Written by Nick Garland on Wednesday May 27th 2026
A lot of our first-time conversations about Assure360 start the same way: what does it cost, and how much time can it save us? They’re reasonable questions. Time costs money, and anyone running a licensed asbestos removal business knows exactly how much of both gets consumed by compliance paperwork, exposure records, audit reporting and post-project administration.
But I think it’s the wrong question – or at least an incomplete one. The more useful question is what your team could actually do if it got that capacity back.
Nobody is sitting around idle in our industry. Supervisors, operatives, contracts managers and admin staff are typically working near their capacity. When you remove friction from their working day, the time you free up gets absorbed into everything else that wasn’t being done properly – or at all – before.
Which means the value of better systems isn’t really measured in hours saved. It’s measured in what those saved hours get used for.
When supervisors no longer spend significant parts of their day on paperwork – filling exposure records, completing site diaries manually or reconciling data after the fact – something shifts in how work gets managed. Supervisors are free to give better oversight, making faster decisions and catching issues before they escalate. The kind of hands-on management and knowledge sharing they’re actually there for.
For admin teams, the benefit looks different. Processing records manually is a drain of time and energy, but streamlining that workflow doesn’t just free up time; it reduces the error risk that comes with manual data handling, and it means information is available when it’s needed – rather than weeks later.
At management level, better data changes what’s possible. When audit results, exposure histories and compliance records are consolidated and current, your overview of your projects and people is more complete, and the strategic picture becomes clearer. You spend less time reconstructing what happened, and more time influencing what happens next.
To prove the point, we’ve built an ROI model based on typical team configurations across the industry. Even for a small operation – one supervisor running a team of four operatives – the estimated time saving across the whole team runs to around 478 hours per year, with an equivalent value of roughly £12,000. For a mid-sized team of two supervisors and six operatives, those figures rise to around 741 hours and £18,000. At four supervisors and ten operatives, it’s closer to 1,267 hours and £30,000.
The split across roles is also worth noting. In each scenario, the largest share of that saved time sits with the admin function – reflecting the sheer volume of exposure record processing that current regulatory requirements generate. Supervisors come second, with the saving driven primarily by streamlined exposure and RPE checks, plant checks and site diary completion. Managers gain less in raw hours, but the value there is arguably qualitative as much as quantitative: better data means better insight, and less time spent reconstructing the compliance picture.
None of this is about replacing people or cutting headcount. The industry doesn’t have a surplus of experienced and skilled staff, and most LARCs’ strongest assets really are their teams and the expertise they represent. Our focus is on empowering the people you already have to do more, better work.
So feel free to ask us how much time you can save. But also ask us what you can do with the safety, performance and efficiency gains you’ll unlock, and the value you’ll see from having your most experienced staff more available, informed and engaged in everything you do.
Try our Return On Investment calculator Assure360 ROI Calculator
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
This week the British Occupational Hygiene Society (BOHS) announced a package of measures to tackle fraud, including the launch of a National Register of Qualified Asbestos Surveyors. That’s a huge moment for our profession.
When BOHS, with its newly minted Royal Charter, launched its Faculty of Asbestos Assessment and Management (FAAM) in 2019, I joined immediately. It was clear to me at the time that asbestos professionals needed a proper home – a body that would represent the scientific and technical community as a profession, not simply as a trade interest.
Over the past two decades I have seen a gradual weakening of professionalism in parts of the sector. Standards blurred, competence diluted, and in some corners outright abuse of the system. It needed to be redressed, and FAAM felt like the organisation that could do exactly that. That’s why I later chose to join the Committee: to play a small part in helping shape and strengthen it.
The launch of a National Register of Qualified Asbestos Surveyors is a major step forward, and represents years of planning and work by BOHS and the FAAM committee.
The problem it addresses is real. Fraudulent operators, falsified certificates and unqualified individuals are not just defrauding householders and businesses – they’re putting lives at risk. Asbestos is unforgiving when disturbed, and poor surveying leads directly to unsafe removal, unnecessary exposure and avoidable disease.
This new register, developed by BOHS following consultation with the Royal Society for Public Health (RSPH) and aligned with United Kingdom Accreditation Service (UKAS) initiatives, will allow qualifications to be verified quickly and transparently. It will be an excellent resource for dutyholders and laboratories – whether UKAS accredited or not. For the first time they will be able to see exactly who is qualified to act as an asbestos surveyor.
This will be a register professionals can be proud to appear on. Verified surveyors will be able to use a logo, with an embedded QR code to provide clients with assurance of their certification.
The new register’s link to a voluntary complaints scheme is crucial. Recognition must sit alongside accountability. Frankly, who wouldn’t want to be part of a transparent verification and complaints process? And would you want those who didn’t working anywhere near asbestos for which you’re responsible?
Alongside a forthcoming Buyer’s Guide and Standards Statement, this represents a coordinated effort to restore clarity, competence and confidence. For me, this kind of action is precisely the reason why FAAM exists – and a very welcome step towards strengthening professionalism in asbestos assessment once again.
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 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 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 January 24th 2024
The Asbestos Network (AN)’s new guidance on personal sampling and exposure is very welcome, but it also contains a lot of detail, and requires some significant changes to the way things have traditionally ‘been done’. That’s why we organised our recent webinar, in which I aimed to give attendees a practical guide.
I’m delighted by how well it was received, and I’d like to thank everyone who turned up and took part in such an engaging Q&A session at the end. We were joined by nearly 50 attendees, comprising many old friends, but also some new faces. It was great to also welcome two members of the Health and Safety Executive (HSE), and representatives from our trade associations.
This guidance covers a very important topic that as an industry we have struggled with. It’s the first official guidance that the AN, and therefore the HSE, has provided to licensed contractors on the subject. Crucially, it contains some major departures from how LARCs traditionally approach personal sampling, which is why we wanted to offer the industry our support.
Our webinar explored practical steps on how to implement the guidance, and demonstrated how Assure360 can be used to achieve full compliance – at the same time as saving hours of work both for supervisors and the admin team. Although, like the guidance, it was focused on the needs of licensed contractors, we hope it was also helpful to analysts and end-clients.
Many of those who joined us later asked if they could have access to a recording, and we’re happy to share it again here. Please feel free to watch, and share it to anyone else who needs support or guidance.
As always, if you do have any further questions, or you’re keen to know more about how we can help you achieve full compliance, please do get in touch – we’re only too happy to help. If you’d like to go ahead with a free demo, book here.
Written by Nick Garland on Thursday January 11th 2024
We’re just two weeks into 2024, and 2023 already seems like a distant memory. It was an important year, though, so we’ve put together a quick look back at some of the key things that happened.
For me, one of the key themes of the year was a renewed focus on innovation and research. From FAAM taking an active role in researching working methods and techniques, through to the excellent and highly promising product development and fresh thinking presented at conferences, 2023 showed a lot of promise.
In March, FAAM held a unique workshop on the four-stage clearance (4SC), bringing together analysts and licensed asbestos removal contractors to examine the purpose of the 4SC, its potential conflicts, and how the two sides of our industry could learn from each other.
In October I was delighted to also be involved in a second FAAM project, investigating a new gel-pack removal technique for asbestos-lagged pipework. Both were featured in November’s FAAM conference, where my colleague Cat Holmes reported on the findings and actions from our 4SC workshop.
The summer brought some welcome news, as the government climbed down on the sunset clause initially contained within the Retained EU Law Bill. Had this made it into law, might have seen vital legislation – including the Control of Asbestos Regulations – struck from the statute books at the end of the year.
On a more personal level, July saw Assure360 hit the 15,000-audit milestone – an incredible achievement, underlining the wealth of data and experience behind Assure360 and its user community.
The summer holidays also saw a last-minute announcement that multiple schools would not reopen, while long-standing reinforced autoclaved aerated concrete (RAAC) was assessed. Many schools are still fully or partially using temporary buildings while they wait for affected structures to be made safe. It’s an awful scenario, compounded by the high proportion of school and other public buildings that also still contain asbestos.
The end of the year brought the shock announcement of ACTA – a new trade association with the potential to shake things up – and two highlights of the events calendar: the aforementioned FAAM conference, and the European Asbestos Foundation (EAF) conference. For 2023, another excellent EAF was given even greater credibility by stronger government buy-in – the Dutch state acted as co-sponsor. The presence of policy makers from across Europe added further weight to EAF’s uniquely brilliant approach.
As I say, a year of much promise, but in 2024 we need to continue building and improving. Changes driven by the Asbestos Network’s new personal monitoring guidance require us all to adapt – that’s the focus of our free webinar on 16 January.
Beyond that, the EU’s Asbestos at Work Directive, and by the more general push to renovate and refit Europe’s ageing buildings, will require us all to be open and receptive to new ideas. As I reflected at the end of last year, there’s a real danger that we in the UK could be left behind as Europe pushes ahead with better protection for its workers, and continues to be the driving force behind the innovation needed to make that happen. We in the UK must be sure to keep pace.
I couldn’t end without also mentioning our dear friend and inspiration, Mavis Nye, who very sadly passed away in November. I’ll always remember Mavis as one of the warmest people you could ever wish to meet. She led a seemingly miraculous life, being in remission for many years from the hideous disease mesothelioma following immunotherapy treatment. She leaves an incredible legacy in the Mavis Nye foundation, and all she and her husband Ray have accomplished in their campaign for an asbestos-free world.
Written by Nick Garland on Wednesday December 13th 2023
I’ve written several times about the Asbestos Network (AN)’s personal sampling and exposure guidance, which was published in August. Both ARCA and ACAD have spent a good percentage of their recent regionals taking members through the details – of which there are lots.
This guidance covers a very important topic that as an industry we have struggled with, and it’s been worth the wait. It’s a fairly weighty 21-page document. Overall it’s very much aimed at the licensed contractor – i.e. the sharp end – but it’ll be useful to analysts and end-clients too.
This is the first official guidance that the AN (and therefore the Health and Safety Executive) has provided to licence contractors on the subject. And there are some major departures from how contractors traditionally approach it.
That’s why we’re hosting a webinar to talk in detail about the changes that the guidance demands. We’ll be exploring practical steps on how to implement them, and demonstrating how you can use Assure360 to achieve full compliance – at the same time as saving hours of work for both your supervisors and admin team.
So whether you’re an Assure360 customer or not, please join us on January 16, 2024. To book your place, please just fill in the details below. We hope to see you there!
Written by Nick Garland on Wednesday September 13th 2023
I’ve written several times about the Asbestos Network (AN)’s personal sampling and exposure guidance, and I’m pleased to report that it’s finally been published. You can get a copy from your trade association, from the AN’s new official home on the CONIAC website, or download it from our website.
Like most guidance, this has been a long time coming, predominantly because the AN is mostly made up of members of the technical working group – who are by definition volunteers. This guidance covers a very important topic that as an industry we have struggled with, and it’s been worth the wait. It’s a fairly weighty 21-page document, but the meat of the guidance is contained within seven pages. Overall it’s very much aimed at the licensed contractor – i.e. the sharp end – but it’ll be useful to analysts and end clients too.
So what does it say? Here’s my summary of the main body of the guidance, with the key elements to look out for. Helping companies with exposure monitoring is very much our thing at Assure360, so I’ll also weave in a few tips as to where we can help implement the guidance effortlessly.
This is a great start to the document, examining why we do personal sampling, and exploring tips on how to be as efficient as possible. The main reasons for doing personals are:
The AN’s guidance confirms what Assure360 has been advocating for some years: that with a properly designed strategy and system to analyse, a single air test could address all of these requirements.
The starting point of any strategy is clearly the question of what type of job you’re dealing with:
It might be useful to think about personal monitoring as an audit of a particular removal activity. You don’t audit every site: you select a wide range so it’s representative, and you weigh it in favour of higher risk activities – whether that’s because of the activity itself, or the experience and competence of the staff. Clearly anything new (new technique or new staff) should be in the high-risk category. Another area you should focus on is obviously ones where you are getting higher than expected results.
So target high-risk activities for monitoring first, then when you have enough data on them, broaden out to other areas like set up, fine cleaning, waste runs and enclosure dismantling. Remembering that anything new always goes to the top of the list. Similarly, make sure you cover all workers, with new starters, short-term workers and agency staff getting a particular focus.
What this means in practice is the old strategic approach to get a personal on 40% of all AIB, 60% of insulation, and 100% of ‘flock’ jobs is very much no longer acceptable. You now have to have a strategy for specific activities. Consider the risk presented by AIB alone. Clearly AIB is more risky to remove when it’s nailed than when it’s screwed, or lying around as debris. But now consider the same activities, but with a team of short-term workers you have no experience with.
For years now, Assure360 has followed this approach, with individual targets for all activities. We also have a new feature that focuses this down to individuals – with some staff tagged as needing additional supervision. The combination will allow enhanced rates of auditing and personals where they’re needed. Data is provided by the supervisor’s Paperless App faster than they could have recorded it on paper – and the database analyses it for you instantly.
We rarely get numbers in guidance, but this one is an exception. If you have a small stable workforce, repetitive work and low previous results, a single monthly personal to keep on top of monitoring is considered sufficient. It goes further – if you don’t do any licensed or Notifiable Non-Licensed Work (NNLW) work in a month – no monitoring would be required. The long-term aim of your strategy shouldn’t be to test every employee on every job, but to eventually cover all employees on all activities.
At this point the guidance adds two important notes. When faced with a certificate giving you the results, there will be lots of numbers. Confusingly you’ll be told what the Calculated and Reported results are. For your purposes always use the Reported result.
The second note is when and how to use the protection factor of the mask being worn. You only use these when comparing it to the Control Limit – i.e. the four-hour time-weighted average (4hr TWA).
There are two types of personal monitoring that we all undertake. The main workhorse is the Specific Short-Duration Activity (SSDA). The second is the Four-hour Control Limit compliance check, more commonly known as the Four-hour Time Weighted Average (4hr TWA). The guidance explains both in some detail.
I’ll start with the dreaded 4hr TWA. As I’ve written a few times, this test is less about fibre levels for a particular activity, and more to do with the operative’s exposure over the course of a shift.
If a normal day for your team is:
then a single air test that covers all of that would be the perfect 4-hr TWA test. However, it wouldn’t be very good at determining the peak in the middle (removal).
The reason why I call the SSDA the workhorse is that, while it’s principally used to measure a specific activity, the results can be used for all of the purposes laid out in the strategy section above. It can even tackle the 4hr-TWA provided the test matches the World Health Organisation (WHO) criteria: a flow rate of 1-2 litres per minute, and a minimum volume of 240 litres – which may be pooled from more than one sample. For maximum flexibility – if you can move your standard test to two litres per minute (2l/m) for two hours – it will cover most areas and will result in a good limit of quantification. As an extra bonus, Assure360 has long had this parameter built in, so we automatically do the calculation for you.
The guidance calls for close supervision, so that when the activity stops, the test should stop. Going back to the example above, the SSDA test should only be run for that middle 30 minutes of AIB removal. You would need to ramp up the flow rate to close to 4l/m to get a good limit of quantification. The analyst should watch the operative throughout the test, summarising what they did on the certificate – especially if they diverged from the planned method.
Advice for Clients and Analysts
Refreshingly, the guidance now speaks directly to the client, prompting them to consider the role of personal monitoring data in helping them discharge their duties under the Construction (Design and Management) Regulations (CDM).
It also helps us rethink the relationship between the licensed asbestos removal contractor (LARC) and the analyst. Irrespective of who is paying for the consultancy, it’s the LARC that should specify the requirements of the personal monitoring, for example specifying a two-hour SSDA at 2l/min, on James Smith, while removing nailed AIB.
Analytical companies are directed to ensure analysts have the right equipment, and that they’re competent to undertake the test. This seems obvious, but it is definitely not just LARCs who have historically struggled with personal monitoring. The Faculty of Asbestos Assessment and Management (FAAM) recognises a poor level of competence in this area, and is looking at how it can improve the skill set across the board.
The guidance also states (in bold!) that analysts must always provide full PM results directly to the LARC as soon as possible after the collection of the sample via either hard copy or electronic means. It also states: “Failure to supply this information might be a breach of the analyst organisation’s duty under Section three of the Health & Safety at Work etc. Act 1974.” So, LARCs should no longer have to hear ‘This is the client’s data, I can’t give it to you’.
Analysis and Review
A LARC is expected to review all personal monitoring reports on site and extract management information from the data.
There are two PM thresholds above which we need to do something. The first is when the result is above what the mask can deal with. This is a combination of the assumed protection factor (APF) of the mask and the control limit (which is 0.1 fibres per millilitre of air sampled (f/ml)). The APF is 20 for a half-face mask, 40 for a full face, and 2000 for a respiratory airline supply (RAS) mask. Therefore:
These are clearly shockingly high results. If you got them, your instinct to stop work immediately and investigate would obviously be the correct course of action.
It’s worth noting that in Europe they are going to reduce the occupational exposure limit (equivalent to our Control Limit) to 0.01f/ml, so the above numbers would become 0.2f/ml and 0.4f/ml. I think the goal here was always to reduce the exposure faced by normal (non-asbestos) workers. However, when these same numbers are applied to removal activities, we’ll have to reassess whether our methods and RPE are capable of meeting them. It’s also worth noting that, while European law no longer automatically applies to the UK since Brexit, on this, we’ll most likely be forced to follow suit. Watch this space.
The second threshold is when PM results are significantly (the guidance says 25%) above your anticipated level. In this case you need to investigate and review the method if necessary.
Prompt investigation underpins everything – identifying (ideally immediately) if a test is elevated, and then establishing why. This then allows you to do the next steps that the Health and Safety Executive (HSE) requires:
Assure360 does indeed make all of this simple. We alert the supervisor when the reading is above the mask capacity, and management are informed instantly if either threshold is exceeded. We also have reports that compare and contrast data for individual operatives, and trend analysis is on all of our dashboards.
The guide details specific, required, practical uses for personal monitoring:
| Estimation of exposure | This is a section that has been long included in competent method statements, but the guidance looks for a little more detail than is perhaps in some documents: a breakdown into activities. Therefore include pre-clean, enclosure construction and fine cleaning in monitoring strategies, as well as the removal phases. You of course get this data from analysing the personal monitoring that you have previously conducted.
The guidance says that industry figures can be used as a starting point for new activities. Assure360 gives you benchmarked access to over 28,000 personals that have been recorded on the system. |
| Exposure Records | This is the written (or digital) record of the personal sampling/air monitoring required in the regulations. The actual detail is in para 482 of the Approved Code of Practice (ACOP), and it’s reproduced in the guidance.
It should be noted that this does not need to be one document, and it can be stored in more than one system. |
| Record of each test | The ACOP also requires you to keep a suitable summary of test results for each individual, so that average exposure for individuals and different activities can can be accurately estimated. It suggests a spreadsheet document(s) or a database. |
| Health Records | You must maintain health records for all employees, whether directly employed, short-term or agency.
Other than names, medicals and other information as detailed in the guidance and the ACOP, you must record the work carried out, location, dates, duration (hours per week), and the RPE used. Records must be kept for 40 years or until the employee is 80, whichever is longer. Therefore, the records of a 20-year-old short-term worker employed for one day must be kept for 60 years, not 40. |
Recording, calculating and displaying all of this data is complex. While it’s possible to create spreadsheets for the job, we’re really at the stage where a database is needed. There are many database programs out there that will allow you to create the analytical systems that the new guidance demands. But there is only one in which the systems are already built for you, and where they’re linked directly to the supervisor and to management teams.
Assure360 Paperless is designed specifically for the average supervisor, shaving hours off their daily admin duties. They’re able to record all of the data needed for this analysis faster than they could have written it down in the first place, and it’s transmitted directly to a database that has the power to analyse it as the HSE wants.
Not only does the system capture and securely store all the required safety and monitoring data, it uses it to give you far greater insight into the way your asbestos removal projects are running. At a glance, you can see how each job is progressing, and use reports to identify training needs. It’s not just a way to stay in compliance with the guidance: Assure360 gives you huge practical benefits that improve safety and quality, and save you money.
We’re always happy to show people how our system works, and how it can benefit every aspect of their business. If you’re interested in a free demo, and a free pilot, please do get in touch.
Written by Nick Garland on Friday September 1st 2023
The announcement from the government that multiple schools will have to close or partially close due to the long known presence of RAAC has further ramifications. Reinforced autoclaved aerated concrete or RAAC was used extensively in public buildings between the 1950s and the 1990s, for those of you that know your asbestos prohibition dates – this is the ‘heyday’ of asbestos use.
Asbestos is frequently hidden in the structure of the building, and can take weeks of planning and careful removal to find and address. In buildings of this vintage, such an issue will be highly likely. This additional delay could extend the school closures, potentially to months. But that is not even the main issue – the urgency of the RAAC question, might lead schools to overlook the asbestos question entirely.
The recent Department of Work and Pensions Select Committee report (April 22) highlighted the specific risk of asbestos in schools. ResPublica have recently stated that 80% of schools contain asbestos. The recent study paper by the National Organisation of Asbestos Consultants (NORAC) and the Asbestos Testing and Consultancy Association (ATaC) has similar figures, with 78% of the buildings they looked at having contained asbestos.
Following the select committee report, the HSE visited 421 schools to inspect their compliance with the regulations. 140 were considered to be falling short and received letters from the HSE instructing them on improvements that were needed in their management of asbestos. Of these, 27 received improvement notices (legal instruction for mandatory specific improvements), and one a prohibition notice (not to enter their boiler room until asbestos was removed). Whilst 33% non-compliance will not be a surprise to the industry, it should be seen as a worryingly high figure.
The Cliff Edge
I recently wrote about the cliff edge the country is heading towards in the race to net zero and the lifespan of system built buildings – deadlines a few years off. Now there is another ultra urgent deadline – repair or replacement of these RAAC structures so the schools can re-open. That is an awful lot of construction work that needs to be done immediately on buildings with clear potential to contain asbestos. The pressing and very public urgency to fix the RAAC problem might overwhelm other considerations – and in particular the asbestos risk.
HSE’s recent findings confirm what has been long suspected, that the model of manage-in-situ is not working well in schools. If the asbestos risk is overlooked now and not factored into the emergency, this latest crisis could be made even worse.
Written by Nick Garland on Wednesday July 12th 2023
The Times is turning into a real champion for those of us who want to change the UK’s approach to asbestos. The paper has kicked off a new – and extremely welcome – campaign to eradicate asbestos from schools [paywall], launching it with another excellent article.
It’s fantastic to finally see the issue getting some mainstream coverage. You’ll probably remember that I’ve written before about asbestos in schools. I think it’s an issue that many of us in the industry feel increasingly strongly about.
It’s instructive to remind ourselves as to the Health and Safety Executive (HSE) advice to schools regarding asbestos. They must:
In a school setting, those most at risk of disturbing ACMs are tradespeople, caretakers and others who work on the fabric of the building. The school’s plan needs to contain provisions to ensure that they have information about the location and condition of ACMs. The duty-holder should also ensure that any staff likely to disturb asbestos are suitably trained.
As I’ve pointed out before, this is essentially the same advice that applies to any other employer, and any other workplace: manage the ACMs in situ. But schools are unique.
In law, a school is a workplace, but the majority of people using them are children – sometimes as young as three. Despite the known vulnerability of children to pollutants, contaminants and other environmental hazards, when it comes to asbestos, schools are treated like any other workplace: they’re subject to workplace asbestos fibre limits, regulations and management approaches. And that’s a problem – both for our children, and the professionals who teach them.
The Times’ article brings together lots of stats that, when read together, paint a very stark picture of the current situation. Figures gathered by the National Union of Teachers’ Joint Union Asbestos Committee (JUAC) reveal that, since 1980, around 400 British school teaching professionals have died of mesothelioma, the cancer almost exclusively linked to asbestos exposure. An average of 19 school teaching professionals now die each year from mesothelioma – up from three per year in 1980.
This is likely to be an underestimate, as occupation is not stated on the death certificate of those over 75 – which is the age group accounting for most victims of this horrible disease. To my mind, the real figure could even be double or triple this number.
Research by the US Environmental Protection Agency estimates that for every teacher that succumbs to the disease, a further nine pupils will go on to die from mesothelioma in later life. The JUAC estimates that as many as 10,000 pupils and staff have died to date due to exposure to asbestos in schools.
A unique challenge
Why is asbestos such a serious problem in schools? Aside from the particular vulnerability of pupils to the substance, the UK has a major problem with how widespread ACMs are – and also with the poor state of repair that some school buildings are in. More than this, schools are under budgetary pressure – heads are thinly spread as it is.
In 2018, the government asked schools to provide information on asbestos in their buildings, through the Asbestos Management Assurance Process. In 2019, AMAP reported that 80% of schools contained asbestos.
In addition to this, the National Audit Office has estimated that 24,000 school buildings are beyond their design life. Nearly two-thirds of these are the system-built buildings that so frequently contain asbestos. Last year the Department for Education revealed that there was a risk of the collapse of one or more blocks in some of these schools.
A recent Freedom of Information request by JUAC to 60 of these system-built schools revealed that nearly half did not have an “up to date” asbestos survey, and two-thirds had not identified where all of the asbestos was.
In an ordinary workplace, the HSE’s ‘manage in-situ’ advice can work very well. Surveyed, recorded and managed properly, ACMs should pose no risk – provided the management plan ensures that they remain undisturbed. Proper management starts with a management team that has the training and experience to properly understand the risk, and design and implement appropriate controls.
The Times’ article brings together a body of evidence demonstrating that, for schools at least, this is not working. Headteachers have been unreasonably forced into the role of duty holder, responsible for management of asbestos in their schools without adequate training, support or budget.
When you add in the fact that the majority of the school population can’t be considered competent around asbestos, and the complication that we don’t know the true scale of the problem, it is not surprising that the system isn’t working.
Phased removal
If management in-situ doesn’t work for schools, the only answer is surely the phased removal called for in the excellent Work and Pensions Committee investigation and report. As I have written before, the government rejected the report’s key recommendation to remove all asbestos from public and commercial buildings, and this is where the Times is taking up the banner for schools, with its five-point plan:
The paper’s campaign has already gained support from significant political figures including Nadhim Zaharwi , Alan Johnson and Matt Hancock, who between them have formerly held the roles of Chancellor, Education Secretary, Home Secretary and Health Secretary.
The Times clearly doesn’t want to let this lie, and I applaud it for that. Its launch article ends by asking if you have been affected by asbestos. If you have, email the paper at [email protected].
Written by Nick Garland on Wednesday July 12th 2023
You may have read about my recent experience in organising the Faculty of Asbestos Assessment and Management (FAAM)’s first four-stage clearance (4SC) workshop. The event produced a trove of information that we can feed back into the faculty conference, and ultimately into better, joint training for analysts and asbestos supervisors. But since the event, I’ve also been keen to use the insight we gained to make sure Assure360 is making the 4SC as straightforward as possible for everyone involved.
That’s why we’re embarking on a complete overhaul of the enclosure 4SC process on the industry-leading Assure360 Paperless app. The aim is to make it a lot clearer to supervisors and analysts, streamline the whole process, and use our learnings from the FAAM joint workshop to make it less confrontational and encourage team effort.
At the same time, we’re also starting an industry-first research project. By harnessing the power of the data management that comes as standard with Assure360, we’re trying to identify the underlying reasons behind whether an enclosure passes or fails the 4SC.
Our new-look process will record not just passes or fails, but the stage at which the enclosure failed:
Assure will also include a statement from the analyst as to whether they were familiar with the scope and project in advance. This should help with understanding the impact of involving or not involving them in the planning stage.
Crunching the numbers
These are all fairly routine data points to collect, but where Assure360 can go further than any other is by cross-referencing them with other data. Examples of where we can do this include:
Like everything we do at Assure360, the number crunching will all be done in the background, and the insight presented to you in handy and easy to use reports. There’ll be absolutely no additional effort needed on your part.
We’re particularly keen to harness the vast expertise of our community of users, so please let us know what other factors might have an impact on the success of a project. We’d really appreciate it if you email your input to us on [email protected]
Assure360 is the industry standard – if you are yet to experience the only productivity tool designed specifically for the asbestos removal industry, please contact us here, or email us on [email 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 March 9th 2023
Friday the 24th February was a big day for me, albeit one that probably wasn’t on your radar. For some time I’ve been planning a workshop on the infamous four-stage clearance (4SC), and I was delighted to take the lead on delivering this inaugural event for FAAM.
This wasn’t just another P404 – BOHS’ official training course on 4SCs – but a unique attempt to bridge the gap between two sides of our industry: analysts, and licensed asbestos removal contractors (LARCs).
The very fact that we all understand what I mean by ‘two sides’ hints at the suspicion and conflict that exists between removalists and analysts. It’s been getting worse over the last 20 years, as the pressure increases on the 4SC – and in particular the visual inspection – as the key check on licensed removal work. Today, the 4SC is the cauldron where the pressures of business come up against the mandatory checks of heavy regulation. Improving the process, and adding to everyone’s understanding, is one of the biggest challenges we have.
With fellow FAAM committee members Louis Slattery of Air Surveys, and Cat Holmes of ION, we tried something new – a practical session to bring together experienced supervisors and analysts so that they could learn from each other. While we didn’t know quite what to expect, we hoped they’d each benefit from the strengths of the other, and also that they’d get an insight into each other’s point of view. The ideal outcome would be better communication and ultimately a stronger team attitude.
We used the fabulous facilities at Airborne Environmental Consultants (AEC) in Manchester, where they have full-scale mock enclosures set up. We focused on the first two key stages of the process.
With the attendees placed into analyst / supervisor pairs, they were thrown in to do the preliminary stage one inspection, where we saw the strengths of the supervisors coming to the fore. And while the supervisors obviously felt in their element, it was also great to hear a different viewpoint from the analysts, and see an instant rapport building between the two. The following debrief was also refreshing, with everyone being open in revealing gaps in their knowledge or things that they might have missed.
After lunch were two realistically mocked up enclosures with a host of issues hidden in each. Now the analysts showed their experience – not particularly with the significant failings, as both members of the team easily found those – but more in their ability to find the small things. We had the pleasure of witnessing analysts’ ‘dark arts’: the carefully angled use of a torch to reveal settled dust, or mirrors to inspect behind and under obstacles. It’s an amazing skill set, so crucial in preventing an unsafe enclosure being handed back.
The final debrief was as good as the first. For me personally there were two significant moments in the end-of-the-day chat. While everyone knew that it is the LARC’s duty to ensure that the enclosure is 100% clean, changes to the handover certificate were also brought up – for the first time the supervisor’s name is being attached to this liability, making them more directly responsible.
For me, the logical conclusion of this personal liability is that it should reposition analysts as the supervisor’s best friend. After all, they’re the final backstop before the supervisor’s enclosure is handed back.
This discussion produced another eye-opener for us all. Although it’s always been the LARC’s responsibility to ensure that an enclosure is free from asbestos when handed back, supervisors have never been given formal training in this as part of their initial or refresher training. This is something I’d personally always assumed was included. And if that incorrect assumption runs all the way up to the Health and Safety Executive (HSE), it would lead to this critical competence issue being overlooked at licence assessment.
I and the other organisers hope that this will be the first of many workshops, with feedback provided to the FAAM conference, and ultimately that our findings will also inform future analyst and supervisor training. The ideal outcome is that joint training in this key competency becomes a routine reality.
I’d like to extend my special thanks to Kellie Naughton of AEC, Ian Halpin of RSK, Liam Bodger of Emchia, Nick Butters of ABP, Aidie O’Neil of East Coast Insulation, Nicola Ratcliffe of TRAC-Associates, John Malloy of RS Asbestos, Neil Hardy of IATP and Phil Roberts of the HSE, who all very generously gave up their time to make this workshop possible.
Written by Nick Garland on Thursday February 9th 2023
Site welfare is something that’s all too often overlooked on asbestos-removal jobs. We’ve all worked on sites with incredibly inadequate facilities, whether it’s too few loos, unsuitable washing facilities, or just nowhere to sit and take a break.
One of the main reasons it’s so common is that a lot of these projects are quite short term. Sometimes it’s just one or two days. Management can become too focused on the complexity of the job itself, which leaves welfare as an afterthought. Another issue is that these short-term jobs are typically in flats and houses, and by their very nature they prevent access to on-site facilities. For example, asbestos removal of the riser in a toilet might mean that the loo is available for the first couple of hours, but then it’s very much not for the rest of the day.
But while the management may forget to provide it, the Health and Safety Executive (HSE) views adequate welfare as a fundamental basic necessity for workers. In fact, during the COVID restrictions, Prohibition and Improvement Notices that mentioned COVID almost exclusively targeted inadequate welfare.
Management can also misinterpret the ‘so far as reasonably practicable’ (SFARP) exception, thinking along the lines of “It’s a one day job. What’s it reasonable for me to allow for?”. The law sets out a basic expectation of toilets, a supply of hot and cold (or warm) water for washing, changing facilities, drinking water, and somewhere to eat and rest. You’d have to have very significant reasons to not provide the minimum.
The HSE is reinforcing this with the release of some new guidance: Construction – Welfare Standards. I’m grateful to Graham Warren at ACAD for flagging it up in the latest newsletter. The guidance is actually for its own officers, not us, but understanding how the HSE will be looking at the subject is crucial: inspectors are directed to take ‘appropriate’ enforcement action to secure compliance.
HSE action
The guidance makes clear that where toilets, hand basins, drying rooms etc. haven’t been provided, or they’re inadequate, an Improvement Notice (IN) is the appropriate response. There will be local exceptions that might even dial this up to a Prohibition Notice (PN), for example if there’s an imminent risk to health. But the guidance also states that prosecution should be considered for repeated offences – or even if the first offence is bad enough.
The penalties for getting it wrong are therefore significant. The guidance quotes multiple regulations and guidance documents, weaving together a framework for the inspectors to justify enforcement action. The most significant is obviously the Construction (Design and Management) 2015 (CDM 2015) regulations. Among other things, these introduced clear definitions for all parties in construction (including clients), removing the cloak of invisibility that had allowed some clients to claim ignorance.
In practice a client needs to create an environment where work can be carried out with the appropriate welfare facilities in place. If the works involve a specific fenced-off construction site, use of the client’s own facilities should not be the default option. The regs go on to say that where there isn’t such a specific construction site, clients are legally required to make their own facilities available for use.
Domestic clients are the exception. CDM 2015 and the HSE guidance both recognise that they don’t have legal duties, so it falls to the principal contractor (PC) and other contractors to ensure compliance.
Contractors’ duties
Principal contractors have clear and unavoidable duties to provide facilities from prior to the start of construction work, all the way through to the end of the project. Contractors’ duties shadow those of the PC. If there are several contractors on a site, it’s a case of liaising and cooperating with the PC. If there’s only one, then all of the duties are yours.
That ‘so far as reasonably practicable’ get-out gets some clarification with regards to welfare. In essence it’s about weighing the measures needed against the sacrifices involved. Crucially, though, it’s weighted in favour of health and safety, i.e. it’s assumed you’ll provide the welfare, unless you can demonstrate it would involve ‘grossly disproportionate sacrifices’. Cost is not the primary focus and shouldn’t be considered ‘disproportionate sacrifice’.
Toilets are mandatory (i.e. you don’t get to say they’re not reasonably practicable), and there’s a hierarchy, with flushing toilets at the top and chemical Portaloos very much at the bottom. The guide states that for large or long-running sites the provision of ‘only portable toilets’ is considered insufficient – as it would very much be reasonably practicable to provide better.
All welfare facilities must also be ‘readily accessible’. What this means varies with the urgency: rest breaks can be planned, so the distance to travel can be greater. Toilet facilities, however, need to be much more convenient. The guide quotes BS6465(1) as stating that construction sites should provide WCs within 150 metres of the workplace. Arranging toilet use with a café that’s 10 minutes’ drive away would not cut it.
For the same reason the numbers of cubicles are also pre-determined:
| Number of people | Cubicles (not urinals) |
| 1-5 | 1 |
| 6-25 | 2 |
| 26-50 | 3 |
There are some other key requirements:
What I find particularly interesting about this guidance is the way that it details other regs and approved codes of practice (ACoPs) detailed in the guidance. It features them along the lines of ‘areas to be considered when considering enforcement and prosecution’. But to think of it another way, I always like to ask one of my favourite questions: ‘Why are we doing this?’ – as understanding why is often the lightbulb moment.
Of course, there’s the basic human dignity of providing somewhere to go. Not to mention hygiene 101: wash your hands before you eat. But as these often don’t seem enough reason, how about:
I’m sure you can think of more examples and, if they apply to the work you’re doing, the HSE inspectors will doubtless think of them too. Perhaps it’s time for those of us who design and commission work to stop treating facilities as so much of an afterthought, and start planning work around the comfort of the people who do, after all, do the work on the ground.
Written by Nick Garland on Thursday February 9th 2023
Last December the Health and Safety Executive (HSE) completed its second post-implementation review (PIR) of the Control of Asbestos Regulations, 2012. A PIR is essentially a state-of-the-nation report to look at whether a set of regulations are working, whether they’re achieving the intended aims, and whether there were any unintended consequences. PIRs are enshrined in the regulations themselves – i.e. as part of the regs, the HSE has to mark itself every five years to make sure it’s achieving what it set out to do.
PIRs are typically huge documents, containing a great deal of evidence. This one is no exception. It includes minute detail on who responded to the associated questionnaire. This time, 1,850 people did, which is clear evidence of the importance our small industry attaches to this legislation.
The people who responded were broken down as follows:
Those figures make it clear that the industry as a whole was engaged in the process.
One unusual thing is that this PIR was delayed by six months. This was for good reasons – the HSE wanted to incorporate the findings and feedback from the Work and Pensions Committee report. Mostly, though, how this featured was where the HSE referred back to its written response to the committee, or even that it fell outside of the scope of the questions they asked the responders – so not much extra light shone on the recommendations.
After the delay, the PIR is now published, and is a vast 160 pages long. If you’re interested in more detail, fortunately the good people at NORAC have boiled it down to something more digestible. In a nutshell, it’s all good, and there are no plans to change the legislation at this time – which hopefully will save it from the bonfire of the European legislation that is coming our way.
Written by Nick Garland on Wednesday December 7th 2022
The recent Work and Pensions Committee report on asbestos management has started to move the conversation in some very positive directions. I wrote recently of how 13 of the committee’s 16 recommendations had been taken up by the Health and Safety Executive (HSE), which was actively investigating how to implement them. As I understand it, such a positive hit rate from a select committee report is near unheard of.
One recommendation that isn’t being adopted is that there should be a national database of asbestos. Like many in the industry, I’ve written about the shortsightedness of this decision, but it has had a very interesting result – the industry is attempting to fill the void itself.
This is principally happening through two initiatives. In the first, UKNAR, Asbestos Smart and Open Asbestos are working to bring all of the asbestos software companies together. The goal is to make it easier to communicate asbestos registers to the people at risk, i.e. those that need to know.
The second initiative owes its existence mostly to the HSE’s assertion that we don’t know what we don’t know. In other words, that there isn’t much data available to measure the effectiveness of duty holders’ management of asbestos in the real world. And what evidence the HSE does have (through visits to properties) is broadly very positive.
Now, the asbestos consultants reading this would have mostly spat their tea out, as it didn’t match what we were seeing. Happily, ATaC and NORAC stepped up to investigate and create a report on what we really do know. Their exercise is intended to be repeated annually, so that we will effectively get a grade card of how well we are doing and how things are changing over time.
The result is a very impressive example of joint research and collaboration. The data set is vast, taking in more than a million lines of information. The data covered 128,761 individual sites, and of these, 100,660 contained asbestos-containing materials (ACMs). The analysis was complicated by the range of terminology used, and some significant reconciliation was needed. Despite this, the study was able to produce some really impressive headline stats.
Damage in the details
A total of 710,433 ACMs were identified. These were mostly non-licensed materials, but some 157,940 (spread over 32,814 buildings) were the higher risk ACMs such as asbestos insulation board (AIB) and pipe insulation. Some 10,054 (6%) of these ‘licensable’ ACMs were deemed to have medium damage, and 19,347 (12%) high damage.
The researchers also segregated between new surveys and reinspection reports (i.e. known asbestos that was being re-checked as part of a management plan). The latter showed:
It’s clearly a very impressive piece of research, and as a point-in-time spot check on asbestos it is an enormously useful data set. But other than “we still have a lot of asbestos” and “there is a long road yet to walk”, what does it tell us?
It’s clear that the report isn’t set up to be a worthy, academic piece. In fact, I think that its messaging was intentionally straightforward. The bulk of the report is given over to ‘Findings’, but it’s actually a blend of the findings and the authors’ take on what this data means.
To my eyes there’s a lack of nuance. For example, in one of the sections it suggests that the very fact that reinspection surveys identified 10,452 ACMs with high damage indicates that either:
The report suggests that either way it demonstrates poor management of the risk. That might be the case, but it could also be that the number was nearer to 12,000 a year ago, and that the duty holders are prioritising their remediation plan, for example by locking away the rest so it is no risk to anyone. The same information could now be seen as evidence of excellent management. We just don’t know.
Perhaps I’m looking at it too deeply, and the point of this first report is just to get the attention of the layperson. I certainly hope it achieves that, but its real value (and it should be huge) will come when it’s repeated year on year. Do we see the percentage of asbestos in poor condition reducing? Are we eliminating ACMs? Are we moving fast enough?
Or, as the report seemingly indicates now, are we actually seeing inactivity, and an attitude more akin to box-ticking than active management of risk? I look forward to finding out, and for us all to be able to act on the answer.
Written by Nick Garland on 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 Thursday June 16th 2022
It feels like we’ve been talking about personal monitoring a lot lately, and rightly so. It’s a critically important part of ensuring the safety of people working in asbestos management, and yet to date there has been a lack of official guidance on it.
However, since 2019 the Asbestos Network (formerly Asbestos Leadership Council) has been working on creating some. It’s my understanding that this summer is the targeted release date. It can’t come too soon, particularly given that some recent licence applicants have been hauled over the coals for supposed failings – which seems unfair when there’s no definitive guidance to go by.
I want to examine the new guidance based on the latest draft. I’ll lay out the main points of it, but I strongly suggest you also give the original a read, and provide your feedback through your trade organisation. You can find the ACAD draft guidance page here (you’ll need to be logged in). ARCA doesn’t seem to publish draft versions of AN minutes on its guidance page, but you will be able to provide feedback through comments.
The first very welcome news is that the guidance is broad. By this I mean it recognises that personal monitoring is a means to several ends. Rather than focusing just on the initial testing, the guidance examines why you are doing the testing, and how you use the results for the practical ‘ends’.
As it stands, the guidance starts with those ends, and what it says is pretty much straight out of existing documentation:
My understanding is that this part of the guidance might be trimmed further, with more emphasis placed on health records (largely the four-hour time-weighted average) and the effectiveness of controls. This interpretation is reinforced by the choice of tests currently selected from the Analysts’ Guide for further detail:
Specific short-duration activity (SSDA) Monitoring
This is the workhorse test that you will use most of the time. It is used to test a specific activity (i.e. to satisfy goals two and five above). The guidance talks about the importance of really focusing on the individual task. To this end it stresses that it is no longer good enough to, for example, talk about removal of asbestos insulation board (AIB) – now you need to detail the fixing too. An example given is breaking out a single AIB panel, followed by fine cleaning. This should be viewed as two separate tasks, and either you should test them separately, or prioritise the high-risk element.
The guidance doesn’t yet state what parameters you should follow for this type of test (but it will in later drafts). As the purpose of the test is to examine an activity, you are allowed quite a bit of licence. The flow rate (how hard the pump is working) should be between two and four litres per minute, and the minimum volume tested should be 120 litres. These recommendations are very much intended to ensure you get a decent limit of quantification (see below).
Four-hour time-weighted average (4Hr TWA)
The second test that the guidance highlights is the dreaded 4Hr TWA – although hopefully these will be far less opaque if you’ve read my previous articles on the subject.
Not in the guidance yet is an explanation as to why on earth we should be doing these tests, beyond ‘it’s for the health records’ or ‘the HSE says so’.
Here’s my understanding. If an employer causes an operative to be exposed to asbestos, we should be able to tell them accurately how much they have been exposed. If we all pick different rules for these tests, it will be a mass of confusing numbers that could be interpreted in a whole host of ways. If however, we all follow an official internationally recognised method, proven to give good results, we have more of a chance at telling the real story.
Back to the guidance. The first thing it makes clear is that these tests are less about the activity, and more about the person exposed. If an operative is building an enclosure in the morning and then removing asbestos in the afternoon – it is the afternoon’s work that you would want to test. If the operative is removing nailed AIB for two hours, and then fine cleaning for one hour before exiting the enclosure, we don’t need to worry too much about splitting the testing down to capture the different activities – but you definitely need to catch that initial peak exposure.
Compared to other parts of the document, this section seems to be in need of a lot more work. Hopefully it will use plain English to detail that we are looking at four hours of activity, but that you are allowed to make some assumptions. Crucially, the guidance needs to underline that it’s NOT a four-hour test – it’s a four-hour calculation.
To understand this, look again at the example above. The operative is exposed for a total of three hours, so you could therefore assume nil exposure for the rest to make it up to four hours. It’s also worth remembering that if you test for two hours, but the activity runs for four, you are allowed to extrapolate the result to give you figures for the full four hours.
Again, the test parameters are not detailed yet, but these would be a flow rate of one to two litres per minute, and a minimum volume of 240 litres. Meeting this volume is crucial, given that there’s some flexibility in the testing parameters.
Keen observers will note that there is some overlap here. If the standard test you commission is two litres per minute for two hours, this will give you the minimum volume you need to qualify for the 4Hr TWA and also the SSDA. It’s therefore an opportunity to greatly increase how many of these ‘tests’ you complete. Whether the guidance will explicitly spell this out is yet to be seen.
Confused? Read my deeper dive into the 4Hr TWA
The personal monitoring guidance will also unpick some of the arcane language used by the Health and Safety Executive (HSE) and analysts. In particular, it tries to explain the following:
Limit of quantification, calculated results and reported results
The limit of quantification (LoQ) is a calculated level of asbestos found, above which the analyst can be confident of the result. Below the LoQ, the counted fibres are so few and far between that some could have been missed. The guidance explains this, then goes on to tell you how to calculate the LoQ, which is probably too much detail for the purpose of the document.
Calculated result. This is effectively the analyst’s ‘workings out’. It is never the final answer, and should be taken with a grain of salt. The reason? It’s often below the LoQ, which we already know is the lower limit of confidence. You, as the user of the data, should always refer to the reported result.
Reported result. This is the analyst’s answer to the question – ‘what was the exposure?’ It will either be equal to or above the LoQ (i.e. the analyst has confidence in reporting it).
It might help to look at a couple of simple examples:
LoQ stated as 0.05
Calculated result 0.01
Reported result <0.05
As the analyst I can only be confident if the result is above 0.05. This is below that, so all I can be sure about is that it is less than my LoQ.
LoQ stated as 0.05
Calculated result 0.06
Reported result 0.06
I can only be confident if the result is above 0.05, and this is above that, so I am comfortable reporting 0.06.
Next, the guidance looks at what level of detail you need to record. The short answer is: ‘more’. The guidance recognises that historically, licensed asbestos-removal contractors made fairly simple records such as ‘AIB removal’, ‘pipe insulation removal’ etcetera. This is now considered insufficient for the obvious reason that removing nailed-on AIB is a very different job to screwed AIB, never mind glued AIB. The minimum parameters you should be detailing are now: activity, the nature of the asbestos-containing material (ACM), and the fixing used to install it.
The final point I listed right at the beginning of this review was health surveillance records, and it does look like the guidance will give a very good steer on what this entails.
Outside of the asbestos industry, employers need to keep employee records for up to six years after the employee leaves the business. In our industry, however, employee health records have to be kept for a very long time – specifically, 40 years after the last entry, or until the employee would be (or would have been) aged 80: whichever is longest. For example, if you employ a 22-year-old for three months, you should keep their health records until they turn 80. If an employee retires at 55, you must keep their health records until they turn 95.
Health records are formed from the exposure records that we have been discussing up to this point, and in particular the 4Hr TWA data. In addition they include:
These can all be from separate records or systems. Records one and three will come from your HR data. Four and five are more related to your personnel certificate management system.
The second one is a little more tricky. The approved code of practice (L143) requires the recording of exposure duration and fibre levels, but it doesn’t require these to be multiplied together to provide a measure of dose in fibre hours; that requirement was retired in 2006. What your system does need to do is give the individual worker a breakdown of their actual exposure against your company’s anticipated levels.
It’s important to remember this remains draft guidance – and it could be some months off being issued formally. What’s more, the HSE is not in the market of giving you a specific solution. Instead, its guidance makes clear your duties and – if written well – should give you a steer as to what they mean in practice. The actual solution is up to you.
Say you implement an extensive system of Excel spreadsheets that you religiously maintain, and data-mine for the answer to different questions. As long as you already record all of the information that the new guidance demands – and your Excel skills for reports, charts and queries are up to the task – there will be little extra work here.
For the rest of us, the presence of guidance brings a very real problem: when it is out, your performance can be measured against it.
Fortunately, I’m able to offer some reassuring news to the Assure360 community. All of our users are already covered, as the ‘new’ three-tiered approach (activity-ACM-fixing) has been in place since I created the system. Also, our comprehensive suite of reports provides all the required detail you’ll need for employee health records, 4Hr TWA calculations and much, much more.
If you’ve got concerns around the guidance and the changes you’ll need to make, or simply if you’re yet to see what Assure360 can do for you, why not contact us? We’d be delighted to give you a demo, and set up a free pilot of the system.
Written by Nick Garland on Wednesday May 11th 2022
At last year’s FAAM conference, Colette Willoughby delivered a raw and personal presentation about the personal safety of female analysts. It was eye-opening and shaming, and it focused the minds of all who heard it on the urgent need for change.
Colette herself set out what needs to change in our industry, and with the support of many colleagues I’m encouraged to see things moving in the right direction. Asbestech – one of the UK’s leading asbestos management companies – has announced that it is retro-fitting locks to all of its decontamination units (DCUs).
Asbestech contract manager Alessia Gilbey commented that “it’s a simple method to provide an additional reassurance to myself and other women that may be required to use a DCU”. And it is simple – a quick, inexpensive change to make existing DCUs safer workplaces.
I’m also encouraged to see that DCU manufacturers themselves are paying attention. I’ve recently been invited to meet with SMH to discuss potential design changes that would improve personal safety in the DCU, and I’m hopeful they’re able to put something effective in place.
It’s heartening to see that the bravery of Colette, and the other female analysts who spoke to her, is resulting in real change. It’s up to everyone now to keep the pressure on, and continue making the improvements to equipment, training and behaviour that our female colleagues demand and deserve.
Read more here about Colette’s talk, Female analysts and four-stage clearance testing
Written by Nick Garland on Wednesday May 11th 2022
As you’ll no doubt all be aware, the Work and Pensions Committee has been conducting an inquiry into the Health and Safety Executive (HSE)’s approach to asbestos management. In its report, published in April, the committee calls for a raft of changes, including a proposed 40-year deadline for the removal of all asbestos from public buildings.
Predictably, I’ve already seen people commenting that 40 years is far too long, while others say the reverse and wonder how we’ll ever pay for it! But the asbestos management report is a substantial document, and I wanted to look at the changes and recommendations behind the headline. The committee has heard many opposing views from industry experts, campaigning groups, charities, victims groups, government ministers and the HSE itself, and to its credit has produced a well-balanced set of proposals that deserve greater scrutiny.
The balance of evidence
Like most in our industry, I’ve been following the progress of the inquiry and the evidence presented to it. Everyone has their own opinion, but there were a couple of witness testimonies that I took issue with. In December, Professor Julian Peto of the London School of Hygiene and Tropical Medicine suggested caution over the mandatory removal of all asbestos, pointing out research in the 1980s showing that airborne asbestos levels in buildings were higher six months after removal than before.
I’ve no reason to doubt that research, but I have first-hand knowledge of how comparatively poor asbestos-removal techniques were when I started my career in the 1990s. In the 1980s it must have been even worse, as analysts weren’t even doing independent clearances back then. I’d be astonished if the equivalent research, conducted today, didn’t reach a very different conclusion.
In February, HSE chief executive Sarah Albon claimed that the 60% drop in asbestos enforcement notices over the last 10 years was evidence of better compliance. However, when we compare 2012/13 with 2019/20 (the most recent pre-pandemic period for which figures are available):
What this suggests to me is that the HSE targeted the companies it thought would be the worst offenders, and pretty much saw what it expected, giving it a much higher hit rate of Prohibition Notices.
If that’s the case, then the figures rather undermine the suggestion of improved compliance. Instead, they suggest to me that some companies are simply avoiding having their collar felt, and I’m not alone. As Darren Evans of Asbestos Training and Consulting (ATaC) told the committee: “There are lots of people out there taking an informed view that they are unlikely to be visited, and therefore corners are cut.”
Let me stress that I’m not blaming the HSE here. Over the 10 years to 2019/20 the organisation experienced a 46% drop in funding – it did well not to cut visits even further.
Regardless of the details, the committee has managed to distil a mound of evidence and come up with some well considered proposals. The report’s key recommendations are:
As I said, these are all well-balanced proposals. It’s hard to argue against any of them, but I can see a particular subset with the potential to bring the fastest, greatest benefits. Five particular points would have an obvious, immediate impact on safety and good management:
Just these five, if acted upon, would have the potential to transform our knowledge and our ability to act appropriately. Let me explain further.
Competence of dutyholders
We are long used to the absolute requirement for access to competent health and safety advice – why should it be any different for asbestos? This has always been something I care about, in all my work with clients – the central pillar is to ensure that they end up more capable of asking the right question at the right time. For large organisations, having this requirement might mean having someone on the books who is P405 qualified. For smaller companies it might be having the right health and safety consultant on retainer.
Digital Register
Whatever we are doing, we’re likely to be more diligent and careful if we know our work is going to be checked. We see the evidence of this all the time in asbestos management: there’s a difference between an unannounced audit and one where they knew you were coming, or a visual inspection with the UKAS assessor in attendance. If organisations know that they’ll be uploading their asbestos survey to the HSE, they’ll do it better. Just the very fact that a survey or register could be independently checked at any time will benefit standards hugely.
Accreditation of Surveyors
It’s always been unexplained why asbestos analysts must be accredited, but it’s only advisable for companies conducting a survey. It’s very costly to get and maintain accreditation, so it’s only really accessible to established organisations. But being un-accredited doesn’t necessarily mean bad – smaller firms and individuals may be unwilling or unable to go down that route.
Regardless, we currently have a situation where UKAS accredited companies must compete commercially against non-accredited companies and individual surveyors – that’s not a level playing field.
Interestingly the recommendation in this regard is that accreditation should be compulsory for the individuals conducting surveys, not the firms employing them. This change would immediately level things out: large and small firms along with individual surveyors should be able to demonstrate competence.
I’d expect that surveyors would welcome this professionalisation of the industry, as the employment power would be devolved down to them. The change wouldn’t allow companies to shirk their responsibilities, as it will remain their duty to ensure competence of the workforce.
Research
If the priority is to focus on schools and hospitals, just how big is the problem there? The short answer is that nobody knows, as very little research has been done. What we do know is that some schools have a good deal of asbestos-containing materials in them. We also know that young lungs are much more susceptible to damage from asbestos, and that youngsters are practically (and legally) considered not to be competent. This latter is crucial as ‘competent workforce’ is an important pillar in the current approach to managing in situ.
I’ve discussed the unique problem of asbestos in schools before, and the risks faced by teachers and pupils alike. As with other public buildings, UK policy has been to manage asbestos in place, but what little research this is based on is now well and truly out of date. Before we settle on any change in policy, we need to know for sure that removal is the safer option.
Increased Enforcement
I’ve said it before, but the 1974 Health and Safety at Work Act is a beautifully written piece of regulation. If you render it down to a couple of sentences, it essentially says: “The employer must be an expert in their field, must understand the risks, and must eliminate them as much as they can. And if they don’t there will be dire consequences.”
The author was very cleverly identifying that proscriptive legislation would never be able to keep up with the best and safest way to operate across multiple industries in a changing world, but that a regulator would be able to use the power of hindsight to identify if something could have been done better.
And that’s where the HSE comes in. It’s vital that they are out there making checks and serving up enforcements to ensure things are done better. To recall Darren Evan’s point, companies need to know they cannot cut corners, because they will be caught.
Will it happen?
I’ve focused on these five very positive recommendations, because together they would improve our knowledge of the problem, make the scale of the issue visible, and leave dutyholders in no doubt that they need to act appropriately. However, they would also represent an increase in costs to business, an increase in health and safety regulation, and an increase in funding for a public body (the HSE).
None of these things have been particularly popular with the UK government for a decade or more. For several years there has been an effective ‘one in one out’ rule for new regulations. Consequently, much of the HSE’s excellent guidance of late has had to be be sneaked out as appendices to Asbestos Network meeting minutes – not exactly the ideal situation.
I would like to end, though, on a point of optimism, from Charles Pickles from the campaign group Airtight on Asbestos. Responding to the report, he told me it was a rejection of the existing line that asbestos was “yesterday’s problem: nothing to see here”.
Instead, he said, it’s a move to acknowledge that “we have a problem with current exposure, and we need a plan to deal with it”. The Work and Pensions Committee has asked the HSE for its plan, and soon. And as Charles put it: “That really is a significant move.”
Written by Nick Garland on Wednesday April 20th 2022
The Health and Safety Executive (HSE) – or rather its Asbestos Network – is about to release some new guidance on non-asbestos risk assessments. Regular readers will know that this is an area very close to my heart. However, as the guidance stands I’m concerned that it will actually set back the industry’s understanding of the process.
The Asbestos Network starts well, explaining that risk management is about taking practical steps to protect people from real harm and suffering, rather than just bureaucratic back covering. It also states that risk assessment should focus on reducing significant risks, and not creating a totally risk-free situation.
The guidance goes on to identify the difference between everyday risks, standard risks and site-specific risks.
Everyday risks
These are those areas that we all experience all of the time. Examples would be getting in or out of the van, driving to the site, preparing lunch and so on. If the task at hand will not change the risk associated with the hazard, then we can ignore these for the purposes of a risk assessment.
Standard risks
These are incredibly routine, every-job situations that can be dealt with using a standard company approach. Examples might include:
These standard approaches can all be detailed in the standard operating procedures (SOPs), and need not be re-assessed with every project.
Take as an example the removal of a one-metre squared asbestos insulating board (AIB) panel, from eye level in a social housing bike store, 10 miles from your HQ. This incorporates some standard everyday risks – a manual handling hazard, working at height (building the enclosure), and Leptospirosis – but we don’t need to spend much time thinking about it as they’re all entirely routine.
Site-specific risks
This is the area that we should be focusing on. Site-specific risks fall into two categories: everyday and standard risks that have somehow been increased or changed because of the job, and new hazards introduced because of the task or location.
By just revising a couple of aspects in the above example, we can see how site-specific risks might completely alter the nature of the job. Imagine we’re removing the same AIB panel, but now at four metres above ground, and 300 miles from the office. Several things change. Driving that kind of distance towing a decontamination unit (DCU) is no longer round the corner, obviously. You’ll also need different methods to physically get to the panel, which may well affect the physical handling.
These changes must be assessed and new control measures designed. Breaks for the driving? A two day job with digs? What’s certain is that working at height now means you need a scaffold tower, and operatives with PASMA training. The manual handling (lifting equipment up to height, and the AIB down to the ground) will also be much more complex, and require appropriate controls.
Anything New?
This guidance confirms the relatively common aspirational goal of returning to the site just ahead of the official start date as best practice. Wherever reasonably practicable you should re-assess the hazards – has anything changed? Is the location of the DCU still appropriate? Are there any new hazards?
To underline the importance of recognising that things change, the guidance also stresses that the supervisor should be conducting their own daily risk assessments. Essentially, a competent experienced supervisor should not blindly follow an out of date method, just because that’s what was written. You may know this practice as point of work risk assessment – in their wisdom, the Asbestos Network terms it ‘dynamic risk assessment’.
To be clear, I fundamentally agree with all of this approach, but I have some relatively minor objections to a couple of specific examples:
| Working at height | Mobile tower required to access asbestos-containing material (ACM) for removal. PASMA trained operatives (named) to erect, with hold point in plan of work (PoW) and checked by supervisor to ensure this is correctly built prior to removal activity |
| Confined space | Purging air to be introduced to facilitate works with trained site team, escape set provision and continuous gas monitoring in place throughout confined space (CS) working |
My problem with the first example is on a practical point – the chances of knowing that Steve the PASMA-trained operative will be assigned to a particular job in a number of weeks’ time is remote to say the least. Naming the specific operative shouldn’t be necessary.
The second is a lazy example that encourages a very poor attitude to confined space. It falls into the trap of taking a standardised approach that fails to recognise the specifics of why a space is confined, and what the exact risks are. In some cases, rolling out these standard controls would make matters worse, as I’ve previously explained in my analysis of the Confined Spaces Guidance.
This is the example they should have given:
| Confined space (due to risk of reduced oxygen levels) | Purging air to be introduced to facilitate works with trained site team, escape set provision and continuous gas monitoring in place throughout CS working |
There is also a final paragraph on quantitative risk assessments (i.e. risk assessments (RAs) with numbers), which states that they are not needed. The logic is that they are ‘only required to prioritise the controls’, and that because it’s a licensed activity you will be doing all of the controls. It is difficult to argue against this, but there may be a practical issue, as many PC clients will not recognise a RA without the quantification element.
What is the purpose of a risk assessment?
Other than these ‘minor’ points, the guidance contains sound advice. But I have a more fundamental issue with this as a standalone separate piece of guidance.
A simple way to think about risk assessment is that it’s like an exam. There is the question, and an answer – but you will also have your workings out. In the world of construction and asbestos – the method statement (how you’re going to do the job) is the ‘answer’, and the risk assessments are your workings out.
The answer is crucial, but the only way you can be sure to get the ‘right’ answer is after you’ve done the workings out. Far too many people make the mistake of seeing risk assessments and method statements as two separate exercises – or even worse two separate documents – and that’s exactly the trap that the current guidance as written is ushering us into.
Instead, the biggest section of the guidance should be focusing on how to translate the identified controls into the method itself. This ‘lost chapter’ in your method statement should have a work area set up section talking about using the hoist to lift the negative pressure unit (NPU) into position. It should be detailing the bagging of the AIB on the scaffold, and then the lowering of it to an operative on the ground. If indeed there is a confined space due to oxygen depletion, it should detail exactly how and when you will be introducing purging air (before you even start building the enclosure, I would presume).
What the current document tells us to do is complete a site-specific risk assessment (good), streamline it so that readers can focus on what is important without the fog of the mundane (great), and check regularly that it’s still valid (brilliant). But not once does it mention the reason we are doing this in the first place – writing a method that the employees can follow that will get them home safely (fail).
Written by Nick Garland on Thursday March 10th 2022
Earlier this year the British Occupational Hygiene Society (BOHS) announced multiple vacancies on its board, along with its two faculty committees. Of these important bodies, regular readers will know well the Faculty of Asbestos Assessment and Management (FAAM) Committee, which is expanding with the addition of five new members.
I’m excited to have been invited to run for election to one of these new positions on the FAAM Committee. I’m especially honoured given the calibre of the others in the list of nominees – I’m standing alongside many highly respected names, and very grateful to Sam Collins and Yvonne Waterman for putting me forward.
I wanted to serve up a brief reminder of the role of FAAM, and how the Committee and its members shape its direction and decision making. The faculty exists as the professional home for all of us who deal with asbestos as part of their work in the UK. Its key focus is on supporting and ensuring the competency and expertise of its members, with the goal of reducing the ongoing issues – such as mesothelioma and other cancers – that relate to historic asbestos use in the UK.
The FAAM Committee exists to steer this work. In FAAM’s own words, it’s there to “act as the guardian of professional standards and ethics in the profession of asbestos assessment and management.”
In practice, this means regular meetings at which the FAAM Committee works towards developing and maintaining standards for the profession. Committee members take part in discussions around qualifications and faculty membership, participating in disciplinary matters, and generally helping to ensure that the Committee continues to deliver against its objectives and satisfy its overall purpose.
It’s an exciting and important role, for a vitally important faculty, focusing on one of the biggest ongoing health and infrastructure challenges faced by this country. As I say, I’m honoured to even be in the running, and I wish all the nominees the very best of luck in the forthcoming election.
__________
If you’re a FAAM member, you should already have received an email inviting you to vote, sent on behalf of Alex Wilson, BOHS Honorary Secretary. If you haven’t seen it, please do check your junk mail folder, as my own invitation landed there.
Written by Nick Garland on Thursday February 10th 2022
One of the main objectives of the new analysts’ guide is to reduce analyst exposure, by clarifying what is licensed work, and what falls under the analyst’s remit. But the HSG 248 document is now massive, running to 238 pages. In cases where it hasn’t been fully read and understood there’s the potential for misunderstanding.
I’ve been thinking about this after a recent project, in which a difference in understanding created the risk of costs spiralling out of control. The project in question related to a wall that had sporadic asbestos insulation spatters underneath an imperfect layer of paint. The job was to scrape the wall back and then encapsulate the residues – so far so normal.
However, in this case the analyst was unwilling to enter the enclosure prior to encapsulation. This created the potential situation that, if the analyst wasn’t happy with their visual after encapsulation, the licensed asbestos removal contractor (LARC) would have to strip all the paint off and start again. The analyst’s view was that the project was not yet finished, the enclosure was therefore live, and that in line with HSG 248, ‘they do not do live enclosure entry’. For the LARC it represented a very expensive project risk.
So what does the guidance suggest? On the surface of it, HSG 248 is fairly ‘clear’:
The nature and extent of exposure will depend on several factors including the activity, the type and condition of the ACM and the effectiveness of any controls. For example, all entry into asbestos enclosures carries a risk of exposure to airborne fibres. Analysts should avoid as far as possible entering ‘live’ enclosures while removal or remediation work is still being carried out. If entry into a ‘live’ enclosure does occur there will be potential exposure to asbestos fibre concentrations above the control limit or short-term exposure limit.
Para 1.6, Pg 11 HSG248
However, if we look deeper (and when I say deeper, I mean we have to read to page 193) there’s more guidance under the section “Clearance for specific situations” – the bold is mine, for emphasis:
Inaccessible or impossible to remove asbestos
Spray-applied asbestos is often found in crevices or holes through walls where pipe work or girders run. These may leave asbestos residues that are impossible to remove. In these cases, the analyst may permit the use of non-flammable sealant such as foams or plaster to fill the hole and seal the asbestos within it. Before the sealant is applied the analyst must be satisfied that as far as reasonably practicable the asbestos has been removed.
Para A5.78, Pg 193 HSG248
Use of encapsulant or sealant
Where asbestos has been sprayed on to porous surfaces (e.g. breeze blocks, bricks, plaster and concrete), it is almost impossible to obtain an asbestos-free surface. The analyst should satisfy themselves that further removal is not reasonably practicable, and should advise the contractor and/or building client to seal the residual asbestos with a permanent proprietary sealant. The visual inspection can restart once the sealant has been applied and dried. In these circumstances encapsulation of asbestos should not take place before the analyst has seen the residual asbestos. A note should be made on the CfR and recorded in the asbestos register and management plan for the premises.
Para A5.80 Pg 194 HSG248
This second paragraph matches my example situation perfectly, but in fact both paragraphs make clear that the analysts must complete a visual before the LARC encapsulates any remaining asbestos to make sure (essentially) they are not hiding anything. While the general guidance in paragraph 1.6 says that analysts should avoid live enclosures ‘as far as possible’, this subsequent guidance takes us to the heart of the issue – a live enclosure is one where removal work is ongoing. In these situations, the enclosures are not ‘live’ as all possible removal has been finished.
Going further
In fact, my personal preference is to go a step further. I believe all such projects should be broken down like this:
With either option after the stage three air test, the client gets valuable extra information that they wouldn’t get with the traditional approach. Based on what happens, they know to what degree they need to be cautious about the wall.
This is my personal preference, and I’d be interested to hear opposing views on it, so let me explain my reasoning. First, read this rather long paragraph from the Analysts’ Guide:
There may be occasions when some asbestos is to remain in situ in the enclosure. It may be that only damaged asbestos lagging is being removed from pipe work, and that undamaged material is to remain; or it could be that only a proportion of asbestos ceiling tiles is being removed. The analyst should have been made aware of this in the discussion on the scope of work as part of stage 1. The contractor should have checked the condition of the remaining ACMs as materials in poor condition could lead to a failure in the four-stage clearance when the analyst checks. If the analyst does find asbestos materials in poor condition these will need to be dealt with (eg repaired, encapsulated or removed, all of which actions are likely to need agreement of the building client and the involvement of a licensed contractor. The four-stage clearance should stop at this point and the contractor/building client should be informed. The four-stage clearance should not restart until the matters have been rectified. Any remaining ACMs in good condition should be recorded in the CfR so that the building client can update the asbestos register and management plan accordingly.
Para A5.76 Pg 192 HSG248
My logic is that if we are working on a wall that only ever had occasional splashes of debris – the risk starts at low. If:
The selection of the scrape and vac technique is therefore intentionally leaving some asbestos in by design, and paragraph A5.76 is the reference that we should be looking to. This allows the analyst to make a judgement that all loose paint has been removed, and the asbestos left in by design would be noted on the four-stage clearance (4SC) certificate.
While we haven’t 100% removed the asbestos-containing material (some is being left in by design), stage two has passed, and there is no absolute need for encapsulation. But if the air test subsequently identifies a problem then we must encapsulate. On the other hand, if the whole 4SC passes, and we still want to encapsulate, well, that’s an ultra risk-averse decision that can be completed as a non-licensed activity.
I appreciate this is possibly a left field opinion, but I believe it addresses what we are trying to do which is understand and mitigate risk, rather than blindly follow what we’ve done before.
Written by Nick Garland on Wednesday 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 July 15th 2021
As you’ll almost definitely know by now, in April the Health and Safety Executive finally released its new Analysts’ Guide. I say finally, because as you’ll also know, the update was previously in the works for more than five years.
It’s been a very long road. The original consultation document was optimistically called ‘Asbestos: The Analysts’ Guide 2016 HSG248’. Like many others, I originally sent in my return to the consultation in November 2015. In 2017 I drafted my white paper, which summarised, analysed and commented on it. At the time, I anticipated that I’d be updating that promptly, but the real thing didn’t appear for more than another three years.
Despite this long gestation, the guide still has a few niggles – not least of which are a number of typos, some of which need clarification. I won’t be concentrating on these here, but I do think it’s likely the HSE will be targeting them in a minor revision before too long.
The big changes – and a typo
I’m not intending to focus on the big changes, in part because the majority of them were telegraphed in the original draft doc and then subsequently ‘leaked’ – we’ve had a long time to talk about them. The biggest example of this is the Supervisor Handover Form, which has been in wide but not universal circulation for a while.
However, now that it is in the guidance, for all practical purposes it becomes mandatory for the supervisor to hand one of these, fully completed, to the analyst before they can start on the four-stage clearance (4SC). This will also be something that the United Kingdom Accreditation Service (UKAS) will be checking when they do their visits to the labs. Assure360 was an immediate adopter of this, so if you’re already using the Assure360 Paperless app you don’t need to do anything.
Discover how Assure360 Paperless helps keep you within the guidelines.
If, however, you haven’t started using the now ‘mandatory’ form, be aware that the template on page 202 of the guide contains a typo. The form asks ‘Has the NPU been switched off and new pre-filter inserted?’ Of course, we all know that this is done by the analyst after they are satisfied that stage two has been passed and they are ready to start the air test.
The asbestos enclosure handover form widely shared by ACAD had this typo rectified – you could contact your trade organisation to get their corrected version. If you do use the one from the guide, be sure to brief your teams on the correct way to use it.
Getting into the subtleties
As I say, I don’t want to focus on the typos, but rather I want to pick up some of the less obvious changes that people might have missed.
Throughout, the Analysts’ Guide stresses the client’s responsibilities with regard to protecting the health of people who work in or on their building. The underlying subtext is that this includes the analyst and the asbestos removal operative. Clients also have fairly extensive duties under the Construction (Design and Management) Regulations (CDM) to ensure that a project can be carried out without risk – so far as is reasonably practical. The combination of these factors could be that the client’s duties extend to cover previously grey areas.
It seems curious that the HSE is effectively extending the well known position that the client and not the licensed asbestos removal contractor (LARC) should appoint the analyst. The reason for this is that the analyst’s four-stage clearance is the final quality control audit prior to handing back for normal occupation, and any conflict of interest at this point is bad.
So far so normal, but the change comes with the highlighting of less formal conflicts in paragraphs 1.23 and 1.24:
“…where the contractor is a major source of work…” and;
“The analyst should not perform site clearance certification where such shared links exist. However, if shared links are unavoidable, the building client should be made fully aware of them. This should be in writing.”
Any such links would therefore generate a UKAS-verifiable paper trail. It will be interesting to see what kind of an impact this will have on the industry.
Regardless, the inevitable conclusion that strikes me is that if personal monitoring is mandatory (it is), and the HSE is giving out a very strong steer that the client should appoint the analyst directly, then the client-appointed analyst should be conducting the LARC’s personal monitoring. It would then be inevitable that if they do, it will form part of the health records of that individual, and must be shared immediately with their employer (the LARC).
This might not seem controversial to those of you removed from the coal face, but the reality is that in many cases client-appointed analysts are refusing to share this crucial data with the LARC on the grounds that ‘the client has paid for it – so we can’t hand it over.’ It is my understanding that the HSE’s position on this will be made crystal clear in upcoming guidance on personal monitoring.
Personal monitoring, again
The most significant of the subtle changes in the new analysts’ guide centres around personal monitoring. I first wrote about these based on the final draft version of the guide. In short, a new type of personal sample has been added: the Specific Short Duration Activity (SSDA) test.
It’s this test that most contractors have tried to use in recent years as it has the most immediate, practical effect – i.e. they use it to test the effectiveness of their methods and make changes as appropriate. The problem has been that as it wasn’t listed in the guidance, analysts were tending to only do the 10-minute version, which is useless in all but a few cases.
Now the HSE has given the optimal test a name, LARCs should immediately adopt the terminology, and request ‘SSDA Personals’ whenever they book personal monitoring tests.
There are dark arts involved in the calculation of four-hour time-weighted average (4hr TWA), and LARCs can take another step that will increase the utility of any personal monitoring air testing. Where possible the go-to or standard test should be at least two hours long, and run at a sample rate of two litres per minute. The full 200 fields/graticules should be counted, too. This single test will then qualify for calculating a SSDA, RPE suitability, and the 4hr TWA. Of course, there may be more complex situations, as I explained in my recent deeper dive on the 4hr TWA.
Finally, those of you who have read my earlier posts may remember I pointed out a typo in the late draft of the guide. It specified a four-litre per minute minimum flow rate for the SSDA tests, but this has been corrected in the final version to specify up to four litres.
Written by Nick Garland on Tuesday June 15th 2021
I’ve had a lot of very positive comments on April’s article about personal monitoring and the four-hour time-weighted average. I thought it might be a good idea to take another look – but this time take a deeper dive into the exposure geek pool. In this post I’m going to really focus on the challenges of the four-hour time-weighted average (4Hr TWA), and give a few more examples of how to do it.
What’s the point of the 4hr TWA?
It’s important to start with a quick refresher on the point of the 4hr TWA. Sam Lord of the Health and Safety Executive (HSE) recently summed it up neatly: the point of 4Hr TWA control limit testing is to really look at compliance, not just nod to it.
I discussed the wider context of the testing and explained the terminology in my previous post. The key point is that the four-hour control limit test is a duty-of-care test, intended to really examine whether we have complied with our duties as an employer.
To recap, the test specifications are:
| Test | Sample Rate (litres/min) | Minimum Volume | Minimum Graticules | Resulting LoQ |
| 4-hour Control Limit | 1-2 | 240 | 100 | 0.04 f/ml |
The control limit is 0.1 fibres per millilitre of air (f/ml) over four hours – measured inside the mask.
The newly (finally) published Analysts’ Guide specifies a simplified version of the World Health Organisation method – an attempt to increase the frequency at which these tests are being completed.
Despite referring to it as a ‘test’, it is better to think of the four-hour TWA as a calculation. It is intended to represent what happened to that person over a continuous four-hour period – it tells a story, if you like. The simplified rules are:
There’s a very important point to make here: you don’t have to do a single four-hour air test to calculate a valid 4hr TWA. What you do need is a record of what happened over those four hours, with test results that support the ‘story’.
The HSE’s simplified approach to this is to require a minimum total air volume of 240 litres. If you do the maths, that means you need at least a two-hour (120-minute) test at two litres per minute.
However, now the analysts’ guide is out, it’s clear that how you get to those numbers is a bit more flexible. You could conduct three individual tests one after the other. Importantly, certain assumptions can also be drawn.
The calculation
Let’s go through some examples of how you do these calculations by hand. The calculations for all of these examples are taken directly from the new analysts’ guide. Please note that the HSE works in hours and fractions of hours, rather than minutes.
Also, before I start, I should point out that while the sums are straightforward, the calculations are yet another burden for asbestos professionals. Later on I’ll explain how Assure360 can do it all for you.
Example 1 – a series of tests to paint a picture
Consider this shift inside the enclosure:
Because we know the sample rate was at least one litre per minute, and the total test duration is four hours, we know that the total air volume exceeds the magic number of 240 litres. In this case we can tell the story of the whole four hours.
This is where the ‘time-weighted’ bit comes in – we multiply each of the measurements by the duration of that specific activity to calculate total exposure. Then we divide by the total duration to produce an effective average exposure rate for the entire duration of the tests:
Example 2 – what if the work lasts more than four hours?
An activity will often carry on beyond the tested period. In this case, the guidance says you can assume that the exposure continued at the same rate, provided the minimum flow rate and sample volume are met. Consider this activity:
Here, the test duration and flow rate ensure the total sample volume is well over the minimum 240 litres. Accordingly, you can assume that the last 40 minutes of the four-hour window would be same as the result of the actual testing:
Example 3 – what if the work lasts less than four hours?
Similarly, where the work (and the air test) last for less than four hours, we can extrapolate. Consider this morning’s work:
Again, as the sampling rate was 1.6 litres per minute for 150 minutes, this means that the total sample volume meets the 240-litre minimum. Accordingly, we can calculate a four-hour TWA:
Of course, if you’ve got the computing skills, you can create a spreadsheet that will do all of that for you. Alternatively it can be done by hand every time. But while the former is bad enough, the latter is quite soul destroying – and either could be prone to mistakes.
Making it simple
Happily we’re able to offer Assure360 customers an alternative. I’ve long sought to simplify personal monitoring for licenced asbestos removal contractors (LARCs), and I want to support the HSE’s renewed push to improve it. We’ve added a new TWA tool to the Assure360 platform, allowing the system to do the heavy lifting for you – and saving hours.
Last month our Paperless app was enhanced so that, along with the test result, it will collect three more data points:
Now that this data is being collected, the Assure360 database reports will, over the coming weeks, give you more and more power to do TWA calculations.
We’re already providing the original simple time-weighted result for every compliant test. We also calculate it for every situation where it is known that exposure continued for the full four hours. Next month we will be adding a system to pool multiple results together, to complete the suite of tools.
By automating calculation of the four-hour TWA, I hope that we can help ensure that more four-hour tests are carried out, and fewer mistakes and misunderstandings made. More than anything, we want to help the HSE improve the depth and quality of personal monitoring, and improve the safety of everyone who works in our industry.
Want to see first-hand how Assure360 Paperless simplifies the four-hour TWA? Why not get in touch to book a free demonstration?
Written by Nick Garland on Monday April 19th 2021
The Health and Safety Executive (HSE) is getting ever closer to the release of its new analysts’ guide – intended to help analysts and their clients comply with the Control of Asbestos Regulations 2012 and its Approved Code of Practice (ACoP). I’m reliably informed it will be coming in the next month or two. I know we have all heard this before, but it really does seem to be imminent now.
UPDATE – May 2021: The guide is now published. Click here to download the Analysts’ Guide from the HSE website.
As I highlighted in my review of last November’s FAAM conference, there are some important changes to the guide’s personal monitoring section. These add to an impression that the HSE is taking personal monitoring increasingly seriously, and trying to get to the bottom of why it is generally done so poorly.
If you are struggling to wrap your head around personal monitoring, be reassured that it is a complex subject that often feels academic, with no practical benefit. And if it makes you feel any better, be aware that not everyone at the HSE understands it fully either.
Be careful what you ask for
In regard to personal monitoring, the HSE seems to be asking ‘why do we never get what we ask for?’. In my view, the reason is that the whole subject has never really been communicated with people on the ground (the actual doers) in mind. Here’s an extract from the draft new analysts’ guide:
| Test | Sample Rate (l/min) | Minimum Volume | Minimum Graticules | Resulting LoQ |
| 4-hour Control Limit | 1-2 | 240 | 100 | 0.04 f/ml |
| 10-minute short term exposure limit | 4 | 40 | 100 | 0.24 f/ml |
| Specific short duration activity | 4 | 120 | 100 | 0.08 f/ml |
| Assessment of suitability of RPE | >0.2-4 | 40 | 100 | 0.24 f/ml |
First, a quick explanation for those of you not familiar with the terminology:
Graticules – if you have ever looked down an analyst’s microscope, a graticule is the little target. Stating how many graticules is effectively a statement as to how long / hard an analyst should read the slide. The longer they look, the more accurate the test.
LoQ – a favourite acronym of us exposure geeks. It stands for Limit of Quantification, but what does that mean? It’s a threshold describing the sensitivity of the test: in effect, the analysts are saying ‘We don’t know exactly how much asbestos is there, but if it were above this number we would have found it all.’
All air tests have a LoQ which varies depending on the specifics of the test: how hard the pump was working (the sample rate), how long the test continued, and how many graticules were inspected. The more air you sample and the harder you examine it, the more sensitive the test is. If you find less asbestos than the LoQ (including none at all), you can’t be sure of this – so you say it was below the limit.
Back to the table. In a change from the existing analysts’ guide, you’ll see there are now four personal monitoring tests. Here’s what they’re for:
Four-hour Control Limit – this is a duty-of-care report: the employer is legally required to do these to demonstrate that individual workers are not exposed to asbestos above a certain limit, over a long period of time. That limit is 0.1 fibres per millilitre of air (f/ml) over four hours.
What you might not realise is that this is inside the RPE that you have provided. The other thing to remember is that these are tests associated with the individual being exposed – not the activity. So when analysing the data, make sure it is person-focused. I’ll go into more detail on these dreaded four-hour time-weighted average (TWA) tests later.
Ten-minute short-term exposure limit – this is the second legally mandated duty of care report. This test is intended to measure short-duration, high-intensity activity, and the limit is 0.6 fibres / ml inside the mask. Essentially this test is to detect brief ‘spikes’ in asbestos concentration, even when the average over four hours was acceptably low.
It’s very hard to achieve meaningful results in these tests. It’s obviously easy for the operative to be ‘painfully careful’ for 10 minutes, avoiding the kind of activity that might have otherwise produced a spike.
Assessment of suitability of RPE – this aims to gauge whether the mask was good enough for the task. This is related to the protection factor (PF) of the masks. To calculate it, you divide the exposure by the PF to identify the likely level inside the mask. Well-fitted, powered full-face masks give a protection factor of 40. Orinasal masks are rated at 20. Simple.
Specific short-duration activity (SSDA) – this is the ‘new’ kid on the block. I say ‘new’ as despite it not being on the list before, it is also the test standard that most licensed asbestos removal contractors (LARCs) try to achieve. It is essentially a test of how effective the method was.
The good news is that it is now on the list. The bad news is that the HSE has stated a sample rate of four litres per minute. Having spoken to the authors I can assure you that they mean up to four. Hopefully this typo will be amended before publication.
It’s my understanding that the HSE views the two most important tests from this list to be the four-hour control limit, and the SSDA. Indeed, now that SSDAs are on the list we will be able to remove one of the biggest problems to completing personal monitoring: analysts. More specifically, that many analysts do what the guidance tells them without exercising a deeper understanding.
Often, when a personal monitoring test is booked, an analyst concludes that they can’t do the four-hour test because the operative isn’t in the enclosure that long. Instead, they do the 10-minute test, the LoQ for which is so high as to be next to useless. This has been driving the HSE quietly mad for years, but now, when you are booking a personal, you can request a ‘SSDA Personal’.
I hope this will solve the problem, but it doesn’t get away from the lack of understanding surrounding the four-hour test, how to apply it, and how to calculate the results. As promised, we need to dive into them.
The dreaded four-hour time-weighted average tests
As I mentioned, the four-hour TWA tests are the main duty-of-care tests that we are legally mandated to do. They follow a World Health Organisation method which assures a level of accuracy that we would all agree is important when we are talking about people’s long-term health.
We do them because it’s the law, but more importantly because high-accuracy testing is the right thing to do. This is unfortunately easier to say than do. The rules are not widely understood, and the maths underpinning the test is fiendish. So here’s my attempt to simplify the whole topic.
Firstly it is better to think of the four-hour TWA as a calculation, not a test. The rules are that the test underpinning the calculation must look like this:
That brings us to the second and most important point: you don’t need to do a single four hour air test to calculate a valid four-hour TWA. Obviously running the air test for four hours will make the maths easier – but it is not essential. As long as the initial test is for two litres per minute and is run for at least two hours, we’re in business. What makes up the rest of the four hours can therefore come down to estimates and assumptions.
Squaring the circle
To explain this further, let’s look at a chart that the HSE presented at last year’s FAAM conference:
The aim is to capture the highest exposure (the initial removal phase) within the four-hour test. But it’s often the case that this doesn’t last for four hours. A second HSE chart helps show how you square the circle:
Charts by kind permission of Sam Lord HSE.
The activity is split into three distinct phases:
On this last bullet – there is a tantalising opportunity. Due to the very low impact of such a short low exposure event, it may be possible to build up a library of test results to populate the last bit of the calculation. But as only tests that comply with the basic WHO rules count, you may have to wait a while to build up the evidence. I have long advocated that the standard test should be one-hour long with a flow rate of two litres per minute. This gives us a decent level of accuracy for short-duration activity tests. If we increase this to two hours as standard, every test we do can be used for any of the HSE’s test categories.
The calculation (and why you don’t have to do it)
I’m going to take you through the steps to do the calculation by hand. But at this stage I should give you a spoiler alert: later in this post I’ll explain that Assure360 can do it all for you!
In the HSE’s example above, the equation is formed from three different work/rest sessions, and what proportion of the four-hour period they take up. As I mentioned – I have rounded the numbers to make it easier:
This gives us:
The trick is to do each of these as separate little sums and add them together (remember zero multiplied or divided by anything is zero):
This gives you an answer of 0.275f/ml for the four-hour TWA.
If you’ve got the computing skills, you can create a spreadsheet that will do all of that for you. Alternatively it can be done by hand every time. But while the former is bad enough, the latter is quite soul destroying.
Making it simple
Those of you who’ve read my articles before will know that trying to simplify personal monitoring for LARCs could be considered ‘my thing’. I wanted to add my support to the HSE’s renewed push on personal monitoring, so we’ve added a new TWA tool to the Assure360 solution. Just as with everything else we do, a small tweak to the front end allows the system to do the heavy lifting for you – saving hours.
Our Paperless app has now been enhanced so that, along with the test result, it will collect three more data points:
The Assure360 database will do everything else for you. It will check the rules to make sure the test qualifies, and it will automatically do the calculation. Every test will be given its four-hour TWA value, and every duty-of-care report will provide the information.
If you are able to specify that all personal monitoring tests are at least two hours long with a flow rate of two litres per minute, it will also automatically start to build up a library of results that could be used to estimate the balance of any exposure
By automating calculation of the four-hour TWA, I hope that we can help ensure that more four-hour tests are carried out, and fewer mistakes and misunderstandings made. Improving the depth and quality of personal monitoring will, I hope, help the HSE reduce exposure in our industry, and improve working conditions for us all.
Want to see first-hand how Assure360 Paperless simplifies the four-hour TWA? Why not get in touch to book a free demonstration?
The Analysts’ Guide was finally published in May 2021. Click here to download it from the HSE website.
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
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.