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.
Strategy and Policy
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:
- To minimise exposure and check it’s below the Control Limit
- To confirm controls (including respiratory protective equipment (RPE)) are adequate
- To support current and future risk assessments
- To maintain employee exposure records
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:
- The asbestos-containing material (ACM) – for example, asbestos insulating board (AIB), sprayed coating or pipe insulation
- Quantity – debris is very different to multiple panels
- The environment – e.g. tight spaces or above head height
- Whether the situation perfectly matches your controls – can you spray, will there be breakage etc?
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.
A change in 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:
- build the enclosure (two hours),
- remove asbestos (30 mins),
- fine clean (one hour)
- and assumed nil exposure for the rest of the day
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:
- Half mask – 20 x 0.1 = 2f/ml
- Full Face – 40 x 0.1 = 4f/ml
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:
- Improve methods
- Drill down and compare operatives conducting the same activity.
- Trend analysis
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.
Required uses for personal monitoring
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.
||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.
||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.
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