Late last year the Health and Safety Executive (HSE) revised its Plan of Work (PoW) guidance – its third attempt.
The first was pretty awful, littered with duplicated effort and illogical formatting. Unfortunately, a good slice of the industry dutifully tried to implement it.
The second, Asbestos Liaison Group (ALG) memo 04/12 (commonly referred to as the ‘aide memoire’), was a huge improvement. It concentrated the contract manager’s mind on the recognised primary focus: a PoW is a tool for the site team, to help them complete the project safely.
As the aide memoire was so effective, it was a slight surprise to me that with the backlog of other priorities, the HSE was taking another run at it. So what’s the current guidance? Here’s a link to Asbestos Regulation 7 plans of work – purpose and core principles, and here’s my attempt to summarise it, and interpret some of the more controversial elements.
The first thing to note is that the memo’s target audience is the HSE’s own inspectors, rather than licensed asbestos-removal contractors (LARCs) themselves. As an internal HSE guide, expect to read language like ‘have they considered’, rather than ‘have you considered’.
But clearly, as a document outlining the approach the HSE will take to assessing PoWs, the memo is also of huge importance to contractors. We’re also told that the guidance will appear in the the new HSG247 Licensed Contractors Guide when we get it – possibly in 2020 – so it’s doubly important.
Thankfully, item two in the introduction states that: ‘A PoW should be a practical and useful document describing a safe working method for staff to follow.’
We should keep this very much in mind, as clearly the PoW will be used by others, including managers, clients, auditors, regulators, and the analyst conducting the four-stage clearance (4SC). But if the document is produced just to please the client and the regulators, and not with your supervisor and operatives at the very forefront of your mind, then it will have failed its primary purpose.
Before we get into the specifics, it’s worth drawing attention to the HSE’s guidance on making PoW documents readable and readily understood. Sensibly, it encourages the use of diagrams, flow charts and photographs as ways to provide key information and break up pages of text.
The guidance recognises different styles of the Plan of Work, from the fully self-contained, to those that make extensive reference to standard procedures. However, it cautions against the inclusion of very standard procedures, such as the bagging of waste and enclosure materials. The HSE’s logic here is that, presented with lines and lines of text covering the mundane, the site team could miss the one line of crucial detail.
The advice here is sensible, but I’d stress that a balance needs to be struck that finds the right level of detail for the team in question. Skills and experience can vary tremendously, and some workers need more guidance on basic procedure than others. If a project will involve new starters, agency staff or short-term workers (STWs), they’re going to need fuller descriptions and more information.
The guidance is structured into appendices:
All seven contain a mix of text and simple bullet points detailing what should be considered where relevant. Remember that I’m pulling out some highlights for you to consider, rather than duplicating everything: you can find the full text here.
There is a full page of bullets in this appendix, which are mostly things that a LARC would expect as standard. There are a few however, that some might have missed in the past.
While most methods include an upper maximum, the guidance is actually calling for the number of staff that will work, both within the enclosure and in support or supervisory roles outside. This is clearly much harder to put a reliable number against, and may vary as a project proceeds.
While the guidance is still only new, I’ve already seen instances where this is being requested by the HSE inspectors. The reason is the impact on how you intend to remove the waste. Will a 1m baglock be large enough to double-bag? Are other solutions to be used – e.g. passed as part of the 4SC process?
I’m going to allow myself to go slightly off topic here because I don’t think some LARCs always understand the double-bagging process. The two bags have to add up to 1,000-gauge polythene, and the outside of the outer bag can’t have been inside the enclosure. It’s this last bit that seems to pass some by. A single wrap made from 1,000-gauge polythene fulfills the first element, but not the second – so it’s not sufficient.
This is a key point. Removal of an asbestos insulating board (AIB) is different when done from a scaffold tower than it is at floor level. The method must detail all of the elements that are different – including getting that waste to the floor.
Welfare is key, and the guidance calls for it to be detailed in the method. It doesn’t matter whether it’s a one-month or one-day job, you need to consider it, make provision and detail those arrangements. This could be temporary cabins that you or the principle contractor (PC) provide – but for very short jobs it could be the use of onsite or nearby facilities.
The biggest impact in this section is where the guidance states that a PoW should detail how long the 4SC is expected to take. If we look at the analysts’ guide (which is still in draft at the time of writing): where timings are mandated, the visual inspections alone are very lengthy. The visual for a single AIB panel is predicted to take up to an hour, and as the supervisor also needs to do this before the analyst can start – a small enclosure can easily take 3-4 hours to sign off. Boiler rooms could be days.
Contractors must essentially agree in advance with the analysts the details and duration of the personal monitoring. As readers will know this is not always easy. Often the analyst is working directly for the client and not the LARC. But it is crucial to know what you want, and to train the supervisor in what to ask for.
What will the HSE’s analyst report change? Read my analysis
Identical projects in a nursing home, an empty warehouse or a demolition site will all be very different. They’ll throw up different answers to questions such as how you segregate your works from moving traffic, or vulnerable adults and children, and whether there are special hazards such as gas vents or live plant which will need to be made safe by specialists.
You will doubtless have a standard approach, but as soon as there is a working-from-height confined-space element, the standard approach won’t fit anymore. There is rarely one answer that fits all situations, and you may have to get imaginative. Sometimes, something as simple as having harnesses on hand that you can use to assist an incapacitated worker may be enough. Remember, too, that the confined space rules changed in 2015 – you can read my analysis here.
The HSE reminds its inspectors of the minimum requirements for all drawings:
In short, this appendix is all about sequencing. It is the raw planning, unique to every site, that the HSE expects to see. It involves answering questions relating to the order in which the job will be tackled. For example, if there are multiple enclosures, are they to be run simultaneously or one after the other?
The timeline needs to include hold points – very important elements of a job such as an electrical isolation, without which work cannot start, or cannot progress to the next stage.
In the case of longer jobs, the guidance also calls for a sensible breakdown of what is expected each day. If management, or the regulator, attend site on day 10, for example, they should be able to tell if the work is on target. The HSE may compare actual site progress against the schedule to draw conclusions about the standard of planning, the efficiency of the site team, or even the quality of its work.
The Timeline should contain the method proper – i.e. “We’ll do this, then this, then this” – so the HSE acknowledges that a PoW might not need a separate control measures section. Control measures could be in the timeline, in standard procedures, or even in site drawings. However you cover control measures, the following are key elements to keep at the front of your mind.
In our industry it is very easy to be blinkered. We’re experts in asbestos, and most contract managers can draft an excellent method to deal with it. But what about other hazards? Sometimes asbestos is the least of our worries. The risk assessment should always be done first, and the control measures included in the PoW.
It’s worth stressing this because it’s simply so important. Say we are dismantling an asbestos cement roof below overhead power lines: it would be very easy to design the perfect asbestos job, which endangers the lives of everyone on site. And while that’s clearly an extreme example, we commonly do work at height, in confined spaces, or near unprotected drops and other hazards. The core thing to remember is to always keep the risk assessment in mind when designing the whole project.
Beyond this critical issue, the HSE focuses on specific areas including the following:
Most of the material in the final appendix is relatively standard: it’s common to most load lists and I won’t repeat it here. There is however one unusual nugget: just listing ‘stepladder’ or ‘tower scaffold’ is not clear enough. The plan writer should specify how many treads the ladder should have, or the size and width of tower scaffolds and their working platform height. The idea is so that the right equipment can be hired, or the site crew know to load enough components.
Overall, this is a very useful document that helps focus the Plan of Work author’s mind on what is important – putting together a comprehensive plan to ensure asbestos removal work is safe and effective.
Together with the analysts’ guide it should help bring best practice situations into the mainstream, raising the standard of the PoW, and with it the quality and safety standards we can achieve across our industry.
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