The Health and Safety Executive (HSE) is in the middle of one of the biggest shakeups of asbestos licensing since the permissioning regime was introduced. I’ve already written about what’s changing, but I want to expand more on how Assure360 is better placed than ever to help customers through the whole licence application process.
The new electronic system of asbestos licence assessments is well into its trial, with multiple organisations already having experienced it. The whole process is radically different for applicants, with much more emphasis being placed on a review of the application and its supporting evidence than on the meeting itself.
When I first heard of the change I was very sceptical – and I know some HSE inspectors have had their doubts. There are obvious advantages to testing the mettle of a potential licensee whilst the asbestos licensing principle inspector (ALPI) looks them in the eye. But there have long been concerns over consistency in the current system, with some areas reputed to be much more rigorous than others. In the new regime, assessments are triaged by a central team, which should help in this regard.
The focus is now on providing evidence to support a licence application and, as at least one HSE inspector has observed, Assure360’s entire premise is to provide information to support sensible decisions. Its power is made even clearer with the new regime. The ability of Assure360 to support the bid – whether at the basic Silver or the fuller Gold and Platinum levels – is clear.
So what can you expect from the new application form? Here’s a brief overview of each section, with an explanation of how Assure360 can help both with your approach, and with providing the evidence that the HSE expects to see. It’s worth noting that the form comes with dire warnings to anyone tempted to use a consultant to complete it: there are grave consequences, potentially including licence revocation.
Dissecting the application form
The first few sections of the application form are fairly broad, asking for details on who will be in the meeting and other key individuals who aren’t going to be present. It also asks what sources of information, legislation and literature you rely on. There are no ‘correct’ answers for any of these – they establish who the controlling minds are in your business, and how you stay abreast of changes and improvements in the industry.
So what helps here? Being a member of a trade organisation helps demonstrate a commitment to higher standards, while attending regional meetings can be an excellent opportunity to share experiences with like-minded professionals. I give out updates via my monthly newsletter (if you haven’t signed up – add your email at the bottom of this page). I also publish safety alerts.
By section four, the application form really starts to test your competence as an organisation by looking at plans of work. The HSE specifically asks for two different examples, and states that they should relate to jobs that you do.
What the form doesn’t say explicitly is that despite it being only two, they should cover all of the different types of job that you do. For example, if you have completed 100 asbestos insulating board (AIB) jobs and one pipe insulation removal, don’t submit two AIB jobs. What you do if your work extends beyond two types of job isn’t entirely clear.
Assure360 comes into its own
After Section four, Assure360 becomes invaluable in your efforts to demonstrate and evidence your competence as a licensed contractor. Without it you’ll be scrabbling around for paper evidence, but with it, everything is at your fingertips. It’s up to you how you submit evidence, either printing it off or giving the HSE a read-only link to the correct page of the system. There is even a page dedicated to the licence application, in which we’ve mapped out the correct reports against each section in the application form.
Sections five and six
These sections are all about site and equipment checks. Ordinarily you’d provide the site files – coffee stains, spelling mistakes and all, and you’d need to scan every page and save them as PDFs. A potential pitfall is the size limit on emails you can send to the HSE. The form states a maximum 25MB, but the real limit seems to vary – with some people reporting less than 12MB.
However, with Assure360 Paperless all of the plant, equipment and site checks are at your fingertips, and you can show them to the HSE. A few clicks will allow inspectors to see absolutely all the relevant checks completed on a site. The feature isn’t just restricted to plant and equipment – it covers enclosure checks and smoke tests too. All certificates completed in the Paperless app are uploaded directly to the project file and are time and date stamped. The App even helps with spelling.
Section seven deals with respiratory protective equipment (RPE), personal protective equipment (PPE) and air monitoring. Understanding and recording this has always been a problem for the industry, but it was one of the first things that Assure360 cracked.
Within two minutes, Assure360 users can provide detailed evidence of:
- Exposure to all their operatives
- Evidence of investigations into elevated personal monitoring tests
- Number and coverage of personals
- How they use their personal monitoring data
- Personal monitoring strategy
- Underlying root cause analysis and their improvement strategy
Just imagine trying to explain all of that with only an Excel spreadsheet!
This section covers health records and medicals. It’s an area that we don’t yet cover, but Assure360 is developing all of the time. Coming soon there will be a full personnel management system, which will be free to all subscribers.
Sections nine and ten
These sections cover leadership and management – often difficult concepts to get your head around, never mind explain in writing. Again, Assure360 is there to provide evidence to backup your words. At the touch of a button you can display exactly what you are observing on site. You can show all of the non-conformances from all of your audits, including what you did to rectify on site and, critically, what you did to ensure they wouldn’t happen again.
With Assure360’s unique benchmark tool you can also spot what the entire army of Assure360 auditors are encountering, across the country. Being forewarned of developing problems allows you to plan to avoid issues and mitigate risk. This constitutes evidence of a proactive approach to health and safety management, and demonstrates your ability to look beyond just your company. Remember that this links in with one of the questions in the form’s early sections, on how you get your health and safety information.
Using Assure360 you can illustrate how many times your contract managers, senior management and even directors attend site. It’s seconds’ work to present the data in a colourful chart showing how many audits the entire team are doing, and providing direct evidence of senior management’s attendance on site and involvement in health and safety.
The final benefit is that you can remap all of the above information to reflect training needs for the individuals across your business. More on that in the next section.
Section 11 is all about training and competence. Assure360 is built around effective auditing, and the first thing we made the data do was drive competence. Providing evidence for all your assessments and training needs analysis is extremely straightforward. Within minutes you can present:
- A top level view of the competence of all your operatives – including agency workers
- A detailed view of individuals – whether they’re contract managers, supervisors, operatives or agency staff
- Actions and training needs raised against individuals in the team – exactly what you found on site and what you did to close it out
With Assure360 you can present a competence scheme that encompasses everyone in the organisation – not just supervisors and operatives. It is so comprehensive that it exceeds the HSE’s expectations.
The final section focuses on reviewing and measuring performance. As I said, auditing is the emotional home of Assure360. Auditing with the system saves about two hours compared to the traditional paper and Excel route. Add to this the fact that the database automatically interprets and re-interprets all of the observations and it’s the health and safety manager’s dream.
When it comes to the new licence assessment system, this section represents exactly what Assure360 was designed for:
Trend analysis – company as a whole, individuals, specific competencies and non conformances
Setting health and safety targets – you can move beyond the standard ‘no RIDDOR’ and ‘no enforcement action’ to set imaginative targets and evidence trends in performance at the individual level
What’s your strategy and are you hitting it? – evidence your success through simple one-click reports
This section also covers personal monitoring, through direct assessment of the method. Assure360’s personal monitoring module can be harnessed to show how you assess every aspect of each project. Users can generate reports to show only the personals that exceeded what was expected, along with links to reveal what was done about it, the assessed root cause, and any supporting evidence.
The HSE is still testing its new licence regime, with current developments officially regarded as a pilot scheme. Doubtless the system will be revised and refined before going ‘final’, but for LARCs renewing their licence it already requires a new approach.
For companies struggling with old, paper-based systems, the licencing regime’s increased focus on excellent record keeping, analysis and management competence is a challenge. However, Assure360 customers not only have the best tool for managing all aspects of asbestos removal, but the best tool for documenting, analysing and demonstrating their competence at doing so.
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