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:

• appropriate air monitoring outside the enclosure is carried out, e.g. in situations where the air exhausted from the enclosure is discharged into an occupied building because it is not reasonably practicable to discharge externally”

And then Paragraph 416 adds that, “air monitoring to reduce risks from spread of asbestos is required to:

• measure the background concentration of asbestos fibres in the work area during work, to check that the control measures are effective;
• measure background fibre levels outside the enclosure, particularly when the enclosure is in occupied premises. Check for fibre leaks around the perimeter of the enclosure and at the airlock and bag lock positions. Also conduct testing at the discharge location of the air extraction equipment, where it is sited internally”

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.

Back on the menu

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:

• The client’s stopped paying
• The instruction to do it was on paragraph 84 out of 116 in the ACoP and…
• …people forget the relevance of the word required.

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.

What do you need to do?

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.

What do we mean by 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.

Why the interest now?

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. As you may have guessed, Assure360 already has you covered, and our Paperless app is already fully compliant with the guidance.

Discover more about Assure360 Paperless – read about the app here, or get in touch for a free demo.

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