In 2014 / 2015, the HSE carried out their Analyst Project – or to give it its full name ‘TheAsbestos Analyst Inspection Programme’. Its aim was to examine the performance of analysts in the removal process. At the BOHS roadshow last month, the HSE’s Martin Gibson revealed the initial findings and the first conclusions – perhaps the most surprising is how it might impact on the licensed contractor.
The UKAS accredited lab survey
The HSE contacted all UKAS accredited labs and asked them to complete a questionnaire – the results were extremely enlightening.
- More than 40% of Four Stage Clearances (4SC) were completed by just 13 labs.
- 43% of companies stated that 81-100% of jobs required additional cleaning before they could pass it.
- 76% of analytical companies stated that they fail up to 20% of enclosures first time.
- Nearly 10% of analytical companies fail under 1% of enclosures first time.
- Approximately 2% of companies fail 81-100% of enclosures first time.
Of the 145 UKAS accredited labs not everyone responded (obviously) – more than a third of them in fact. But if they thought they would stay under the radar, they were mistaken and the team targeted them for visits just the same.
Targeted four stage clearance visits
Twenty 4SC visits were planned and in all cases the analysts were told to expect the HSE. Whilst this solved the issue of turning up when nothing is happening, it did mean that the analysts would be on their best behaviour.
I have broadly split the findings into the four stages of the process. I have also tried to highlight areas in the draft analysts’ guide that is intended to correct this. A copy of my white paper summarising the guide can be obtained on the Assure360 website.
One general point to be made is that wherever I mention photos – each has to be digital and date and time stamped to prevent forgery. And as usual there is a health warning with this post – this time from Martin Gibson – he stressed that the findings did not apply to all the analysts!
Stage 1: Initial checks
Whilst the analysts were checking that the asbestos had been removed, a detailed review of the surrounding area was a different matter. Whether the general site conditions were fit to start the inspection was often ignored. The worst example was this transit route – strewn with rubble and other non-asbestos material. It should have prevented failed at Stage 1.
The new draft guide has detailed the key inspection areas for the first stage of the process (including the transit routes and the areas surrounding the enclosure). Photographs are now required to demonstrate the adequacy of the situation.
Stage 2: The visual inspection
The HSE’s view is that this is the critical part of the whole process, and raised the most number of issues in the investigation.
Analysts were observed moving randomly around the enclosure. Guidance (and logic) has always had it that a methodical pattern will help avoid missing something.
20% of the analysts wore domestic clothes underneath their overalls. This would have prevented them from decontaminating properly in case of a failure. Any of my regular readers will know that I believe that full decontamination via the DCU should be followed with every enclosure entry.
Formal failure certs were not always issued when an enclosure was rejected by the analyst. Whilst I can understand the instinct not to create paperwork, these failed certs are critical for addressing the root cause – that the LARC didn’t clean it sufficiently and the Supervisor failed to identify the issue. Clearer guidance on when to formally fail an enclosure is included in the new guide.
Two analysts arrived without overalls and two were unshaven. I don’t know whether these were the same individuals, but when you remember that the analysts were expecting HSE attendance – this kind of sloppiness is shocking.
What PPE and what to wear underneath is also detailed extensively in the new guide – the handy table is reproduced in my white paper on page 44.
There were also some startling implications over the amount of cleaning that analysts do – but I will leave that till later in the piece.
Stage 3: The air test
There were incidents that raised questions over basic competence namely calculating fibre concentrations incorrectly (decimal point wrong). This may just be the nerves of being overlooked.
More significant, in my eyes, is that one of the analysts forgot the brush for the disturbance test. Again, when you recall that the analyst knew the HSE would be in attendance, wouldn’t the instinct be to double and triple check your equipment? A photograph of the brush is now needed in the new look Certificate for Reoccupation.
Generally, the HSE found insufficient time was spent on reading the slides – one took just nine minutes to read three slides. This compares with the 10-15 minutes per slide in the current draft analysts guide and the 10-25 minutes in the old version! Just as I was forgiving to the analyst that got the decimal place wrong, to race through this phase of the process when observed by the authorities makes you wonder ‘what normally happens?’. The new look certificate with time and date stamped photos and time declaration at the signature stage should help this.
Stage 4: Final assessment
This is where the final checks are conducted post dismantling the enclosure, but I also include decontamination and PPE.
Frequently the analysts did not wear overalls when conducting the final checks. This is obviously unwise as dismantling the enclosure can reveal hidden problems. Mostly the analysts were entirely unprepared for these unpleasant surprises including not carrying RPE. Whilst the guidance is a little clearer in the new guide – Stage 4 is missed off the handy summary table, and the reader must go hunting in the Appendix. Hopefully the final draft will be amended.
The HQ visits established that practical training for decontamination was lacking. On site this was evidenced by analysts being unsure when to decontaminate and following the incorrect DCU entry/exit procedures when they did. Much more detailed guidance on decontamination procedures is included in the new guide – including training as a core skill.
Personal Air Tests
No apologies for this section, though my regular readers might think that I am a broken record. The project established what we have been seeing with the Assure360 data. Most personals air tests were very short term and usually only 10 minutes. Further, they included no contextual information – just ‘removal works’. To compound this, the analysts often reported the calculated results which were below their own Limit of Quantification (LoQ). This is next to useless to the LARC who is attempting to improve their methods. They need long duration tests, with decent (low) LoQs and detailed information over what was happening during the test. Assure360 has analysed over 5000 personal air tests and even here we are finding that approximately 10% are for only 10 minutes.
More on visuals
This is what I hinted at earlier – something that all analysts will already know – analysts do quite a bit of cleaning as part of the visual. What makes it startling is the implications.
I am very aware that the LARCs have views on analysts and the ‘helpful’ ones are those that pitch in to get the enclosure through the clearance. I counted myself as one of those. In the Project, many analysts stated that they conducted minor cleaning. But what constitutes ‘minor’? Well in one case it was cleaning for over an hour!
The HSE’s view of this is that >15 mins cleaning constitutes licensable work and must not be done by the analyst. What’s more – any such breach is considered, at least in part, the LARC’s fault:
36. (1) Where the commission by any person of an offence under any of the relevant statutory provisions is due to the act or default of some other person, that other person shall be guilty of the offence, and a person may be charged with and convicted of the offence by virtue of this subsection whether or not proceedings are taken against the first-mentioned person.
All change for the supervisor?
Whilst the new analysts’ guide (still draft) has been written in such a way as to take some of these findings into account (get a copy of my white paper here), some last-minute changes have found their way in.
- Strongly worded guidance – ‘Do not carry out cleaning’;
- If >10 mins cleaning is required – the analyst should formally fail the 4SC;
- The supervisor is to complete a new handover certificate. A draft version was briefly flashed up at the roadshow and will no doubt get amended further – but key elements include:
- Have you got access equipment?
- Have you checked all floor surfaces and ledges?
- Have all ACMs been removed?
- Have you checked all rooms?
- Have you checked all cables and wiring?
- Time taken on visual.
- Statement of any defects.
- Signed by supervisor.
- Signed by analyst BEFORE 4SC can commence.
The new Licenced Contractor Guide which I understand was complete – just awaiting a slot in the HSE schedule to publish it – will now need a re-draft. Further guidance will be included on
- Thorough fine cleaning.
- Supervisor re-inspections (the process).
- Time for the supervisor’s re-inspection.
- Supervisor to provide photographic evidence. This had several ‘???’ against it – so we’ll have to wait and see.
“It is very rare that site supervisors carry out an inspection before the analyst arrives.” Analyst – Anon
My experience however is that the good supervisors take their role seriously and complete these visual inspections. However, the required declaration by the supervisor ‘time taken on visual’ may come as a bit of a shock.
The HSE’s view is that the visual inspection is by far the most important part of the whole clearance process. If the responsibility is primarily the LARC’s – a light touch / brief visual by the supervisor won’t be acceptable. The draft analyst guide gives us very detailed suggested times for these visuals.
This table indicates that a small boiler room should be inspected by the supervisor for 2-4 hours before the analyst can start stage 1 of the process. It also begs the question if the Supervisor is conducting a visual and therefore not supervising the rest of the team – does all activity stop?
There will have to be a sea change in expectations.
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