Assure 360

Last month’s Faculty of Asbestos Assessment and Management (FAAM) conference already feels like ancient history – but at the time of writing it’s all of three weeks ago! Below is a brief look at some of the highlights for me. Broadly speaking, the conference’s focus on new research really summed up what FAAM should be about. As an organisation, we really can bring the structure, independence and academic rigour that can help bind our industry together.

In last month’s newsletter I wrote about an incredible piece of research that FAAM undertook to investigate the viability of a brand new removal method. At the conference, FAAM’s earlier research into the working relationship between analysts and supervisors provided a real highlight.

Cat Holmes, a colleague of mine on the FAAM committee and a consultant at ION in North Wales, gave a groundbreaking talk examining our unique attempt to bridge the gap between two sides of our industry: analysts, and licensed asbestos removal contractors (LARCs), during the period of highest stress and conflict – the clearance of enclosures.

Cat explained the lessons that were learned on the day – the fact that the supervisors can teach analysts a lesson or two in the first stage (completion of the job and condition of the enclosure). But also how the analysts showed their experience in the mocked up second stage (visual inspection), and in particular their ability to find the small things.

The biggest reveals though were the lack of formal training that any supervisor receives in this critical area, or the attention given to it by the Health and Safety Executive (HSE). To my knowledge, no LARC has ever been asked to prove a supervisor’s competence in visual inspections.

Cat outlined that the next step will be another round of workshops, this time focusing on how best to deliver that training. These may possibly lead to joint refresher courses for supervisors and analysts. Professional bodies such as BOHS, IATP, ACAD and ARCA have all expressed interest in sharing in that experience.

A sticky subject

The HSE’s Martin Saunders gave a fascinating talk on the regulator’s research into the effectiveness of control measures in asbestos removal. And there were some very useful takeaways. Despite the site teams knowing the HSE was observing them, time pressures tended to lead to poor practice. In one example methodical removal of asbestos insulation board ceiling tiles morphed into uncontrolled breakage (caught on recorded CCTV footage). 

Martin also discussed the use of PVA (the white glue we all remember from primary school) in improving asbestos control. It’s actually been used in asbestos removal for many years, as when diluted and sprayed it can act as a temporary binder or sealant for asbestos fibres. There have always been two uses – one bad and one good.

The first is spraying the enclosure liberally before an analyst starts their visual and air test in the four-stage clearance process. This has been quite rightly outlawed for a very long time, as it prevents the analyst from adequately testing the enclosure. The second is spraying the polythene enclosure walls after the third stage (air test). This is good practice but has largely fallen out of favour for some reason – possibly because it’s become wrongly linked to the former nefarious use.

The reason why it is good practice is that when you dismantle the enclosure after a successful clearance, there is a new exposure risk that can be minimised if an effective sealant is applied to the sheeting. As the polythene is disposed of as asbestos waste anyway, sealing any rogue fibres to it is a good thing.

And that brings me to another point raised regarding the reuse of sheeting. All polythene is considered contaminated waste, and therefore shouldn’t be re-used. This includes airlocks: while they are visually inspected by the analyst, they’re rarely if ever air tested, so they are considered waste even more so than the enclosure polythene.

Sam Lord, also of the HSE, gave a great overview of the ongoing HSE school investigation. I say ongoing, because the regulator is about to start on a new series of inspections. Sam’s talks are always worth catching, as she manages to summarise the key information in incredibly accessible language. Two slides encapsulate that perfectly – the first concerned things that are frequently done wrongly:

Asbestos Register

  • No confirmation that actions are completed
  • The location of asbestos-containing materials (ACMs) was not easily accessible or easy to understand by the users
  • No photos of the ACMs for location and easy condition monitoring

Management Plan

  • Specific roles and responsibilities often missing – as were deputies and contingencies in case of absence
  • No clear plan as to how information is made available to emergency services

Staff and Contractors

  • In-house staff not aware of the limitations of the surveys – e.g. which areas have NOT been inspected
  • No permit-to-work type system for controlling work on site
  • Training for staff with assigned responsibilities

The second summed up key messages to all schools:

  • Check your asbestos register for clarity – can you find ACMs using the information on the register?
  • Does the register reflect actions you have taken?
  • Can the register be updated to add new information on condition, risk or remediation work (e.g. a link to certificates of reoccupation following licensed removal)?
  • Has the plan been tested with simulations:
    • A realistic emergency scenario e.g. burst pipe damaging AIB ceiling
    • Something routine e.g. new fire alarm
  • Does everyone assigned responsibilities for asbestos management 
    • know who they are
    • know who the others are
    • have appropriate training
    • understand the asbestos management plan at the school
  • Check that everyone who could disturb asbestos at the school knows where it all is, and what to do if it is accidentally damaged.

And finally a teaser for the upcoming European Asbestos Foundation (EAF) conference. Dr Yvonne Waterman of the EAF gave an overview of the current global state of affairs – a sweeping look at the asbestos bans across the world, and legal cases where some are hopefully being brought to account for their, and their companies misdeeds.

Yvonne has also been able to reveal the incredible news that the Dutch government is co-hosting this year’s conference. This means that the World Health Organisation, along with a wide range of member states, will be sending delegates. The keynote speech is by Gordana Materljan LLM. (EU Commission DG EMPL), who was intimately involved in  the new Asbestos at Work Directive.

This critical piece of legislation will have impacts on not only the cleanliness of an asbestos enclosure before it is handed back, but also the nuts and bolts of protecting the worker tasked with cleaning it. Can the respirators available on the market today cope with the new limit and the existing methods of removal? Probably not. Do the methods need to change wholesale? Almost certainly. 

If the FAAM conference is the first must-attend conference of the year, the EAF is clearly the other. It’s a two-day event, with the main conference taking place in Brussels on Friday 1 December – I hope to see you all there. 

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