Assure 360

Five takeaways from the new exposure guidance

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.

It Exists!

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.

Good Strategy

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?

  • Quantity – debris is very different to multiple panels
  • The fixing – glued, nailed, screwed and lay-in are all very different
  • The environment (e.g. tight spaces or above head height) – Does the situation perfectly match your controls? Can you spray, will there be breakage etc?
  • Who is doing the job – a new starter (whether that is someone fresh from a new op course, or an agency operative you don’t know from Adam) is much higher risk than a trusted, careful employee

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: 

  1. Record the ACM and fixing
  2. Record what you are doing – normal removal, or if it is a more complex atypical method
  3. The scale of removal – differentiate between one-off panels and large-scale projects

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.

Clients should, and analysts must

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!

What tests to do – and why

The guidance lists the four tests you could do, but it focuses us on two:

  • Specific short-duration activity (SSDA) 
  • Four-hour time-weighted average (4Hr TWA)

It also explains why.

SSDA

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:

  • How effective was your method – does it need to be changed?
  • Are your assumptions about exposure correct?
  • Are some operatives better at doing things than others?
  • Can you learn from those differences?

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).

4Hr TWA

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?

Why is it important?

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. 

Why only four hours?

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. 

Never ask an analyst to do a personal

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.

  1. The four-hour control limit
  2. The 10-minute control limit
  3. The (defunct) Action Level
  4. Suitability of RPE

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.

In case you missed it: our personal exposure webinar

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.

 

A webinar on the new exposure guidance

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!

 

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Webinar: Social distancing tools and tips for companies returning to work

Written by Nick Garland on Thursday July 23rd 2020

With the UK past the peak of the Covid-19 pandemic, the focus has shifted towards kickstarting the economy. While we acknowledge that many in the asbestos and construction industries continued to work throughout lockdown, as sites ramp up fully again we all face new health and safety challenges to comply with social distancing requirements.

Assure360’s cloud-based solution provides companies with the platform through which to help manage a safe return to work. Offering a paper-free and secure way to audit and monitor site performance, it ensures that critical data can be communicated to site teams, and gathered for compliance and analysis, with less reliance on face-to-face meetings.

In particular, Assure360 Paperless ends the reliance on inefficient site paperwork when logging critical safety checks. It reduces the amount of potentially contaminated material travelling to and from site, and offers efficiencies which help offset the time lost to stricter controls in the workplace.

We want to help, which is why we’re offering a free-of-charge 3-month trial. We believe Paperless can provide important support in these difficult times, and we’re also inviting you to a free webinar to explain how.

A repeat of our popular Benefits of Paperless in a Social Distancing Climate webinar will be running via Zoom at 3pm on Monday September 14th. Places are free, but please book by following the link above.

During the webinar, Assure360 founder Nick Garland will share a detailed description of how our Paperless solution – part of the Platinum subscription – could help you increase your use of remote management, lower costs, and reduce the need for teams to come back to the office during these unprecedented times.

We believe that our solution can really help LARCs get through this, and we want to help. Please join us at the Benefits of Paperless in a Social Distancing Climate to find out more.

Sign up to our regular free webinars led by our team of experts

Written by Nick Garland on Saturday July 27th 2019

We run regular free webinars that help leaders in the asbestos sector stay up-to-date on all our latest tools made available through Assure360 system. Created by the teams that helped develop these products and best practices, our webinars provide details on the best ways to use our suite of apps and platform.

Join our next upcoming Webinar on the Paperless App on 27 November 2019

We also know not everyone in our industry considers themselves technical. So if you’re wondering what a webinar is – let alone how the app works – don’t worry, check out our one-minute explainer video to give you an idea of what is involved.

In November our webinar topic is our new Paperless app, which provides a solution the entire asbestos removal industry has been waiting for. Phase one of our our digital support tool for site supervisors, records safety critical checks including:

  • Site registers
  • Inductions
  • Exposure
  • RPE checks
  • Timesheets
  • Site diaries
  • Visitor information

Sign up of our webinar on 27 November 2019 and find out why more and more supervisors and managers in the asbestos removal sector are using it.

Nick Garland, our founder, will take you through everything you need to know about the system and demonstrate how it saves teams time and money. If you’d like to register for our November webinar, simply sign up and we’ll send you more information.

Book your free place on the Assure360 Paperless Webinar on 27 November 2019. 

Our webinars take place on the fourth Wednesday of each month at 1pm and 3pm unless otherwise stated.
Please use the link above to book.

Assure360 Webinars explained: join our free demonstrations from anywhere

Written by Nick Garland on Wednesday February 20th 2019

Assure360 Paperless is a powerful tool that transforms the way asbestos removal contractors work. Like most tools, the best way to see the difference it makes is with a hands-on demonstration. That’s why we’re holding free monthly webinars, where we explore and explain all the product’s brilliant features. If you’re interested, great – you can sign up here.

At the same time, we know not everyone in our industry considers themselves technical. If you’re wondering what a webinar is – let alone how the app works – don’t worry, check out our one-minute explainer video:

Sign up for the webinar and we’ll send you a link you can follow to join in from any browser. You can sit back and watch as we walk you through the product, and if you have any questions, simply type them in as they occur to you. The Assure360 Paperless webinars usually take an hour: although we stick around for as long as there are questions, you’re free to leave whenever you like.

So why not join us for our next webinar? Just click the link above to get started.