the prospect of accidentally losing vital legal mechanisms is very, very real.
So it was some comfort when I came across a fantastic article published by the Institute for Government last month, which brought to my attention the significance beyond the headlines of a statement by Business and Trade Secretary Kemi Badenoch.
There seems to have been an outbreak of sense in the approach to the REUL, inasmuch as Rishi Sunak and Kemi Badenoch “have agreed to ditch the sunset from the bill and instead provide parliament with a list of all REUL the government intends to repeal.” It will now be these selected laws that disappear automatically at the end of the year, rather than all EU based laws.
It will still be a mammoth task for legislators to unpick the long list of regs that are disappearing – but at least the immediate risk of oversights and mistakes, has gone away.
As the Institute for Government article also recognises, the wording of Badenoch’s statement, suggesting a much more sensible approach to regulatory reform. Words such as “proper assessment and consultation” make a welcome appearance, for example.
However, a concerning element of the amended REUL is that in the original legislation, only the Supreme Court could depart from established EU case law, but the bill now effectively opens the way for any court to do it. That leaves a legal avenue for anyone who did not like a decision under EU law. The government is also giving itself a permanent power to amend REUL under the bill, without any additional commitment to consultation or proper parliamentary scrutiny.
In this matter, the House of Lords has done a great service to the country, forcing the government to address the unrealism and risks of its self-imposed deadline. But there are still big question marks over the amended approach – and more work to be done.
Written by Nick Garland on Tuesday May 16th 2023
The Times recently carried a special report on asbestos (paywall). Steve Boggan’s excellent article was a rare example of a detailed, thoughtful, well-researched and intelligent piece of writing on the subject in the mainstream press. Without the unscientific scaremongering that is so often peddled out, this piece told the unvarnished reality – which frankly should be scary enough.
Boggan interviewed several sufferers and family members. These included Wayne: an HGV mechanic, Grace: a retired teacher, and Garry: who recently lost his wife Debbie to the disease. While their stories are all different in the detail of their unfairness and tragedy, they all share a central core – the fact that they didn’t know that they were being exposed.
The article discusses the recent Department of Work and Pensions Select Committee report, and focuses on the two main recommendations that would address this ignorance. These were a national register of asbestos, so we know where all of the material is, and a plan to remove it all. Both have been rejected by the government.
Boggan quotes the prominent campaign group ResPublica who state that 90% of hospitals and about 80% of schools contain asbestos. The recent study paper by the National Organisation of Asbestos Consultants (NORAC) and the Asbestos Testing and Consultancy Association (ATaC) has similar figures, with 78% of the buildings they looked at having contained asbestos.
I don’t know how accurate the ResPublica figures are, and I know the NORAC/ATaC piece was only a snapshot, but in part that’s the point: no one has an authoritative overall view of how big a challenge we have.
The Cliff Edge
As a country we are heading towards two impending cliff edges. The first is that many of the schools and other structures that contain asbestos have a light steel frame construction. These have a design lifespan of 40 years, and we’re at least 10 years beyond that now.
The second is Net Zero. If we’re going to achieve this, there’ll be an awful lot of building work required.
Between these two massive construction challenges, many of the buildings we currently use are either going to be demolished or heavily refurbished in the next few years. Without knowing how big the asbestos problem is or having a national removal plan in parallel, it would be human nature to lose sight of the issue.
Many still see asbestos as a problem we fixed long ago. It’s still there, though, just not widely known or understood. The climate emergency, by contrast, comes with a very pressing and public deadline. But if we don’t get the asbestos plan right, it seems inevitable that the rush to Net Zero will lead to an avoidable spike in asbestos exposure – and it could be centered on the schools and hospitals used by the most vulnerable in our society.
Written by Nick Garland on Tuesday May 16th 2023
Another great asbestos article by the Times (paywall), this time on a subject I’ve raised a couple of times in the past – asbestos exposure from makeup. Katherine Quarmby and Andrew Ellson’s story reveals that over 100 British women suffering from mesothelioma are currently taking on American cosmetic giants to get compensation.
A bit of background. Talc is a mineral that is mined out of the ground. What is not so widely known is that it’s chemically fundamentally the same as asbestos. The mineral develops into asbestos or talc according to slightly different geological conditions. In fact most talc mines also contain asbestos deposits and some fibres even start at one end as talc and end up asbestos. The low-tech nature of mining for talc has inevitably led to contamination of the supply chain.
What’s also not so widely known is that talc is not just sold as talc and in baby powders. Many brands and types of makeup use the mineral as a key ingredient. In fact you’ll be hard pressed to find eye-shadow, foundation or blusher that doesn’t contain it.
The article highlights that the latest UK statistics showed a 7% increase in women being diagnosed with mesothelioma, a faster rise than in the previous eight years. New cases in women have doubled since the early 1990s, while they’ve ‘only’ increased by about half in men.
The Times doesn’t draw a direct line between these alarming numbers and makeup, but the latest HSE statistics indicate that only around a third of female diagnoses are linked to occupational exposure, or living with a partner who was exposed.
It does seem the potential for asbestos contamination in talc has been known by these companies for decades. But setting that to one side for a moment, we certainly know it now, and we know that talc in makeup presents a health risk. Whilst we haven’t yet quantified the level of risk, the regulations state that there shouldn’t be any. There are safe and cheap alternatives, such as corn starch. Which begs the question: why does talc’s use persist?
Written by Nick Garland on Wednesday April 12th 2023
Regular readers might remember that, last summer, I wrote a summary of the monitoring, health and exposure guidance that the Asbestos Network has been working on since 2019. I’m reliably informed that, with a fair wind, this guidance will actually be released this summer.
I’m aware I’ve said this before, but the latest draft has come quite a long way since my last review. Now it really does feel like it’s nearly there, but this also means that it’s worth revisiting – as a lot has changed.
I’m going to cover the main points in this update to my previous review, but I strongly suggest you give the original a read. It’s also worth providing your feedback through the trade organisations, as there’s still time for your input to help shape the outcome.
In this review I’m going to highlight how Assure360 users are already prepared. Essentially, this new industry best practice has been Assure360 standard practice for years. It’s all powered by Assure360 Paperless, which is both compliant AND massively more efficient than using Excel and paper.
Since my last review, the guidance document has been honed down to eight pages, plus appendices. The Asbestos Network recognises that this is first and foremost a communication piece for licensed contractors, and by focusing on that audience it does the job well.
That said, there are nuggets for clients, which give the guidance a wider reach. The likes of FAAM will be looking at it closely in their attempts to investigate and improve the personal monitoring skill set of analysts.
The first couple of pages set out the what and the why. The ‘what’ summarises the tests that need to be done. It’s now been honed down to a simple four-bullet list:
Those who need more detail can find it in the appendices, but two tests are picked out as being key, and these get a bit more detail within the main body of the guidance. Not surprisingly, these are the 4Hr TWA and the SSDA tests that I’ve written about before. As a reminder, here’s my analysis of the techniques:
Specific short-duration activity (SSDA) Monitoring
This is the workhorse test that you will use most of the time. It’s used to test a specific activity. The guidance talks about the importance of really focusing on the individual task. To this end it stresses that it’s no longer good enough to, for example, talk about removal of asbestos insulation board (AIB) – now you need to detail the fixing too. An example given is breaking out a single AIB panel, followed by fine cleaning. This should be viewed as two separate tasks, and either you should test them separately, or prioritise the high-risk element.
As the purpose of the test is to examine an activity, you are allowed quite a bit of licence. The flow rate (how hard the pump is working) should be between two and four litres per minute, and the minimum volume tested should be 120 litres. These recommendations are very much intended to ensure you get a decent limit of quantification.
Four-hour time-weighted average (4Hr TWA)
The dreaded 4Hr TWA should be far less opaque if you’ve read my previous articles on the subject. Its main purpose is to discharge your duty to ensure workers are not exposed above the Control Limit (after taking into account the mask protection). Essentially, if an employer causes an operative to be exposed to asbestos, we should be able to tell them accurately how much they have been exposed to. The testing rules are set internationally, so the results can be accurate and comparable.
As 4Hr TWA is all about the person, rather than the activity, it can’t be used to populate the SSDA data. However the reverse is not true – if you select test parameters that comply with both, then you will be able to satisfy both duties in one. In short – if your default SSDA test is run for two hours at two litres/minute and 200 graticules – you will get a good accurate test that can also be used to populate the 4Hr TWA data. As Assure360 users will know, the system automatically does the calculation for you, provided your test follows the rules.
The guidance then goes into more detail on the ‘why’, mostly pointing you at the various regulations that demand compliance. However, littered through the document are more ‘whys’. Fundamentally, it makes the case that exposure monitoring – if done correctly – can be a practical management tool for testing competence.
The next part of the guidance focuses very helpfully on strategy. The starting point is to give an indication of absolute minimums – for example if you have a small, stable team, with consistently low readings and a predictable list of project types, you should aim for at least one test per month.
The first very important steer that you need to be aware of comes next. The traditional approach for LARCs’ exposure strategy is that 40% of all AIB jobs, 60% of all pipe insulation, and 100% of all flock jobs get a personal. This isn’t going to be good enough anymore.
Just as with audits, you should be targeting high-risk situations over low risk. The guidance gives you areas to consider when setting your strategy:
To obtain this data, the LARC therefore needs to be very clear as to what they want. No matter who is actually employing the analyst, you need to specify when, where, doing what, and who (will be doing it).
This new granular strategy, able to focus on individual removal techniques and the experience of a worker is going to really test your Excel skills. For Assure360 users however, it’s again very easy. We allow you to set targets for individual activities, and the system tracks how many times anyone uses each method on site. With every recorded instance it reassesses your strategy and alerts you to any personals you might need to do. Again, it’s all automatic through the Paperless system. We can even tag agency or new starters to increase their testing frequency.
Looking to the Construction (Design and Management) regulations and the duties that these place on clients, the guidance makes the point that personal monitoring data is a valuable measure for management of a project, and that clients should therefore insist on personal monitoring data in the contract. The implication is that if the client is appointing the analyst as good practice dictates, they should specify personal monitoring, along with leaks and clearances.
The LARC should view the dynamic between themselves and the analyst as customer and supplier. At this moment, no matter who actually pays the analyst, they’re providing the LARC with a service. To further underline this new way of looking at the relationship, the LARC should ensure the competence of the analyst to conduct personal monitoring, just as they should with any supplier.
The implication is that the Health and Safety Executive (HSE) is starting to believe that United Kingdom Accreditation Service (UKAS) accreditation alone isn’t enough. But the guidance doesn’t suggest how a LARC can be assured a consultancy has demonstrated competence in this area. Possibly this is where the likes of FAAM step in to investigate and improve the skill set across the board.
As delays in getting personal monitoring data could lead to increased exposure to asbestos, the guide states that analysts must provide the certification ASAP, no matter who is paying for the service. There is a stark warning that failure to do so could be seen as a breach of their duties under the Health and Safety at Work Act.
The second half of the guidance is very heavy on how you should analyse and use the data – which takes us firmly away from the thoroughly outdated idea that ‘we test because the HSE says we must’. The key to all of the points I’ll detail now is that you need to be responsive in how you interact with the data.
The supervisor needs to analyse the results, and there are two triggers for intervention:
With some training, the supervisor should be able to keep on top of this for you. Assure360 users have an extra layer of control, as any elevated result automatically sends an email to management and tracks what action has been taken.
All of the results must be reviewed by management, and the guidance tells you what you need to be checking:
There are really only two ways that you can do all of the analyses that the full guidance requires. The first is through a spreadsheet, which involves some skill with software and a great deal of time entering in the data from paper site records. The other is with Assure360 – there’s no real alternative system.
Our software takes the data that the supervisor is routinely recording, and does all the analysis for you. This doesn’t happen by luck, for years we’ve been exploring how to use site data more intelligently to provide greater safety and insight.
As our industry guidance increasingly calls for smarter data collection and analysis to drive safety, Assure360 customers are already reaping the benefits of this approach. In the words of one HSE inspector – ‘Assure360 presents all the information to you on a plate, allowing you to make sensible decisions’.
If you’ve got concerns around the guidance and the changes you’ll need to make, or simply if you’re yet to see what Assure360 can do for you, why not contact us? We’d be delighted to give you a demo, and set up a free pilot of the system.
Written by Nick Garland on Thursday February 9th 2023
Site welfare is something that’s all too often overlooked on asbestos-removal jobs. We’ve all worked on sites with incredibly inadequate facilities, whether it’s too few loos, unsuitable washing facilities, or just nowhere to sit and take a break.
One of the main reasons it’s so common is that a lot of these projects are quite short term. Sometimes it’s just one or two days. Management can become too focused on the complexity of the job itself, which leaves welfare as an afterthought. Another issue is that these short-term jobs are typically in flats and houses, and by their very nature they prevent access to on-site facilities. For example, asbestos removal of the riser in a toilet might mean that the loo is available for the first couple of hours, but then it’s very much not for the rest of the day.
But while the management may forget to provide it, the Health and Safety Executive (HSE) views adequate welfare as a fundamental basic necessity for workers. In fact, during the COVID restrictions, Prohibition and Improvement Notices that mentioned COVID almost exclusively targeted inadequate welfare.
Management can also misinterpret the ‘so far as reasonably practicable’ (SFARP) exception, thinking along the lines of “It’s a one day job. What’s it reasonable for me to allow for?”. The law sets out a basic expectation of toilets, a supply of hot and cold (or warm) water for washing, changing facilities, drinking water, and somewhere to eat and rest. You’d have to have very significant reasons to not provide the minimum.
The HSE is reinforcing this with the release of some new guidance: Construction – Welfare Standards. I’m grateful to Graham Warren at ACAD for flagging it up in the latest newsletter. The guidance is actually for its own officers, not us, but understanding how the HSE will be looking at the subject is crucial: inspectors are directed to take ‘appropriate’ enforcement action to secure compliance.
HSE action
The guidance makes clear that where toilets, hand basins, drying rooms etc. haven’t been provided, or they’re inadequate, an Improvement Notice (IN) is the appropriate response. There will be local exceptions that might even dial this up to a Prohibition Notice (PN), for example if there’s an imminent risk to health. But the guidance also states that prosecution should be considered for repeated offences – or even if the first offence is bad enough.
The penalties for getting it wrong are therefore significant. The guidance quotes multiple regulations and guidance documents, weaving together a framework for the inspectors to justify enforcement action. The most significant is obviously the Construction (Design and Management) 2015 (CDM 2015) regulations. Among other things, these introduced clear definitions for all parties in construction (including clients), removing the cloak of invisibility that had allowed some clients to claim ignorance.
In practice a client needs to create an environment where work can be carried out with the appropriate welfare facilities in place. If the works involve a specific fenced-off construction site, use of the client’s own facilities should not be the default option. The regs go on to say that where there isn’t such a specific construction site, clients are legally required to make their own facilities available for use.
Domestic clients are the exception. CDM 2015 and the HSE guidance both recognise that they don’t have legal duties, so it falls to the principal contractor (PC) and other contractors to ensure compliance.
Contractors’ duties
Principal contractors have clear and unavoidable duties to provide facilities from prior to the start of construction work, all the way through to the end of the project. Contractors’ duties shadow those of the PC. If there are several contractors on a site, it’s a case of liaising and cooperating with the PC. If there’s only one, then all of the duties are yours.
That ‘so far as reasonably practicable’ get-out gets some clarification with regards to welfare. In essence it’s about weighing the measures needed against the sacrifices involved. Crucially, though, it’s weighted in favour of health and safety, i.e. it’s assumed you’ll provide the welfare, unless you can demonstrate it would involve ‘grossly disproportionate sacrifices’. Cost is not the primary focus and shouldn’t be considered ‘disproportionate sacrifice’.
Toilets are mandatory (i.e. you don’t get to say they’re not reasonably practicable), and there’s a hierarchy, with flushing toilets at the top and chemical Portaloos very much at the bottom. The guide states that for large or long-running sites the provision of ‘only portable toilets’ is considered insufficient – as it would very much be reasonably practicable to provide better.
All welfare facilities must also be ‘readily accessible’. What this means varies with the urgency: rest breaks can be planned, so the distance to travel can be greater. Toilet facilities, however, need to be much more convenient. The guide quotes BS6465(1) as stating that construction sites should provide WCs within 150 metres of the workplace. Arranging toilet use with a café that’s 10 minutes’ drive away would not cut it.
For the same reason the numbers of cubicles are also pre-determined:
| Number of people | Cubicles (not urinals) |
| 1-5 | 1 |
| 6-25 | 2 |
| 26-50 | 3 |
There are some other key requirements:
What I find particularly interesting about this guidance is the way that it details other regs and approved codes of practice (ACoPs) detailed in the guidance. It features them along the lines of ‘areas to be considered when considering enforcement and prosecution’. But to think of it another way, I always like to ask one of my favourite questions: ‘Why are we doing this?’ – as understanding why is often the lightbulb moment.
Of course, there’s the basic human dignity of providing somewhere to go. Not to mention hygiene 101: wash your hands before you eat. But as these often don’t seem enough reason, how about:
I’m sure you can think of more examples and, if they apply to the work you’re doing, the HSE inspectors will doubtless think of them too. Perhaps it’s time for those of us who design and commission work to stop treating facilities as so much of an afterthought, and start planning work around the comfort of the people who do, after all, do the work on the ground.
Written by Nick Garland on Wednesday September 14th 2022
Photograph courtesy of Horizon Environmental Ltd.
Consider the case of a client with a boiler room, once liberally splattered with asbestos-based insulation material. It’s comparatively easy for a licenced asbestos-removal contractor (LARC) to strip out the bulk of the material with low-risk techniques, but it soon becomes a case of diminishing returns. The less asbestos there is remaining, the harder it can become to remove it, and the greater the expense.
When faced with asbestos insulation residues on semi-porous substrates like brick and concrete, removal of the final 0.1% of asbestos-containing material (ACM) is very challenging. Residual fibres can be embedded in pits, dimples and micro cracks – making the traditional, low-impact approach of hand scraping accompanied by suppression and shadow vacuuming extremely time-consuming. Often, the removal ends in an admission of failure and encapsulation – a process all too likely to be repeated by another LARC in a few years time.
Clearly this is quite an unsatisfactory position for the client. They’re spending a vast sum of money on asbestos removal, only to be presented with a residual risk that still has to be managed – and probably at the same level and cost as before.
It’s therefore easy to understand the temptation of aiming for 100% ACM removal in a boiler room. It’s broadly possible through the use of two competing techniques: blasting (using wet media), and low-vibration needle gunning. Both have their champions – two LARCs I know are very firmly in opposing camps. In the red corner we have: ‘Blasting is faster at cleaning than needle guns, even when you factor in the additional clean-up’. And in the blue corner: ‘Needle gunning is a much simpler method that creates lower exposure and is easier to manage’.
Comparing blasting and needle guns
It’s important to start with one thing that both needle guns and blasting have in common: you’re not supposed to use either technique unless you’ve already done your best to remove all significant deposits of asbestos through traditional methods. This means scraping off all but the last miniscule ACM traces manually – accompanied by sprayed surfactant and shadow-vaccing.
With the use of needle guns on the rise, I’ve also heard that HSE inspectors are coming across it more. And, quite rightly, they’re asking whether the method has been properly assessed. I’ve heard that while the HSE isn’t tremendously keen on blasting, it has questions over the vibration levels of needle guns (more on this later). Clearly this is crucial to any technique or technology: it must be properly assessed, and your team must be competent to use it.
Both techniques present their own challenges which need to be considered if you are aiming for spotless. You’ll need to balance all of the pros and cons when you complete your risk assessments.
Noise and vibration
The noise levels of blasting vary dramatically depending on several factors including the choice of media, and even the location (boiler rooms usually reverberate more, for example). Due to this uncertainty, Quill – one of the leading blasting manufacturers – is a little cautious about publishing noise figures. Essentially, it’s not possible to predict an accurate noise level unless you know the usage situation. Quill says that noise at the lance could be >110dB(A). Vibration magnitude is negligible at around 0.2m/s2. That’s 10 times lower than the EC-specified minimum level for unrestricted hours of work.
Needle guns used to be known for their huge vibration levels, but recent pneumatic variants are much improved. The one I am familiar with is the Trelawny VL303, whose manufacturer claim it has a noise level of 109.5dB(A), and vibration of 2.3m/s2. However, there does seem to be some question marks about this very low figure. Not least because normal operation is to use two hands… Clearly, unlike with blasting, whatever the HAVS (hand-arm vibration syndrome) data is, it is not negligible. If you plug 2.3m/s2 into the HSE’s HAVS calculator, you get a remarkable nine hours and 27 minutes to reach the lower exposure action value (EAV). However, worst case vibration data from the manufacturer indicates something nearer to 90 minutes or below. I understand Trelawny are conducting some independent HAVS testing and the report will be out soon.
Whether blasting or needle guns are selected, then effective hearing protection will be mandatory. Vibration needs to be looked at, and hopefully accurate data will be available soon
Waste
There’s no avoiding the issue, blasting will add waste to the project. Quill states there’ll be 0.5-1.1kg of material created per minute of use. You’ll need to consider the increased manual handling issues that this will create for the project. These may be exacerbated if you have to lug waste up from the basement – especially if there is any restricted access involved.
Fibre release
Both techniques are high-impact, high-disturbance methods that should only be used on trace residues. Both techniques use different approaches to keep dust and fibre levels down. As the name suggests, wet blasting uses water – which atomises as it hits the substrate with the blast media. This will probably be most effective when removing chrysotile residues, as amphibole fibres such as amosite or crocidolite are hydrophobic (they repel water).
Needle guns use the shadow vac technique, and come with dedicated vac cowls. The H-Type vacuum is attached at point A in the diagram, providing effective local exhaust ventilation (LEV) at the point of disturbance (B).
As with any asbestos-removal technique, you’ll need to test that exposure is as low as practicable, and investigate any elevated results.
The real problem for wet blasting comes with all that water; Quill states that you’ll be using 2-4 litres per hour. Water vapour plays havoc with air testing – whether that is standard optical or electron microscopy – occluding the filters so they can not be read. The default position seems to be that you should assume a high fibre release, and use supplied-air respirator (RAS) masks.
By contrast the needle and shadow vac technique is relatively easy to test. The results I’ve seen are favourable, with an average of 0.06f/ml (fibres per millilitre of air), highest reading of 0.12f/ml, and lowest of 0.01f/ml.
Water vapour
The high humidity of blasting creates two more issues that you need to allow for. Water does not play well with a negative pressure unit (NPU)’s HEPA filter. To counter this, Quill provides moisture vanes that work along with the standard pre-filter to protect the HEPA.
Another impact – especially in the cooler atmosphere common to basements – is that we often hit the dew point and visibility falls dramatically. Neatly, Beacon’s recirculating NPU incorporates an in-line heater to prevent this. You cannot underestimate the impact of low visibility on supervision – vision panels and especially CCTV will both become very limited, and you’ll need to identify enhanced supervision techniques to combat this. You may consider having a deputy supervisor in the enclosure to be the eyes of the lead supervisor outside.
Other considerations
There’s a rather unfortunate, nebulous bag of additional issues that you will need to factor in. As we’ve established, both blasting and needle gunning are very, very noisy, clearly requiring hearing protection. The follow on effect of that is that operatives will not be able to hear you when you try to communicate with them, whether routinely or in case of an emergency.
This is further compounded by the visibility issue discussed above – i.e. you can’t see them, and they can’t hear you. You might consider flashing beacons, activated externally, at the point of work, which will allow you to stop work quickly and easily. The extra internal supervisor would also help with this.
You also need to consider that needle guns are quite heavy, in addition, large-bore compressor hoses and metal coupling will add markedly to this. You should always step down to the narrower whip lines to minimise this manual handling issue. Generally, you should also consider fatigue as a hazard.
Another consideration with blasting is that the media obviously goes somewhere. Predominantly this will be the floor, but if operatives are working near the enclosure wall it could damage the sheeting and lead to a breach. A less obvious risk is that the media can be blasted into inaccessible voids, resulting in a spread of asbestos. Your design process needs to include careful planning of how and when to use the technique to avoid this.
Finally, while it’s not really part of the risk assessment, needle guns are much more mechanical than blasting equipment. As such they have moving parts, and need to be maintained through periodic stripping down, cleaning and oiling. They are also vulnerable to icing up where the weather outside is cold. For both cleaning and good maintenance, Trelawny recommends ISO22 low viscosity anti-freeze oil.
It’s hard to argue against a client’s wholly understandable desire for an asbestos-free boiler room, and these two techniques are the only options that get close to achieving it. As with all asbestos removal methods, however, they bring a range of issues that have to be individually and collectively assessed. It’s our job as professionals to understand the complexity, and ensure that we manage all of the risks.
Written by Nick Garland on Wednesday May 11th 2022
At last year’s FAAM conference, Colette Willoughby delivered a raw and personal presentation about the personal safety of female analysts. It was eye-opening and shaming, and it focused the minds of all who heard it on the urgent need for change.
Colette herself set out what needs to change in our industry, and with the support of many colleagues I’m encouraged to see things moving in the right direction. Asbestech – one of the UK’s leading asbestos management companies – has announced that it is retro-fitting locks to all of its decontamination units (DCUs).
Asbestech contract manager Alessia Gilbey commented that “it’s a simple method to provide an additional reassurance to myself and other women that may be required to use a DCU”. And it is simple – a quick, inexpensive change to make existing DCUs safer workplaces.
I’m also encouraged to see that DCU manufacturers themselves are paying attention. I’ve recently been invited to meet with SMH to discuss potential design changes that would improve personal safety in the DCU, and I’m hopeful they’re able to put something effective in place.
It’s heartening to see that the bravery of Colette, and the other female analysts who spoke to her, is resulting in real change. It’s up to everyone now to keep the pressure on, and continue making the improvements to equipment, training and behaviour that our female colleagues demand and deserve.
Read more here about Colette’s talk, Female analysts and four-stage clearance testing
Written by Nick Garland on Wednesday May 11th 2022
As you’ll no doubt all be aware, the Work and Pensions Committee has been conducting an inquiry into the Health and Safety Executive (HSE)’s approach to asbestos management. In its report, published in April, the committee calls for a raft of changes, including a proposed 40-year deadline for the removal of all asbestos from public buildings.
Predictably, I’ve already seen people commenting that 40 years is far too long, while others say the reverse and wonder how we’ll ever pay for it! But the asbestos management report is a substantial document, and I wanted to look at the changes and recommendations behind the headline. The committee has heard many opposing views from industry experts, campaigning groups, charities, victims groups, government ministers and the HSE itself, and to its credit has produced a well-balanced set of proposals that deserve greater scrutiny.
The balance of evidence
Like most in our industry, I’ve been following the progress of the inquiry and the evidence presented to it. Everyone has their own opinion, but there were a couple of witness testimonies that I took issue with. In December, Professor Julian Peto of the London School of Hygiene and Tropical Medicine suggested caution over the mandatory removal of all asbestos, pointing out research in the 1980s showing that airborne asbestos levels in buildings were higher six months after removal than before.
I’ve no reason to doubt that research, but I have first-hand knowledge of how comparatively poor asbestos-removal techniques were when I started my career in the 1990s. In the 1980s it must have been even worse, as analysts weren’t even doing independent clearances back then. I’d be astonished if the equivalent research, conducted today, didn’t reach a very different conclusion.
In February, HSE chief executive Sarah Albon claimed that the 60% drop in asbestos enforcement notices over the last 10 years was evidence of better compliance. However, when we compare 2012/13 with 2019/20 (the most recent pre-pandemic period for which figures are available):
What this suggests to me is that the HSE targeted the companies it thought would be the worst offenders, and pretty much saw what it expected, giving it a much higher hit rate of Prohibition Notices.
If that’s the case, then the figures rather undermine the suggestion of improved compliance. Instead, they suggest to me that some companies are simply avoiding having their collar felt, and I’m not alone. As Darren Evans of Asbestos Training and Consulting (ATaC) told the committee: “There are lots of people out there taking an informed view that they are unlikely to be visited, and therefore corners are cut.”
Let me stress that I’m not blaming the HSE here. Over the 10 years to 2019/20 the organisation experienced a 46% drop in funding – it did well not to cut visits even further.
Regardless of the details, the committee has managed to distil a mound of evidence and come up with some well considered proposals. The report’s key recommendations are:
As I said, these are all well-balanced proposals. It’s hard to argue against any of them, but I can see a particular subset with the potential to bring the fastest, greatest benefits. Five particular points would have an obvious, immediate impact on safety and good management:
Just these five, if acted upon, would have the potential to transform our knowledge and our ability to act appropriately. Let me explain further.
Competence of dutyholders
We are long used to the absolute requirement for access to competent health and safety advice – why should it be any different for asbestos? This has always been something I care about, in all my work with clients – the central pillar is to ensure that they end up more capable of asking the right question at the right time. For large organisations, having this requirement might mean having someone on the books who is P405 qualified. For smaller companies it might be having the right health and safety consultant on retainer.
Digital Register
Whatever we are doing, we’re likely to be more diligent and careful if we know our work is going to be checked. We see the evidence of this all the time in asbestos management: there’s a difference between an unannounced audit and one where they knew you were coming, or a visual inspection with the UKAS assessor in attendance. If organisations know that they’ll be uploading their asbestos survey to the HSE, they’ll do it better. Just the very fact that a survey or register could be independently checked at any time will benefit standards hugely.
Accreditation of Surveyors
It’s always been unexplained why asbestos analysts must be accredited, but it’s only advisable for companies conducting a survey. It’s very costly to get and maintain accreditation, so it’s only really accessible to established organisations. But being un-accredited doesn’t necessarily mean bad – smaller firms and individuals may be unwilling or unable to go down that route.
Regardless, we currently have a situation where UKAS accredited companies must compete commercially against non-accredited companies and individual surveyors – that’s not a level playing field.
Interestingly the recommendation in this regard is that accreditation should be compulsory for the individuals conducting surveys, not the firms employing them. This change would immediately level things out: large and small firms along with individual surveyors should be able to demonstrate competence.
I’d expect that surveyors would welcome this professionalisation of the industry, as the employment power would be devolved down to them. The change wouldn’t allow companies to shirk their responsibilities, as it will remain their duty to ensure competence of the workforce.
Research
If the priority is to focus on schools and hospitals, just how big is the problem there? The short answer is that nobody knows, as very little research has been done. What we do know is that some schools have a good deal of asbestos-containing materials in them. We also know that young lungs are much more susceptible to damage from asbestos, and that youngsters are practically (and legally) considered not to be competent. This latter is crucial as ‘competent workforce’ is an important pillar in the current approach to managing in situ.
I’ve discussed the unique problem of asbestos in schools before, and the risks faced by teachers and pupils alike. As with other public buildings, UK policy has been to manage asbestos in place, but what little research this is based on is now well and truly out of date. Before we settle on any change in policy, we need to know for sure that removal is the safer option.
Increased Enforcement
I’ve said it before, but the 1974 Health and Safety at Work Act is a beautifully written piece of regulation. If you render it down to a couple of sentences, it essentially says: “The employer must be an expert in their field, must understand the risks, and must eliminate them as much as they can. And if they don’t there will be dire consequences.”
The author was very cleverly identifying that proscriptive legislation would never be able to keep up with the best and safest way to operate across multiple industries in a changing world, but that a regulator would be able to use the power of hindsight to identify if something could have been done better.
And that’s where the HSE comes in. It’s vital that they are out there making checks and serving up enforcements to ensure things are done better. To recall Darren Evan’s point, companies need to know they cannot cut corners, because they will be caught.
Will it happen?
I’ve focused on these five very positive recommendations, because together they would improve our knowledge of the problem, make the scale of the issue visible, and leave dutyholders in no doubt that they need to act appropriately. However, they would also represent an increase in costs to business, an increase in health and safety regulation, and an increase in funding for a public body (the HSE).
None of these things have been particularly popular with the UK government for a decade or more. For several years there has been an effective ‘one in one out’ rule for new regulations. Consequently, much of the HSE’s excellent guidance of late has had to be be sneaked out as appendices to Asbestos Network meeting minutes – not exactly the ideal situation.
I would like to end, though, on a point of optimism, from Charles Pickles from the campaign group Airtight on Asbestos. Responding to the report, he told me it was a rejection of the existing line that asbestos was “yesterday’s problem: nothing to see here”.
Instead, he said, it’s a move to acknowledge that “we have a problem with current exposure, and we need a plan to deal with it”. The Work and Pensions Committee has asked the HSE for its plan, and soon. And as Charles put it: “That really is a significant move.”
Written by Nick Garland on Thursday February 10th 2022
One of the main objectives of the new analysts’ guide is to reduce analyst exposure, by clarifying what is licensed work, and what falls under the analyst’s remit. But the HSG 248 document is now massive, running to 238 pages. In cases where it hasn’t been fully read and understood there’s the potential for misunderstanding.
I’ve been thinking about this after a recent project, in which a difference in understanding created the risk of costs spiralling out of control. The project in question related to a wall that had sporadic asbestos insulation spatters underneath an imperfect layer of paint. The job was to scrape the wall back and then encapsulate the residues – so far so normal.
However, in this case the analyst was unwilling to enter the enclosure prior to encapsulation. This created the potential situation that, if the analyst wasn’t happy with their visual after encapsulation, the licensed asbestos removal contractor (LARC) would have to strip all the paint off and start again. The analyst’s view was that the project was not yet finished, the enclosure was therefore live, and that in line with HSG 248, ‘they do not do live enclosure entry’. For the LARC it represented a very expensive project risk.
So what does the guidance suggest? On the surface of it, HSG 248 is fairly ‘clear’:
The nature and extent of exposure will depend on several factors including the activity, the type and condition of the ACM and the effectiveness of any controls. For example, all entry into asbestos enclosures carries a risk of exposure to airborne fibres. Analysts should avoid as far as possible entering ‘live’ enclosures while removal or remediation work is still being carried out. If entry into a ‘live’ enclosure does occur there will be potential exposure to asbestos fibre concentrations above the control limit or short-term exposure limit.
Para 1.6, Pg 11 HSG248
However, if we look deeper (and when I say deeper, I mean we have to read to page 193) there’s more guidance under the section “Clearance for specific situations” – the bold is mine, for emphasis:
Inaccessible or impossible to remove asbestos
Spray-applied asbestos is often found in crevices or holes through walls where pipe work or girders run. These may leave asbestos residues that are impossible to remove. In these cases, the analyst may permit the use of non-flammable sealant such as foams or plaster to fill the hole and seal the asbestos within it. Before the sealant is applied the analyst must be satisfied that as far as reasonably practicable the asbestos has been removed.
Para A5.78, Pg 193 HSG248
Use of encapsulant or sealant
Where asbestos has been sprayed on to porous surfaces (e.g. breeze blocks, bricks, plaster and concrete), it is almost impossible to obtain an asbestos-free surface. The analyst should satisfy themselves that further removal is not reasonably practicable, and should advise the contractor and/or building client to seal the residual asbestos with a permanent proprietary sealant. The visual inspection can restart once the sealant has been applied and dried. In these circumstances encapsulation of asbestos should not take place before the analyst has seen the residual asbestos. A note should be made on the CfR and recorded in the asbestos register and management plan for the premises.
Para A5.80 Pg 194 HSG248
This second paragraph matches my example situation perfectly, but in fact both paragraphs make clear that the analysts must complete a visual before the LARC encapsulates any remaining asbestos to make sure (essentially) they are not hiding anything. While the general guidance in paragraph 1.6 says that analysts should avoid live enclosures ‘as far as possible’, this subsequent guidance takes us to the heart of the issue – a live enclosure is one where removal work is ongoing. In these situations, the enclosures are not ‘live’ as all possible removal has been finished.
Going further
In fact, my personal preference is to go a step further. I believe all such projects should be broken down like this:
With either option after the stage three air test, the client gets valuable extra information that they wouldn’t get with the traditional approach. Based on what happens, they know to what degree they need to be cautious about the wall.
This is my personal preference, and I’d be interested to hear opposing views on it, so let me explain my reasoning. First, read this rather long paragraph from the Analysts’ Guide:
There may be occasions when some asbestos is to remain in situ in the enclosure. It may be that only damaged asbestos lagging is being removed from pipe work, and that undamaged material is to remain; or it could be that only a proportion of asbestos ceiling tiles is being removed. The analyst should have been made aware of this in the discussion on the scope of work as part of stage 1. The contractor should have checked the condition of the remaining ACMs as materials in poor condition could lead to a failure in the four-stage clearance when the analyst checks. If the analyst does find asbestos materials in poor condition these will need to be dealt with (eg repaired, encapsulated or removed, all of which actions are likely to need agreement of the building client and the involvement of a licensed contractor. The four-stage clearance should stop at this point and the contractor/building client should be informed. The four-stage clearance should not restart until the matters have been rectified. Any remaining ACMs in good condition should be recorded in the CfR so that the building client can update the asbestos register and management plan accordingly.
Para A5.76 Pg 192 HSG248
My logic is that if we are working on a wall that only ever had occasional splashes of debris – the risk starts at low. If:
The selection of the scrape and vac technique is therefore intentionally leaving some asbestos in by design, and paragraph A5.76 is the reference that we should be looking to. This allows the analyst to make a judgement that all loose paint has been removed, and the asbestos left in by design would be noted on the four-stage clearance (4SC) certificate.
While we haven’t 100% removed the asbestos-containing material (some is being left in by design), stage two has passed, and there is no absolute need for encapsulation. But if the air test subsequently identifies a problem then we must encapsulate. On the other hand, if the whole 4SC passes, and we still want to encapsulate, well, that’s an ultra risk-averse decision that can be completed as a non-licensed activity.
I appreciate this is possibly a left field opinion, but I believe it addresses what we are trying to do which is understand and mitigate risk, rather than blindly follow what we’ve done before.
Written by Nick Garland on 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 protected]. This is a totally confidential inbox that is monitored by Colette, Jean Prentice and Sara Mason, who are all on the working group set up in the wake of FAAM to address the issue.
Written by Nick Garland on Thursday November 11th 2021
After the roaring success of last year’s virtual FAAM conference, the team made an early, risk-averse decision that this year, FAAM Asbestos 2021 would also be online. We will all be ‘gathered’ for the 17th and 18th of November for an intense and varied programme of speakers that includes industry experts, doctors and academics.
So what ground is the conference covering this year? It starts with a deeper look into the use of AI in reading asbestos slides. You may remember that I wrote about Marvin the robot after Frontier Microscopy’s presentation at the 2019 European Asbestos Forum conference.
We were told how it was used in Australia, where getting analysts to remote places was a huge challenge. Instead, samples are sent to a central lab for analysis, where Marvin uses AI to analyse the samples more quickly and accurately than humans. At FAAM we’re going to hear from Frontier, Ethos and xRapid on where the technology has gone in the last couple of years.
After the morning break, we will be looking at more traditional approaches. But even here there’s a new slant – discussing how certain changes to how we take the sample can give us the opportunity to improve the limit of quantification.
The rest of the first day – with one notable exception – will be focusing on the European Chemical Agency (ECHA) Assessment for Asbestos. You may not be aware, but the ECHA produced a substantial report back in February, seeking consultation on its recommendation that the occupational exposure limits (OEL) be dramatically reduced.
You’d wonder who would argue against this kind of proposal, but in fact it seems that the science behind the move may be flawed, and the recommendations impractical. Andrey Korchevskiy, Robin Howie and John Hodgson are all speaking on the subject then, after the break, Gary Burdett will present the ECHA opinion.
Outside the ECHA chamber
The ECHA exception I mentioned is Dan Barrowcliffe, who will be presenting on the exposure study that he led on removal operative exposure during licensed work. Dan has been very present at FAAM conferences, but has recently taken up a post at the new Building Safety Regulator. I’m sure he’ll be at future conferences, though: we all know there is no real escape from the asbestos industry!
Day two kicks off with a series of talks on the UK’s asbestos legacy, with a focus on mesothelioma and treatment advances – a subject that is ever present in our minds. Before lunch we look at the law, and the role of the expert in asbestos claims. After the gripping mock trial last year I expect this will be a compelling examination of what can happen when it all goes wrong.
We round up the day with site-based issues, ranging from communication between clients and LARCs, and Sara Mason’s talk on the challenges to site analysis. Several talks here sound promising. I’m eager to hear from Dale Timmons of further advances in thermochemical asbestos destruction – a technology that could hold the key to preventing landfilling.
I’m also interested in Graham Warren’s look at the implications of ‘net zero’ for the asbestos industry. And finally, given that the four-stage clearance (4SC) is a topic close to my heart, I’m hopeful that Colette Willoughby will be telling us about some practical solutions to the additional challenges faced by female analysts during the 4SC.
It’s a packed programme, and my experience from last year suggests that – despite the virtual format – the event remains unmissable. You can sign up for FAAM 2021 via the BOHS website. I hope to ‘see’ you there!
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.
Looking ahead
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!
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:
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.
Practical steps
In any event, make sure your contract managers know what constitutes a standard solution – give examples in your procedures. Few licensed asbestos removal contractors (LARCs) have anyone in-house competent at designing scaffolding. If you’re using scaffold as the basis for a soffit enclosure, make sure the scaffolder knows it is unlikely to come under TG20, and that it will need a design. Similarly, don’t embellish Heras fencing with branded sheeting. If necessary, use the (expensive) netting designed for this purpose.
The supervisors, as usual, are the checkers. They need to confirm that the operative built, installed or erected the item correctly. Recording these checks can be time consuming, but it’s something we’re all used to. That’s exactly why we designed the Assure360 Paperless solution, which slashes supervisor administration time by up to 80%.
So in summary, the things that LARCs build or erect are always temporary works, and you ignore that fact at your peril. By following some simple steps we can repurpose the activities we routinely do anyway, ensuring that the job gets done properly, checked appropriately, and that we’re observing the proper guidance throughout.
Want to see first-hand how Assure360 Paperless streamlines routine safety checks, and makes the data available for insight and analysis? Get in touch now for your free demo!
Written by Nick Garland on Thursday May 20th 2021
We’ve said it before and it remains true: the construction industry is an inherently dangerous business. According to 2019/20 figures, the sector recorded the highest number of fatalities of any industry, and the second highest rate of injury.
However, focusing on the top-level statistics overlooks a fundamental truth: that comparatively few workplace accidents happen truly without warning. All too often they’re the end result of a trend, or they become possible thanks to a blind spot in safety culture or supervision. Each year, lives could be saved and life-changing injuries avoided if we could better identify the conditions, oversights and company cultures that allow people to get hurt.
Without doubt, the most important pillar in driving down workplace accidents is to fully record and investigate them, along with the incidents and near-misses that often precede them. As we’ve written before, the accident triangle theory suggests that any near miss could be a warning of a potential accident. It’s essential to capture and analyse data – and act on the insight to prevent something worse.
The construction industry takes this seriously, and many employers do it well, but the same is less true in the specialised world of asbestos management. Historically, it’s something we’ve been rather poor at.
Across all industries, a culture of continuous improvement demands that any accident, incident or near-miss is recorded so that lessons can be learned. Recording should be mandatory, and any barriers to it should be removed: that’s the philosophy behind Assure360 Incident.
Incident exists precisely to minimise the barriers to recording safety incidents in the workplace. Providing a simple and intuitive interface, it improves record keeping. With the Assure360 dashboard, it helps provide the analysis and insight that organisations need to improve.
Now, we’ve improved the app itself, with a refreshed interface and a raft of other features. Chief among these is that, like Paperless before it, Assure360 Incident 2.0 is now available on Android.
Other major improvements include:
Above all, we’ve focused on making Incident 2.0 as streamlined as possible. By making incident and near-miss reporting easy, our aim is to help you make it quick and comprehensive. Why not download Assure360 Incident now, and start strengthening your health and safety culture?
Written by Nick Garland on Wednesday January 13th 2021
For Assure360, our Audit app has a special significance. Originally launched back in 2014, Assure360 Audit is at the heart of our streamlined and paperless health and safety auditing system. In 2017 we gave it a major refresh, adding more functions and a fresher look. As we pass 10,000 audits, I’m excited to announce that we’re hard at work on version 3.0.
The latest version is going to be brilliant, but before I tease you with the improvements, I thought I’d recap a little on the history of the app, and how it’s tied into our own. The Assure360 system is the result of my nearly 30 years spent working as a health and safety professional, specialising in the asbestos industry. One of our most important product features is that we offer our customers the benefits of everything I’ve learned in my ‘day job’.
The genesis of Assure360 came when I was working as an embedded health and safety manager for several licensed asbestos removal contractors (LARCs). I was designing audit schemes, completing training needs analysis and competence systems, and undertaking the analysis of exposure results… again and again.
I’d created a series of interconnected Excel spreadsheets to help me complete the work, but there was still plenty of manual work involved. It was repetitive, time-consuming – and prone to error.
In the space of a couple of months I met an app developer and a database company, and had a bit of a lightbulb moment. I realised that I needed an app to record the data quickly, and a database to do the tedious legwork in the background. Most pertinently, I realised that if I needed it, so would other professionals in our industry, and that’s how Assure360 and the Audit app came about.
From the start, the app accomplished most of what I set out to achieve, but our ethos has always been to work with our community to continually make things better. After three years of using the app myself and gathering feedback from our early customers, we updated it to version 2.0 – essentially the version you’re using today.
Version 2.0 had some big improvements over the original. It was better to look at, and added some powerful new functionality. Most importantly we added the ability to craft bespoke audit question sets, giving the app immense appeal to non-asbestos construction firms and specialists like demolition teams. It’s a testament to Audit’s appeal, usability and usefulness that it’s rated 4.5 out of 5 on the App Store.
“I just find it so, so easy to use, so simple. It doesn’t take up half the time of my own audit system – where I’m uploading photos, copying and pasting information. It’s none of that, it’s quick. It’s a great app really.”
Chris Pedley, CP Safety
Roll forward another three years or so, and we’re delighted to be working on another major upgrade. Just like with version 2.0, changes for version 3.0 will be the result of our continued experience using the app. And I mean ‘our’. I still use Audit daily in my ongoing work in health and safety, but the whole Assure360 team is tuned in to the feedback and suggestions we get from the ever-expanding Assure360 community.
So what’s new in version 3.0? As with our recent updates to the Assure360 Paperless and Incident apps, one of the biggest new features will be Android compatibility. With the release of Audit version 3.0, the entire Assure360 suite will be available for Android devices for the first time. This lowers the barriers to entry for our system, as Android devices tend to be a fair bit cheaper than those from Apple. Just as importantly it gives our customers more choice and flexibility, for example letting them run Assure apps on rugged tablets in the harshest environments.
Other improvements will include the ability to log multiple photos with an item, and the instant upload of audit findings – helping ensure teams are working with the very latest data.
We’re also excited to be adding new self-help tools that will let users craft their own bespoke audits. Much like when we introduced bespoke question sets, this allows auditors and other users to tailor the app and our system to the exact work they’re doing. The goal is to streamline the process further, and remove any obstacles and manual workarounds that could introduce errors.
“My clients aren’t just getting a box-ticking exercise, they’re benefitting from my expertise and feedback, and the software’s ability to help produce actionable information.”
Chris Pedley, CP Safety
We’re working on lots of other improvements alongside those main revisions, but like everything we do, the upgrades are a community approach. If you’ve got a feature to suggest, an issue to flag up, or any other idea for making version 3.0 as good as possible, please do drop us a line.
Want to discover more about the refreshed and improved Assure360 apps? Read more about our health and safety and asbestos management apps
Written by Nick Garland on Thursday December 10th 2020
Who would have thought that a virtual conference could keep you glued to your seat? If I’m honest, not me. Times are busy for us at Assure360, and so when I looked at the programme for the BOHS/FAAM conference there were a few slots where I thought “I might be able to miss that.” More fool me – the two days were absolutely riveting.
So here’s my attempt to sum up a few of the highlights from the conference. I haven’t included all the sessions, but if you’re a FAAM member I think the plan is for you to be able to log in and browse them all.
The control limit
The conference got underway with a history lesson, but one that really set up so much else for the two days. The Health and Safety Executive (HSE)’s Sam Lord took us on an interesting journey through how we arrived at the current asbestos control limit. She even explained the logic behind the name, and the important shift in thinking that it represented: that is, that there is no ‘safe’ limit.
Sam went on to give us an update on the HSE’s new Analysts’ Guide, which does finally seem to be nearing release next year. The guidance will contain two changes to the air testing criteria which I think are brilliant.
The first is that the UK will come in line with the World Health Organisation (WHO) method for sampling against the control limit. The four-hour time weighted average (4hr TWA) test has always been very challenging – not least because many tasks (when you take off breaks and decontamination) are not four hours long. But whilst they are difficult, these are legally mandatory duty-of-care tests.
The new guidance introduces important flexibility in the pump flow rate:
| Application | Sampling rate (l/min) | Min air volume 25mm ⌀ filter (litres) | Minimum number of graticule areas to be examined | Calculated airborne concentration at the LOQ |
| 4-hour control limit | 1-2* | 240 | 100 | 0.04 |
| 10-minute short-term exposure limit | 4 | 40 | 100 | 0.24 |
| Specific short-duration activities | 4 | 120 | 100 | 0.08 |
| Assessment of suitability of RPE | >0.2-4 | 40 | 100 | 0.24 |
* Note the change from 1 to ‘1-2’. This allows for higher volume tests in a shorter period.
** Brand new test – see below
Sam’s talk linked nicely with a presentation by Dan Barrowcliffe on the second day, about personal monitoring. I was able to catch up with Dan after the conference for some more thrilling personal monitoring chat (I appreciate perhaps not everyone shares my enthusiasm).
He and I discussed how the minimum volume column is important. For a 4hr TWA test this volume is 240 litres, which means you need to run the pump for between two and four hours. If you’re running it for two hours, where do the other two hours of a 4hr TWA come from?
If you have good enough data, based on accurate personal monitoring, you can interpolate them from your anticipated values. This opens up exciting potential for Assure360 users, as with 18,000+ personals already in the system we can potentially convert an awful lot more tests into the difficult-to-achieve standard. Watch this space – we will have a new report to do just this in the new year.
Short-duration activities
The other crucial change to the guidance – and something I’ve been calling for for years – is the new ‘Specific short-duration activities’ test. This is essentially what a well run, competent LARC does all of the time: test the peak high fibre release activities to measure the effectiveness of their methods.
Now that it is in the guide, analysts will know what parameters to test against, finally allowing LARCs to do their job properly. I personally would like a little more flexibility (a flow rate of 2-4, rather than 4), but now I’m being picky.
At the end of day one, Dan did an updated review of his four-stage clearance (4SC) project (see my summary of the preliminary findings here), and how it has influenced the new analyst guide. The project showed some encouraging improvements in analyst behaviour and performance on site. One of the main points however, is the application of a hard limit of 10 minutes on how much cleaning can be done within the 4SC. Equally importantly, this shouldn’t be done by the analyst at all. This change should bring an end to nightmare jobs where a hoard of operatives are trying to clean in the enclosure during the inspection itself.
The day of the trial
Day two started with an innovative mock trial, which moved from fascinating to excruciating as we watched the full horror unfold. The ‘case’ examined what could happen when an organisation that thinks it’s on top of asbestos policy discovers the hard way that it hasn’t been. The actors were all asbestos professionals – and somehow were able to tone down their knowledge levels to stay in character. I still don’t know how they did it, but it was absolutely enthralling.
The afternoon focused on asbestos technology. I found it all very interesting, particularly when learning about Hysurv’s use of drones to conduct visual surveys of buildings. I was lining up plenty of ‘well, it won’t work because…’ and ‘all very well, but what about…’ comments, only to find them comprehensively eliminated by their capabilities. One highlight was watching a drone fly through a tangled ceiling void!
The ability to survey a roof in vivid detail, showing the precise location and accurate measurements of presumed asbestos materials, was incredible. The equipment also seemed well capable of surveying confined and restricted-access spaces – potentially improving safety and raising surveying standards in the most challenging jobs.
So, far from skipping sessions I found myself largely glued to my screen for the full two-day programme. If virtual conferences are the shape of things to come – and it looks like they might be for a few months yet – then consider me an enthusiastic convert.
Written by Nick Garland on Thursday December 10th 2020
Let’s be honest, nobody’s going to look back fondly on 2020. The arrival of Covid 19 and the ongoing pandemic has ruined plans, destroyed businesses – and sadly cost far too many lives. But while it’s been a challenging and sobering year, new vaccines promise better times ahead. And many of the changes forced on businesses will be the basis for better trading as we turn the corner.
The year everything changed
You can’t look back on 2020 without discussing Covid 19. Mushrooming from a small outbreak centered in Wuhan, China, to a global pandemic in just three months, the virus has left few aspects of our lives untouched. From the outset, the lockdowns necessary to control the disease’s spread created social, financial and emotional scars that may take years to heal.
For many businesses, it was quickly clear that the pandemic represented an existential challenge. We in the construction and asbestos-removal sectors have been luckier than some, with much of our work allowed for most of the year, but still these have been difficult times.
So far, so obvious, but for the rest of this post I want to focus as much as possible on the positives from this year – the new tools and solutions that have helped us carry on at the pandemic’s peak, and which will continue to make business better as we emerge.
A lucky break with tradition
In April we marked a year since the Health and Safety Executive (HSE)’s introduction of the new digital service for asbestos-removal licensing. Fraught with challenges – and, for a short time, horror stories – the long overdue overhaul had a difficult few months, but in retrospect it got here just in time.
By the time the pandemic hit, the HSE had ironed most of the creases out of its new system. The industry, too, had a better understanding of what the HSE expected – helped in part by innovations such as Assure360’s custom licensing module.
As inspectors were grounded under lockdown conditions, the move to digital assessments began to seem uncannily well-timed. Asbestos-removal contractors could renew their licenses and continue working, where otherwise they might have been dependent on inspector visits that couldn’t happen.
A new way to work
If 2020 is remembered for anything other than Covid, it will be as the year that accelerated digital transformation. Global businesses were already on the path, digitising existing processes and inventing new ways to work, but few smaller firms had been caught up in the wave. Covid changed that at a stroke – forcing even the smallest firms to embrace Zoom, cloud-working, and countless other digital tools.
For the asbestos removal industry, it’s a big change. We’ve been around for a while, and our highly regulated industry previously depended on meticulous paperwork. Assure360 has been selling the technology to change that for some years, but 2020 has seen a dramatic growth in interest, as more firms sought out ways to support socially-distanced working.
This is particularly true for Assure360 Paperless. Our digital supervisor support tool removes the site paperwork from asbestos projects. In itself, this cuts the amount of materials being passed around between workers, but during the pandemic another benefit grew in significance.
By automatically synchronising site data with our cloud-based system, Assure360 presents managers with reports and analysis based on the freshest data from the project. Many users have relied on this to reduce their visits to site, confident that Assure360 is providing the insight they need to manage jobs remotely.
Zoom spreads
As the year drew on, people began to use these new digital tools more extensively. In the asbestos industry, briefings and supervisor meetings started to happen over Zoom. In the wider world, recruitment and induction was increasingly carried out remotely – some people are still working from home in new jobs where they’re yet to meet their colleagues!
And as it became obvious that the usual round of conferences and seminars wouldn’t happen, organisations began to think about how they could deliver essential events virtually. ACAD switched its regional meetings to a virtual platform, for example, while we provided a webinar on Covid-safe working.
While the biggest events like the Hazardous Materials Expo have had to be cancelled altogether, academic conferences like BOHS and FAAM were able to go ahead online – to great effect.
As businesses, event and training providers all get greater experience with digital tools, it’s likely we’ll all continue to do things in new ways as the pandemic begins to recede. For example, several of our Paperless customers are planning to continue remote management, with fewer site visits. As Phil Neville of Asbestech pointed out, aside from helping greatly through the pandemic, our paperless technology has helped him reduce vehicle mileage in line with the firm’s ISO 14001 undertakings.
For events, digital access could help more delegates ‘attend’ even far-flung conferences. Next year’s iMig2021 – originally due to be held in Brisbane this year, then postponed to next March – will now take place virtually in May. While it’s a shame for people who would have made it to Australia, the pivot to a virtual setting means that far more people can now take part.
For many, 2020 has been a miserable year, and it may be a few months yet before things get better. 2021 begins with the end of the Brexit transition period and whatever fallout that brings, and it may be some months before the vaccination programme really bears fruit.
In the meantime, paperless and remote technology continues to help us navigate the pandemic, and promises to improve efficiency and create new possibilities in the future. After a difficult year, that’s a welcome source of hope as we go into 2021.
Written by Nick Garland on Wednesday November 11th 2020
If it wasn’t clear already, the arrival of second lockdowns in England, Wales, and several European countries confirm that this crisis will be here a while longer yet. Despite promising news from various vaccine trials – most notably the Pfizer/BioNTech candidate – mass vaccination programmes seem unlikely before Q2 next year. In the meantime the world needs to do its best to control the virus without disastrous damage to the economy.
What the UK government is trying to achieve with the second English lockdown is almost insanely difficult. The public needs to be fearful enough of the disease that it takes control measures seriously, optimistic enough that it can see light at the end of the tunnel, and yet still go out to work so that the economy does not grind to another halt. This despite a cycle of lockdown and release that’s likely to continue until late spring next year.
Processing what we need to do to come out the other side is going to be crucial. Construction and manufacturing have been targeted as protected parts of the economy, and the messaging is clear: keep safe, but keep going.
I’ve already written a couple of articles focusing on how to tackle the challenging working environment that Covid presents. Here I’m going to briefly revisit this and look at the latest advice. But it’s also important we acknowledge that changes such as increased remote working are going to be here to stay. I want to look at why embracing them, and making them part of a future strategy, is important to business success post-Covid.
For all contractors, the first place to start is with the most recent version of the Construction Leadership Council (CLC)’s safe operating procedures (SOPs). At the time of writing these were up to version six, dated 20 October.
The SOPs have an excellent section structured according to the hierarchy of control, which succeeds in being both detailed and clear. However, the key points from this version are:
The challenges that these guidelines present will of course vary depending on the site. Space is crucial. In smaller, enclosed sites with limited access, maintaining a safe separation is likely to prove challenging. On large sites with big workforces, there may need to be staggered start/finish times – and careful management of queues entering the site or core facilities like the canteen.
Other issues will tax everyone – for example, the difficulty of simply getting staff to the site in shared vehicles. The government’s guidance remains much the same: increased washing and cleaning, barriers, bubbled teams and short journey times. However there’s a key difference in lockdown two: public transport isn’t yet being reserved for key workers. If you must use it, cover your face.
When it comes to face coverings, we’ve certainly moved on from when I last wrote. At that time, Royal Society president Venki Ramakrishnan was calling for face coverings to be part of standard procedures. Now the CLC agrees – up to a point. While the SOP clearly states that we should not be recommending additional PPE due to Covid, it does specify face coverings in certain confined situations.
My view – and it is certainly something I have practiced since April – is that we should be wearing face coverings when we can’t guarantee social distancing. On busier sites, and particularly indoor projects, that has been most of the time.
What hasn’t been discussed much is the problem of wearing face coverings with glasses, whether that is readers, safety, or – as in my case – both. Anyone who has the problem of fogging is balancing the risks of impaired vision against the protection of their fellow workers. For what it’s worth, the only face masks I have found that fit close enough to reduce fogging are the ones with the metal strip on the bridge of the nose.
Whatever face covering you wear, you should absolutely avoid dust masks with a valve. Remember that we’re wearing face coverings not to protect ourselves, but to disrupt our breath out – and therefore protect others. Valved masks keep glasses clear because they let our breath escape unimpeded. For similar reasons, face shields offer little other than immediate protection if someone coughs on us.
The most difficult, draconian measures will be gone with the pandemic. But I wanted to stress the importance of stepping back and looking at positive changes that will continue to reap benefits beyond it. Companies who have been forced to find ways to reduce site traffic and enable remote working are finding new efficiencies that will support a stronger recovery when the pandemic is over.
Let’s not kid ourselves – there’s no substitute for boots on the ground when it comes to construction work – but the technologies businesses put in place now will have a longer-term benefit than ‘just’ minimising the risks from Covid.
We know that remote workplace technologies reduce the risk to managers and supervisors, and lower the chances that they spread the virus to or from their colleagues. Yet at the same time they introduce new and lasting efficiencies. Video calls reduce the need to travel, saving on expenses and letting managers use their time more effectively. Video briefings and inductions help reduce face-to-face contact, but they can also be more flexible and convenient. We all recognise the difficulties caused by having to shut projects down for an afternoon just to get the whole team together, now this can just be an hour at the end of the shift where everyone logs in to a call.
We see the same benefits from removing the paperwork involved in asbestos management and health and safety auditing. During Covid, the Assure360 Paperless app has helped customers reduce the amount of paperwork and other material going on and off site, and improved visibility for managers as they seek to maintain quality while minimising site visits. In the words of GreenAir Environmental director Graham Patterson: “If it wasn’t for Assure360 I think we’d have a major issue with having paper method statements, everybody touching it, and the virus sitting on that surface which you can’t wipe down.”
However, the benefits to streamlining critical safety checks predate the pandemic, and will continue after it’s gone. Customers who have adopted Paperless and other Assure360 solutions as a way to improve their ability to manage jobs in a socially-distanced environment have already discovered the big efficiency improvements we can deliver in normal times. “The Assure360 system has streamlined the company massively,” adds Graham Patterson. “And if we were to go back to the old paper systems I think we would struggle.”
The second wave of lockdowns remind us that we’re not done with Covid yet. We’re continuing to improve our products to provide essential support now, and more worthwhile benefits in the long term. After redesigning Paperless to make it even easier to use and even more of a time-saver, we’re working on an update to Assure360 Incident – our accident and near-miss reporting app.
The same principles apply as with all Assure360 products: an effortless user interface, letting even non-technical users improve and streamline essential health and safety record keeping. And with this update, Incident will also become the second Assure360 app to gain Android support, reducing the cost of entry to the Assure360 system.
Now more than ever it’s imperative to cut paperwork and supervision overheads, while simultaneously ensuring greater compliance. And when things are better, the efficiencies your business discovers today will continue to deliver benefits and competitive advantages as the economy recovers. I think we should all see this as evidence that the light at the end of the tunnel is actually a brighter future.
Written by Nick Garland on Wednesday November 11th 2020
With Covid still here and big events like the Hazardous Materials Expo already postponed – again – this year’s conference season promises to be very different. Happily, some events are still going ahead, albeit virtually.
On 18-19 November the British Occupational Hygiene Society (BOHS) and the Faculty of Asbestos Assessment and Management (FAAM) are presenting what will be my first ever virtual conference. While I’m not sure what to expect, I am indeed looking forward to it.
The conference programme kickstarts with a review of the asbestos control limit: the limit for asbestos concentration beyond which legally imposed controls become necessary. Sam Lord of the Health and Safety Executive (HSE), and Rick Pomeroy of ABP Associates, will be talking about the history and challenges of air testing during works. I’m curious to know whether they’ll expand the conversation to take a broader look at licensed contracting and testing against the contractor’s own internal procedures – often much more stringent than the old control limit.
After the break on day one it’s the turn of Garry Burdett, principal scientist at the Health and Safety Laboratory. He’ll be giving us the lowdown on the implications of work done by the European Chemical Agency and the USA’s Environmental Protection Agency. Are we set for a change in the control limit? Sam Lord takes the final slot before lunch to give us a progress report on the Analysts’ Guide. Astonishingly my white paper on the draft is still relevant, several years on.
After lunch I’m keenly looking forward to what most people might see as a minor part of the sessions. When we became aware last year about asbestos identified in some marble, my concern was not so much ‘is that kitchen worktop hazardous’, as whether the worker cutting the slab to size was adequately protected. We haven’t heard much on that yet – hopefully we will on 18 November.
In the morning of the second day the programme will cover some interesting developments in duty holder training, along with the HSE’s view on where we are failing in this area. The final afternoon is taken up by technology and myth busting sessions – always a great way to end a conference!
If you have not signed up, I urge you to do so. In a year where so much of the usual industry networking and discussion has been blocked by the need to maintain social distancing, the FAAM conference takes on even greater significance than usual. And as with so many long overdue catch ups – while we can’t be there in person, doing so virtually is the next best thing.
Written by Nick Garland on Thursday October 15th 2020
Back at the start of July the Health and Safety Executive (HSE) released its annual accident statistics, covering 2019 / 2020. Among these, as always, are figures detailing the worst case situation – people who die while at work.
The headline figure is encouraging. Over the period, 111 workers were killed – a significant decrease on previous years. Over the previous period 149 workers had lost their lives, and the average over the past five years was 137.
While this is clearly good news, the figures have – like so much else – been affected by the Covid-19 pandemic. Economic activity dipped in February and March – alarmingly in many sectors – so some reduction in injuries was to be expected. Those of you who work on construction sites will know they were eerily quiet at the end of Q1, only recovering near to full speed toward the end of the lockdown.
Our own Assure360 figures back up that impression, with a drop on year-on-year audits. In the past 12 months, 1,790 audits have been completed, whereas in the previous 12 months it was 2,048. That’s a 13% drop, against a background of rising subscriber numbers through the year, with most of the reduced activity seen between March and June. Thankfully we are now back to more normal rates, indicating that at least with Assure360 users, we are seeing some recovery.
How dangerous is construction?
If we go back to the HSE figures, we can drill down a bit to get more detail on how this year compares to last:
| Sector | Fatalities 19/20 | Fatalities 18/19 | 5yr average (19/20) |
|---|---|---|---|
| Construction | 40 | 30 | 37 |
| Agriculture | 20 | 32 | 27 |
| Manufacturing | 15 | 26 | 20 |
| Transport | 11 | 16 | 14 |
| Wholesale and retail | 6 | 18 | 9 |
| Waste and recycling | 5 | 7 | 9 |
| Administration and support | 6 | 10 | 4 |
| Other | 8 | 10 | |
| Total | 111 | 149 |
As you can see, all sectors saw the drop that you might expect against a backdrop of reduced activity – with the exception of construction, which instead experienced a 33% rise in fatalities. The obvious question is, “Why?”
The HSE’s report points out that “in statistical terms, [the] numbers are small and subject to fluctuation”, but construction still looks like an outlier.
Superficially, things look more encouraging for the sector if you examine the fatality rates expressed per 100,000 workers. When viewed this way, we can see that agriculture and waste are significantly more hazardous industries. But again, construction is the only sector showing an increase.
| Sector | Fatalities per 100,000 (19/20) | Fatalities per 100,000 (18/19) |
|---|---|---|
| Agriculture | 5.96 | 9.21 |
| Waste and recycling | 4.57 | 6.05 |
| Construction | 1.74 | 1.31 |
| Transport | 0.69 | 1.00 |
| Manufacturing | 0.52 | 0.92 |
| Administration and support | 0.38 | 0.62 |
| Wholesale and retail | 0.10 | 0.31 |
The per-sector view makes it clear that the agriculture and waste industries face serious safety challenges. Construction is inherently hazardous, too, but effective legislation such as the Construction (Design and Management) Regulations 2015 (CDM 2015) ensures we have tightly controlled working procedures. Even so, that’s cold comfort when the normalised rates above confirm that the increase in fatalities isn’t down to an increase in workers. The hard truth is that we just failed to keep our people as safe as in previous years.
Look at the detail of the HSE figures and we see that working at height and related issues (for example, dropped objects) are by far the biggest killer – they make up 42% of all fatalities. While we can’t identify from the report how many of these deaths are in the construction and asbestos industries, height is clearly a hazard we encounter frequently.
Interestingly, there’s been a small increase over the 18/19 figures, where height-related incidents were a factor in 38% of fatalities. Perhaps this is an indicator of where we may be going wrong. Is the sector as a whole taking its eye off its most significant risk?
Again, we can shed further light on the HSE figures by examining our own. Assure360’s community-based approach to health and safety means that our users benefit from aggregated figures recorded across all auditing and near-miss reporting on our system.
Auditing and near-miss reporting have always been the traditional methods we use to identify and mitigate safety issues. So what does our data tell us about height-related non-conformance?
| Question Text | 18-19 | 19-20 | % Difference |
|---|---|---|---|
| RA (Height) | 27 | 8 | -70% |
| Tied (scaffold) | 23 | 13 | -43% |
| Double hand rails (scaffold) | 22 | 8 | -64% |
| Scaffold (Fans) | 18 | 6 | -67% |
| Safe access between lifts | 16 | 11 | -31% |
| Inspection (Scaffold) | 13 | 8 | -38% |
| Scaffold (Design) | 13 | 14 | 8% |
| Scaffold (Gates/hatches) | 12 | 4 | -67% |
| Ladders / Hop Ups (Suitable) | 9 | 3 | -67% |
| Scaffold (Boards) | 8 | 12 | 50% |
| Scaffold (Matches Design) | 7 | 6 | -14% |
| Scaffold changed by site team | 5 | 4 | -20% |
| Inspected (ladder & podium) | 4 | 2 | -50% |
| Scaffold (Condition) | 4 | 5 | 25% |
| Double hand rails (tower) | 3 | 2 | -33% |
| Ladders in use (where podiums could be) | 3 | 2 | -33% |
| Ledger Bracing | 2 | 0 | -100% |
| Inspection (Tower) | 2 | 2 | 0% |
| Ladder & Podium (condition) | 1 | 0 | -100% |
| Lifting Plan (method) | 1 | 0 | -100% |
| Training (Height) | 1 | 0 | -100% |
| Trip Hazards (scaffold) | 1 | 0 | -100% |
| Work at Height (rescue plan) | 1 | 0 | -100% |
| Tower (condition) | 0 | 1 | 100% |
| Unprotected openings (scaffold) | 0 | 1 | 100% |
| Total | 196 | 112 | -43% |
| AUDITS | 2048 | 1790 | -13% |
In fact, it reveals that observed height related nonconformances among our users have gone down dramatically, from 196 to 112 in year-on-year comparison. That’s a 43% drop in observed issues, whereas (as we covered earlier) the number of audits fell by only 13% during the same period.
That means one of two things. Either Assure360’s users are bucking the apparent trend in the industry, and fewer height-related issues are there to be seen. Of course, that would be great, but the figures could instead show that – perhaps like the wider industry – we’re not looking hard enough at this area.
This is the age-old problem of auditing: no matter how good you are, there’s always the chance of blind spots. As the circumstances behind some of the annual fatalities would doubtless reveal, being ignorant of this can be catastrophic. All the more reason to ensure you include external, independent audits in the mix, to help you challenge systemic bias or shortcomings in your processes.
Historically the UK has been the best in the world at bringing people home safely from work. This is absolutely an achievement to be proud of, but these figures remind us that safety is something we must all work at. Especially in high-risk industries, we can never be complacent. As health and safety professionals we should be redoubling our efforts to give workers the protection they deserve.
And if you can, it’s best to learn from other people’s lessons as well as your own. One advantage that Assure360 can offer its users is that they don’t have to wait for annual HSE reports to see what is happening in the industry – our shared benchmarked data is available 24/7.
Written by Nick Garland on Thursday October 15th 2020
The last six months or so have been, to put it mildly, challenging. Since Covid-19 first gained a foothold in the UK, the restrictions on businesses and individuals have had a huge impact on the economy. At the same time, the toll on public health has been staggering. As the UK braces itself for ‘Covid winter’, many face an uncertain outlook.
Against this backdrop, there are of course positive stories – there have been boom times for home improvement, furnishings and supermarkets. The construction industry hasn’t been quite so lucky, but it’s not the worst hit. Work continues – and for many asbestos workers, existing stocks and experience with PPE meant that it never stopped.
The pandemic is by no means over of course, and at Assure360 we’re determined to help our customers ride it out as safely and successfully as possible. I wanted to take a moment to talk about the things we’ve been doing to try and help. And, as we prepare for more disruption across the winter, flag up a couple of other things we’ve got in the pipeline.
Improved apps
The first and most important thing we’ve done is to offer a free upgrade to our Platinum subscription level to those who aren’t already on it. Platinum includes the Assure360 Paperless app, designed from the outset to replace a supervisor’s site paperwork with the electronic recording of safety checks and information.
In normal times one of Paperless’ main benefits is a big uplift in supervisor and back office efficiency, but during the pandemic the app’s role in cutting site traffic has become even more important.
Electronic record-keeping reduces the paperwork that has to go back and forth, and provides management with an up-to-date, remote view of any developing issues, helping them manage more effectively with less time on site. As Graham Patterson, director of GreenAir Environmental put it: “Assure360 [Paperless] itself has streamlined the company massively, but it’s helped greatly under the lockdown.”
At the same time we released a new, improved version of Paperless, which now supports Android devices as well as iPads. The most significant change is a completely reimagined Site Diary feature, designed to minimise the amount of text entry by supervisors. Now almost every imaginable entry is covered by drop down menus, and evidenced by photos when needed.
We’ve also updated our system to reflect the changed circumstances we’re all working in. For example, we’ve added Covid-specific audit questions.
More help and advice
We’ve always prided ourselves on the help we offer our customers, both when initially setting them up on the system, and with the day-to-day questions and issues that arise. During the pandemic we’ve been very aware of the difficulty of travel, and the need to cut down on face-to-face meetings, so we’ve been working especially hard to improve our support for those new to the system.
We’ve improved and added to the Assure360 Help Centre, creating more “How to…” videos to support the quick and easy rollout of Assure360 to your team. For customers adopting Paperless as part of their response to the pandemic, these have become a central part of inducting staff.
“One of the things that was a Godsend were the videos on how to use Paperless,” explains Phil Neville of Asbestech. “There’s one for supervisors – like a 10-minute long video – on how to use the tablet on site. It’s very instructional. It runs through from logging on to the system to closing a project down, very succinctly.
“We used that video as the core of our induction because we weren’t able to bring supervisors in and do face-to-face training – because we were avoiding unnecessary personal meetings.”
Phil Neville also explains how the Android tablets bought for Paperless became essential to Asbestech’s ability to support remote working. “We had Zoom put on all the tablets so that we can have training sessions and screen sharing with the supervisors remotely. Alongside Paperless, we added virtual meetings to our toolbox.”
This ability of Android and iPad tablets to support more than just Paperless helps customers increase the return on investment from adopting the Assure360 solution. In addition to the multiple benefits of Paperless itself, the tablets support other ways to work safely and remotely during challenging times. If we assume the average licensed asbestos removal contractor (LARC) has a site team of 10, then the average saving per year is in the region of £10,000 – even when you factor in the costs of Assure360. Even a micro LARC with just one supervisor would save money overall.
Doing more
Despite this, we’re aware that some firms are still struggling to get back on track after a summer of disruption to essential paperwork and administrative tasks. Particularly, there are concerns for some businesses as they approach licence renewal, with paper site records yet to be processed, and vital evidence not available for easy entry on the HSE’s online form.
We’re doing everything we can to help new customers – and those upgrading to Paperless – get their existing data onto our system so it’s available to support licence applications and the proper management of their work. And we’re continuing the free three-month upgrade to the Platinum subscription level for those who aren’t yet on it.
We’re also working on new and improved versions of both the Assure 360 Audit health and safety auditing app, and the Assure360 Incident near-miss reporting app. Like Paperless, the updated versions will be available on Android for the first time, meaning we’ll support a far wider range of devices. And as Android tablets are generally cheaper than iPads, the cost of entry to Assure360 will fall further.
These are difficult times, and we’re not out of the woods yet. We’re working hard to support our industry and communities, but if there’s any way we can help you more, do please get in touch and let us know.
Written by Nick Garland on Tuesday August 11th 2020
Confined spaces and asbestos removal often go hand in hand, yet the lack of understanding about risks and controls could be putting people in danger.
As I discussed in an article last year, the Health and Safety Executive (HSE)’s confined space rules changed back in 2014. The changes were subtle, though. The minimal fanfare around them has meant that – even six years on – those that commission projects and their appointed consultants still miss much of the point. But the fact that licensed asbestos-removal contactors (LARCs) are unwilling or unable to correct the misguided instructions they’re getting has the potential to make dangerous situations worse.
To recap briefly, there are two triggers that together will make a work area a ‘confined space’. The first is whether access to the area is substantially confined, with ladders, ducts, and ‘enclosures for the purpose of asbestos removal’ specifically listed. The second is whether one or more of five proscribed hazards – fire, heat, gas, or free-flowing solids or liquids – are present. In essence, if the access arrangements restrict people’s ability to get in or out of the workspace, and there is a risk of sudden death, then the confined space regulations apply.
What’s The Hazard?
It seems simple, but the nature of the hazard is absolutely critical to determining what the correct controls should be. The proscribed hazards are for the most part quite different in the risks they pose:
It only takes a moment’s thought to realise that the controls to mitigate risk from explosion, say, are entirely different to those required for drowning, poisonous gas or elevated temperatures. In fact, the controls required for any single hazard could actually make other risks more serious. Despite this, what LARCs often see is an insistence from their clients on implementing the stock controls for poisonous gasses – regardless of the situation.
This problem is particularly serious if we consider ‘increased body temperature’. Elevated body temperature can cause loss of coordination and serious health risks, and untreated can quickly become a major risk to life.
In warm weather, many typical asbestos enclosures – in roofs, for example – are going to become confined spaces by risk of heat. But when contractors realise that an area is a confined space, the common response is to require equipment such as an escape kit. Not only will an escape kit do nothing to help, but the extra bulk might make matters worse. And the outcome could be catastrophic.
Read more on safe working at high temperatures.
So how do you avoid catastrophe? Firstly, whether you’re the client, principal designer, principal contractor or a subcontractor, you must be aware that all asbestos enclosures satisfy the first trigger for the confined spaces regulations.
Secondly, and most important, as soon as you confirm that a second trigger is present, you must understand in detail what the hazard is. If you can’t eliminate it, you need to implement controls specifically to deal with that hazard.
The threats that trigger a confined space are different in their nature, and there is no one-enclosure-fits-all approach to properly managing them. The consequences of applying inappropriate controls could be as bad as – or worse than – not managing the risk at all. And if you’re imposing the wrong controls on a subcontractor out of ignorance you could be liable for the consequences.
Written by Nick Garland on Wednesday June 10th 2020
When it comes to working in confined spaces, hot environments are the new challenge that the asbestos-removal industry needs to get its head around.
I say ‘new’, but as I wrote in an earlier article, the Health and Safety Executive (HSE)’s confined space rules changed back in 2014. The changes were subtle, though, and the minimal fanfare around them has meant that, even five years on, some confined space training courses still miss much of the point.
To recap briefly, there are two triggers that together make a work area a confined space:
In short, if the access arrangements restrict your ability to get out, or that of emergency responders to get in, and there is a risk of (frankly) sudden death, then it is a confined space, and the confined space regulations apply.
I want to focus on one of the five proscribed hazards: ‘loss of consciousness arising from increased body temperature’ – or simply, working in high temperatures. Normal body temperature is between 36.1°C to 37.2°C. If it rises above 38°C, something serious is going wrong. Heat stroke – a body temperature above 40°C -is fatal without urgent attention.
It’s important to remember that these are body temperatures – not the working environment. While humans can cool themselves when the air temperature is higher than body temperature, if they’re active, or wearing heavy clothing, much lower temperatures can prove dangerous. The same is true if there’s raised humidity – sweat is slow to evaporate when the air is already saturated.
Asbestos workers are particularly vulnerable to high temperatures, as many of the controls we introduce to address the asbestos issue make it very difficult for our bodies to deal with heat. Impervious overalls prevent effective sweating, masks stop regular hydration, and the rigmarole of exiting the enclosure is a barrier to rest periods.
Therefore, ANY asbestos enclosure where it could get hot should be considered a confined space. There are some obvious ones, such as boiler rooms and ducts with hot water or steam pipes. But there are some that come at you from the leftfield, for example any open air enclosure in the summer, along with roof voids, rooftops, soffits, contaminated land and so on.
So what do you do? You may be able to eliminate the hazard, for example by isolating a boiler. The asbestos enclosure will still have restricted access, but as the second trigger has been removed, it is no longer confined.
Of course, there will be situations where you can’t remove the risk, and if you absolutely can’t (the client wouldn’t like it is not enough!), you need to try and reduce it. There are dozens of imaginative ways you might be able to do this depending on the source of the heat:
Even after you have reduced the temperature, the risk may remain. If so you will have to monitor it very carefully, and control the residual risk. It’s here that people often overreact, or more accurately, respond with controls which don’t address the fundamental risk.
When someone says confined space, the some consultants’ knee jerk reaction is often to introduce measures like gas detection, 15-minute escape kits, harnesses, tripods and so on. However controls are only useful if they are specific to the hazard. If the risk is pockets of poisonous gas, then this could be a good design. However, if the only proscribed hazard is heat, the escape kits could make matters worse – why carry more heavy kit during an already tough job?
If a confined space is so primarily because of a heat risk, you need to develop something different. The following are pointers and areas that you should consider when designing the project.
Fit and healthy is the key. Anyone unwell or recovering from an illness will be more prone to heat exhaustion and ultimately heat stroke.
Hydration – make sure that plenty of drinking water is available, and that workers drink it before and after each work period. Don’t forget the means to access it – it’s not good enough to have a tap on site if there are no cups!
Staff need to understand how to recognise early symptoms of heat stress in themselves and their colleagues. They need to know what to do if they see these signs. It’s critical to have qualified first aiders on site to be able to spot, intervene and help in these situations.
Heat stress symptoms can include any or all of:
Heat stroke has similar symptoms, but sufferers can accelerate through them very quickly to collapse.
There are ways to monitor the health of operatives, and depending on the risk assessment some or all of these should be included in the plan
We’re not just interested in temperature, but in the effective temperature – taking into account other factors that may increase the risk for workers. For that we use wet-bulb globe temperatures (WBGTs), which factor in the effects of humidity, wind speed and infrared radiation (sunlight and other heat sources) on our ability to stay cool. Fortunately, these days we use electronic WBGT meters, which meansmean we no longer have to do all the calculations ourselves. There is no maximum safe working temperature, you will have to assess the lowest you can practically get the enclosure down to – and compare to that.
Slow, with frequent breaks. This will mean regular transiting through the decontamination unit (DCU) and an acceptance of low productivity. Regular breaks will also allow the supervisor to monitor the workers’ condition.
The enclosure should be designed to maximise the amount of cool air introduced. Consider the case of a roof void, a common example of what’s now clearly a confined space. These are enormously hot in the summer, so avoid the temptation to block the only access with a roving head! Use the natural leakiness of the roof tiles and eaves, and reverse the air-flow.
Communication and supervision become critical where workers are exposed to immediate risks, including heat. Work plans must ensure excellent communication, and the ability for 100% external supervision. There can be no lone working, and everyone should be on the lookout for symptoms in their mates.
You can’t do much about the overalls, but you might consider cool suits and air-fed masks, which may deliver cooler external air directly to the worker.
Review the normal ‘absolute no’ of entering a confined space to affect a rescue. This standard rule is to prevent would-be rescuers becoming another victim, brought down by the same gas, water, free-flowing solid or fire as their colleague.
With heat it’s different: in all but the very hottest environments (where frankly I’d be questioning whether you can control the risks at all), heat exhaustion has a slow build up with warning signs. Clearly there is a critical role outside the enclosure – contacting emergency services and making preparation for first aid – but once that is done, should the supervisor rule out helping the rescue? You will need to assess the risks of this, rather than blindly following the ‘standard’ rules.
You should always ask, “How will I get ‘Big George’ out of this work area?” The plan might involve trolleys or harnesses to help them walk, and if there is a vertical ascent, the infamous tripod.
What to do? I can’t stress enough: it’s critical to have qualified first aiders on site. Ideally both within the confined space, and up top. Heat stroke is very serious and can rapidly accelerate through the symptoms to collapse. Whilst the first aid response to heat stress, exhaustion and stroke is similar, – reduce the body temperature, liquids, salts and rest. However, if there’s any suspicion of heat stroke there should be an immediate call to 999.
When the old guidance for asbestos removal at high temperatures was withdrawn all those years ago, there was nothing to replace it. Fortunately that changed in 2014 with this revision to the confined spaces regulations – it’s unfortunate that our industry awareness, and the quality of our training, is yet to catch up.
Whatever the potential hazard – fire, heat, gas, solid or liquid – confined spaces are incredibly dangerous places to work, and we should remember that the projects we design have a direct influence on the life expectancy of our teams. The risks of confined spaces need appropriate and effective controls. Merely copying and pasting them in from the last off-the-peg training course might lead to disaster.
Written by Nick Garland on Wednesday March 25th 2020
Updated on 20/04/2020 10:30
Whatever your business, I’m sure you are trying to get your head around the crazy new world that we are living in.
The asbestos removal industry is pretty good at hazard identification, risk assessment and mitigation and all our personal protective equipment (PPE) is of the required grade. The other way to look at the immediate future is that we have a particular skill set, in that we clean up contaminated surfaces whilst keeping our workforce safe. As an industry our core competence may be called upon in the COVID19 national effort.
The Secretary of state for Business, Alok Sharma, supportive letter to all businesses operating in the construction sector was seen as real boost for the entire sector. This encouraged many of the Tier 1 contractors to reopen sites and insist that their subcontractors support them.
This will present significant challenges in the coming weeks as we all try and follow the latest government advice. The Construction Leadership Council have issued Site Operating Procedures. The highlights of the SOP are:
The underlying point of all this is critically we need to observe social distancing. I’m going to reword that for clarity: physical distancing. Because the ‘social’ bit makes us think that it is something we consider after work.
Physical distancing is keeping two metres away from anyone that you don’t live with – that’s likely to mean everyone you work with. The HSE will be all over whether we are succeeding and have a lot of powers to close down sites if they feel it appropriate.
I’ve been considering how – and whether – we can continue to work safely in the current circumstances, and I wanted to share my thoughts in this post. But there’s a big caveat: I am not an expert virologist. Instead I’m drawing on my experience of hazard identification and mitigation. I believe these are all areas we should be thinking of. If you have anything to add, and especially if I have said something stupid, please shout asap.
Working through the steps to the following are some of the decision / hold points that we need to consider.
Let’s start by looking at the risk hierarchy:
If our starting point is that the only ‘safe’ place is in an individual’s own home, it is possibly helpful to think of any asbestos-removal job as though the site is thoroughly contaminated with rat urine or pigeon guano. But where does ‘the job’ start and finish? We have to change how we think. Where does the risk now start? What new areas do we need to think about?
The government guidance remains that with the exception of key industries, we should be attempting to carry on. Here’s a link to the latest guidance on what should and shouldn’t go ahead. Certainly with Work carried out in people’s homes, including repairs and maintenance, can apparently continue, provided they can maintain 2 metre distance from any household occupants AND the household is not isolating or where an individual is being shielded. Here’s a link to the detailed guidance.
There are some examples of projects that will obviously be needed, where we may be remediating an existing risk, or facilitating oxygen lines in a hospital. The example of an asbestos removal job to facilitate a kitchen installation whilst is less clearcut, is not actually prohibited.
Remember that the point of physical distancing is that if we cut the number of people those carrying the infection pass it on to, by just 33%, the knock on effect over time is enormous:
A graphic which shows how social distancing can reduce the spread of coronavirus. Credit: Dr Robin Thompson/ University of Oxford, via itv.com
Individual tasks should also be assessed – and where it is not possible to follow the social distancing guidelines in full, consider whether that activity needs to continue for the site to continue to operate, and, if so, take all the mitigating actions possible to reduce the risk of transmission. I go in to suggestions below.
You need to give very clear guidance to all workers on who should and shouldn’t come to work – and if they do turn up, when to send them home. Anyone who meets one of the following criteria should not come to work:
If a worker develops a high temperature or a persistent cough while at work, they should:
I would err on the side of caution.
Typically we might have a driver and two passengers in the front of a van. Clearly this is not physical distancing. You will need to start thinking how you can achieve this. Can the workers arrive at site separately via their own transport (remembering that public transport is for critical workers now)? Many operatives don’t drive, so how do you mitigate the risk?. Can you limit the number, for example by carrying only one passenger? Maintain travelling companions (i.e. keep to the same passenger). Face away from each other and open the windows to increase ventilation. Daily disinfecting of the vehicle cabin by the site team, no eating, drinking or smoking (all of which increase the chance of touching the face).
It could mean donning RPE, but half-masks have a limit for how long you should wear them. For longer journeys you’ll need to factor in regular breaks.
As a back-up it would probably be prudent to do regular full decontamination of the vehicles back in the yard – treat this like an ‘environmental clean’ with full face RPE and dilute bleach (1:60).
Again, physical distancing! Keep two metres away from anyone that you don’t live with – i.e. everyone you work with.
Again, is it possible to do the work and obey physical distancing? The nature of the property may help or hinder this (very small flats vs larger areas). Again consider the risk hierarchy. Just as with a site posing a psittacosis risk, we would ordinarily disinfect surfaces before we start, increase ventilation, introduce strict eating, drinking and smoking procedures, and require PPE (gloves, RPE and overalls). We’d also increase our washing frequency.
The normal challenge on sites is welfare, and that’s even more the case now. Again, if we are imagining that the area is thoroughly contaminated with rat urine or pigeon guano, we would obviously wash our hands before any break. We need to be thinking along those lines – but even more so. Workers should wash their hands on arrival at the site and then regularly after that. How can our guys frequently wash their hands for the required 20 seconds? They can use hand sanitiser if you have it, but this must contain more than 60% alcohol. Possibly better is a killer spray, with one person spraying whilst the second washes their hands.
Home-brew Sanitiser Recipe
I understand that this will come out much stronger smelling and thinner than you would expect. The ingredients are expensive online – but as you apparently only need a few drops, it should last. Remember that the advice is to ‘wash’ hands for at least 20 seconds, ensuring that every nook is thoroughly rubbed clean.
I received a photo from a truck driver at one of the UK largest construction sites on the first day of the lockdown. It shows an enclosed canteen crammed with people just inches from each other – clearly madness.
The standard operating procedures published by Build UK – so hopefully this is a thing of the past.
It shouldn’t need saying, but DO NOT USE CANTEENS. Everyone should wash their hands before all breaks. There should be no crowding into the toilets – give everyone plenty of space and extra time if needed. Individuals should bring their lunch and drinking water from home – remembering that those working in a warm enclosure will need to drink plenty. There should be no eating together as a team. Stay at least two metres apart!
Clearly, we are very well protected in the enclosure, although possibly less so on semi-controlled jobs. It may be worth considering full-face powered RPE for all works as that also prevents people from touching their face. Similarly, full transit procedures for all works may be a good idea. You will also need to consider staggered use of the DCU – allow the first operative to exit, before the next one starts to transit.
Thorough external cleaning – again using the dilute bleach solution (1:60). This should be done at the end of the project and before issuing it to site.
It’s much easier at the office, but still a challenge – again, the primary focus is physical distancing, so how do you achieve this?
It may be possible to have an unmanned reception for visitors and deliveries, showing a number people can call (on their own phone) to let you know they’ve arrived. This ‘high risk area’ could be disinfected after every ‘exposure’.
It needs to be remembered that the virus can, apparently, survive on some surfaces for several days. Staff should be encouraged to wipe down surfaces with dilute bleach or a soap solution, and frequently wash their hands.
However (and it’s a biggie), the advice is still uncertain. I started by saying that the government advice is that construction can go ahead, but the Mayor of London, Sadiq Khan, has said: “My view is no construction work unless it is for a safety reason.”
If, after all of this, you decide not to keep operating and you have spare stocks of PPE – our medics are in desperate need.
Further reading:
Build UK Site Operating Procedures – Protecting Your Workforce
HSE: Coronavirus (COVID-19): latest information and advice
Thanks to all those that helped with this note.
Good luck, stay in touch and we’ll get through this together.
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.