(Image courtesy of @IsteadAV / Twitter)
This year has felt rather full with conferences, which isn’t exactly surprising after the couple of years’ Covid-enforced hiatus that led up to it. To top it all off, my favourite two come almost back to back. I’ll circle back to EAF, which is on 11 November in Amsterdam, but first I wanted to give my customary write-up of the FAAM conference, which took place on 18-19 October.
Organised by the Faculty of Asbestos Analysis and Management (our home as asbestos professionals), FAAM was a thorough success. This year marked the first time it’s been launched by a policy maker: Stephen Timms MP, chair of the Work and Pensions Select Committee.
Mr Timms revealed some of the inner workings, thoughts and movements leading up to – and in the aftermath of – the committee’s crucial report on the Health And Safety Executive’s Approach To Asbestos Management. Of its 16 recommendations, 13 have been taken forward by the HSE, a remarkable success.
It’s a bit harder to pin down which three suggestions didn’t make the cut. One is the deadline for removing asbestos, and another is the centralised national register. I believe the last is including more work history information on death certificates, which is outside the purview of the HSE anyway.
It’s a shame: all of these would have enormous value. The 40-year deadline on removing asbestos from non-domestic buildings is simply crucial: if there’s no plan, the retrofitting and refurbishment required to reach Net Zero could bring about a catastrophe of disturbed materials.
And, as Mr Timms explained, just having to submit your asbestos survey to a central register would encourage better behaviour and be a sampling point for enforcement: when building X doesn’t have a register on the system, it’s a good idea to pay it a visit. However, as the Government Digital Service would have to lead on this, it seems there’s been a government decision not to provide funds.
My reading of the report’s reception is that the HSE has taken forward everything it can, and that the government has blocked – or at least shown no interest in actioning – the remainder. I’ve written before about the significance of the funding crisis facing the HSE, and Mr Timms finished his talk with a welcome call to arms – write to your MPs and demand more funding for the HSE so it can do its job properly.
Occupational exposure – a fascinating challenge
The rest of the first morning was taken up by a series of discussions centering on the European Union goal to reduce the Occupational Exposure Limit (OEL) for asbestos, and the challenges it might create – in the UK we have a control limit instead. Dr Yvonne Waterman spoke about the very strong political movement to reduce the European OEL to 0.001 fibres per millilitre of air (f/ml), but in the end the figure that’s been settled upon is a less stringent 0.01f/ml. This compromise level is seen as more practical, in that it wouldn’t need much in the way of prolonged technical adaptation.
Morally it is not possible to argue against this, as less exposure can only ever be a good thing. However, Gary Burdett was there to articulate the challenges of achieving this target – and in particular a fundamental flaw with the proposal.
Principally, the issue is that to test to a given level, the EN standard (EN482) demands that we are able to measure an order of magnitude lower: to reach the current OEL of 0.1f/ml, for example, we must be able to measure down to 0.01f/ml. That’s possible with the existing optical microscopy methods, but if the OEL is 0.01f/ml, we need to get down to 0.001f/ml. If it were 0.001f/ml, then the method needs to achieve 0.0001f/ml!
Gary was doubtful that the current WHO method could achieve these lower levels, so we need to agree on something new. As Gary explained, that means new technology, new competencies, and having the time to implement both. To be clear, he’s not arguing against the new limits, more that we need to agree on a method and work together on implementing it. He did go further, suggesting that research into reducing dust emissions would potentially reduce the risk more effectively.
The move to new methods throws up other challenges, such as how you find conversion factors to link new and old fibre-counting methods. In his talk, Remy Franken reported on an attempt to do just that. There was also a perceptive question from Andrey Korchevskiy on whether there should be different OELs for different fibre types – I’ll return to that in a moment.
Next up was a short presentation by Philip Hibbs of FAMANZ, about the burgeoning new Faculty of Asbestos Management of Australia and New Zealand. The key moment for me was when Philip mentioned that 3.8% of their membership are asbestos removal professionals – or as they put it splendidly, removalists.
Gary Burdett said later that was a lightbulb moment, and I couldn’t agree more. In the UK our industry has always been very much them and us, with a schism between the removers and analysts that only seems to get worse. Would this be the answer here – welcoming in asbestos professionals from all elements of the sector?
Into the afternoon
In the afternoon, Andrey Korchevskiy took us deep into the weeds of lifetime risk assessments. To illustrate his points, he presented two imaginary case studies – Mr and Mrs Smith.
Mr Smith was exposed to 0.1f/ml of asbestos over 20 years whilst working in the construction industry. This was predominately (95%) chrysotile, but 5% of his exposure was to amosite. For Mr Smith, the lifetime risk analysis identifies an increased risk of cancer of 391 cases in 1,000,000. Interestingly 64% of this risk arises from his comparatively tiny exposure to amosite, and this explains Andrey’s earlier question concerning different OELs for different fibres. Tightening the amphibole OEL makes a lot more sense to him, as it is responsible for so much more of the risk.
Mrs Smith’s exposure was through talc contaminated with asbestos – 0.07% tremolite, 50% of which was not asbestiform (essentially chunky fragments that don’t have the morphology that indicates a high risk). Her risk calculation indicated 0.24 cases of cancer in 1,000,000. This seems absolutely tiny – and if correct it would be a huge comfort to anyone that is concerned about similar exposure. That said, it doesn’t line up with the increasing case law emerging from the states, or the decision of Johnson & Johnson to stop selling talc.
Day two
To kick off day two, the HSE’s Sam Lord gave us an overview of the executive’s plans to implement one of the DWP report recommendations: a focus on improved monitoring in schools. Four hundred primary and secondary schools will be selected for visits – in fact, these have already started, and are expected to be completed by March 2023. The idea is for this to be a collegiate supporting visit, with more of a focus on why and how schools actually manage asbestos. In short, how they go beyond just “the survey report is available”.
A year earlier, Colette Willoughby had shocked FAAM 2021 with her testimony about the personal safety of female analysts. She was here again to update us on the Female Analyst Working Group – one of the many positive outcomes from her courage in speaking out. Real measurable progress has been made, although she would say there is still a mountain to climb.
The group recognises that analysts (no matter their gender) are often put into a difficult position, with huge responsibilities that result all too often in abuse. But its findings show that for female analysts it’s even worse – and sadly not in the least consigned to history. Their mission is to start with the female experience and focus on that. This should improve matters for everyone, before they widen the remit.
The group’s first meeting set several key areas and goals:
Its main progress to date is in the area of decontamination, with recognition by the HSE that currently available Decontamination Units don’t comply with the Construction (Design and Management) regulations on welfare. This can be fixed – Colette name-checked Beacon International’s simple but revolutionary magnetic lock, which allows the user to secure all doors from the inside. The wider focus is on education for LARCs. Specifically, the need to help supervisors better understand the role of analysts, what all the stages of the four-stage clearance are, and what exactly they’re signing with the handover form.
There’s a continuing need to hear from analysts and others in the industry who have suffered or witnessed abuse, intimidation or other unacceptable behaviours. If you need to share an experience, you can contact the group through two confidential email addresses: concerns@norac.org.uk and concerns@itsnotacceptable.co.uk.
Colette will also be attending the ACAD regionals in the coming weeks to brief LARCs directly, and staying for questions afterwards. Hopefully ARCA will be able to extend a similar invitation to her – we all need to be better.
Wrapping up
The toughest slot of the conference – the final 30 minutes of a two-day event – was filled with some finesse by ACAD’s Graham Warren. He closed the circle by providing the LARC’s view of the four-stage clearance process. Graham covered recognition by the trade organisation, the importance of the supervisor visuals, and how ACAD is using its audit scheme to explore compliance. “Developing, getting there – but some way to go” was the message.
ACAD had also completed some research on its members. Ninety one percent either introduced the clearance handover form in 2018, or already had an equivalent system. The final 9% only introduced the form with the recent publishing of HSG248 – the HSE’s Analysts’ Guide.
When asked, “Are analysts demanding the form?”, the news was less encouraging.
While just 9% said analysts rarely asked for the form, only two thirds (65%) of analysts were always or nearly always demanding it – that’s surprisingly low compliance overall.
When asked how the process could be improved, members cited improved planning, communication, and better analyst understanding of the removal process. Graham recognised the fact that this was echoing the goals of a workshop proposal that had come up earlier in the day.
Helping FAAM’s membership beyond the conference
Gary Burdett and I spoke just before lunch on joint research ideas for improving the value of FAAM’s membership. FAAM wants to help its members be more directly involved with – and benefit from – faculty membership beyond the conference. As FAAM Committee members, it’s a subject close to our hearts.
The first suggestion we came up with was to explore the dearth of advice for the general public when they are presented with small and large-scale asbestos issues at home. Often the advice from local authorities is to contact the HSE or ARCA, with not much else on top. The initial step in improving this would be for interested members to help with contacting local authorities to explore the advice available. We’d then work together with the goal of designing competent advice. Participants in the research would be able to use this for CPD.
The second suggestion is something quite close to my heart, echoing what FAMANZ’s Philip Hibbs said, and feeding directly into the behaviour issues that Colette talked about. The premise is that our supervisors and operatives don’t understand what analysts do or need, and vice versa.
Our proposed solution is that FAAM organises workshops where the two sides of the industry can get together and learn from each other. The hope here is that closer ties will produce better understanding and cooperation. Ultimately, we all might just get better at our jobs. We’re still at early stages, but initial conversations with the Independent Asbestos Training Providers (IATP) have been very positive, and I am hopeful that both ACAD and ARCA will be enthusiastic supporters.
If you are interested in getting more information, helping develop, or participating in either of these ideas, FAAM will be reaching out with ways you can do that. The same goes if you’d like to share and have support with any other bright ideas that will help the industry. If you’re not a FAAM member, you’re always welcome to contact me directly (see below).
Returning briefly to the conference, it was again a thoroughly interesting and engaging event. More than that, I found it a very welcome return to the face to face experience. As I said at the top, my favourite two conferences are back-to-back, and the brilliant EAF is on Friday 11th of November. Depending on when you read this, I hope to see you there, or at one of next year’s events.
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