Written by Nick Garland on Thursday March 10th 2022
Earlier this year the British Occupational Hygiene Society (BOHS) announced multiple vacancies on its board, along with its two faculty committees. Of these important bodies, regular readers will know well the Faculty of Asbestos Assessment and Management (FAAM) Committee, which is expanding with the addition of five new members.
I’m excited to have been invited to run for election to one of these new positions on the FAAM Committee. I’m especially honoured given the calibre of the others in the list of nominees – I’m standing alongside many highly respected names, and very grateful to Sam Collins and Yvonne Waterman for putting me forward.
I wanted to serve up a brief reminder of the role of FAAM, and how the Committee and its members shape its direction and decision making. The faculty exists as the professional home for all of us who deal with asbestos as part of their work in the UK. Its key focus is on supporting and ensuring the competency and expertise of its members, with the goal of reducing the ongoing issues – such as mesothelioma and other cancers – that relate to historic asbestos use in the UK.
The FAAM Committee exists to steer this work. In FAAM’s own words, it’s there to “act as the guardian of professional standards and ethics in the profession of asbestos assessment and management.”
In practice, this means regular meetings at which the FAAM Committee works towards developing and maintaining standards for the profession. Committee members take part in discussions around qualifications and faculty membership, participating in disciplinary matters, and generally helping to ensure that the Committee continues to deliver against its objectives and satisfy its overall purpose.
It’s an exciting and important role, for a vitally important faculty, focusing on one of the biggest ongoing health and infrastructure challenges faced by this country. As I say, I’m honoured to even be in the running, and I wish all the nominees the very best of luck in the forthcoming election.
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If you’re a FAAM member, you should already have received an email inviting you to vote, sent on behalf of Alex Wilson, BOHS Honorary Secretary. If you haven’t seen it, please do check your junk mail folder, as my own invitation landed there.
Written by Nick Garland on Thursday March 10th 2022
While the pandemic has presented us all with very real challenges, it has also meant many missed opportunities. In a specialist industry like ours – where face-to-face knowledge sharing and training are crucial – it’s been hard to maintain momentum and drive things forward. That’s why I’m more than delighted to share the news that the European Asbestos Forum (EAF) conference is returning this year, with a two-day event in Amsterdam.
It’s great to see the conference return after its Covid-enforced hiatus – it was last held in 2019. EAF traditionally brings together many of the world’s preeminent experts on asbestos, its health risks, and its removal and disposal. It’s a place where professionals and asbestos victims alike can go to share their experiences, enjoying networking and social events to help build a close asbestos ‘family’. Together, the goal is that we’ll help develop the new approaches that will ultimately reduce harm for everyone.
Not the least of the experts attending the event will be EAF founder and president Dr Yvonne Waterman MFAAM herself. This year Yvonne is putting together a conference programme on the theme of ‘Asbestos and the State of the Art’. Expect a first day comprising workshops, and an exclusive excursion to visit a metal foundry that denatures and recycles asbestos-contaminated steel.
The second day of the conference will feature a variety of top speakers from across the globe, profiling new science, developments, innovations and insights. I’m also delighted to be chairing one of the two afternoon breakout sessions. It’s a real pleasure to be involved in such a highly regarded – not to mention enjoyable event!
I look forward to sharing more details in the future, but for now you can find more information on the European Asbestos Forum website. Please be sure to save the date:
10-11 November 2022
Van der Valk Hotel Oostzaan (Amsterdam)
I very much look forward to seeing you there.
Written by Nick Garland on Thursday February 10th 2022
One of the main objectives of the new analysts’ guide is to reduce analyst exposure, by clarifying what is licensed work, and what falls under the analyst’s remit. But the HSG 248 document is now massive, running to 238 pages. In cases where it hasn’t been fully read and understood there’s the potential for misunderstanding.
I’ve been thinking about this after a recent project, in which a difference in understanding created the risk of costs spiralling out of control. The project in question related to a wall that had sporadic asbestos insulation spatters underneath an imperfect layer of paint. The job was to scrape the wall back and then encapsulate the residues – so far so normal.
However, in this case the analyst was unwilling to enter the enclosure prior to encapsulation. This created the potential situation that, if the analyst wasn’t happy with their visual after encapsulation, the licensed asbestos removal contractor (LARC) would have to strip all the paint off and start again. The analyst’s view was that the project was not yet finished, the enclosure was therefore live, and that in line with HSG 248, ‘they do not do live enclosure entry’. For the LARC it represented a very expensive project risk.
So what does the guidance suggest? On the surface of it, HSG 248 is fairly ‘clear’:
The nature and extent of exposure will depend on several factors including the activity, the type and condition of the ACM and the effectiveness of any controls. For example, all entry into asbestos enclosures carries a risk of exposure to airborne fibres. Analysts should avoid as far as possible entering ‘live’ enclosures while removal or remediation work is still being carried out. If entry into a ‘live’ enclosure does occur there will be potential exposure to asbestos fibre concentrations above the control limit or short-term exposure limit.
Para 1.6, Pg 11 HSG248
However, if we look deeper (and when I say deeper, I mean we have to read to page 193) there’s more guidance under the section “Clearance for specific situations” – the bold is mine, for emphasis:
Inaccessible or impossible to remove asbestos
Spray-applied asbestos is often found in crevices or holes through walls where pipe work or girders run. These may leave asbestos residues that are impossible to remove. In these cases, the analyst may permit the use of non-flammable sealant such as foams or plaster to fill the hole and seal the asbestos within it. Before the sealant is applied the analyst must be satisfied that as far as reasonably practicable the asbestos has been removed.
Para A5.78, Pg 193 HSG248
Use of encapsulant or sealant
Where asbestos has been sprayed on to porous surfaces (e.g. breeze blocks, bricks, plaster and concrete), it is almost impossible to obtain an asbestos-free surface. The analyst should satisfy themselves that further removal is not reasonably practicable, and should advise the contractor and/or building client to seal the residual asbestos with a permanent proprietary sealant. The visual inspection can restart once the sealant has been applied and dried. In these circumstances encapsulation of asbestos should not take place before the analyst has seen the residual asbestos. A note should be made on the CfR and recorded in the asbestos register and management plan for the premises.
Para A5.80 Pg 194 HSG248
This second paragraph matches my example situation perfectly, but in fact both paragraphs make clear that the analysts must complete a visual before the LARC encapsulates any remaining asbestos to make sure (essentially) they are not hiding anything. While the general guidance in paragraph 1.6 says that analysts should avoid live enclosures ‘as far as possible’, this subsequent guidance takes us to the heart of the issue – a live enclosure is one where removal work is ongoing. In these situations, the enclosures are not ‘live’ as all possible removal has been finished.
Going further
In fact, my personal preference is to go a step further. I believe all such projects should be broken down like this:
With either option after the stage three air test, the client gets valuable extra information that they wouldn’t get with the traditional approach. Based on what happens, they know to what degree they need to be cautious about the wall.
This is my personal preference, and I’d be interested to hear opposing views on it, so let me explain my reasoning. First, read this rather long paragraph from the Analysts’ Guide:
There may be occasions when some asbestos is to remain in situ in the enclosure. It may be that only damaged asbestos lagging is being removed from pipe work, and that undamaged material is to remain; or it could be that only a proportion of asbestos ceiling tiles is being removed. The analyst should have been made aware of this in the discussion on the scope of work as part of stage 1. The contractor should have checked the condition of the remaining ACMs as materials in poor condition could lead to a failure in the four-stage clearance when the analyst checks. If the analyst does find asbestos materials in poor condition these will need to be dealt with (eg repaired, encapsulated or removed, all of which actions are likely to need agreement of the building client and the involvement of a licensed contractor. The four-stage clearance should stop at this point and the contractor/building client should be informed. The four-stage clearance should not restart until the matters have been rectified. Any remaining ACMs in good condition should be recorded in the CfR so that the building client can update the asbestos register and management plan accordingly.
Para A5.76 Pg 192 HSG248
My logic is that if we are working on a wall that only ever had occasional splashes of debris – the risk starts at low. If:
The selection of the scrape and vac technique is therefore intentionally leaving some asbestos in by design, and paragraph A5.76 is the reference that we should be looking to. This allows the analyst to make a judgement that all loose paint has been removed, and the asbestos left in by design would be noted on the four-stage clearance (4SC) certificate.
While we haven’t 100% removed the asbestos-containing material (some is being left in by design), stage two has passed, and there is no absolute need for encapsulation. But if the air test subsequently identifies a problem then we must encapsulate. On the other hand, if the whole 4SC passes, and we still want to encapsulate, well, that’s an ultra risk-averse decision that can be completed as a non-licensed activity.
I appreciate this is possibly a left field opinion, but I believe it addresses what we are trying to do which is understand and mitigate risk, rather than blindly follow what we’ve done before.
Written by Nick Garland on Wednesday January 19th 2022
We’re already a fortnight into 2022, the schools are back, and our focus is well and truly on the year ahead. It’s a sad reality that we’re all still living with the risk and disruption of Covid-19, but it does seem likely that this will be the year we move towards living with the virus. And as the policy shifts away from trying to contain it, it’s likely that in some ways this will be a more normal year than 2020 or 2021.
So what can we expect in the construction and asbestos industries? First and foremost, it seems that we’ll see a return of more in-person events. As it stands, most major industry events in 2022 seem likely to go ahead in person, which should bring more opportunities to network and catch up with colleagues we may not have seen for some time.
At Assure360, we’re seizing the opportunity, and kicking the year off with the return of our popular breakfast meetings. If you’re not familiar, these serve as a warm up to selected ACAD regional meetings, and provide an opportunity for existing customers to discuss the future direction and evolution of the Assure360 system. It’s our community’s biggest opportunity to help shape the next stage of Assure360 development.
The meetings aren’t just for existing customers, though. Me and my brother, Rick Garland, will be happy to provide all comers with an overview of the system. We’ll be able to answer any questions and give demonstrations, all while you enjoy a light breakfast. So please do come along to one of the following:
Please RSVP via our LinkedIn events pages or by email to enquiries@assure360.co.uk so we can confirm numbers for catering.
Other events
It’s hard to predict exactly how the rest of the year will pan out, but among the big events likely to go ahead, the Hazardous Materials Expo is set for 14-15 September at the NEC. Assuming the situation allows for it, expect a return to a much bigger event than has been possible for the last two years.
We also hope that the improving situation lets the 10th international symposium on modern principles of air monitoring and biomonitoring (Airmon 10) go ahead. Originally scheduled for last September, it’s now planned for 7-10 November. As always, we’ll be trying to keep our regular events listing updated as more events are announced or confirmed.
Finally, a reminder that the Work and Pensions Committee is continuing its examination of how the Health and Safety Executive manages the continued presence of asbestos in buildings. After a call for evidence and the first oral evidence sessions last year, the committee will continue its work of examining the risks, how the HSE manages them, and how UK practice compares to the rest of the world.
As we said, it’s hard to predict exactly how the year will pan out, but we can hope that things return more closely to normal as vaccination and other measures help bring Covid under control. However things develop, we wish you all the best throughout 2022 and beyond.
Written by Nick Garland on Wednesday January 19th 2022
I originally wrote this review of the Asbestos Network technical committee’s upcoming guidance on DCU safety two years ago, and in some ways not a great deal has changed since. The guidance is still in draft, still imminent, and still missing some of the more practical direction on safety that I identified.
Part of the issue is that the scope of the guidance is limited to gas and electrical installations, but in reality the DCU represents a wider range of risks. In particular, I feel it’s now important to revisit the draft guidance in the light of Colette Willoughby’s raw and emotional testimony at FAAM last year. With the benefit of Colette’s experiences and insight, it’s clear that we must also consider analysts’ personal safety.
We all know that the job of asbestos removal is dangerous – that’s why it’s so tightly regulated. But while the most serious risks are often found inside the enclosure, they don’t stop there. The decontamination unit (DCU) presents its own hazards, including:
So what guidance is available, and how can it help keep analysts and operatives safe?
For the last two years the Asbestos Network technical committee has made time in several meetings to discuss DCU safety. Unfortunately they’ve made slow progress in producing guidance, and the final version hasn’t been issued.
I wanted to revisit what there is so far. For the most part it’s good stuff, but the way I perceive our workplace changed at the 2021 FAAM conference. Colette opened my eyes to additional risks faced by female analysts, which can and must be addressed. In this light, DCU guidelines that focus only on electrical and gas safety are missing a major opportunity to protect our colleagues.
Colette’s FAAM talk has shone a light on what should have been blindingly obvious for decades – decontaminating in the DCU represents a very vulnerable moment for a female analyst.
The Construction (Design and Management) regulations state: “Separate washing facilities must be provided for men and women, except where they are provided in a room the door of which is capable of being secured from the inside, and the facilities in each room are intended to be used by only one person at a time.”
As we know, DCUs are shared, yet their access is controlled by an external lock. Obviously this isn’t compliant. What has also become obvious, given the experiences detailed by Colette and the other female analysts she has spoken to, is that it’s simply not appropriate protection for our colleagues at a vulnerable time.
I am sure that the makers of DCUs can and should implement better solutions that give the occupant of the DCU control over entry and exit. But in the meantime, adding a simple bathroom-style bolt to all of the doors would seem like a very easy and quick solution. Clearly, there would also need to be a revised DCU procedure, as the unit would not be accessible from the time the analyst leaves it secured, until the point they leave the enclosure and fully decontaminate. During this time it would effectively become a one-person unit, but this is not that different to current, Covid-era practice, where operatives’ exit from the enclosure is staggered so as to be one at a time.
Another significant issue raised by Colette is that disposable underwear is simply not available for women. Laundering services for contaminated clothing don’t seem to be commercially available, either. Employers need to find an acceptable interim solution – such as using standard underwear or swimsuits and disposing of them after a single use.
The following is predominately unchanged from my review a year ago and concentrates on the physical issues covered (or not covered) by the guidance.
The gas safety guidance starts predictably enough, instructing that gas boilers should meet the required BS EN standards, that they should be installed by an accredited gas fitter, and that each appliance should be fitted with an isolating valve and flame failure device. However, it then goes on to say that all boilers situated in the clean end – rather than a sealed cupboard – should be of the balanced flue type.
For those of us who aren’t gas engineers, in a balanced flue (also known as room-sealed) boiler, the entire combustion circuit is sealed off from the room that the boiler’s in. The fresh air supply, combustion chamber, heat exchanger and exhaust gases are open to the atmosphere only, meaning that if something goes wrong, any toxic or flammable gases should be vented out of the DCU.
Insisting on this type is wise, as they’re much safer than open flue boilers which draw their combustion air from the room they’re in, but following the guidelines might mean an expensive upgrade for any older DCUs.
There are some other issues to pick up on. If the boiler is mounted in a separate sealed cupboard it is best practice for that boiler to be room-sealed anyway, but regardless the cupboard door must be closed and sealed at all times. Many times I’ve seen cupboard doors left open, sometimes for convenience, but sometimes because there is otherwise insufficient ventilation in the cupboard for the boiler to work. If the boiler only works when you leave the cupboard door open, then it’s effectively in the clean end, and must be room-sealed.
It’s important to understand that a room-sealed boiler doesn’t guarantee that combustion products like carbon monoxide (CO) can’t leak into the room. Seals can fail, so there should always be a CO alarm fitted in the clean end, adjacent to the vent to the shower compartment. Correct positioning is important – I’ve seen random locations, not all of which will be effective according to the guidance.
The guidance here pretty much summarises existing standard guidance. In brief, the gas bottle(s) should be:
Note, too, that there should be a maximum of two 16kg bottles, and that nothing spark-generating should be stored with them.
So far, so standard, but then we get to areas where I’m not sure we have much compliance. Gas bottles should be:
There’s some welcome clarity here: DCUs require mandatory 12-monthly gas-safety certificates. Some HSE inspectors are still referring to a very old note that mandated six-monthly inspections for open-flued units. This detailed guidance supersedes and clarifies this.
In day-to-day use, the gas pipework needs to be checked daily and at the end of the project – not a job that I’ve seen on many supervisor checklists. There should also be emergency procedures to follow if gas is smelled. The advice states that gas should be isolated at the end of the shift, but it then goes on to contradict itself, suggesting that if there’s no oil-filled radiator the pilot light should be left running in cold weather. Presumably, this will be cleared up in the final pre-publication checks.
All vents, clearly, need to be kept clear. If you have an open-flue boiler in a sealed cupboard, that cupboard needs to be kept closed and the seals must be in good condition. In all cases the CO alarm must be checked at least weekly.
This is usually the area that gets the most attention when a job is audited, but the justification for this seems patchy at best. To my knowledge there has never been a DCU electrocution, so the previous guidance has clearly been serving us well.
This guidance states that all DCUs must regularly be electrically inspected and tested – we rarely see units that haven’t been. In fact, the biggest risk is likely to come from using the client’s mains supply if it turns out to be faulty. The moment of greatest risk is brief – when an individual is standing on the floor, but touching the metal frame of the DCU.
The guidance offers some pointers on how to eliminate electrocution risks:
However the guidance really calls for better design of DCUs to ensure better electrical separation, along the lines of a bathroom. Generally there should be layers of insulation between electricity and people, and the power for recharging masks should come from two-pin, low-voltage sockets. Where there are concerns about the quality of the source electrical supply, it’s perhaps wisest to use a single-phase generator rated below 10kVA, which doesn’t need earthing at all.
As I laid out last year, another pressing DCU safety issue relates to the risks when positioning them. DCUs are heavy beasts. Moving them using a vehicle presents multiple hazards, and manoeuvring them by hand typically takes more than one person. Both approaches require coordination and well-designed procedures to prevent workers from being trapped or injured, yet these are all too often overlooked.
I personally know of one serious injury that has occurred due to lack of concentration when manoeuvring a DCU. The following is the safe working procedure that was created after the event:
When positioning, re-positioning or removing a DCU from site it is critical that it is done so safely. DCUs are heavy pieces of plant. They can cause injury by trapping operatives against fixed structures and can become unstable if moved over rough ground.
Where necessary – a traffic marshal will use a barrier to stop traffic when the DCU is to be moved into the road to be hitched onto the waiting van.
It’s important to reiterate that the scope of the DCU guidance was limited to gas and electricity issues. As such, I know I’m being slightly unfair in expanding my analysis out to other issues such as personal safety and manual handling. However, both are important issues, and as we’re not likely to get more guidance on DCUs for the foreseeable future, this seems an ideal time to provide something comprehensive whilst the bonnet is up.
Written by Nick Garland on Thursday December 9th 2021
I normally do a roundup of the FAAM asbestos conference, letting those that didn’t get to attend know some of the more important areas that were discussed by the leading thinkers in our industry. I will be doing that, but this piece is in many ways much more important.
** Warning, the content includes an upsetting personal revelation, and some readers may be affected by the issues raised.**
Colette Willoughby’s talk on the second day, Female Analysts and Four-Stage Clearance Testing, was the most raw and personal talk I have ever heard at a conference. The talk was split into two parts – the first a short history lesson on how things have changed during Colette’s distinguished career.
Having started out in 1982, Colette really was at the birth of the new world of asbestos analysis. She entered an industry where – astonishingly – a clearance just meant the contractor dropping a pump off at a lab. She witnessed it change to one where analysts started actually doing tests and – most revolutionarily of all – a visual, where the analyst actually checked the contractor had done what they said they would. My career started shortly after this, where people still talked about what it used to be like. Now this seems more like myth and legend.
The main part of the talk, though, related to Colette’s own experiences, and those of four other women she had interviewed. The interviewees were Jean Prentice, Joanna Parker, Sam Collins and an anonymous analyst still actively doing four-stage clearances (4SCs). The five women between them represent a huge amount of experience, gained from the mid-1960s to the present day.
Colette’s talk frankly and openly discussed the widest range of experiences, from the broadly positive (Sam and Jean), to the worst you can imagine. Colette, despite being one of the warmest and most professional people you could ever want to meet, has experienced some of the most unwelcome experiences possible. From initially not being allowed on site at all, to – after years of campaigning – being told: “OK, but we don’t think you’ll cope”.
What followed was a litany of sexist ‘banter’ from contractors, with comments such as: “You’re a woman, you’re just picky” and “You’re more used to cleaning: no wonder you can do it better.” Yet at the back of Colette’s mind, a traitorous voice insisted that now she’d convinced her bosses she could do the job, this was something she just had to put up with.
The ‘banter’ was shameful enough, but examples of criminal abuse followed. On numerous occasions, naked operatives have intentionally followed her into the decontamination unit (DCU) – the most recent occurrence being only four years ago.
Then came a horrific experience where she was raped on site by the supervisor. As Colette explains: “I was sexually abused and was raped on numerous occasions, but did not have the ability to go back and say anything because I was quite consistently told by him ‘Nobody’s going to believe you. You’re 23/24 years old, I’m a middle-aged man. I’m well respected, you were just asking for it. You’ve come into our environment [and] you’ve got to put up with it’.”
How Colette kept it together after that I will never know.
While spared the full horrors of Colette’s experience, Joanna and the anonymous, still-serving analyst both had multiple examples of threats of, or actual sexual abuse. And they both shared the belief that reporting it would be futile.
The hostile environment
Asbestos is of course part of the construction industry. To put some numbers to the hostile environment that women in our industry endure, Colette turned to a 2017 report, which found that four in 10 women had been on the receiving end of unwanted sexual behaviour, and that one in nine mothers had been dismissed, compulsorily made redundant, or treated so poorly that they left the post. The pay gap was 17.3%, to add insult to injury.
Colette is the chair of NORAC, Principle Examiner for asbestos at BOHS, and Director and Technical Expert at ACL. She is, quite frankly, one of the most impressive consultants in the industry, but the abuse and discrimination that she and other female analysts have experienced left me and the rest of her audience stunned. Speaking personally, I am ashamed of the ignorance that I had been labouring under.
How do we change?
Colette then moved on to what needs to change, and how. The distance we need to travel is vast – but at some levels utterly basic. For example, PPE must by law be fit for purpose and fit for use. But disposable overalls and underwear are all made for the male body shape and don’t fit women. Here, companies are effectively in breach for failing to provide the correct protective equipment.
The DCU poses a particular problem. Construction (Design and Management) regulations state: “Separate washing facilities must be provided for men and women, except where they are provided in a room the door of which is capable of being secured from the inside, and the facilities in each room are intended to be used by only one person at a time.”
DCUs are shared, yet their access is controlled by either a key or a combination lock, both of which are external. Again, this means they’re not compliant. I can only think that DCU manufacturers must be ignorant of the issue, or they would have changed this already.
Finally, Colette stressed two more areas where we need to do so much more. The first is the glaring need for simple respect. It should go without saying, but is clearly, sadly, very very lacking. Male colleagues must do all they can to help here – calling out even the borderline ‘banter’ – never mind the sexist abuse above.
Employers need to acknowledge the differences, and provide training so that female analysts are better prepared for the pressures. Crucially, they also need to offer support, so that analysts are comfortable and secure enough to report and get help when they need it.
As I said, it was a raw and eye-opening talk, and one which I profoundly hope will bring about change. Hearing the testimony were HSE officers, asbestos removal trade organisations, and consultancy business owners among others. It’s an oft repeated phrase that asbestos is the most regulated industry after nuclear – surely there were enough of the ‘right’ people in the room to make a change.
If you’ve been affected by this subject and wish to respond or raise similar concerns, email concerns@norac.org.uk. This is a totally confidential inbox that is monitored by Colette, Jean Prentice and Sara Mason, who are all on the working group set up in the wake of FAAM to address the issue.
Written by Nick Garland on Thursday December 9th 2021
FAAM 2021 was held virtually on the 17th and 18th of November, and was broadly a very interesting and engaging conference again. I say ‘broadly’ in no way intending to underplay it, as all of the talks were fascinating. However, Colette Willoughby’s day-two presentation on female analysts and what they have to endure was so raw and personal that it quite unavoidably dominated the whole event.
I have written about Colette’s talk separately, as it deserves to be considered separately and seriously by us all. However there were many other thought-provoking and informative talks throughout the programme: here are some of the highlights.
The conference started with a fascinating, deep look into the marriage of cutting edge new technologies to tried and tested Phase Contrast Microscopy (PCM) techniques. Frontier, Ethos and xRapid all had slightly different takes on enhancing PCM with artificial intelligence and robotics, to improve consistency, accuracy and speed.
That today’s PCM process is quite straightforward probably shouldn’t be surprising, given that it’s a technology that predates WW2. For asbestos, the analyst looks down the microscope and carefully looks for any fibres that follow the accepted rules as to what qualifies as asbestos. They count the number that fall within a defined area in the middle of their view (or field), then move this view randomly and make another count, adding to the total. This is repeated a given number of times to give a total number of asbestos fibres in a given number of fields.
The weakest link
That’s the process, but it’s important to look at the problems humans bring to it. I can testify to the first flaw, which is that the mark I eyeball is of varying quality – and my eyes are not what they were. So our ability to see the very fine fibres will vary. The rules as to what ‘counts’ as a fibre are straight forward, but we have to apply them correctly every time.
In addition, humans get tired, and tend to be less competent later in the day. We’re also flawed in that we have desires, and that we can be influenced by persuasion or threats that may consciously or otherwise affect which fields get counted. Add in the time pressures we all need to work under, and you will understand that the accuracy of on-site analysis is different to the work done in a lab with a nice cuppa to hand.
The application of AI and robotics has the potential to eliminate nearly all of these issues. Random is random, the rules are the rules, a calibrated eyeball mark II is accurate to a known degree – and it doesn’t get tired.
Automated analysis is also a lot quicker, at less than five minutes per sample. All of this really does promise a fascinating and exciting change for our analysts. Supported by AI, they will be able to concentrate on the really crucial visual inspection. And when that passes, the computer says no (or yes).
Ethos, based in Scotland, has taken the technology a step further with a kit that can take the sample as well. Currently the size of a pedal bin, the technology incorporates a very powerful pump, cartridges of filters, slides and a robotic microscope. Essentially you position it in the enclosure, press go and it takes the sample, mounts the slide and starts reading it. You can then move it to a new location whilst the analysis is ongoing and repeat.
Ethos says the turnaround for the first sample is only 20 minutes, but the current model is an advanced prototype and has limitations. Not least the fact that it looks heavy – making it a potential challenge for some analysts to heft around.
Rolling moss uncovers the stone?
The next really fascinating talk was a case study of a project being led by Colette. The site is a vast military storage facility, with 60 acres of asbestos cement roofing! All of it is past its anticipated life expectancy, but still, asbestos cement: what’s the problem?
In fact, one of the main issues is moss. As it turns out cement is not some inert binder – but an ideal source of nutrients. Here you can see how enthusiastically the site has been colonised.
There is some greenery, but there is also a lot of dead moss that eventually drops off. And with the dead moss comes pure asbestos fibre.
This material has contaminated walkways, roads and the nation’s fighting vehicles, and potentially exposed serving personnel. It’s an ideal nesting material for birds, who may have carried it away to contaminate nearby houses. Over the past two and a half years the project has evolved from assessment, to imaginative decontamination techniques.
The ECHA chamber
The afternoon of the first day was devoted to the European Chemical Agency (ECHA) subcommittee’s research report on a potential for a new occupational exposure level (OEL) for asbestos.
Just to rewind a bit, the report’s terms of reference were to:
It’s an important area for legislation, as different types of asbestos fibre are known to pose widely differing levels of threat. For example, there’s a nearly 500:1 jump in mesothelioma risk with exposure to crocidolite (blue) compared to chrysotile (white) asbestos.
However, the committee seems to have gone off-piste, and has instead chosen to answer entirely different questions with dubious scientific justification. Andrey Korchevskiy and Garry Burdett’s presentations laid bare the problems that would be encountered if the report was accepted.
Its first fundamentally flawed assumption is to assume that operatives won’t know which type of fibre they’re working with. Given that the ‘O’ in OEL stands for occupational, it’s a very sound argument that people working with asbestos rather should know its type. Assuming that, just because there’s a Europe-wide ban, all exposure will be a mixture of fibres will lead to a significant unnecessary exposure risk.
Yet despite this, the committee elected to average out the danger and assume a single risk for all fibre types. The result of this crude approach is to set the level of risk far too high for chrysotile, and far too low for amosite and crocidolite.
Unasked for – the report also discards proven PCM technology in favour of expensive and cumbersome electron microscopy. All the existing lifetime risk assessment data is based on PCM science, and it would be a stretch to apply the new technology to old data. Moreover, if this recommendation were adopted, it would likely also prove unachievable for poorer EU nations.
Day two
As I said, for me day two was dominated by Colette’s talk Female Analysts and Four-Stage Clearance Testing. I had expected this presentation to cover the practical issues that our female colleagues experience, but it was so much more disturbing and worrying than that. Focusing on her own experience and the testimony of four other analysts, Colette left her audience pretty stunned and speechless. I have covered her talk and the issues it raises separately, to give it the attention it deserves.
To sum up, the FAAM conference was yet again incredibly useful and informative. More than ever it was also thought-provoking, and demanding of self-reflection. The overall impression it gave was that change was coming – both due to the positive impact of new technologies, but also I hope in response to the now public darker side of our industry.
Written by Nick Garland on Thursday November 11th 2021
After the roaring success of last year’s virtual FAAM conference, the team made an early, risk-averse decision that this year, FAAM Asbestos 2021 would also be online. We will all be ‘gathered’ for the 17th and 18th of November for an intense and varied programme of speakers that includes industry experts, doctors and academics.
So what ground is the conference covering this year? It starts with a deeper look into the use of AI in reading asbestos slides. You may remember that I wrote about Marvin the robot after Frontier Microscopy’s presentation at the 2019 European Asbestos Forum conference.
We were told how it was used in Australia, where getting analysts to remote places was a huge challenge. Instead, samples are sent to a central lab for analysis, where Marvin uses AI to analyse the samples more quickly and accurately than humans. At FAAM we’re going to hear from Frontier, Ethos and xRapid on where the technology has gone in the last couple of years.
After the morning break, we will be looking at more traditional approaches. But even here there’s a new slant – discussing how certain changes to how we take the sample can give us the opportunity to improve the limit of quantification.
The rest of the first day – with one notable exception – will be focusing on the European Chemical Agency (ECHA) Assessment for Asbestos. You may not be aware, but the ECHA produced a substantial report back in February, seeking consultation on its recommendation that the occupational exposure limits (OEL) be dramatically reduced.
You’d wonder who would argue against this kind of proposal, but in fact it seems that the science behind the move may be flawed, and the recommendations impractical. Andrey Korchevskiy, Robin Howie and John Hodgson are all speaking on the subject then, after the break, Gary Burdett will present the ECHA opinion.
Outside the ECHA chamber
The ECHA exception I mentioned is Dan Barrowcliffe, who will be presenting on the exposure study that he led on removal operative exposure during licensed work. Dan has been very present at FAAM conferences, but has recently taken up a post at the new Building Safety Regulator. I’m sure he’ll be at future conferences, though: we all know there is no real escape from the asbestos industry!
Day two kicks off with a series of talks on the UK’s asbestos legacy, with a focus on mesothelioma and treatment advances – a subject that is ever present in our minds. Before lunch we look at the law, and the role of the expert in asbestos claims. After the gripping mock trial last year I expect this will be a compelling examination of what can happen when it all goes wrong.
We round up the day with site-based issues, ranging from communication between clients and LARCs, and Sara Mason’s talk on the challenges to site analysis. Several talks here sound promising. I’m eager to hear from Dale Timmons of further advances in thermochemical asbestos destruction – a technology that could hold the key to preventing landfilling.
I’m also interested in Graham Warren’s look at the implications of ‘net zero’ for the asbestos industry. And finally, given that the four-stage clearance (4SC) is a topic close to my heart, I’m hopeful that Colette Willoughby will be telling us about some practical solutions to the additional challenges faced by female analysts during the 4SC.
It’s a packed programme, and my experience from last year suggests that – despite the virtual format – the event remains unmissable. You can sign up for FAAM 2021 via the BOHS website. I hope to ‘see’ you there!
Written by Nick Garland on Thursday November 11th 2021
With the HSE’s electronic licence assessment process now nearly three years old, the original pilot companies are going through the process again. The promise for the new system was that licensed asbestos removal contractors (LARCs) would feel the pain only on their first time through, with all subsequent renewals being much more straightforward. Only time will tell whether the HSE’s view of simplicity matches ours.
But assuming the process has bedded down into an initial, intense assessment, followed by more of an ongoing ‘light touch’, what is certain is that the regulator will be focused on what’s new. This will range from any changes you have made internally, through the findings of any HSE visits, and crucially the results of your own audit programme.
And as anyone that’s been through the licence process will know, while the HSE values a well-managed internal audit programme, external audits are near-mandatory – and huge store is put on their findings.
First off, it’s important to explain that I’m a huge supporter of internal audits. Without looking for yourself, it is easy to fall into the trap of running your company with blinkers on. This wilful blindness will lead to poor practice through ignorance, and a degree of shock when others – such as the HSE – see something that you haven’t.
The key is that these internal audits need to be effective. Significant pitfalls to avoid would be:
The weaknesses in both come because it is human nature to see what you expect to see. If you always have the same auditor, they’ll always spot the things they’re great at spotting. The things they’re not so good at spotting will always get missed. When marking your own homework it is difficult to spot your own mistakes!
Contracts managers (CMs) who audit their own jobs will be particularly vulnerable to this. The takeaway is not necessarily to (as some would say) avoid CM auditors, it is rather to ensure that you’re aware of their limitations, and that you look for these in the results. Whether audits are conducted by a CM or a regular internal auditor, if they typically don’t find anything wrong, it’s unlikely to mean there isn’t anything to find. In fact, it should be seen as a warning. A blend of auditors makes for a healthy system. A LARC can benefit most from the eyes and interpretation of the CMs, the MD, and even supervisors themselves.
This last group is often underused for auditing, but while they don’t realise it, supervisors audit every job. Often they even record their findings – for example your supervisor’s pre-start check is an audit of the RAMS (risk assessment method statement) against the reality they are faced with.
It’s important to use this data, and so recording it needs to be easy. Assure360 is specifically designed to streamline all aspects of construction safety, so we allow supervisors to complete pre-start checks digitally – with the data automatically contributed to the internal audit system.
Assure360 also allows safety tours, so any time that the CM and MD complete a site visit they can record any issues they see. Again, this flexibility helps record and highlight issues that typically get resolved there and then, and would otherwise be forgotten by the time an audit rolls around. Finally – uniquely to Assure360 – we help avoid the ‘snow blindness’ sometimes caused by over-reliance on internal audits. All our users get to see benchmark data from the many thousands of audits already completed on the system – letting you learn from other people’s lessons.
External sets of eyes
It’s clear that a well-managed internal audit programme is crucial for health and safety. So what does an external expert add? Their key role is to provide a check and balance on your own observations – allowing you to recalibrate.
The HSE knows all too well the limitations of internal audits, and approaches them with a pinch of salt. For the purposes of licence assessment, it needs some sort of external verification of the evidence submitted. In the past this would have been HSE visits – and lots of them. But with budgets as they are, we’re not seeing the dramatic step up in inspections that would be needed. In fact the numbers are down again – continuing the trend of the last four years:
| HSE Annual Report 2017 / 2018 | HSE Annual Report 2019/2020 | HSE Annual Report 2020/2021 | |
| Asbestos visits | 1,000 | 900 | 860 |
| Inspectors | 1,066 | 1059 | 1045 |
| Proactive inspection visits | 20,000 | 13,300 | 14,880 |
To supplement its own visits, the HSE will therefore be focusing its attention on what other external eyes have spotted – and that means the finding of external auditors.
The first round of the new licence assessment required LARCs to submit three internal and three external audits conducted in the six months before application. With the HSE’s licence assessment now focused solely on what’s new and what’s changed, these audits will take centre stage.
All of which brings us back to a subject I wrote about earlier in the year – the increasing importance of the external auditor. In any healthy auditing ecosystem – and explicitly in the three-and-three minimum outlined by the HSE – the independent auditor presents a vital, fresh perspective on the otherwise closed feedback loop of internal audits.
Fundamentally, external auditors improve the overall quality of an audit system in multiple ways:
Independent audits should always be seen as a vital check, regardless of how we’re licensed, but the HSE’s increasing reliance on them may well be about to drive up demand as the industry begins its second rotation through the new system. To the handful of existing quality auditors, we need to add other skilled and experienced professionals, able to help protect and improve the safety standards to which we all aspire.
If you know my history, you’ll know this is an area I feel strongly about. Through Assure360 I’m determined to help improve auditing standards in our industry, which is why we’re continuing to offer Assure360 as a free-of-charge service to suitably qualified independent auditors. Whether or not the end client is using Assure360, this means the auditor will benefit from:
The system is even more appealing if the client happens to be an Assure360 customer. In these cases, all audits will automatically read across to the client’s slice of the system, allowing:
We’re keen to expand the group of selected, quality auditors who use Assure360 to simplify their audits, and improve the depth and clarity of their reporting. If you’re interested in joining them, why not get in touch to understand more about how Assure360 can support you?
“Assure 360 auditing software has made my auditing process seamless, and provides a quality audit for my clients in an easy-to-read format. The system is very stable. Nick and the team are on hand to provide support when required. It is very rare to find such experts in the field running and operating great software.”
Craig Ablett, Consulo Health & Safety Ltd
“I just find it so, so easy to use, so simple. It doesn’t take up half the time of my own audit system – where I’m uploading photos, copying and pasting information. It’s none of that, it’s quick. It’s a great app really.”
Chris Pedley, CP Safety
“It’s the benchmark we should all be working to. It covers just about everything you could want on an asbestos audit, along with general health and safety.”
Dave Philips, D&N Asbestos Advisory Services
“I’m an absolute fan. When I turn up on site, I’m not carrying pens, paper and clipboards. It’s just user friendly, it’s so easy.”
Paul Beaumont, BIACS
“My clients aren’t just getting a box-ticking exercise, they’re benefitting from my expertise and feedback, and the software’s ability to help produce actionable information.”
Chris Pedley, CP Safety
Written by Nick Garland on Thursday October 14th 2021
Originally founded in 1965, the Breyer Group has grown to become one of the UK’s leading principal contractors. Still owned and managed by the Breyer family, the group now has more than 400 employees, and specialises in roofing, construction, responsive repairs and maintenance.
Breyer’s success is founded on its reputation for customer service, environmental care, and commitment to health and safety. Its management systems are ISO 9001:2015 and ISO 45001:2018 accredited, underlining its focus on delivering satisfaction and ensuring the wellbeing and safety of everyone on site. To this end, it has a dedicated Health, Safety and Environmental team, which works to performance targets set by the board.
As a large company comprising hundreds of staff, working on multiple sites for many different clients, Breyer faced the challenge of effectively monitoring and maintaining health and safety. Historically the company had audited its sites with a bespoke software tool, but this didn’t extend to tracking accidents and incidents. The cost and complexity of maintaining separate systems had begun to mount, and were becoming an obstacle to improvement. In addition the internal system’s support contract was due to expire, adding urgency to the need to find its replacement.
Breyer became an early customer for the Assure360 system, and the Assure360 Audit health and safety auditing app. The company now also uses Assure360 Incident to track and act on all accidents, incidents and near-misses.
Assure360’s configurable cloud database delivered the flexible approach that Breyer had been missing. Quickly implemented to work ‘out of the box’, the system was further customised to provide bespoke auditing questions. Not only did it replace and build on the functionality of the previous auditing tool, it combined accident and incident tracking into a single, integrated solution.
Enhanced by the specialised Audit and Incident apps, Assure360 provided Breyer with a single, centralised platform for the effective monitoring and management of health and safety throughout the group. Reporting observations and incidents became quicker, while the system provided ready visibility to all who needed it – from site managers and clients, all the way up to the board.
Today, Assure360 plays a vital dual role within the Breyer group. Most importantly, it’s fundamental to the group’s ability to inspect sites and ensure compliance with best practice. The system’s granular approach to data, and cloud-based synchronisation between site and office, ensures that the management team is immediately provided with audit and incident data.
Secondly, Assure360’s powerful reporting and analysis features help the business demonstrate its legislative compliance and exemplary track record – whether that’s to internal managers, the Health and Safety Executive, or to potential clients.
It’s fundamentally important to us as a business that we bring our staff home safely every day. Only the very highest health and safety standards will do.
More than this, our customers only want to work with contractors who can demonstrate exemplary standards. It’s important for winning new business and building long-term partnerships that we have the track record and the figures to back up our strategic commitment to safety.
And while safety is our overriding focus, there are other advantages to constantly striving towards the safest working environment. By minimising injury, we pay less on insurance, for example.
Assure360 has been a breath of fresh air since we started using it. It allows us to quickly and easily audit sites, and to report, track and investigate health and safety incidents. The cloud database lays all of the information I need to do my job on a plate. I can instantly understand what our findings are telling us. Reporting to the board is no longer something I have to take weeks to prepare for: everything is at the touch of a button.
And that’s what you want. You don’t want to trawl through loads of paperwork and information. That’s not relevant today. Assure360 is easy to use and has helped us get rid of all that. What’s even better is that the system is so easy to use, it is no longer me and my team that ‘do health and safety’ – all of the contracts managers and directors participate.
It makes safety proactive rather than reactive. With the Assure360 Incident app – because everyone loves an app – something that people look at as a boring chore in fact becomes interesting because you’re looking at a mobile phone. They haven’t got to fill a form in, or go to the table we used to have.
They just get out their phone, answer six or seven series of questions, upload a photo, send it off to me and it goes into my stats. So I can see efficiency, and near-misses like “Tiles left on footpath” or “Skip not closed”. It’s good for myself, but also clients: they always ask “How do you report near misses?”. With Incident I can show them.
One of the things I like about Assure360 Audit is that it doesn’t just highlight non-conformity, it creates an action for what you’re going to do to close it out. So for example you might sit down with the contracts manager and say, “Handrail missing from scaffold.” You’d resolve it by assigning the action to contact the scaffold company, with a three-day timeframe. Then the contracts manager or site manager, when they’ve rectified it, will go in, upload a photo, and then they’ve closed it out.
So it’s not just there to show people’s failings, it’s there to put an action plan in place. A lot of apps just go out and mark everything as bad news – “That’s wrong, that’s wrong, that’s wrong, that’s wrong” – but not how you’ve closed it out or how you’ve made it safe. Whereas Assure360 produces a trail that shows how you’ve made it safe. You can record best practice, too – highlight the good stuff that’s on site.
That’s useful not only because it means that things get resolved, but also because you can demonstrate good practice to clients, contractors, borough councils, or for things like our ISOs and accreditations.
Written by Nick Garland on Thursday October 14th 2021
Cast your mind back 12 months and it was evident the pandemic was far from over. The government had introduced the three-tier system, and events were once again being cancelled and postponed. With this in mind, we should all be grateful that this year’s Contamination Expo was back at the NEC.
As probably the biggest event in our industry, the Expo is our major opportunity to come together, exchange ideas and information, and get a real feel for what’s going on. I was looking forward to being there but then, just a couple of days before, tested positive for Covid.
I’ve written loads about the ability – indeed the need – for firms to have technology that adds flexibility and remote-working capabilities, and it was interesting to get a chance to demonstrate first-hand. Our team leaped into action, helping me film my talk Demystifying the four-hour time-weighted average (4hr TWA) so that I could present it remotely to the conference – almost as planned!
Hopefully the talk still comes over well despite my not being 100% well – I’m happy to report that my symptoms were mild and I’ve recovered now. If you’re interested in reading more about the topic, this summer I wrote in depth about the HSE and personal monitoring, and took a deeper dive into the 4hr TWA.
Looking ahead
Brilliant though technology is, and as much as it’s changing the industry we work in, there’s still no substitute for in-person conventions and events. Things will be more normal by this time next year, and the Contamination & Geotech Expo 2022 will no doubt be bigger and better. Mark out 14-15 September in your diaries!
We list the Expo and all the other occasions we know about in our regularly updated diary of asbestos and construction events. Aside from the regular ARCA and ACAD regional meetings, we’ll keep you posted on the various events and symposiums that accelerate the sharing of knowledge in our industry. Please let us know if you’re organising something so we can add it to the list.
Personally, I’m most looking forward to the next European Asbestos Forum (EAF) conference. Given the ongoing challenges with international travel this has been postponed until 2022, but I’m reliably informed next year’s event will be worth the wait. Given the quality of the 2019 conference, I don’t doubt it for a minute.
Want to see first-hand how Assure360 simplifies the 4hr TWA? Get in touch for your free demo!
Written by Nick Garland on Wednesday September 15th 2021
Asbestos, construction, and safety events calendar
Covid-19 is still with us, but with few restrictions in place, most in-person events are back.
Here’s our list of all the other essential meetings, briefings and other dates for your diary.
16th September 2021
Celtic Manor, Newport
This year’s awards and golf day will be a long-awaited opportunity to safely meet up with old friends and industry colleagues. Assure360 will be sponsoring the Audit awards. We look forward to seeing you there!
POSTPONED
Rearranged for November 2022 – see below.
22-23 September 2021
The NEC, Birmingham
Like most other leading events, the 2020 Expo couldn’t run because of the pandemic. This year it’s rebranded to acknowledge its importance to the Geotech industry. As before, the event is composed of a series of child events that includes the Hazardous materials expo. Keynote speakers include Yvonne Waterman, founder and president of the European Asbestos Forum foundation.
At 2pm on 23 September, our own Nick Garland will be giving his talk on the four-hour TWA and the HSE’s new focus on personal monitoring. Nick will also be at the ACAD stand during most of the two-day event.
Find out more
8 October 2021
Lords Cricket Ground
ARCA returns to Lords for its 2021 general meeting. Full details are yet to be announced, but the HSE’s Sam Lord has been confirmed as a speaker. The event usually includes updates from the leadership team and other staff, along with lunch and ample opportunities to network. As in previous years, there’ll be an after-lunch speaker to wrap things up with a smile.
Virtual
The event will bring together researchers, academics, practitioners and regulators, through various plenary talks and technical sessions with a programme that will include UK and international speakers, dealing with scientific topics covering key areas regarding the assessment, control and management of asbestos. Click here for further information and the preliminary programme.
4-30 November 2021
Various
ARCA will be returning to face-to-face meetings for its autumn regionals, which take place at various locations throughout November. However, it’s providing an additional date for a remote meeting. Find more details on the link below, or email info@arca.org.uk to learn more.
7-10 November 2022
Bristol Marriott Hotel
Airmon is the leading international forum for air monitoring. The tenth instance of the event was previously scheduled for September 2021, but has now been rearranged for November 2022. It will build on previous conferences, providing an exciting programme. Thought-provoking keynote presentations will be combined with oral presentation sessions. Presentations from students or early-career researchers are warmly encouraged, and short training courses, delivered by experts in their field, are an integral component of this event.
If you’re hosting, postponing or cancelling an event you’d like us to list here, please get in touch.
Written by Nick Garland on Wednesday September 15th 2021
What on earth are Temporary Works? According to the Health and Safety Executive (HSE) they’re ‘the parts of a construction project that are needed to enable the permanent works to be built’. But this definition is a little misleading, and leads us to think only about major construction items, holding up partly built structures.
This over-simplified definition reflects a wider problem with how temporary works are perceived, and how the asbestos industry in particular deals with them. For the most part, we tend to ignore the whole issue as not applicable to us.
On the HSE’s side, there’s some problematic guidance in which the definition is subtly different. Essentially, here temporary works are anything that ‘might or might not remain in place at the completion of the works’. And if you’re thinking that could apply to anything, you’d probably be right.
Let’s step back from this confusion and explore the founding principles for temporary works (TW). TWs are assigned design categories, which reflect the complexity and innovation of their design. They also have a risk classification, which reflects the consequences should they fail.
The design categories are officially 1-3, but there’s an unofficial extra one – ‘0’:
0 – Standard solutions. Essentially off-the-shelf systems that have been previously judged or tested as safe.
1 – Simple designs. Some thought has been put into creating the solution. Examples might include simple formwork and propping.
2 – More complex designs. These would usually include piling and excavations.
3 – Complex, innovative designs. These are departures from the usual to solve novel problems or achieve an innovative result.
Depending on the category, the design requires a greater or lesser degree of extra checks.
Once we’ve established the appropriate design category, we determine the classification of risk by asking, ‘What are the consequences of failure?’ This often changes how temporary works are regarded. For example, temporary (i.e. Heras) fencing might be design category 0 – tried and tested. Put it next to a busy dual carriageway and it remains design category 0, but it becomes high risk. This raised level of risk means we undertake more stringent site checks to make sure the solution has been built as designed.
We’re actually very familiar with this kind of concept, as an asbestos enclosure is a great example. Enclosures are typically built to a very standard design, making them design category 0. But the consequences of failure will vary. In an open field there may be minor, manageable consequences. In a busy school they’d be very serious. Consequently, you may include additional checks for the latter.
Understanding risk categories
The obvious examples of TWs that we all think about are trenches, concrete formwork, and the propping up of partially constructed structures. But with the above definition in mind (anything that ‘might or might not remain in place at the end of the project’), they also include scaffolding, towers, hoarding, fencing and asbestos enclosures.
Essentially all the things we build in the asbestos industry are temporary works. So what do we need to understand about the rules?
Nearly everything that we do has a standard solution, and will have a design category of 0. Speedframe Airlocks, internal timber enclosures, Heras fencing, simple scaffolding, towers: it’s all off the shelf, so no specific design is required. However, there are times when we do something a little extra, and that changes things dramatically.
If instead of the standard Heras fencing we put up timber hoarding, the support and foundations for these are firmly in the category 1 arena. Adding logo sheeting to Heras fencing would also move it into category 1, with the associated changes in how it needs to be managed.
Many other common adaptations will modify category 0 structures in this way. If the existing site scaffolding is a standard design covered under the National Access & Scaffolding Federation’s TG20:21 guidance, great. But when we construct a full enclosure on this we’re adding a huge sail to a multi-ton structure. That’s very definitely no longer a TG20 scaffold!
If a temporary works fails, the consequences could be serious – and the HSE will certainly be investigating. Say for example that high winds topple the soffit enclosure scaffold, the scaffold company could well be in the clear – the reason it fell was because we added the sail. If we have specified category 1, 2 or 3 temporary works, but then not had them properly designed, it’s us in the dock.
Managing risk, avoiding disaster
So if everything we build is a TW, and mostly it’s category 0, but occasionally it’s not, what should we be doing? It’s unfortunate that there’s no official guidance. Instead, everything is effectively governed by the British Standard BS:5975. This document outlines the best practice you should be following. And in our industry we know that while we don’t have to follow guidance, we can’t ignore it, and we must do something equivalent or better.
BS:5975 states that you must have a procedure for TWs. This could simply be an extension to your existing standard procedures, essentially laying out what standard designs you use and what you will not do. You must also appoint certain roles. These include a designated individual: a senior person in the organisation responsible for establishing and maintaining the TW procedure. The designated individual must also appoint the temporary works coordinator: a competent person to manage the temporary works.
All temporary works must be designed by a competent person, or be to a standard (i.e. off the peg) design. And there may be a need to double-check aspects of the designs depending how complex they are. Anyone who designs a TW is a TW designer. They have exactly the same duties as any designer under the Construction (Design and Management) Regulations 2007.
All temporary works must be checked on site to ensure they have been installed or built as per the design. As we mentioned before, the degree of checks required depends on the risk.
How might this work in practice? The appointed roles might be shared out as follows:
The first and second of these have to be formally appointed, and accept the position.
There’s excellent training available for temporary works coordinators – you can find much of it through Easybook – but it’s not compulsory. In the low-risk category 0 world we inhabit, you might choose to send one person, then have them cascade the information to all of the TWCs.
Practical steps
In any event, make sure your contract managers know what constitutes a standard solution – give examples in your procedures. Few licensed asbestos removal contractors (LARCs) have anyone in-house competent at designing scaffolding. If you’re using scaffold as the basis for a soffit enclosure, make sure the scaffolder knows it is unlikely to come under TG20, and that it will need a design. Similarly, don’t embellish Heras fencing with branded sheeting. If necessary, use the (expensive) netting designed for this purpose.
The supervisors, as usual, are the checkers. They need to confirm that the operative built, installed or erected the item correctly. Recording these checks can be time consuming, but it’s something we’re all used to. That’s exactly why we designed the Assure360 Paperless solution, which slashes supervisor administration time by up to 80%.
So in summary, the things that LARCs build or erect are always temporary works, and you ignore that fact at your peril. By following some simple steps we can repurpose the activities we routinely do anyway, ensuring that the job gets done properly, checked appropriately, and that we’re observing the proper guidance throughout.
Want to see first-hand how Assure360 Paperless streamlines routine safety checks, and makes the data available for insight and analysis? Get in touch now for your free demo!
Written by Nick Garland on Thursday July 15th 2021
As you’ll almost definitely know by now, in April the Health and Safety Executive finally released its new Analysts’ Guide. I say finally, because as you’ll also know, the update was previously in the works for more than five years.
It’s been a very long road. The original consultation document was optimistically called ‘Asbestos: The Analysts’ Guide 2016 HSG248’. Like many others, I originally sent in my return to the consultation in November 2015. In 2017 I drafted my white paper, which summarised, analysed and commented on it. At the time, I anticipated that I’d be updating that promptly, but the real thing didn’t appear for more than another three years.
Despite this long gestation, the guide still has a few niggles – not least of which are a number of typos, some of which need clarification. I won’t be concentrating on these here, but I do think it’s likely the HSE will be targeting them in a minor revision before too long.
The big changes – and a typo
I’m not intending to focus on the big changes, in part because the majority of them were telegraphed in the original draft doc and then subsequently ‘leaked’ – we’ve had a long time to talk about them. The biggest example of this is the Supervisor Handover Form, which has been in wide but not universal circulation for a while.
However, now that it is in the guidance, for all practical purposes it becomes mandatory for the supervisor to hand one of these, fully completed, to the analyst before they can start on the four-stage clearance (4SC). This will also be something that the United Kingdom Accreditation Service (UKAS) will be checking when they do their visits to the labs. Assure360 was an immediate adopter of this, so if you’re already using the Assure360 Paperless app you don’t need to do anything.
Discover how Assure360 Paperless helps keep you within the guidelines.
If, however, you haven’t started using the now ‘mandatory’ form, be aware that the template on page 202 of the guide contains a typo. The form asks ‘Has the NPU been switched off and new pre-filter inserted?’ Of course, we all know that this is done by the analyst after they are satisfied that stage two has been passed and they are ready to start the air test.
The asbestos enclosure handover form widely shared by ACAD had this typo rectified – you could contact your trade organisation to get their corrected version. If you do use the one from the guide, be sure to brief your teams on the correct way to use it.
Getting into the subtleties
As I say, I don’t want to focus on the typos, but rather I want to pick up some of the less obvious changes that people might have missed.
Throughout, the Analysts’ Guide stresses the client’s responsibilities with regard to protecting the health of people who work in or on their building. The underlying subtext is that this includes the analyst and the asbestos removal operative. Clients also have fairly extensive duties under the Construction (Design and Management) Regulations (CDM) to ensure that a project can be carried out without risk – so far as is reasonably practical. The combination of these factors could be that the client’s duties extend to cover previously grey areas.
It seems curious that the HSE is effectively extending the well known position that the client and not the licensed asbestos removal contractor (LARC) should appoint the analyst. The reason for this is that the analyst’s four-stage clearance is the final quality control audit prior to handing back for normal occupation, and any conflict of interest at this point is bad.
So far so normal, but the change comes with the highlighting of less formal conflicts in paragraphs 1.23 and 1.24:
“…where the contractor is a major source of work…” and;
“The analyst should not perform site clearance certification where such shared links exist. However, if shared links are unavoidable, the building client should be made fully aware of them. This should be in writing.”
Any such links would therefore generate a UKAS-verifiable paper trail. It will be interesting to see what kind of an impact this will have on the industry.
Regardless, the inevitable conclusion that strikes me is that if personal monitoring is mandatory (it is), and the HSE is giving out a very strong steer that the client should appoint the analyst directly, then the client-appointed analyst should be conducting the LARC’s personal monitoring. It would then be inevitable that if they do, it will form part of the health records of that individual, and must be shared immediately with their employer (the LARC).
This might not seem controversial to those of you removed from the coal face, but the reality is that in many cases client-appointed analysts are refusing to share this crucial data with the LARC on the grounds that ‘the client has paid for it – so we can’t hand it over.’ It is my understanding that the HSE’s position on this will be made crystal clear in upcoming guidance on personal monitoring.
Personal monitoring, again
The most significant of the subtle changes in the new analysts’ guide centres around personal monitoring. I first wrote about these based on the final draft version of the guide. In short, a new type of personal sample has been added: the Specific Short Duration Activity (SSDA) test.
It’s this test that most contractors have tried to use in recent years as it has the most immediate, practical effect – i.e. they use it to test the effectiveness of their methods and make changes as appropriate. The problem has been that as it wasn’t listed in the guidance, analysts were tending to only do the 10-minute version, which is useless in all but a few cases.
Now the HSE has given the optimal test a name, LARCs should immediately adopt the terminology, and request ‘SSDA Personals’ whenever they book personal monitoring tests.
There are dark arts involved in the calculation of four-hour time-weighted average (4hr TWA), and LARCs can take another step that will increase the utility of any personal monitoring air testing. Where possible the go-to or standard test should be at least two hours long, and run at a sample rate of two litres per minute. The full 200 fields/graticules should be counted, too. This single test will then qualify for calculating a SSDA, RPE suitability, and the 4hr TWA. Of course, there may be more complex situations, as I explained in my recent deeper dive on the 4hr TWA.
Finally, those of you who have read my earlier posts may remember I pointed out a typo in the late draft of the guide. It specified a four-litre per minute minimum flow rate for the SSDA tests, but this has been corrected in the final version to specify up to four litres.
Written by Nick Garland on Wednesday June 23rd 2021
Asbestos Essentials was founded in late 2017 by a leadership team boasting more than 50 years of industry experience. With offices in Milton Keynes and London, the company has expanded rapidly to offer comprehensive, UK-wide asbestos surveying, removal and remediation services.
The foundations of Asbestos Essential’s growth come from its twin commitments to customer service, and best practice safety and environmental standards. In addition to a highly experienced management team, the business is certified to ISO 9001, ISO 14001 and ISO 45001, and licensed by the HSE and Environment Agency in asbestos management and disposal.
The asbestos industry is highly regulated. As Asbestos Essentials’ business gathered pace, it faced many of the common administrative challenges posed by mandatory record keeping. With site records completed on paper and held in large binders on site, managers didn’t have easy access to information that would help them improve the performance on safety of ongoing jobs.
Additionally, the team faced the headache of processing large quantities of paperwork once it returned to the office at the end of an audit or project. With huge files, containing hundreds of sheets of paper, the task was taking up valuable office time that could be better dedicated to improving standards and growing the business.
In spring 2020, Asbestos Essentials became an Assure360 customer. It chose to deploy the Assure360 Paperless app, in the process equipping its site supervisors with iPads. Asbestos Essentials took advantage of the Assure360 rollout to provide supervisors with other support for remote working, installing Dropbox to allow the easy sharing of plant and equipment paperwork, along with policies, licences and other useful site documentation.
Asbestos Essentials quickly began to benefit from Assure360 Paperless’ ability to streamline and simplify asbestos management paperwork. While some of its less technical staff initially needed extra guidance, the team could call on Assure360’s technical support and assistance to help ensure that everyone quickly understood the new system.
Assure 360’s granular data capture and cloud database meant that critical site and employee information could now be gathered and stored electronically, dispensing with the need for bundles of paper. Additionally, with essential reference documents now provided electronically, project teams no longer needed large folders to hand while they worked.
Aside from streamlining on-site record collection – and allowing supervisors to concentrate on supervising – the move to Paperless brought major benefits to the office. With information gathered and shared in near-real time, the management team could see at a glance what was being done on site – and whether anything had been forgotten.
The ready availability of site data has also freed office staff from the chore of processing large volumes of paperwork as it returns from site. And with automated analysis of the data, the team has easier access to insight that can help them drive safety and environmental standards still higher.
“The amount of paperwork, audits and so on that we produced was astronomical. Having a cloud-based system like this, it allows us to see in real time what’s going on on site. Plus all of the paperwork that had to get done and sorted when it got back to the office, that’s now done on the system – rather than having big huge files which we then have to archive.
“It means as well that I don’t have to pull out files and show auditors: ‘well, that’s this file. That’s this file.’ and so on. Now I just need to find a job on the system and pull it up and it’s there.
“Our work in this industry is very much process-driven. A really good thing about Assure360 is you can’t move on to the next bit until you’ve done the bit before. It won’t let you close the job at the end of the day until you’ve done all the checks and all the things you’re supposed to do.
“Also, if we have jobs going on where we’ve got multiple supervisors, you can actually hand it over to another supervisor and it appears on their iPad instantaneously. If an HSE inspector turns up and says ‘you only started working at four o’clock today; what happened during the rest of the day?’, you can run through all of the things that have been done on the previous shift because it’s all there for you.
“When we first took on Assure360, we met with some initial scepticism on our supervisors’ part. All that they had known was paper, so their concerns were understandable. However, with support from myself – and directly from the Assure360 team, they have really taken to the system.
“The Paperless app is so easy to use and intuitive, it cuts out nearly all of their admin tasks. They love it – even if I wanted to go back to the old ways, they wouldn’t let me.”
Written by Nick Garland on Tuesday June 15th 2021
I’ve had a lot of very positive comments on April’s article about personal monitoring and the four-hour time-weighted average. I thought it might be a good idea to take another look – but this time take a deeper dive into the exposure geek pool. In this post I’m going to really focus on the challenges of the four-hour time-weighted average (4Hr TWA), and give a few more examples of how to do it.
What’s the point of the 4hr TWA?
It’s important to start with a quick refresher on the point of the 4hr TWA. Sam Lord of the Health and Safety Executive (HSE) recently summed it up neatly: the point of 4Hr TWA control limit testing is to really look at compliance, not just nod to it.
I discussed the wider context of the testing and explained the terminology in my previous post. The key point is that the four-hour control limit test is a duty-of-care test, intended to really examine whether we have complied with our duties as an employer.
To recap, the test specifications are:
| Test | Sample Rate (litres/min) | Minimum Volume | Minimum Graticules | Resulting LoQ |
| 4-hour Control Limit | 1-2 | 240 | 100 | 0.04 f/ml |
The control limit is 0.1 fibres per millilitre of air (f/ml) over four hours – measured inside the mask.
The newly (finally) published Analysts’ Guide specifies a simplified version of the World Health Organisation method – an attempt to increase the frequency at which these tests are being completed.
Despite referring to it as a ‘test’, it is better to think of the four-hour TWA as a calculation. It is intended to represent what happened to that person over a continuous four-hour period – it tells a story, if you like. The simplified rules are:
There’s a very important point to make here: you don’t have to do a single four-hour air test to calculate a valid 4hr TWA. What you do need is a record of what happened over those four hours, with test results that support the ‘story’.
The HSE’s simplified approach to this is to require a minimum total air volume of 240 litres. If you do the maths, that means you need at least a two-hour (120-minute) test at two litres per minute.
However, now the analysts’ guide is out, it’s clear that how you get to those numbers is a bit more flexible. You could conduct three individual tests one after the other. Importantly, certain assumptions can also be drawn.
The calculation
Let’s go through some examples of how you do these calculations by hand. The calculations for all of these examples are taken directly from the new analysts’ guide. Please note that the HSE works in hours and fractions of hours, rather than minutes.
Also, before I start, I should point out that while the sums are straightforward, the calculations are yet another burden for asbestos professionals. Later on I’ll explain how Assure360 can do it all for you.
Example 1 – a series of tests to paint a picture
Consider this shift inside the enclosure:
Because we know the sample rate was at least one litre per minute, and the total test duration is four hours, we know that the total air volume exceeds the magic number of 240 litres. In this case we can tell the story of the whole four hours.
This is where the ‘time-weighted’ bit comes in – we multiply each of the measurements by the duration of that specific activity to calculate total exposure. Then we divide by the total duration to produce an effective average exposure rate for the entire duration of the tests:
Example 2 – what if the work lasts more than four hours?
An activity will often carry on beyond the tested period. In this case, the guidance says you can assume that the exposure continued at the same rate, provided the minimum flow rate and sample volume are met. Consider this activity:
Here, the test duration and flow rate ensure the total sample volume is well over the minimum 240 litres. Accordingly, you can assume that the last 40 minutes of the four-hour window would be same as the result of the actual testing:
Example 3 – what if the work lasts less than four hours?
Similarly, where the work (and the air test) last for less than four hours, we can extrapolate. Consider this morning’s work:
Again, as the sampling rate was 1.6 litres per minute for 150 minutes, this means that the total sample volume meets the 240-litre minimum. Accordingly, we can calculate a four-hour TWA:
Of course, if you’ve got the computing skills, you can create a spreadsheet that will do all of that for you. Alternatively it can be done by hand every time. But while the former is bad enough, the latter is quite soul destroying – and either could be prone to mistakes.
Making it simple
Happily we’re able to offer Assure360 customers an alternative. I’ve long sought to simplify personal monitoring for licenced asbestos removal contractors (LARCs), and I want to support the HSE’s renewed push to improve it. We’ve added a new TWA tool to the Assure360 platform, allowing the system to do the heavy lifting for you – and saving hours.
Last month our Paperless app was enhanced so that, along with the test result, it will collect three more data points:
Now that this data is being collected, the Assure360 database reports will, over the coming weeks, give you more and more power to do TWA calculations.
We’re already providing the original simple time-weighted result for every compliant test. We also calculate it for every situation where it is known that exposure continued for the full four hours. Next month we will be adding a system to pool multiple results together, to complete the suite of tools.
By automating calculation of the four-hour TWA, I hope that we can help ensure that more four-hour tests are carried out, and fewer mistakes and misunderstandings made. More than anything, we want to help the HSE improve the depth and quality of personal monitoring, and improve the safety of everyone who works in our industry.
Want to see first-hand how Assure360 Paperless simplifies the four-hour TWA? Why not get in touch to book a free demonstration?
Written by Nick Garland on Thursday May 20th 2021
We’ve said it before and it remains true: the construction industry is an inherently dangerous business. According to 2019/20 figures, the sector recorded the highest number of fatalities of any industry, and the second highest rate of injury.
However, focusing on the top-level statistics overlooks a fundamental truth: that comparatively few workplace accidents happen truly without warning. All too often they’re the end result of a trend, or they become possible thanks to a blind spot in safety culture or supervision. Each year, lives could be saved and life-changing injuries avoided if we could better identify the conditions, oversights and company cultures that allow people to get hurt.
Without doubt, the most important pillar in driving down workplace accidents is to fully record and investigate them, along with the incidents and near-misses that often precede them. As we’ve written before, the accident triangle theory suggests that any near miss could be a warning of a potential accident. It’s essential to capture and analyse data – and act on the insight to prevent something worse.
The construction industry takes this seriously, and many employers do it well, but the same is less true in the specialised world of asbestos management. Historically, it’s something we’ve been rather poor at.
Across all industries, a culture of continuous improvement demands that any accident, incident or near-miss is recorded so that lessons can be learned. Recording should be mandatory, and any barriers to it should be removed: that’s the philosophy behind Assure360 Incident.
Incident exists precisely to minimise the barriers to recording safety incidents in the workplace. Providing a simple and intuitive interface, it improves record keeping. With the Assure360 dashboard, it helps provide the analysis and insight that organisations need to improve.
Now, we’ve improved the app itself, with a refreshed interface and a raft of other features. Chief among these is that, like Paperless before it, Assure360 Incident 2.0 is now available on Android.
Other major improvements include:
Above all, we’ve focused on making Incident 2.0 as streamlined as possible. By making incident and near-miss reporting easy, our aim is to help you make it quick and comprehensive. Why not download Assure360 Incident now, and start strengthening your health and safety culture?
Written by Nick Garland on Thursday May 20th 2021
It’s been a long and difficult 18 months or so. The world has changed markedly since Covid-19 began to take hold, and while it seems the UK is on the way to better times, many regions still face huge and dangerous challenges.
The pandemic has been traumatic in so many ways. Alongside the human costs, businesses have struggled, and the construction industry offers no exception. You can get a simple idea of the impact of the pandemic on our customers’ ability to trade with a simple measure of activity: the number of audits recorded each month.
As you can see, the first lockdown caused a huge dropoff in activity, as firms struggled with new dangers – and limited understanding and resources to help overcome them. The strong recovery as we headed toward the June 2020 end of that lockdown reflects businesses implementing ‘Covid-safe’ working practices.
Being our customer data, it also strongly reflects support from the remote working features of the Assure360 system. After seeing first hand how Assure360 was helping businesses stay open during the first lockdown, we were inspired to try and do more. From July we made Assure360 Paperless available on a three-month free trial.
Paperless was designed from the outset to remove paperwork, maximise productivity for the supervisor and promote remote management. In normal times this is a huge boost to site efficiency, allowing supervisors to concentrate on the works at hand. It’s also a great way for contract managers to reduce their dependence on site visits to ensure everything is proceeding as planned.
In Covid, these benefits became even more useful. We spoke to customers such as GreenAir Environmental, who had abolished all site paperwork, and were using wipe-clean iPads as their on-site hub: supervising jobs, holding Zoom meetings and communicating the method statement to the team. Asbestech told us how, by doing away with paperwork returning from site, they’d eliminated one vector through which the virus could spread.
The take-up of our free Paperless offer was strong. Not only was this an endorsement of a product we strongly believe in, but it’s made us incredibly proud to know we could do something to help our community through a once-in-a-lifetime crisis.
Look again at the graph above and you might notice a marked difference as the UK began to lock down again, from late September 2020, through to the full lockdown in the first months of 2021. By this point, many of us had strong experience of Covid workplace safety measures, and far more of our customers were using Paperless to help reduce paperwork and support remote working. The result was a far smaller drop in activity, with more of our customers able to keep working throughout.
Despite the success of vaccination and lockdown measures in reducing cases, hospitalisations and deaths, it’s too soon to say that Covid is behind us. Less than half of the population is fully vaccinated, and we’re still a way off everyone having that first shot. Even so, we seem to be through the darkest days. So what have we learned?
The first, soberingly, is that the pandemic might not be over yet. While we’re in a far better position than even a few months ago, Covid has already proved its tenacity with additional waves and variants. The government is keen to stress the need for continued caution, even as it removes the restrictions we’ve all been living and working under.
For employers, this makes it even more important to look beyond government or industry guidance, no matter how sensible it is. As I wrote in February, it’s our legal duty to keep employees safe from Covid. If the government is both opening things up and urging caution, it’s hard to avoid an implied transfer of responsibility to the private sector.
We’ve also learned that some of the changes forced on us by Covid have been good. It’s a small ray of sunshine to take from 18 months of awfulness, but it’s clear that changes like reduced paperwork and increased home or remote working are here to stay.
At Assure360 we’ve also seen how many customers who took advantage of the free Paperless upgrade have decided to stay with the product after the three-month period. It really is a system that has to be used to be believed, so we’ve extended the offer: now every new Assure360 Platinum contract will include the first three months free.
Finally I wanted to take a quick look at what our audit data can tell us about any changes on the ground. If we compare the non-conformances we were seeing in the first quarter of last year with the first quarter of this, we see:
| Non Conformances Identified in Q1 2020 | Non Conformances Identified in Q1 2021 | ||
| Risk Assessments (detailed in method proper) | 15 | RPE Maintenance – Certificate on site | 20 |
| Drawings (accurate) | 13 | RPE (Monthly) | 18 |
| Method Statement (clearly written, site specific and appropriate) | 13 | Risk Assessments (detailed in method proper) | 15 |
| Electricity – Isolation | 12 | Drawings (accurate) | 13 |
| Housekeeping | 11 | COSHH Assessments | 11 |
| Method Statement (appropriate) | 11 | Electricity – Isolation | 11 |
| Welfare Facilities (general) | 11 | Medical | 11 |
| Analyst Recorded (including who contracted to) | 9 | Method Statement (appropriate) | 10 |
| Method (QC) | 9 | Training | 10 |
| PAT | 9 | Trip Hazards (general) | 10 |
At first glance, it looks like a lot has changed, but if we look at broad trends we start to see some similarities. In 2020, the large majority of issues were related to the method statement, and its suitability and accuracy. Looking at the broader picture for Q1 2020, we can break the top 10 down like this:
In 2021 we see four very admin-related issues coming into the top 10: RPE maintenance certificates, monthly RPE checks, and medical and training certificates (not) being on site. Looking at the broader picture we can break the top 10 down like this:
This might hint at a picture where admin teams are struggling to adapt to the ‘new normal’, or simply that they’ve been furloughed and that some of their responsibilities aren’t getting picked up. However, other than the new challenges of getting the right paperwork to site, the picture painted by data is relatively similar year-on-year. I’d be interested to know if this tallies with your experience. What are you finding on site?
It’s hard to know just how different – or not – the world will be post-Covid. And again, I’m mindful that for many this nightmare is far from over. But it’s certain that in many ways the changes of the last 18 months will be permanent.
Just like many of you, we’ve spent the last year changing how we do things. First we added Android support to the Paperless and Incident apps. In Paperless we added site diary entries with photographs – a hugely important and flexible tool for all supervisors and contract managers. We’ve been responding to other changes, too. Last month we introduced our solution to calculating four-hour TWAs – something that the industry has been waiting on for 30 years!
We’re still adapting and improving our products as quickly as we can. Next on the list – and coming very soon – is Assure360 Audit 3.0. Just as with Paperless and Incident it will be available for both Apple (iOS) and Android devices. We’ll be refreshing the look, but we’re also taking the opportunity to add in lots of features that many of you have been asking for:
To quickly elaborate on the last point, this means that Auditors powered by Assure360 will be able to better cooperate with their clients to help drive through improvements.
As I said, Audit 3.0 is coming very soon. We’re looking for customers who’d like to test the beta release from the end of May. If you’d like to take part, please get in touch below.
And whatever your personal experience of the pandemic, I hope that things are improving for you now and that you, too, are able to look forward. I hope we stand on the verge of a period of rebuilding, growth and – let’s hope – renewed social interaction. May we all make the best of it.
Want to help shape and test the next version of the Assure360 Audit app? Get in touch to join the beta programme.
Written by Nick Garland on Friday April 23rd 2021
BIACS is a provider of safety services ranging from IATP-audited training, to nationwide asbestos surveying. Founded by Paul Beaumont, BIACS embodies more than 30 years’ of experience within the asbestos industry. The business is focused on being impartial, independent, but fair when assessing progress, procedures and compliance.
When building his business, Paul drew on his extensive experience of operating licensed asbestos removal companies to design consistent and comprehensive audits for his clients. As the demand for audits increased, it became more obvious that much of the auditing process relied on set procedures and questions. Paul realised that gathering information in a structured and repeatable way would help BIACS to improve the consistency of its work, and further raise the quality of the audits it delivered.
In early 2020 BIACS began using Assure360’s auditing capabilities to support and enhance its work. Among the benefits, the simplicity of the Assure360 Audit app meant that Paul could turn up on site armed only with an iPad – doing away with the need for pens, paper or clipboards.
BIACS’ adoption of Assure360 has proved a boon for its auditing business. Offering guided support through a comprehensive site audit process, Assure360 Audit ensures that Paul can capture detailed information on site with the minimum of fuss. By implementing a structured data-gathering process, the app ensures that no checks are missed and that the audit is thorough. Widespread and simple support for photo evidencing means that all findings can be backed up with images, helping highlight both shortcomings and good practice.
By following a consistent process, the app guarantees extremely high consistency between audits. This helps ensure that no checks are missed, but it also supports higher quality analysis and comparison between audits. Able to demonstrate a highly consistent approach, BIACS is often asked to audit alongside LARCs’ own internal auditors, providing a benchmark and comparison.
Repeated auditing with Assure360 allows BIACS to produce detailed training needs analyses for its clients. Where those clients also use Assure360, the data can be pooled to ensure the most complete understanding of training requirements. As an IATP-audited provider of training, BIACS can use its deep understanding of clients’ needs to provide tailored and highly targeted training.
There’s a benefit to auditing based on a consistent process. Fundamentally it means you can’t forget to do something – either on site, or when writing up the audit. The flip side of that is I’ve done audits for other organisations where you’re literally given an A4 document with tick boxes on it, and you go down and tick them. You’re limited to ticking the box. And you’re also inheriting any blind spots in their system.
It’s not like that with Assure360. You’re going through the boxes and you’re saying: “yes, the guy has got training, yes he has got a medical, yes he’s fit-tested”, but you can comment on anything. With Assure360 it’s got that consistency: the layout’s the same, the information is the same.
It’s easy to follow and it’s easy to identify needs in operatives as well. When I deliver training for clients who use Assure360 they can present us with information to say, for example: “We’ve got three guys who aren’t that good in this particular area. Can you cover that in the training?”. It lets us focus the training more – makes it more valuable.
Back when I was personally getting trained as an operative, we’d turn up for mandatory training every 12 months and go through the same training course we’d had the previous year. What a proper training needs analysis allows us to do is to tailor that course, not only to make it informative, but also to make it interesting so they’re actually learning something, rather than just sitting there going through the same old stuff they did before.
Written by Nick Garland on Monday April 19th 2021
The Health and Safety Executive (HSE) is getting ever closer to the release of its new analysts’ guide – intended to help analysts and their clients comply with the Control of Asbestos Regulations 2012 and its Approved Code of Practice (ACoP). I’m reliably informed it will be coming in the next month or two. I know we have all heard this before, but it really does seem to be imminent now.
UPDATE – May 2021: The guide is now published. Click here to download the Analysts’ Guide from the HSE website.
As I highlighted in my review of last November’s FAAM conference, there are some important changes to the guide’s personal monitoring section. These add to an impression that the HSE is taking personal monitoring increasingly seriously, and trying to get to the bottom of why it is generally done so poorly.
If you are struggling to wrap your head around personal monitoring, be reassured that it is a complex subject that often feels academic, with no practical benefit. And if it makes you feel any better, be aware that not everyone at the HSE understands it fully either.
Be careful what you ask for
In regard to personal monitoring, the HSE seems to be asking ‘why do we never get what we ask for?’. In my view, the reason is that the whole subject has never really been communicated with people on the ground (the actual doers) in mind. Here’s an extract from the draft new analysts’ guide:
| Test | Sample Rate (l/min) | Minimum Volume | Minimum Graticules | Resulting LoQ |
| 4-hour Control Limit | 1-2 | 240 | 100 | 0.04 f/ml |
| 10-minute short term exposure limit | 4 | 40 | 100 | 0.24 f/ml |
| Specific short duration activity | 4 | 120 | 100 | 0.08 f/ml |
| Assessment of suitability of RPE | >0.2-4 | 40 | 100 | 0.24 f/ml |
First, a quick explanation for those of you not familiar with the terminology:
Graticules – if you have ever looked down an analyst’s microscope, a graticule is the little target. Stating how many graticules is effectively a statement as to how long / hard an analyst should read the slide. The longer they look, the more accurate the test.
LoQ – a favourite acronym of us exposure geeks. It stands for Limit of Quantification, but what does that mean? It’s a threshold describing the sensitivity of the test: in effect, the analysts are saying ‘We don’t know exactly how much asbestos is there, but if it were above this number we would have found it all.’
All air tests have a LoQ which varies depending on the specifics of the test: how hard the pump was working (the sample rate), how long the test continued, and how many graticules were inspected. The more air you sample and the harder you examine it, the more sensitive the test is. If you find less asbestos than the LoQ (including none at all), you can’t be sure of this – so you say it was below the limit.
Back to the table. In a change from the existing analysts’ guide, you’ll see there are now four personal monitoring tests. Here’s what they’re for:
Four-hour Control Limit – this is a duty-of-care report: the employer is legally required to do these to demonstrate that individual workers are not exposed to asbestos above a certain limit, over a long period of time. That limit is 0.1 fibres per millilitre of air (f/ml) over four hours.
What you might not realise is that this is inside the RPE that you have provided. The other thing to remember is that these are tests associated with the individual being exposed – not the activity. So when analysing the data, make sure it is person-focused. I’ll go into more detail on these dreaded four-hour time-weighted average (TWA) tests later.
Ten-minute short-term exposure limit – this is the second legally mandated duty of care report. This test is intended to measure short-duration, high-intensity activity, and the limit is 0.6 fibres / ml inside the mask. Essentially this test is to detect brief ‘spikes’ in asbestos concentration, even when the average over four hours was acceptably low.
It’s very hard to achieve meaningful results in these tests. It’s obviously easy for the operative to be ‘painfully careful’ for 10 minutes, avoiding the kind of activity that might have otherwise produced a spike.
Assessment of suitability of RPE – this aims to gauge whether the mask was good enough for the task. This is related to the protection factor (PF) of the masks. To calculate it, you divide the exposure by the PF to identify the likely level inside the mask. Well-fitted, powered full-face masks give a protection factor of 40. Orinasal masks are rated at 20. Simple.
Specific short-duration activity (SSDA) – this is the ‘new’ kid on the block. I say ‘new’ as despite it not being on the list before, it is also the test standard that most licensed asbestos removal contractors (LARCs) try to achieve. It is essentially a test of how effective the method was.
The good news is that it is now on the list. The bad news is that the HSE has stated a sample rate of four litres per minute. Having spoken to the authors I can assure you that they mean up to four. Hopefully this typo will be amended before publication.
It’s my understanding that the HSE views the two most important tests from this list to be the four-hour control limit, and the SSDA. Indeed, now that SSDAs are on the list we will be able to remove one of the biggest problems to completing personal monitoring: analysts. More specifically, that many analysts do what the guidance tells them without exercising a deeper understanding.
Often, when a personal monitoring test is booked, an analyst concludes that they can’t do the four-hour test because the operative isn’t in the enclosure that long. Instead, they do the 10-minute test, the LoQ for which is so high as to be next to useless. This has been driving the HSE quietly mad for years, but now, when you are booking a personal, you can request a ‘SSDA Personal’.
I hope this will solve the problem, but it doesn’t get away from the lack of understanding surrounding the four-hour test, how to apply it, and how to calculate the results. As promised, we need to dive into them.
The dreaded four-hour time-weighted average tests
As I mentioned, the four-hour TWA tests are the main duty-of-care tests that we are legally mandated to do. They follow a World Health Organisation method which assures a level of accuracy that we would all agree is important when we are talking about people’s long-term health.
We do them because it’s the law, but more importantly because high-accuracy testing is the right thing to do. This is unfortunately easier to say than do. The rules are not widely understood, and the maths underpinning the test is fiendish. So here’s my attempt to simplify the whole topic.
Firstly it is better to think of the four-hour TWA as a calculation, not a test. The rules are that the test underpinning the calculation must look like this:
That brings us to the second and most important point: you don’t need to do a single four hour air test to calculate a valid four-hour TWA. Obviously running the air test for four hours will make the maths easier – but it is not essential. As long as the initial test is for two litres per minute and is run for at least two hours, we’re in business. What makes up the rest of the four hours can therefore come down to estimates and assumptions.
Squaring the circle
To explain this further, let’s look at a chart that the HSE presented at last year’s FAAM conference:
The aim is to capture the highest exposure (the initial removal phase) within the four-hour test. But it’s often the case that this doesn’t last for four hours. A second HSE chart helps show how you square the circle:
Charts by kind permission of Sam Lord HSE.
The activity is split into three distinct phases:
On this last bullet – there is a tantalising opportunity. Due to the very low impact of such a short low exposure event, it may be possible to build up a library of test results to populate the last bit of the calculation. But as only tests that comply with the basic WHO rules count, you may have to wait a while to build up the evidence. I have long advocated that the standard test should be one-hour long with a flow rate of two litres per minute. This gives us a decent level of accuracy for short-duration activity tests. If we increase this to two hours as standard, every test we do can be used for any of the HSE’s test categories.
The calculation (and why you don’t have to do it)
I’m going to take you through the steps to do the calculation by hand. But at this stage I should give you a spoiler alert: later in this post I’ll explain that Assure360 can do it all for you!
In the HSE’s example above, the equation is formed from three different work/rest sessions, and what proportion of the four-hour period they take up. As I mentioned – I have rounded the numbers to make it easier:
This gives us:
The trick is to do each of these as separate little sums and add them together (remember zero multiplied or divided by anything is zero):
This gives you an answer of 0.275f/ml for the four-hour TWA.
If you’ve got the computing skills, you can create a spreadsheet that will do all of that for you. Alternatively it can be done by hand every time. But while the former is bad enough, the latter is quite soul destroying.
Making it simple
Those of you who’ve read my articles before will know that trying to simplify personal monitoring for LARCs could be considered ‘my thing’. I wanted to add my support to the HSE’s renewed push on personal monitoring, so we’ve added a new TWA tool to the Assure360 solution. Just as with everything else we do, a small tweak to the front end allows the system to do the heavy lifting for you – saving hours.
Our Paperless app has now been enhanced so that, along with the test result, it will collect three more data points:
The Assure360 database will do everything else for you. It will check the rules to make sure the test qualifies, and it will automatically do the calculation. Every test will be given its four-hour TWA value, and every duty-of-care report will provide the information.
If you are able to specify that all personal monitoring tests are at least two hours long with a flow rate of two litres per minute, it will also automatically start to build up a library of results that could be used to estimate the balance of any exposure
By automating calculation of the four-hour TWA, I hope that we can help ensure that more four-hour tests are carried out, and fewer mistakes and misunderstandings made. Improving the depth and quality of personal monitoring will, I hope, help the HSE reduce exposure in our industry, and improve working conditions for us all.
Want to see first-hand how Assure360 Paperless simplifies the four-hour TWA? Why not get in touch to book a free demonstration?
The Analysts’ Guide was finally published in May 2021. Click here to download it from the HSE website.
Written by Nick Garland on Wednesday March 10th 2021
What exactly is an ‘environmental clean? It’s a phrase we’ve all heard, and maybe even used many times. But the term has never been defined by any regulation, or in official guidance. And therein lies the problem. Undefined, the ‘environmental clean’ is often used as a get-out, describing a situation that a client, consultant or contractor doesn’t think warrants an enclosure.
As a vague process, the environmental clean could mean almost anything. Some have long pushed at the boundaries of what’s acceptable: in practice environmental cleans reveal a very wide interpretation of what controls are appropriate, from the sensible, down to almost none.
Not surprisingly, the Health and Safety Executive (HSE) has always hated the phrase, and can get quite cross when it’s mentioned. The HSE has encountered a history of poor judgement by individuals in the industry on whether an enclosure was necessary. No doubt you’ve heard concerns dismissed with “It’s only an environmental clean” – it’s often been used as an excuse to justify cutting corners.
I’ve always counseled licensed asbestos removal contractors (LARCs) never to use the phrase. The alternative is to have it defined in your Standard Procedures. A detailed specification covering the meaning of the phrase, the narrow parameters in which it can be used – and what controls are required – would prevent its misuse. Just writing it down means that it will be reviewed by the team, and by the HSE during your licence assessment. If you define it, you have control.
But now the HSE is acting to solve the problem, via the newly renamed Asbestos Network Technical Working Group. Previously known as the Asbestos Liaison Group, and chaired by Martin Gibson until his retirement, the group is now headed up by Sam Lord – very much out of the same mould as Martin. In a new set of minutes, the group is trying to completely reclaim the term ‘environmental clean’.
As you may or may not know, the working group’s minutes are used to share the thinking of the powers-that-be as to how the industry should be doing something. They are highly considered documents, which have been pored over for many weeks and months. The minutes have a fuzzy legal status – they’re not official guidance, but certainly the HSE uses them as part of its best practice model. Ignore them at your peril.
So what do the minutes actually say about the environmental clean? The very first point they make is that all work with an asbestos containing material (ACM) falls under the Control of Asbestos regulations 2012 (CAR), and the Approved Code of Practice (ACoP). Accordingly, there is absolutely no difference between cleaning, removing, encapsulating and so on. It’s all ‘work with asbestos’, and therefore the nature and duration of the task will determine whether it is notifiable, and what controls are required.
This makes it the legal responsibility of the company doing the work to get it right. Getting it wrong could lead to the spread of asbestos. In turn that could lead to severe legal repercussions and very severe civil claim exposure.
So to reiterate the obvious, a job requires a licence if you are dealing with licenseable material as defined in the CAR. The ACoP (Regulation 2) offers this definition:
“Licensable work with asbestos” is work:
(a) where the exposure to asbestos of employees is not sporadic and of low intensity; or
(b) in relation to which the risk assessment cannot clearly demonstrate that the control limit will not be exceeded; or
(c) on asbestos coating; or
(d) on asbestos insulating board or asbestos insulation for which the risk assessment:
(i) demonstrates that the work is not sporadic and of low intensity, or
(ii) cannot clearly demonstrate that the control limit will not be exceeded, or
(iii) demonstrates that the work is not short duration work.
Note the overlapping use of the words ‘and’ & ‘or’.
So it doesn’t matter what you call the job. It is licenseable work if you are dealing with asbestos coatings, or insulating board / insulation – unless your risk assessment clearly shows that it is short duration (two person hours, once a week as per the ACoP paragraph 31). Even then it would need to be below the four-hour or 10-minute control limits. If the job involves some other ACM, it still requires a licence if the exposure is likely to be over the four-hour or 10-minute control limits.
The minutes seek to further clarify this tight definition in certain areas. For example, if the material was originally insulation, but now is so deteriorated as to be merely unidentifiable trace debris on a floor, how do we establish whether the work requires a licence?
The starting point taken by the minutes is to try to separate out the grey areas that tend to get covered by an “it’s only a …’ fig leaf. These are the:
The minutes define environmental cleaning as picking up, wiping up, collecting or vacuuming unattached ACMs. If the ACM is identifiable as coating, insulating board or insulation (either because you can identify if or because the source material is right there) – it will require a licence and must be notified. The exception is if it will be a very short job (see paragraphs 30-31 of the ACoP).
The memo then goes on to recognise that if all you are doing is vacuuming a small patch of asbestos insulation board fragments, then the required controls might not include a full enclosure. This highlights an often misunderstood part of the regulations. Whether something requires a licence and whether it requires an enclosure are two separate questions. The first nearly always triggers the latter, but not always. Your risk assessment must determine what controls you implement. And remember you are looking for the worst case scenario: what if the method goes wrong?
The minutes open clear daylight between environmental cleans and re-cleans. A reclean is where you are revisiting a situation where someone failed to clean properly in the first place. The ACM is often surface residues which were difficult to get at, too hard to dislodge, or simply “missed”. The material is often randomly spread, particularly over imperfect surfaces. Recleans, the memo states, require a licence subject to the ‘very short duration’ caveat. It also implies that, because of the vigour required to remove ‘attached’ residues, the controls are likely to be more onerous (i.e. full enclosure).
Finally the group has addressed pre-cleans. The minutes point you at the Licensed Contractors Guide (HSG 247), paragraphs 6.27-6.28. Here it clearly states that a pre-clean is merely phase one of the licensed removal project. It may include sheeting over plant equipment, ACMs that are to be retained, wet floors and so on. The work may include cleaning minor ACM dust and debris, and it will require appropriate controls such as dust suppression, RPE and PPE. The risk assessment will determine whether or not this can be done in advance of the soon-to-be-constructed enclosure.
Far from telling you what an environmental clean looks like in regards to methods, controls and PPE, the aim of the document is to focus you on the starting point of your decision making:
The advice I have always given LARCS stands: what a job looks like in practice (enclosure, decontamination and so on) must still be defined in the working method, and in your Standard Procedures.
These minutes draw attention to the way that a failure to define a procedure, or the use of a ‘folk’ definition, can give rise to confusion. More importantly, they remove one opportunity for less scrupulous players to cut corners and compromise safety. In practice, I believe their biggest impact may be preventing the pressure that’s applied by consultants or clients trying to get a nice quick job, because they perceive it as ‘only a…’.
Written by Nick Garland on Monday March 8th 2021
We’re now nearly two years on from the Health and Safety Executive (HSE)’s revolutionary change to the asbestos licence assessment system. Despite early and significant teething troubles, the word out there is that the new system is largely working OK. As it happens, the evidence based, online system could also have been specifically designed for the 2020 that no one expected.
But if the privations of the last 12 months have combined with the HSE tearing up the licensing regime to create a dark cloud, I’m happy to suggest a rather surprising silver lining: a rise in the need for, and importance of, the independent auditor.
To explain, let me take a step back and look at the importance of auditing in general. In a strong health and safety system, internal audits are crucial, providing critical knowledge of exactly what’s going on on site. Having this information first-hand is fundamental to developing a deeper understanding, learning lessons, and making the improvements you need.
So how does that fit in with the HSE’s licencing shakeup? With a move away from in-person licencing assessments, the HSE doubtless needs more enforcement visits to verify contractors’ evidence-based submissions – and to give itself confidence that the new system is working. The HSE recognises that it needs a lot more boots on the ground to see what’s really happening. But with the budgets as they are, those won’t be lots more HSE boots – indeed, the recent trend in actual visits is down not up.
The pragmatic route around this is for the HSE to require licensed asbestos removal contractors (LARCs) to conduct audits – and lots of them. Specifically, the HSE’s licence renewal evidence guide calls for a minimum of six audits to be submitted as part of the application, split between three internal and three external ones.
This balance between internal analysis and external appraisal is essential. My mantra has always been that there must be a blend of internal and external audits. The former should take the bulk of the load, but the latter is an essential source of balance. Having fresh eyes is essential to uncover any blind spots.
Who should conduct internal audits? I know from experience that the HSE is wary of contract managers ‘marking their own homework’, but in most businesses there are other sources of internal eyes. For example, a contracts manager can conduct peer review audits and supervisors can audit the method statements and whether they are fit for purpose.
Sometimes – particularly in smaller businesses – a contract manager will have to audit their own job, but even this can be useful, especially if they are harsh markers.
Independent auditors are an essential check on the feedback loop of internal audits, but not all auditors are created equal. In my view, independent auditors should be both experts in asbestos legislation, and offer deep experience of construction health and safety. You’d think our industry would create them by the bucket load, but they were a rarity when I started my career, and they’re a rarity now.
Things may be about to change though. Belts are tightening after the past year, and while labour supply agencies saw an immediate hit, in-house health and safety teams are following suit. Sadly that means redundancies, and the additional concern of weakened safety cultures at the affected organisations.
Still, it’s a very ill wind that blows nobody any good. As the HSE outsources its eyes, a pool of experts is likely to be looking for new opportunities, and this is leading to an interesting shift in the industry. The creation of a whole new sector, of amply experienced and qualified independent auditors, is something to be celebrated and welcomed.
I feel this particularly strongly, as In 2004 I made a switch that most consultants never do, and started advising licensed asbestos contractors on health and safety. It was this that really completed my education: without direct experience of both sides of the industry, we professionals can be very blinkered.
I have got a lot out of my career so far, both professionally, but also a personal feeling of value. By working for several removal contractors at once I feel I have been able to help all of them become better. So as this is very much my emotional home, I have a great deal of empathy and want to help those taking a similar route.
For this reason we’ve decided to offer the use of Assure360 completely free of charge to suitably qualified independent auditors. Whether the auditor’s end client is on Assure360 or not, this will be a massive boon. The auditor will benefit from:
The system is even more appealing if the client happens to be an Assure360 customer. In these cases, all audits will automatically read across to the client’s slice of the system, allowing:
We already work with selected auditors who use Assure360 to simplify their audits, and improve the depth and clarity of their reporting. Read what they say – and contact us if you’d like to start using Assure360 yourself.
“I just find it so, so easy to use, so simple. It doesn’t take up half the time of my own audit system – where I’m uploading photos, copying and pasting information. It’s none of that, it’s quick. It’s a great app really.”
Chris Pedley, CP Safety
“It’s the benchmark we should all be working to. It covers just about everything you could want on an asbestos audit, along with general health and safety.”
Dave Philips, D&N Asbestos Advisory Services
“I’m an absolute fan. When I turn up on site, I’m not carrying pens, paper and clipboards. It’s just user friendly, it’s so easy.”
Paul Beaumont, BIACS
“My clients aren’t just getting a box-ticking exercise, they’re benefitting from my expertise and feedback, and the software’s ability to help produce actionable information.”
Chris Pedley, CP Safety
“My clients get a full report from me, in that will be the audit, lots of nice photos, and an overview of the site H&S. But there’ll also be graphs and charts from Assure360, which I don’t have to create, and that’s brilliant.”
Dave Philips, D&N Asbestos Advisory Services
Written by Nick Garland on Tuesday February 23rd 2021
DMD Environmental is an asbestos specialist with offices in the East Midlands and East of England. Offering asbestos surveys, management, and removal, the company works with customers ranging from major government bodies and housing organisations, to individual homeowners.
Like many licensed asbestos removal contractors, DMD Environmental has found that the successful expansion of its business has come with a large administrative burden. Mandatory record keeping, and the need to analyse and act on the data it collects, represents a major undertaking for a business running multiple projects and sites at any one time.
DMD Environmental had previously tried to address this, implementing a digital form-based system to capture site data. Unfortunately the system was only a partial success, with staff finding it complex and hard to use. Moreover, the company was still heavily reliant on paperwork, and committing many hours of manpower to labour-intensive processing and analysis.
As the company continued to prosper, it faced a growing need to streamline its existing processes. Additionally, it recognised that modernising its data collection and analysis had the potential to improve the way it could manage projects and staff. In January 2021 it hired group coordinator Kriston Fox, and tasked him with finding solutions.
Fox quickly understood that the existing system didn’t meet DMD Environmental’s needs and, after fruitlessly contacting the vendor, began looking at alternatives. With an entrepreneurial background in IT and customer-facing roles, Fox sought out a data capture and analysis solution that would support a modernised, paper-free approach to site management. Within a month, the business had implemented an Android tablet-based solution powered by Assure360.
Fox understood the full potential of moving DMD Environmental to cloud-based technology. By adopting Assure360 Paperless and Assure360 Audit, the business was able to free its supervisors from the burden of paperwork. Just as importantly, with data flowing back from sites in near real time, managers gained a more detailed view of their projects, letting them offer more proactive and timely support.
The rollout of Assure360 presented an opportunity to reinvent the way that DMD Environmental managed its sites. Fox equipped the tablets with Zoom and Microsoft Teams, creating a tool that connected managers with their project teams. With easy communication, instant data capture and paper-free site management, the business cut down the need for site visits, and removed common friction points from its asbestos removal workflows.
Importantly, the solution has been embraced by the same staff who had a poor experience with the earlier system. During training, supervisors were astonished that they could fill in job details in Assure360 Paperless, and seconds later see the data arrive in the cloud-based Assure360 dashboard. Instead of having to carry large ring binders of paperwork around, site teams and their information are now linked to the wider business via a single, wipe-clean tablet.
DMD Environmental’s experience shows that it’s possible to rapidly improve and modernise paper-bound asbestos removal processes – even when they are longstanding.
Assure360’s experience and support also played a key part in getting DMD Environmental up and running quickly. From video-based demonstrations during pre-sales, to extensive support and training materials during rollout, the Assure360 team was on hand to ensure a friction-free experience. It also worked with Fox to ensure that the business could realise the full benefits of the platform, and get the maximum return on its investment.
“Our business had a lot of paper – the industry itself is very traditional, and can be quite tech-averse. At the same time, the people who work on site have an exceptional level of knowledge and understanding. Our goal was to try and get the two to merge together – supporting our workers’ expertise with technology that would help them apply it.
I took a look at the previous system and understood the feedback the staff had given me on it: ‘I tried it but it doesn’t work. It’s too complex. It’s not user friendly’. I realised I wouldn’t want to use it. I knew we needed something better, and having spoken to Rick and Chris [Garland], we landed on Assure360.
People in the office can’t go and strip asbestos out of a building – they wouldn’t have a clue. But you need to provide the information from the site in the way that people in the office – and the Health and Safety Executive – want it. That’s what Assure360 does. The more you use it, the more info it collates, the more detailed your reports become – it’s pretty mega.
Having Assure360, the hard work’s already done. As soon as we’re inputting the info on site, our contract manager or auditor can go out and audit again using Assure360. This constantly gives us a live picture of where we stand.
Being able to have instant, live connectivity is a game-changer for this industry. And anyone that’s in this industry that doesn’t realise that will fast become outdated, and they will struggle – look at what’s happened in retail. Now I can instantly see how things are going on our sites. Our MD or contracts manager can come in and ask me ‘What’s going on on that job?’ and I hit a button and there it is – with pictures and everything.
And if we get a problem, we can crack on Teams and sort it out. Rather than the supervisor having to call in, and the contract manager having to go out to site – which could be 100 miles away. That saves them two or more hours of driving, and the manager thinking ‘What are the problems going to be?’, and having to work out ‘If we need a new bit of equipment, where are we going to get it from? If we need a new member of staff, where are we going to get them from?’
If we know straight away, we can deal with that issue straight away.
I think it helps that when I send Assure360 an email I get a response, whereas with our previous vendor I didn’t get a response until I terminated our contract. What I found in Assure360 was a provider who was open to new ideas, wasn’t holier than thou, and was credible. They know what they’re talking about.”
Written by Nick Garland on Wednesday February 10th 2021
The Covid pandemic is virtually unprecedented in living memory. And aside from the awful human cost, its impact on the economy will be felt for many years to come. As a health and safety consultant, I’m also fascinated by the challenges it has created around workplace safety, and the effect on employers, employees and the regulator as we all try to stay safe.
And what of the regulator? The Health and Safety Executive (HSE) has been under enormous budgetary pressure for many years. And over the long months of the pandemic, I’ve become increasingly concerned that its lack of resources is hampering its ability to enforce Covid-safe working conditions.
Let’s begin by looking at how the HSE’s budgetary challenges were already impacting its operations before Covid. Looking at the data from the 2017-18 and 2019-20 annual reports, we can see the following:
| HSE Annual Report
2017 / 2018 |
HSE Annual Report
2019/2020 |
|
| Proactive inspection visits | 20,000 | 13,300 |
| Prosecutions | Not reported | 355 |
| INs | Not reported | 5,000 |
| PNs | Not reported | 1,900 |
| Asbestos visits | 1,000 | 900 |
| Inspectors | 1,058 | 1,059 |
| Prosecutions | 509 | 355 |
| Construction fatalities | 30 | 40 |
While the number of inspectors didn’t drop between reports, site visits did very markedly. Even the HSE’s attendance on asbestos sites fell by 10%. In the same period, prosecutions were down by 30%, and construction fatalities climbed by a third.
The tail end of this reporting period also saw the emergence and spread of Covid-19. The HSE recently told the Guardian that it had made 32,000 site visits during the pandemic. Meanwhile, the HSE’s Coronavirus management information dashboard provides this monthly breakdown of covid case notifications throughout 2020-21:
If these figures are accurate, they represent a massive surge in activity for an already overstretched body. Despite the recent trend of falling attendance on site and a reduction in prosecutions, there has now been a huge increase in numbers of unannounced visits. But is it having the desired effect?
Nationally we have seen very worrying increases in the infection rate during the most recent wave of the pandemic, and data from PHE suggests that some of this is coming from workplaces.
The latest Public Health England surveillance data suggests workplace infections surged as people returned to work in January. The number of coronavirus outbreaks in workplaces rose by almost 70% in the first week of the national lockdown, with 175 Covid case clusters reported in English workplaces
The Guardian 16th January 2021
Before continuing, I wanted to provide a short reminder of the levers that the HSE has available when it comes to enforcement. As a starting point, it can issue verbal and written instruction or guidance, which can be as simple as a chat or email from the inspector.
Certainly within the licensed asbestos removal industry, these basic measures have some real weight. If you don’t act effectively on instruction or guidance there can be dire consequences during licence renewal. However, in other less heavily regulated industries I’m not sure whether they provide quite the same imperative to act.
The HSE’s next level of action is quite a big step up. Improvement Notices (IN) give detailed instructions on what improvements you need to make, and by when. They can be appealed, but unless that’s successful you will need to act.
Next come Prohibition Notices (PN), which are very severe – and often also lead to prosecution. A PN essentially stops a certain activity immediately. Again, you can appeal, but the stoppage still kicks in with immediate effect. PNs can be wide-ranging and major: they can shut down an entire construction site or factory.
So, has the surge in HSE visits to companies translated into more of these enforcement actions? Recent news articles would suggest not. According to a January 2021 analysis by the Observer, the HSE had been contacted nearly 97,000 times on Covid-related workplace safety issues – including 2,945 times between 6 and 14 January alone. The newspaper found that overall, just 0.1% of these Covid safety cases received an IN or PN. A simple calculation suggests that’s roughly 97 Covid-related enforcements throughout the pandemic.
A January BBC News article quoted slightly higher figures for complaints during the same 6-14 January period, and suggested significantly higher levels of enforcement. In that week, it says the HSE received 3,934 coronavirus-related complaints, and took action in 81 cases. However, it notes that only one company faced more than a verbal or written warning.
A brief look at the enforcement action register suggests that the number of enforcement notices might even be lower than these headline figures. I found eight PNs where the only reason COVID was mentioned was as a justification as to why another misdemeanor was hard to close out. A similar investigation into the INs might show up similar cases.
Further analysis shows another interesting trend – Covid-related enforcements seem to centre on companies in the construction sector. Of the nine remaining PNs I found, five went to just two companies. Of the six companies found at fault, all but one were in the construction sector – and the inspectors’ comments seem to focus on washing facilities.
This seems out of step with reality when, as the BBC notes, the 500 confirmed or suspected office outbreaks in the second half of 2020 were more than those centered on supermarkets, construction sites, warehouses, restaurants and cafes combined. So why were no PNs issued here?
As others have noted, while workplace safety enforcement in the UK as a whole relies on the Health and Safety at Work Act (HASAWA), Scotland has legally obligated employers to ensure their employees can work from home wherever possible. But is this the most sensible health and safety advice?
HASAWA should give ample powers to the regulators. Since 1974, employers must assess the risks at work and reduce them so far as reasonably practicable. And if they don’t there is the big stick of enforcement action and prosecution. Many of the examples given in the articles above appear to be pretty flagrant breaches.
However, home working or furloughing staff might add financial burdens that are the final straw for a company’s survival. And therein lies the balancing act for an employer. I can imagine situations where, in the face of practical and financial challenges from sending people home, a diligent employer is instead able to make the workplace covid secure. The flexibility of HASAWA allows this to happen. If home working was an employee’s right, imaginative and effective solutions might not exist, and some companies may not survive.
Obviously, where it’s reasonably practicable, the goal should be to eliminate the risk. In the case of Covid-19:
Elimination may be impossible, or very burdensome, whereas mitigation may bring the risk down to a low enough level for people to remain in the workplace.
Despite this, in many cases cited by journalists it looks like little or no effort has been made. Interviewees speak of working side by side in warehouses, or conducting telephone sales and administration in a very small or poorly ventilated office.
The law is simple: if a company has not done enough to mitigate or eliminate a risk, then they are liable for serious punishment. But only if they get caught. With 33,000 visits, it’s clear that the HSE is making serious efforts to enforce safety during Covid. But with only approximately 80 INs and nine PNs, the evidence suggests that its approach to enforcement might be very light-touch.
An example contained in a second BBC article hints at where we might be going wrong on workplace Covid safety. A member of the public alleges that he works among 30 people on one floor of his employer’s office, that the windows are always closed, and – unbelievably – that they still hot-desk. With five or six covid cases apparently linked to the firm, it seems a clear example of a company not doing enough, or at least taking actions that are demonstrably not working.
The firm states in its defence: “We have worked closely with Public Health England since the start of the pandemic to implement extensive safety measures in line with government advice.”
And for me, that’s the heart of the issue.
During the pandemic, companies are looking to the guidance and – in far too many cases – scratching their heads on how they follow it and still make a profit. What they’re not doing is following the principle on which the HASAWA is built: looking at their underlying duties, and ensuring they take effective and specific actions to deliver a safe workplace.
An employer is compelled by law to ensure that its place of work is as safe as possible. The government also provides helpful advice (guidance) on how employers can fulfill this legal duty. How you go about making your workplace safe is, to some extent, up to you. You can follow the guidance, or craft something else – but the immutable fact remains that your legal duty is to make it safe.
My fear is that the HSE’s approach may be permitting a culture in which companies can point to generic guidance, in place of implementing specific measures that keep their employees most safe in their specific workplace. The HASAWA is beautifully crafted to get the extra mile out of employers – but if there is no enforcement, then an important pillar is missing, and the whole church is at risk of falling down.
Written by Nick Garland on Wednesday January 13th 2021
For Assure360, our Audit app has a special significance. Originally launched back in 2014, Assure360 Audit is at the heart of our streamlined and paperless health and safety auditing system. In 2017 we gave it a major refresh, adding more functions and a fresher look. As we pass 10,000 audits, I’m excited to announce that we’re hard at work on version 3.0.
The latest version is going to be brilliant, but before I tease you with the improvements, I thought I’d recap a little on the history of the app, and how it’s tied into our own. The Assure360 system is the result of my nearly 30 years spent working as a health and safety professional, specialising in the asbestos industry. One of our most important product features is that we offer our customers the benefits of everything I’ve learned in my ‘day job’.
The genesis of Assure360 came when I was working as an embedded health and safety manager for several licensed asbestos removal contractors (LARCs). I was designing audit schemes, completing training needs analysis and competence systems, and undertaking the analysis of exposure results… again and again.
I’d created a series of interconnected Excel spreadsheets to help me complete the work, but there was still plenty of manual work involved. It was repetitive, time-consuming – and prone to error.
In the space of a couple of months I met an app developer and a database company, and had a bit of a lightbulb moment. I realised that I needed an app to record the data quickly, and a database to do the tedious legwork in the background. Most pertinently, I realised that if I needed it, so would other professionals in our industry, and that’s how Assure360 and the Audit app came about.
From the start, the app accomplished most of what I set out to achieve, but our ethos has always been to work with our community to continually make things better. After three years of using the app myself and gathering feedback from our early customers, we updated it to version 2.0 – essentially the version you’re using today.
Version 2.0 had some big improvements over the original. It was better to look at, and added some powerful new functionality. Most importantly we added the ability to craft bespoke audit question sets, giving the app immense appeal to non-asbestos construction firms and specialists like demolition teams. It’s a testament to Audit’s appeal, usability and usefulness that it’s rated 4.5 out of 5 on the App Store.
“I just find it so, so easy to use, so simple. It doesn’t take up half the time of my own audit system – where I’m uploading photos, copying and pasting information. It’s none of that, it’s quick. It’s a great app really.”
Chris Pedley, CP Safety
Roll forward another three years or so, and we’re delighted to be working on another major upgrade. Just like with version 2.0, changes for version 3.0 will be the result of our continued experience using the app. And I mean ‘our’. I still use Audit daily in my ongoing work in health and safety, but the whole Assure360 team is tuned in to the feedback and suggestions we get from the ever-expanding Assure360 community.
So what’s new in version 3.0? As with our recent updates to the Assure360 Paperless and Incident apps, one of the biggest new features will be Android compatibility. With the release of Audit version 3.0, the entire Assure360 suite will be available for Android devices for the first time. This lowers the barriers to entry for our system, as Android devices tend to be a fair bit cheaper than those from Apple. Just as importantly it gives our customers more choice and flexibility, for example letting them run Assure apps on rugged tablets in the harshest environments.
Other improvements will include the ability to log multiple photos with an item, and the instant upload of audit findings – helping ensure teams are working with the very latest data.
We’re also excited to be adding new self-help tools that will let users craft their own bespoke audits. Much like when we introduced bespoke question sets, this allows auditors and other users to tailor the app and our system to the exact work they’re doing. The goal is to streamline the process further, and remove any obstacles and manual workarounds that could introduce errors.
“My clients aren’t just getting a box-ticking exercise, they’re benefitting from my expertise and feedback, and the software’s ability to help produce actionable information.”
Chris Pedley, CP Safety
We’re working on lots of other improvements alongside those main revisions, but like everything we do, the upgrades are a community approach. If you’ve got a feature to suggest, an issue to flag up, or any other idea for making version 3.0 as good as possible, please do drop us a line.
Want to discover more about the refreshed and improved Assure360 apps? Read more about our health and safety and asbestos management apps
Written by Nick Garland on Thursday December 10th 2020
Who would have thought that a virtual conference could keep you glued to your seat? If I’m honest, not me. Times are busy for us at Assure360, and so when I looked at the programme for the BOHS/FAAM conference there were a few slots where I thought “I might be able to miss that.” More fool me – the two days were absolutely riveting.
So here’s my attempt to sum up a few of the highlights from the conference. I haven’t included all the sessions, but if you’re a FAAM member I think the plan is for you to be able to log in and browse them all.
The control limit
The conference got underway with a history lesson, but one that really set up so much else for the two days. The Health and Safety Executive (HSE)’s Sam Lord took us on an interesting journey through how we arrived at the current asbestos control limit. She even explained the logic behind the name, and the important shift in thinking that it represented: that is, that there is no ‘safe’ limit.
Sam went on to give us an update on the HSE’s new Analysts’ Guide, which does finally seem to be nearing release next year. The guidance will contain two changes to the air testing criteria which I think are brilliant.
The first is that the UK will come in line with the World Health Organisation (WHO) method for sampling against the control limit. The four-hour time weighted average (4hr TWA) test has always been very challenging – not least because many tasks (when you take off breaks and decontamination) are not four hours long. But whilst they are difficult, these are legally mandatory duty-of-care tests.
The new guidance introduces important flexibility in the pump flow rate:
| Application | Sampling rate (l/min) | Min air volume 25mm ⌀ filter (litres) | Minimum number of graticule areas to be examined | Calculated airborne concentration at the LOQ |
| 4-hour control limit | 1-2* | 240 | 100 | 0.04 |
| 10-minute short-term exposure limit | 4 | 40 | 100 | 0.24 |
| Specific short-duration activities | 4 | 120 | 100 | 0.08 |
| Assessment of suitability of RPE | >0.2-4 | 40 | 100 | 0.24 |
* Note the change from 1 to ‘1-2’. This allows for higher volume tests in a shorter period.
** Brand new test – see below
Sam’s talk linked nicely with a presentation by Dan Barrowcliffe on the second day, about personal monitoring. I was able to catch up with Dan after the conference for some more thrilling personal monitoring chat (I appreciate perhaps not everyone shares my enthusiasm).
He and I discussed how the minimum volume column is important. For a 4hr TWA test this volume is 240 litres, which means you need to run the pump for between two and four hours. If you’re running it for two hours, where do the other two hours of a 4hr TWA come from?
If you have good enough data, based on accurate personal monitoring, you can interpolate them from your anticipated values. This opens up exciting potential for Assure360 users, as with 18,000+ personals already in the system we can potentially convert an awful lot more tests into the difficult-to-achieve standard. Watch this space – we will have a new report to do just this in the new year.
Short-duration activities
The other crucial change to the guidance – and something I’ve been calling for for years – is the new ‘Specific short-duration activities’ test. This is essentially what a well run, competent LARC does all of the time: test the peak high fibre release activities to measure the effectiveness of their methods.
Now that it is in the guide, analysts will know what parameters to test against, finally allowing LARCs to do their job properly. I personally would like a little more flexibility (a flow rate of 2-4, rather than 4), but now I’m being picky.
At the end of day one, Dan did an updated review of his four-stage clearance (4SC) project (see my summary of the preliminary findings here), and how it has influenced the new analyst guide. The project showed some encouraging improvements in analyst behaviour and performance on site. One of the main points however, is the application of a hard limit of 10 minutes on how much cleaning can be done within the 4SC. Equally importantly, this shouldn’t be done by the analyst at all. This change should bring an end to nightmare jobs where a hoard of operatives are trying to clean in the enclosure during the inspection itself.
The day of the trial
Day two started with an innovative mock trial, which moved from fascinating to excruciating as we watched the full horror unfold. The ‘case’ examined what could happen when an organisation that thinks it’s on top of asbestos policy discovers the hard way that it hasn’t been. The actors were all asbestos professionals – and somehow were able to tone down their knowledge levels to stay in character. I still don’t know how they did it, but it was absolutely enthralling.
The afternoon focused on asbestos technology. I found it all very interesting, particularly when learning about Hysurv’s use of drones to conduct visual surveys of buildings. I was lining up plenty of ‘well, it won’t work because…’ and ‘all very well, but what about…’ comments, only to find them comprehensively eliminated by their capabilities. One highlight was watching a drone fly through a tangled ceiling void!
The ability to survey a roof in vivid detail, showing the precise location and accurate measurements of presumed asbestos materials, was incredible. The equipment also seemed well capable of surveying confined and restricted-access spaces – potentially improving safety and raising surveying standards in the most challenging jobs.
So, far from skipping sessions I found myself largely glued to my screen for the full two-day programme. If virtual conferences are the shape of things to come – and it looks like they might be for a few months yet – then consider me an enthusiastic convert.
Written by Nick Garland on Thursday December 10th 2020
Let’s be honest, nobody’s going to look back fondly on 2020. The arrival of Covid 19 and the ongoing pandemic has ruined plans, destroyed businesses – and sadly cost far too many lives. But while it’s been a challenging and sobering year, new vaccines promise better times ahead. And many of the changes forced on businesses will be the basis for better trading as we turn the corner.
The year everything changed
You can’t look back on 2020 without discussing Covid 19. Mushrooming from a small outbreak centered in Wuhan, China, to a global pandemic in just three months, the virus has left few aspects of our lives untouched. From the outset, the lockdowns necessary to control the disease’s spread created social, financial and emotional scars that may take years to heal.
For many businesses, it was quickly clear that the pandemic represented an existential challenge. We in the construction and asbestos-removal sectors have been luckier than some, with much of our work allowed for most of the year, but still these have been difficult times.
So far, so obvious, but for the rest of this post I want to focus as much as possible on the positives from this year – the new tools and solutions that have helped us carry on at the pandemic’s peak, and which will continue to make business better as we emerge.
A lucky break with tradition
In April we marked a year since the Health and Safety Executive (HSE)’s introduction of the new digital service for asbestos-removal licensing. Fraught with challenges – and, for a short time, horror stories – the long overdue overhaul had a difficult few months, but in retrospect it got here just in time.
By the time the pandemic hit, the HSE had ironed most of the creases out of its new system. The industry, too, had a better understanding of what the HSE expected – helped in part by innovations such as Assure360’s custom licensing module.
As inspectors were grounded under lockdown conditions, the move to digital assessments began to seem uncannily well-timed. Asbestos-removal contractors could renew their licenses and continue working, where otherwise they might have been dependent on inspector visits that couldn’t happen.
A new way to work
If 2020 is remembered for anything other than Covid, it will be as the year that accelerated digital transformation. Global businesses were already on the path, digitising existing processes and inventing new ways to work, but few smaller firms had been caught up in the wave. Covid changed that at a stroke – forcing even the smallest firms to embrace Zoom, cloud-working, and countless other digital tools.
For the asbestos removal industry, it’s a big change. We’ve been around for a while, and our highly regulated industry previously depended on meticulous paperwork. Assure360 has been selling the technology to change that for some years, but 2020 has seen a dramatic growth in interest, as more firms sought out ways to support socially-distanced working.
This is particularly true for Assure360 Paperless. Our digital supervisor support tool removes the site paperwork from asbestos projects. In itself, this cuts the amount of materials being passed around between workers, but during the pandemic another benefit grew in significance.
By automatically synchronising site data with our cloud-based system, Assure360 presents managers with reports and analysis based on the freshest data from the project. Many users have relied on this to reduce their visits to site, confident that Assure360 is providing the insight they need to manage jobs remotely.
Zoom spreads
As the year drew on, people began to use these new digital tools more extensively. In the asbestos industry, briefings and supervisor meetings started to happen over Zoom. In the wider world, recruitment and induction was increasingly carried out remotely – some people are still working from home in new jobs where they’re yet to meet their colleagues!
And as it became obvious that the usual round of conferences and seminars wouldn’t happen, organisations began to think about how they could deliver essential events virtually. ACAD switched its regional meetings to a virtual platform, for example, while we provided a webinar on Covid-safe working.
While the biggest events like the Hazardous Materials Expo have had to be cancelled altogether, academic conferences like BOHS and FAAM were able to go ahead online – to great effect.
As businesses, event and training providers all get greater experience with digital tools, it’s likely we’ll all continue to do things in new ways as the pandemic begins to recede. For example, several of our Paperless customers are planning to continue remote management, with fewer site visits. As Phil Neville of Asbestech pointed out, aside from helping greatly through the pandemic, our paperless technology has helped him reduce vehicle mileage in line with the firm’s ISO 14001 undertakings.
For events, digital access could help more delegates ‘attend’ even far-flung conferences. Next year’s iMig2021 – originally due to be held in Brisbane this year, then postponed to next March – will now take place virtually in May. While it’s a shame for people who would have made it to Australia, the pivot to a virtual setting means that far more people can now take part.
For many, 2020 has been a miserable year, and it may be a few months yet before things get better. 2021 begins with the end of the Brexit transition period and whatever fallout that brings, and it may be some months before the vaccination programme really bears fruit.
In the meantime, paperless and remote technology continues to help us navigate the pandemic, and promises to improve efficiency and create new possibilities in the future. After a difficult year, that’s a welcome source of hope as we go into 2021.
Written by Nick Garland on Wednesday November 11th 2020
If it wasn’t clear already, the arrival of second lockdowns in England, Wales, and several European countries confirm that this crisis will be here a while longer yet. Despite promising news from various vaccine trials – most notably the Pfizer/BioNTech candidate – mass vaccination programmes seem unlikely before Q2 next year. In the meantime the world needs to do its best to control the virus without disastrous damage to the economy.
What the UK government is trying to achieve with the second English lockdown is almost insanely difficult. The public needs to be fearful enough of the disease that it takes control measures seriously, optimistic enough that it can see light at the end of the tunnel, and yet still go out to work so that the economy does not grind to another halt. This despite a cycle of lockdown and release that’s likely to continue until late spring next year.
Processing what we need to do to come out the other side is going to be crucial. Construction and manufacturing have been targeted as protected parts of the economy, and the messaging is clear: keep safe, but keep going.
I’ve already written a couple of articles focusing on how to tackle the challenging working environment that Covid presents. Here I’m going to briefly revisit this and look at the latest advice. But it’s also important we acknowledge that changes such as increased remote working are going to be here to stay. I want to look at why embracing them, and making them part of a future strategy, is important to business success post-Covid.
For all contractors, the first place to start is with the most recent version of the Construction Leadership Council (CLC)’s safe operating procedures (SOPs). At the time of writing these were up to version six, dated 20 October.
The SOPs have an excellent section structured according to the hierarchy of control, which succeeds in being both detailed and clear. However, the key points from this version are:
The challenges that these guidelines present will of course vary depending on the site. Space is crucial. In smaller, enclosed sites with limited access, maintaining a safe separation is likely to prove challenging. On large sites with big workforces, there may need to be staggered start/finish times – and careful management of queues entering the site or core facilities like the canteen.
Other issues will tax everyone – for example, the difficulty of simply getting staff to the site in shared vehicles. The government’s guidance remains much the same: increased washing and cleaning, barriers, bubbled teams and short journey times. However there’s a key difference in lockdown two: public transport isn’t yet being reserved for key workers. If you must use it, cover your face.
When it comes to face coverings, we’ve certainly moved on from when I last wrote. At that time, Royal Society president Venki Ramakrishnan was calling for face coverings to be part of standard procedures. Now the CLC agrees – up to a point. While the SOP clearly states that we should not be recommending additional PPE due to Covid, it does specify face coverings in certain confined situations.
My view – and it is certainly something I have practiced since April – is that we should be wearing face coverings when we can’t guarantee social distancing. On busier sites, and particularly indoor projects, that has been most of the time.
What hasn’t been discussed much is the problem of wearing face coverings with glasses, whether that is readers, safety, or – as in my case – both. Anyone who has the problem of fogging is balancing the risks of impaired vision against the protection of their fellow workers. For what it’s worth, the only face masks I have found that fit close enough to reduce fogging are the ones with the metal strip on the bridge of the nose.
Whatever face covering you wear, you should absolutely avoid dust masks with a valve. Remember that we’re wearing face coverings not to protect ourselves, but to disrupt our breath out – and therefore protect others. Valved masks keep glasses clear because they let our breath escape unimpeded. For similar reasons, face shields offer little other than immediate protection if someone coughs on us.
The most difficult, draconian measures will be gone with the pandemic. But I wanted to stress the importance of stepping back and looking at positive changes that will continue to reap benefits beyond it. Companies who have been forced to find ways to reduce site traffic and enable remote working are finding new efficiencies that will support a stronger recovery when the pandemic is over.
Let’s not kid ourselves – there’s no substitute for boots on the ground when it comes to construction work – but the technologies businesses put in place now will have a longer-term benefit than ‘just’ minimising the risks from Covid.
We know that remote workplace technologies reduce the risk to managers and supervisors, and lower the chances that they spread the virus to or from their colleagues. Yet at the same time they introduce new and lasting efficiencies. Video calls reduce the need to travel, saving on expenses and letting managers use their time more effectively. Video briefings and inductions help reduce face-to-face contact, but they can also be more flexible and convenient. We all recognise the difficulties caused by having to shut projects down for an afternoon just to get the whole team together, now this can just be an hour at the end of the shift where everyone logs in to a call.
We see the same benefits from removing the paperwork involved in asbestos management and health and safety auditing. During Covid, the Assure360 Paperless app has helped customers reduce the amount of paperwork and other material going on and off site, and improved visibility for managers as they seek to maintain quality while minimising site visits. In the words of GreenAir Environmental director Graham Patterson: “If it wasn’t for Assure360 I think we’d have a major issue with having paper method statements, everybody touching it, and the virus sitting on that surface which you can’t wipe down.”
However, the benefits to streamlining critical safety checks predate the pandemic, and will continue after it’s gone. Customers who have adopted Paperless and other Assure360 solutions as a way to improve their ability to manage jobs in a socially-distanced environment have already discovered the big efficiency improvements we can deliver in normal times. “The Assure360 system has streamlined the company massively,” adds Graham Patterson. “And if we were to go back to the old paper systems I think we would struggle.”
The second wave of lockdowns remind us that we’re not done with Covid yet. We’re continuing to improve our products to provide essential support now, and more worthwhile benefits in the long term. After redesigning Paperless to make it even easier to use and even more of a time-saver, we’re working on an update to Assure360 Incident – our accident and near-miss reporting app.
The same principles apply as with all Assure360 products: an effortless user interface, letting even non-technical users improve and streamline essential health and safety record keeping. And with this update, Incident will also become the second Assure360 app to gain Android support, reducing the cost of entry to the Assure360 system.
Now more than ever it’s imperative to cut paperwork and supervision overheads, while simultaneously ensuring greater compliance. And when things are better, the efficiencies your business discovers today will continue to deliver benefits and competitive advantages as the economy recovers. I think we should all see this as evidence that the light at the end of the tunnel is actually a brighter future.
Written by Nick Garland on Wednesday November 11th 2020
With Covid still here and big events like the Hazardous Materials Expo already postponed – again – this year’s conference season promises to be very different. Happily, some events are still going ahead, albeit virtually.
On 18-19 November the British Occupational Hygiene Society (BOHS) and the Faculty of Asbestos Assessment and Management (FAAM) are presenting what will be my first ever virtual conference. While I’m not sure what to expect, I am indeed looking forward to it.
The conference programme kickstarts with a review of the asbestos control limit: the limit for asbestos concentration beyond which legally imposed controls become necessary. Sam Lord of the Health and Safety Executive (HSE), and Rick Pomeroy of ABP Associates, will be talking about the history and challenges of air testing during works. I’m curious to know whether they’ll expand the conversation to take a broader look at licensed contracting and testing against the contractor’s own internal procedures – often much more stringent than the old control limit.
After the break on day one it’s the turn of Garry Burdett, principal scientist at the Health and Safety Laboratory. He’ll be giving us the lowdown on the implications of work done by the European Chemical Agency and the USA’s Environmental Protection Agency. Are we set for a change in the control limit? Sam Lord takes the final slot before lunch to give us a progress report on the Analysts’ Guide. Astonishingly my white paper on the draft is still relevant, several years on.
After lunch I’m keenly looking forward to what most people might see as a minor part of the sessions. When we became aware last year about asbestos identified in some marble, my concern was not so much ‘is that kitchen worktop hazardous’, as whether the worker cutting the slab to size was adequately protected. We haven’t heard much on that yet – hopefully we will on 18 November.
In the morning of the second day the programme will cover some interesting developments in duty holder training, along with the HSE’s view on where we are failing in this area. The final afternoon is taken up by technology and myth busting sessions – always a great way to end a conference!
If you have not signed up, I urge you to do so. In a year where so much of the usual industry networking and discussion has been blocked by the need to maintain social distancing, the FAAM conference takes on even greater significance than usual. And as with so many long overdue catch ups – while we can’t be there in person, doing so virtually is the next best thing.
Written by Nick Garland on Thursday October 15th 2020
Back at the start of July the Health and Safety Executive (HSE) released its annual accident statistics, covering 2019 / 2020. Among these, as always, are figures detailing the worst case situation – people who die while at work.
The headline figure is encouraging. Over the period, 111 workers were killed – a significant decrease on previous years. Over the previous period 149 workers had lost their lives, and the average over the past five years was 137.
While this is clearly good news, the figures have – like so much else – been affected by the Covid-19 pandemic. Economic activity dipped in February and March – alarmingly in many sectors – so some reduction in injuries was to be expected. Those of you who work on construction sites will know they were eerily quiet at the end of Q1, only recovering near to full speed toward the end of the lockdown.
Our own Assure360 figures back up that impression, with a drop on year-on-year audits. In the past 12 months, 1,790 audits have been completed, whereas in the previous 12 months it was 2,048. That’s a 13% drop, against a background of rising subscriber numbers through the year, with most of the reduced activity seen between March and June. Thankfully we are now back to more normal rates, indicating that at least with Assure360 users, we are seeing some recovery.
How dangerous is construction?
If we go back to the HSE figures, we can drill down a bit to get more detail on how this year compares to last:
| Sector | Fatalities 19/20 | Fatalities 18/19 | 5yr average (19/20) |
|---|---|---|---|
| Construction | 40 | 30 | 37 |
| Agriculture | 20 | 32 | 27 |
| Manufacturing | 15 | 26 | 20 |
| Transport | 11 | 16 | 14 |
| Wholesale and retail | 6 | 18 | 9 |
| Waste and recycling | 5 | 7 | 9 |
| Administration and support | 6 | 10 | 4 |
| Other | 8 | 10 | |
| Total | 111 | 149 |
As you can see, all sectors saw the drop that you might expect against a backdrop of reduced activity – with the exception of construction, which instead experienced a 33% rise in fatalities. The obvious question is, “Why?”
The HSE’s report points out that “in statistical terms, [the] numbers are small and subject to fluctuation”, but construction still looks like an outlier.
Superficially, things look more encouraging for the sector if you examine the fatality rates expressed per 100,000 workers. When viewed this way, we can see that agriculture and waste are significantly more hazardous industries. But again, construction is the only sector showing an increase.
| Sector | Fatalities per 100,000 (19/20) | Fatalities per 100,000 (18/19) |
|---|---|---|
| Agriculture | 5.96 | 9.21 |
| Waste and recycling | 4.57 | 6.05 |
| Construction | 1.74 | 1.31 |
| Transport | 0.69 | 1.00 |
| Manufacturing | 0.52 | 0.92 |
| Administration and support | 0.38 | 0.62 |
| Wholesale and retail | 0.10 | 0.31 |
The per-sector view makes it clear that the agriculture and waste industries face serious safety challenges. Construction is inherently hazardous, too, but effective legislation such as the Construction (Design and Management) Regulations 2015 (CDM 2015) ensures we have tightly controlled working procedures. Even so, that’s cold comfort when the normalised rates above confirm that the increase in fatalities isn’t down to an increase in workers. The hard truth is that we just failed to keep our people as safe as in previous years.
Look at the detail of the HSE figures and we see that working at height and related issues (for example, dropped objects) are by far the biggest killer – they make up 42% of all fatalities. While we can’t identify from the report how many of these deaths are in the construction and asbestos industries, height is clearly a hazard we encounter frequently.
Interestingly, there’s been a small increase over the 18/19 figures, where height-related incidents were a factor in 38% of fatalities. Perhaps this is an indicator of where we may be going wrong. Is the sector as a whole taking its eye off its most significant risk?
Again, we can shed further light on the HSE figures by examining our own. Assure360’s community-based approach to health and safety means that our users benefit from aggregated figures recorded across all auditing and near-miss reporting on our system.
Auditing and near-miss reporting have always been the traditional methods we use to identify and mitigate safety issues. So what does our data tell us about height-related non-conformance?
| Question Text | 18-19 | 19-20 | % Difference |
|---|---|---|---|
| RA (Height) | 27 | 8 | -70% |
| Tied (scaffold) | 23 | 13 | -43% |
| Double hand rails (scaffold) | 22 | 8 | -64% |
| Scaffold (Fans) | 18 | 6 | -67% |
| Safe access between lifts | 16 | 11 | -31% |
| Inspection (Scaffold) | 13 | 8 | -38% |
| Scaffold (Design) | 13 | 14 | 8% |
| Scaffold (Gates/hatches) | 12 | 4 | -67% |
| Ladders / Hop Ups (Suitable) | 9 | 3 | -67% |
| Scaffold (Boards) | 8 | 12 | 50% |
| Scaffold (Matches Design) | 7 | 6 | -14% |
| Scaffold changed by site team | 5 | 4 | -20% |
| Inspected (ladder & podium) | 4 | 2 | -50% |
| Scaffold (Condition) | 4 | 5 | 25% |
| Double hand rails (tower) | 3 | 2 | -33% |
| Ladders in use (where podiums could be) | 3 | 2 | -33% |
| Ledger Bracing | 2 | 0 | -100% |
| Inspection (Tower) | 2 | 2 | 0% |
| Ladder & Podium (condition) | 1 | 0 | -100% |
| Lifting Plan (method) | 1 | 0 | -100% |
| Training (Height) | 1 | 0 | -100% |
| Trip Hazards (scaffold) | 1 | 0 | -100% |
| Work at Height (rescue plan) | 1 | 0 | -100% |
| Tower (condition) | 0 | 1 | 100% |
| Unprotected openings (scaffold) | 0 | 1 | 100% |
| Total | 196 | 112 | -43% |
| AUDITS | 2048 | 1790 | -13% |
In fact, it reveals that observed height related nonconformances among our users have gone down dramatically, from 196 to 112 in year-on-year comparison. That’s a 43% drop in observed issues, whereas (as we covered earlier) the number of audits fell by only 13% during the same period.
That means one of two things. Either Assure360’s users are bucking the apparent trend in the industry, and fewer height-related issues are there to be seen. Of course, that would be great, but the figures could instead show that – perhaps like the wider industry – we’re not looking hard enough at this area.
This is the age-old problem of auditing: no matter how good you are, there’s always the chance of blind spots. As the circumstances behind some of the annual fatalities would doubtless reveal, being ignorant of this can be catastrophic. All the more reason to ensure you include external, independent audits in the mix, to help you challenge systemic bias or shortcomings in your processes.
Historically the UK has been the best in the world at bringing people home safely from work. This is absolutely an achievement to be proud of, but these figures remind us that safety is something we must all work at. Especially in high-risk industries, we can never be complacent. As health and safety professionals we should be redoubling our efforts to give workers the protection they deserve.
And if you can, it’s best to learn from other people’s lessons as well as your own. One advantage that Assure360 can offer its users is that they don’t have to wait for annual HSE reports to see what is happening in the industry – our shared benchmarked data is available 24/7.
Written by Nick Garland on Thursday October 15th 2020
The last six months or so have been, to put it mildly, challenging. Since Covid-19 first gained a foothold in the UK, the restrictions on businesses and individuals have had a huge impact on the economy. At the same time, the toll on public health has been staggering. As the UK braces itself for ‘Covid winter’, many face an uncertain outlook.
Against this backdrop, there are of course positive stories – there have been boom times for home improvement, furnishings and supermarkets. The construction industry hasn’t been quite so lucky, but it’s not the worst hit. Work continues – and for many asbestos workers, existing stocks and experience with PPE meant that it never stopped.
The pandemic is by no means over of course, and at Assure360 we’re determined to help our customers ride it out as safely and successfully as possible. I wanted to take a moment to talk about the things we’ve been doing to try and help. And, as we prepare for more disruption across the winter, flag up a couple of other things we’ve got in the pipeline.
Improved apps
The first and most important thing we’ve done is to offer a free upgrade to our Platinum subscription level to those who aren’t already on it. Platinum includes the Assure360 Paperless app, designed from the outset to replace a supervisor’s site paperwork with the electronic recording of safety checks and information.
In normal times one of Paperless’ main benefits is a big uplift in supervisor and back office efficiency, but during the pandemic the app’s role in cutting site traffic has become even more important.
Electronic record-keeping reduces the paperwork that has to go back and forth, and provides management with an up-to-date, remote view of any developing issues, helping them manage more effectively with less time on site. As Graham Patterson, director of GreenAir Environmental put it: “Assure360 [Paperless] itself has streamlined the company massively, but it’s helped greatly under the lockdown.”
At the same time we released a new, improved version of Paperless, which now supports Android devices as well as iPads. The most significant change is a completely reimagined Site Diary feature, designed to minimise the amount of text entry by supervisors. Now almost every imaginable entry is covered by drop down menus, and evidenced by photos when needed.
We’ve also updated our system to reflect the changed circumstances we’re all working in. For example, we’ve added Covid-specific audit questions.
More help and advice
We’ve always prided ourselves on the help we offer our customers, both when initially setting them up on the system, and with the day-to-day questions and issues that arise. During the pandemic we’ve been very aware of the difficulty of travel, and the need to cut down on face-to-face meetings, so we’ve been working especially hard to improve our support for those new to the system.
We’ve improved and added to the Assure360 Help Centre, creating more “How to…” videos to support the quick and easy rollout of Assure360 to your team. For customers adopting Paperless as part of their response to the pandemic, these have become a central part of inducting staff.
“One of the things that was a Godsend were the videos on how to use Paperless,” explains Phil Neville of Asbestech. “There’s one for supervisors – like a 10-minute long video – on how to use the tablet on site. It’s very instructional. It runs through from logging on to the system to closing a project down, very succinctly.
“We used that video as the core of our induction because we weren’t able to bring supervisors in and do face-to-face training – because we were avoiding unnecessary personal meetings.”
Phil Neville also explains how the Android tablets bought for Paperless became essential to Asbestech’s ability to support remote working. “We had Zoom put on all the tablets so that we can have training sessions and screen sharing with the supervisors remotely. Alongside Paperless, we added virtual meetings to our toolbox.”
This ability of Android and iPad tablets to support more than just Paperless helps customers increase the return on investment from adopting the Assure360 solution. In addition to the multiple benefits of Paperless itself, the tablets support other ways to work safely and remotely during challenging times. If we assume the average licensed asbestos removal contractor (LARC) has a site team of 10, then the average saving per year is in the region of £10,000 – even when you factor in the costs of Assure360. Even a micro LARC with just one supervisor would save money overall.
Doing more
Despite this, we’re aware that some firms are still struggling to get back on track after a summer of disruption to essential paperwork and administrative tasks. Particularly, there are concerns for some businesses as they approach licence renewal, with paper site records yet to be processed, and vital evidence not available for easy entry on the HSE’s online form.
We’re doing everything we can to help new customers – and those upgrading to Paperless – get their existing data onto our system so it’s available to support licence applications and the proper management of their work. And we’re continuing the free three-month upgrade to the Platinum subscription level for those who aren’t yet on it.
We’re also working on new and improved versions of both the Assure 360 Audit health and safety auditing app, and the Assure360 Incident near-miss reporting app. Like Paperless, the updated versions will be available on Android for the first time, meaning we’ll support a far wider range of devices. And as Android tablets are generally cheaper than iPads, the cost of entry to Assure360 will fall further.
These are difficult times, and we’re not out of the woods yet. We’re working hard to support our industry and communities, but if there’s any way we can help you more, do please get in touch and let us know.
Written by Nick Garland on Thursday September 10th 2020
In its 2018 report on the asbestos analysts inspection programme, the Health and Safety Executive (HSE) found that the practice of personal sampling was very poor. Tests were predominantly run for only 10-30 minutes and included very limited information on what the operative was doing at the time. Together this leads to such small sample sizes that the reported results are alarmingly high, yet it provides no information to understand what led to ‘hugh’ reading. In short, it’s near useless.
In contrast, the HSE judged background monitoring to be good. It found accurate counting of fibres, plus floor plans and contextual information that illustrated clearly what was going on.
But here’s the issue: the skill set for both of these areas is fundamentally identical, and yet one was found to be very poor and the other excellent It seems to me that the problem is one of ignorance about what the tests are for. Background tests are broadly understood, but personal monitoring much less so.
To get more useful results, we need licensed asbestos removal contractors (LARCs) to focus on why they need to do the test. Despite what many will tell you, they’re not doing it to check that the exposure is below the control limit. In fact they’re attempting to measure how successful their own control measures have been, and use this to drive improvements.
For this to be effective we need as low a limit of quantification (LoQ) as possible. And to achieve this we must have high flow rates, longer durations, and the full 200 graticules read.
Assure360 and its member companies are taking this principle to heart, but we’re also using data to add to a collective, community-based approach. By analysing data shared among the group, we help each other drive improvements. Assure360 members have been recording, analysing and sharing personal monitoring data since 2014. And at the time of writing, 17,818 tests have been processed through the system.
The HSE Science Division (previously HSL) has been conducting further research into improving the quality of sampling results in its Asbestos Exposure Project. The study is examining the life-cycle of asbestos removal projects. It includes working methods, types of masks and air monitoring during the work – and clearance testing at the end.
The research not only shadows the air test results of on-site analysts with electron microscopy, but uses biological monitoring of the removal operatives. The latter involves sputum and breath condensate. In-mask samplers have also been used to determine levels inside the RPE – i.e. asbestos that has bypassed the filter completely. The aim of the study was to establish how effective protective methods are, and whether any changes are required to the guidance.
In the course of the work, the HSE became aware of our vast library of personal monitoring data. Following a request by lead researcher Daniel Barrowcliffe, our member companies asked for it to be shared not just with the research project, but with the wider community. Accordingly I’m delighted to attach two appendices providing the anonymised data from our community.
Appendix 2 – All Personal Monitoring Data
I’m proud that we’re in a position to help with such an important, and potentially lifesaving bit of research, and I’m particularly grateful to our customers for their willingness to share this data. In particular I’d like to thank Asbestech, Asbestos Essentials, Gwella, Hendersons, Horizon and Sperion for their help with the project.
By sharing our data, I hope we can help drive a greater understanding of the risks faced by asbestos-removal contractors. And, returning to my initial point, I hope we can help push more LARCs to focus on more thorough personal tests. Ideally, we’ll contribute to a change of focus that sees personals not as a box-ticking exercise, but as an opportunity to reduce exposure and risk for those on the front line of dealing with asbestos.
Written by Nick Garland on Thursday September 10th 2020
Nick Garland is the CEO of Assure360. He has 25+ years of experience in the industry. He tells the story of where the vision for Assure360 came from, the hurdles along the way, and what’s coming next.
It was effectively a happy accident.
I was an embedded H&S Manager for several licensed removal companies. I was designing and participating in audit schemes, completing training needs analysis and competence systems, undertaking the analysis of exposure results… again and again. The Assure360 system already existed, but as a series of interconnected Excel spreadsheets. I was repeating the same tasks over and over again which was incredibly time-consuming and prone to error.
In the space of a month or two I met an app designer (Matt Glover, who still works on the project) and a database company that I was reviewing for the Royal Mail. The penny dropped – what I needed was an app to record the data quickly, and a database to do the clever legwork.
I have been working in the asbestos industry since 1992, at first as an analyst. In 1999 I retrained into health and safety (H&S). This was initially just an extra string to my bow, but I quickly realised the obvious – asbestos removal was just a construction project with a complex and highly regulated hazard attached. In 2004 I made the switch that most consultants never do, and started advising licensed asbestos contractors on H&S. It was this that really completed my education. Without direct experience of both sides of the industry we professionals can be very blinkered.
Working in the licensed sector – and for several different companies simultaneously – has given me a deep understanding of how the HSE thinks and what it requires. In recent years I’ve been able to strengthen this through close contacts with senior HSE figures: their insight was instrumental as we helped customers through the licence renewal overhaul in 2019.
Smaller removal contractors – especially ones that go to the expense of hiring a H&S manager – also taught me something else that makes all the difference. They recognise that looking after their people and, that precious licence, is of critical importance. They don’t want to pay for advice couched in clever terms or so caveated that it is opaque. They want clear advice that represents your opinion – even if that is a hard truth.
The solution has evolved to add additional functionality. Our system now helps tick off all of the tasks that the HSE demands, but which are very difficult to achieve and remain commercially competitive.
We started with competence and training needs which ordinarily would be a massive additional task to add to an already busy team. By making the audit smarter we created a tool that could do this task for you at no extra effort.
Recording exposure testing was next. This always seemed a fruitless task that only kept the HSE happy to no practical use. The Assure360 database changed that, so that every test and daily exposure became an audit of the removal method – driving improvements.
Recording and analysing near misses and incidents is critical to avoiding serious accidents in the workplace. Next we developed Assure360 Incident, our reporting app, to provide insight into safety performance and trends. Crucially, it helps identify the process, equipment or training gaps that could be putting people at risk.
We’ve recently redesigned Assure360 Paperless, the latest addition to our suite of apps. Since its original launch, the app has been streamlining the record-keeping process, allowing supervisors to focus on actually supervising. Meanwhile, the office can process and review checks as they’re made – instead of having to wait for the site paperwork to come back.
In the new version we’ve made the process even easier, reimagining the Site Diary feature to use drop down entries and photos – a far quicker way of recording the day’s significant events. We also added Android support, lowering the cost of entry to the Assure360 solution and opening it up to more users.
Paperless has been the biggest challenge, without a doubt. We had to solve seemingly insurmountable twin requirements. We needed offline data capture, meaning that it was not susceptible to the vagaries of poor signal. We also had to work out what happens if the iPad was lost or damaged – we had to make sure customers wouldn’t lose all their paperwork.
We cracked both challenges by using data – rather than forms – so we only ever deal with tiny snippets, rather than whole files. The information stays on the iPad, but the app chirps updates back to the cloud whenever it has a little signal.
Of course, more recently everybody has faced a huge challenge in the shape of the Covid-19 pandemic, and the construction and asbestos-removal industries certainly haven’t been immune. We knew that Paperless was the ideal product to help reduce site visits and the need to handle paperwork, so from early on in the crisis we offered our customers free access. We’ve now formalised this into a free three-month trial.
As well as offering ‘wipe-clean paperwork’, we’ve introduced Covid-19 specific audit questions into the system. And throughout we’ve been publishing regular updates on safe working on our website and in the newsletter.
The birth of Assure360 was, in a way, a lucky happenstance. The need was always there, but meeting both the app developer and the cloud database designer in short order led to a lightbulb moment.
We continue to add to our series of How To videos, which have been warmly received by clients. Many are using them as the core of their training on the system (although we can offer tailored support). We haven’t stopped at updating the Paperless app – we’ll be refreshing Audit and Incident, and will add Android support for both. The People and Plant sections of the system will also develop into full modules designed to help Admin and Stores.
It’s important. As the HSE’s Dr Martin Gibson has put it: “Britain was the first to have an industrial revolution. We were the first to start importing asbestos, and we have imported the most asbestos. In fact – we imported 40% of the world’s capacity to produce amosite* in the 50s, 60s and 70s. We have so much asbestos that we have to manage the problem.”
* amosite is the most common of the highly dangerous amphibole (needle-like) forms of asbestos
Written by Nick Garland on Thursday September 10th 2020
The Health and Safety Executive (HSE) guidance on blasting techniques was released a few years ago by the Asbestos Liaison Group (now the Asbestos Leadership Council) as appendices to meeting minutes. This approach was a handy way of releasing the guidance without all of the pesky red tape that normally plagues official documents. Alas, even this route has now closed – evidenced by the fact that the last one was well over a year ago.
I wrote about the guidance at the time. Technology has changed over the last few years, but the original document started with the recognition that blasting may be required in a few rare circumstances. It also emphasised that the process should only be considered as a last resort, and that it shouldn’t be regarded as a go-to solution.
The guidance also insisted that the use of processes like Quill, Torbo or ice (above other more traditional approaches) must be fully justified by the licensed contractor, with evidence in support. What this translates to is that the method must not merely address and mitigate the significant additional hazards, but that the reasons for introducing them in the first place must be declared and justified.
It’s important to consider those additional hazards, which typically include:
At the time there was also a concern about potential high vibration at the lance end. This concern however seems to have been unfounded, or at least it has been mitigated by newer devices. A recent HSE case study has found no significant vibration exposure from the technique.
Regardless, other concerns remain: in particular the potential for very high exposure, and the inability to effectively conduct personal monitoring or supervise the works. So why would anyone still consider blasting?
Clients and analytical consultants are normally the main driver when it comes to blasting, often due to an eagerness for ‘an asbestos-free building’. It would therefore be wise to involve them more fully in the decision making process, and explore whether their reasons for wanting to be asbestos-free outweigh the added hazards from blasting.
Ultimately, the guidance says that blasting should be justified, and that robust processes should be in place to ‘prevent misuse’. Or to put it another way, there should be a review of the justification, and it should be signed off by senior management. The technique must also be declared on the ASB5.
On a more practical level, the amount of waste the technique generates is quite astounding. The contaminated grit is heavy and requires frequent clean up. In addition, the grit itself can impact into the surface you have cleaned – requiring extensive fine cleaning. If you are not very careful, the grit can be blasted beyond the boundaries of the enclosure – spreading the problem by contaminating hard-to-access voids.
Blasting clearly presents contractors with additional challenges that make it anything but a silver bullet, and the tightening guidance has generally made it less suitable, more of the time. However, since I last wrote on the subject, new equipment that has become available that could offer a potential lifeline.
For example, Beacon’s smart recirculating NPU is an astonishing piece of kit that allows for prodigious number of air changes – vastly more than the traditional approach. Graham Warren of ACAD wrote a very good summary of how the system works, and how it can improve working conditions in the enclosure.
From the perspective of blasting in particular, the really clever bit is that the Beacon’s NPU combines recirculation and an inline heater. This means that the air inside the enclosure can be kept above the dew point – preventing condensation and drastically reducing the visibility issues and the barrier to personal monitoring.
But while the vibration issues of blasting are less of a concern, and visibility and air testing are much improved, there still remain many issues. If you’re still considering the technique for a project, you should refer to the list of additional controls suggested in the original guidance – I discussed these in my earlier article.
Still, as any H&S professional will tell you, the first thing you should consider is elimination. And in this case, technology improvements among needle guns may make it easier to eliminate blasting as an option.
While blasting requires a huge trailer, needle guns – such as the Trelawny VL303 Needle Scaler, with an electric compressor and dust cowl – are much more portable and convenient. Trelawney’s solution is low vibration, allowing for more than eight hours’ trigger time, and the H-type vacuum attachment ensures that the dust and waste generation is minimal.
So could improved needle guns finally end the need for blasting? Both techniques are slow going, but I’ve spent time talking to supervisors proficient in both, and needle gunning seems to win. I’m sure there may still be times when blasting is the only workable approach, but as the alternatives improve, the justifications for blasting will have to be stronger and stronger to pass muster.
Written by Nick Garland on Tuesday August 11th 2020
Confined spaces and asbestos removal often go hand in hand, yet the lack of understanding about risks and controls could be putting people in danger.
As I discussed in an article last year, the Health and Safety Executive (HSE)’s confined space rules changed back in 2014. The changes were subtle, though. The minimal fanfare around them has meant that – even six years on – those that commission projects and their appointed consultants still miss much of the point. But the fact that licensed asbestos-removal contactors (LARCs) are unwilling or unable to correct the misguided instructions they’re getting has the potential to make dangerous situations worse.
To recap briefly, there are two triggers that together will make a work area a ‘confined space’. The first is whether access to the area is substantially confined, with ladders, ducts, and ‘enclosures for the purpose of asbestos removal’ specifically listed. The second is whether one or more of five proscribed hazards – fire, heat, gas, or free-flowing solids or liquids – are present. In essence, if the access arrangements restrict people’s ability to get in or out of the workspace, and there is a risk of sudden death, then the confined space regulations apply.
What’s The Hazard?
It seems simple, but the nature of the hazard is absolutely critical to determining what the correct controls should be. The proscribed hazards are for the most part quite different in the risks they pose:
It only takes a moment’s thought to realise that the controls to mitigate risk from explosion, say, are entirely different to those required for drowning, poisonous gas or elevated temperatures. In fact, the controls required for any single hazard could actually make other risks more serious. Despite this, what LARCs often see is an insistence from their clients on implementing the stock controls for poisonous gasses – regardless of the situation.
This problem is particularly serious if we consider ‘increased body temperature’. Elevated body temperature can cause loss of coordination and serious health risks, and untreated can quickly become a major risk to life.
In warm weather, many typical asbestos enclosures – in roofs, for example – are going to become confined spaces by risk of heat. But when contractors realise that an area is a confined space, the common response is to require equipment such as an escape kit. Not only will an escape kit do nothing to help, but the extra bulk might make matters worse. And the outcome could be catastrophic.
Read more on safe working at high temperatures.
So how do you avoid catastrophe? Firstly, whether you’re the client, principal designer, principal contractor or a subcontractor, you must be aware that all asbestos enclosures satisfy the first trigger for the confined spaces regulations.
Secondly, and most important, as soon as you confirm that a second trigger is present, you must understand in detail what the hazard is. If you can’t eliminate it, you need to implement controls specifically to deal with that hazard.
The threats that trigger a confined space are different in their nature, and there is no one-enclosure-fits-all approach to properly managing them. The consequences of applying inappropriate controls could be as bad as – or worse than – not managing the risk at all. And if you’re imposing the wrong controls on a subcontractor out of ignorance you could be liable for the consequences.
Written by Nick Garland on Tuesday August 11th 2020
Established in 1983, Asbestech has grown to become one of the leading asbestos and hazard-removal businesses in the UK. With a nationwide presence, supported by five regional offices, Asbestech delivers the highest quality solutions for major clients in the public and private sectors. Originally focused only on asbestos removal, today Asbestech has extensive hazard-abatement expertise spanning specialisations including lead paint and ventilation cleaning. In addition, the company has expertise in reinstatement work to replace hazardous materials with modern alternatives.
Already an Assure360 customer, Asbestech was using the system to reinforce and extend its culture of safety, quality and performance. In particular, Assure360 had helped the company dramatically improve the way it audits and analyses its performance on site. However, despite enjoying increased efficiency, and having gained a more dynamic view of where to focus investments in process, training and support, operations director Phil Neville was keen to target further improvements.
In particular, Neville was aware that the Assure360 Paperless app might offer significant productivity gains, by reducing the on site paperwork burden for Asbestech’s supervisors. However, for various operational reasons – the company had yet to move forward with the upgrade.
Things changed at the peak of the Covid-19 lockdown. As Neville successfully renewed the company’s asbestos-removal licence, he realised how much adopting Paperless would have helped with the questions asked by the Health and Safety Executive (HSE). At the same time, Assure360 was working on a revised Paperless app which would support Asbestech’s existing Android mobile device infrastructure, and the company became part of the beta testing programme.
Asbestech used the momentum of the lockdown to implement improvements to the way it manages jobs on site. In addition to investing in updated Android tablets and the Assure360 Paperless upgrade, the company installed remote working tools including Zoom. Doing so immediately helped increase face-to-face contact with teams using the new virtual tools, and reduced the need for staff and paperwork to travel between office and site locations.
In addition, the switch to Paperless allowed Asbestech to improve and streamline its processes on site. With supervisors no longer needing to make and manage paper records, more time was available to supervise asbestos-removal work. With data regularly synchronised to the cloud, rather than languishing in folders in the site office, contract managers gained a real-time view of supervisors’ checks, helping identify and correct any issues as they developed.
“We used a paper-based system before. We’d do our checks then we’d have to go and finish our paperwork – it was very time consuming that way. Even so, I was a bit sceptical about using a paperless system at first. I’m not the most computer-literate person in the world.
“The new system is better. Obviously it takes a few days to get used to the app – but once you do it’s quicker. It’s exactly the same checks you’d be doing with a paper system, but you haven’t got the folder. You haven’t got the paper there – it’s just done on a small screen. It’s made my job easier.”
“Paperless is a more efficient way of doing the paperwork on site. It means nothing gets mislaid or has a cup of coffee spilt over it, and you can always read it because there’s no poor handwriting to contend with. It’s very efficient.
“It wasn’t easy making changes during lockdown, but what prompted me to roll out Paperless in the middle of the pandemic was that I could see how much it would help our site teams, and also with the questions that the HSE were asking as part of our licence renewal.
“Removing the paperwork has really helped us. Now supervisors don’t need to bring reams of paperwork back to the office, which is good because that’s one vector through which the coronavirus might otherwise spread. It’s also good in terms of eliminating unnecessary travel, helping us meet the environmental commitments of our ISO 14001 certification.
“The other way in which it is a real godsend for us is that my contract managers get the information everyday, whereas before they were talking to the sites, but they wouldn’t see paperwork until they did a site visit or it came to the end of a project. Now we can see every day what paperwork’s been done – and quality check it. If one of the supervisors needs a bit of coaching on filling out his site diary effectively, we can jump on it straight away rather than wait until the end of the job.
“It has helped in other aspects of the business too. For example, we recently had a scheduled audit from the British Standards Institute as part of our ISO 45001 accreditation, and being able to run through the site info via the PC while screen sharing with the auditor made the process simple. The auditor commented that he thought the Paperless system was excellent, and that he wishes more of his clients he audits had it.”
Website: www.asbestech.com
twitter: @asbestech
Written by Nick Garland on Thursday July 23rd 2020
GreenAir Environmental is a Glasgow-based asbestos surveying and removal company. Founded in early 2016, the company has built its reputation on exemplary standards and competitive pricing, delivered through a partnership between experienced staff and cutting edge technology.
Today, GreenAir has grown into a leader in the asbestos industry, completing contracts of all sizes across the UK. Using technology from CCTV to drones, it prides itself on offering full transparency and accountability to clients and the Health and Safety Executive.
GreenAir’s director, Graham Patterson, has pursued a clear strategy to distinguish the company in the marketplace. By using the latest equipment and systems, GreenAir aims to offer not only higher standards of safety and cleanliness, but to operate with streamlined workflows and agile working methods.
Graham has focused on the application of technology to achieve greater transparency and better results, for example by equipping all enclosures with wifi enabled CCTV which allows for remote viewing. At the same time, he has designed record-keeping and collaborative working systems that reduce paperwork, and support scalable, flexible teams. By minimising his administrative overheads, and reducing the need for him to be on site, Graham’s business can work more efficiently and offer more competitive pricing.
GreenAir chose Assure360 as a central component in its technology-led approach. By exploiting its combination of app-based, granular data collection and a secure, cloud-based dashboard, Graham has been able to cut paper out of his business processes, and improve his vision of what happens on site.
Graham’s approach has proved a great success in normal times, but during the Covid-19 pandemic it became vital. Like many asbestos removal contractors, GreenAir’s protective equipment meant it could keep operating at the height of lockdown. Even so, restrictions on staff contact meant that the company had to devise new working methods that met or exceeded social distancing requirements outside the enclosure.
Assure360 proved fundamental to these efforts, supporting a completely paperless approach. “We wipe the iPad down and we can pass it to each other,” said Graham. “Having the iPad on site is transformative. We use date-stamped photographs to record attendance, and whether someone’s clean-shaven – our guys can take the photos from two metres away. We can pass the method statement round on the iPad, so everyone knows what they’re doing.”
This ability proved critical under lockdown, as partners and principle contractors queried multiple details in an effort to ensure safe working. “We got to the fourth revision of the method statement before we were allowed on one site,” Graham explained. “To be honest, not much had changed from the first revision, because they were trying to get us to implement things – such as face-fitting our masks – that we already do.”
“We wouldn’t normally mention face fitting in a method statement because it’s mandated by our licence,” he adds. “So we were having to add stuff that we wouldn’t normally put in, for their benefit rather than ours.”
“Assure360 itself has streamlined the company massively, but it’s helped greatly under the lockdown. If it wasn’t for Assure360 I think we’d have a major issue. The supervisor’s doing all his checks and enclosure inspections on Assure360, so again it’s all done at the click of a button. If work needs updated we can do it remotely and it’s updated on the system – we don’t need to print anything off.
“We’re lucky that, while we’ve never experienced anything like the Covid-19 pandemic before, the precautions that they’re asking us to take are something we do on a daily basis without actually thinking of it too much. But if we were to go back to the old paper systems for actually managing jobs I think we would struggle.”
Graham Patterson
Director
Written by Nick Garland on Thursday July 23rd 2020
With the UK past the peak of the Covid-19 pandemic, the focus has shifted towards kickstarting the economy. While we acknowledge that many in the asbestos and construction industries continued to work throughout lockdown, as sites ramp up fully again we all face new health and safety challenges to comply with social distancing requirements.
Assure360’s cloud-based solution provides companies with the platform through which to help manage a safe return to work. Offering a paper-free and secure way to audit and monitor site performance, it ensures that critical data can be communicated to site teams, and gathered for compliance and analysis, with less reliance on face-to-face meetings.
In particular, Assure360 Paperless ends the reliance on inefficient site paperwork when logging critical safety checks. It reduces the amount of potentially contaminated material travelling to and from site, and offers efficiencies which help offset the time lost to stricter controls in the workplace.
We want to help, which is why we’re offering a free-of-charge 3-month trial. We believe Paperless can provide important support in these difficult times, and we’re also inviting you to a free webinar to explain how.
A repeat of our popular Benefits of Paperless in a Social Distancing Climate webinar will be running via Zoom at 3pm on Monday September 14th. Places are free, but please book by following the link above.
During the webinar, Assure360 founder Nick Garland will share a detailed description of how our Paperless solution – part of the Platinum subscription – could help you increase your use of remote management, lower costs, and reduce the need for teams to come back to the office during these unprecedented times.
We believe that our solution can really help LARCs get through this, and we want to help. Please join us at the Benefits of Paperless in a Social Distancing Climate to find out more.
Written by Nick Garland on Thursday July 9th 2020
As the UK begins to lift its lockdown restrictions, the focus is shifting towards how we safely restart the economy. Work is resuming on construction and demolition sites across the country – and more trades are coming onto those where it never had to stop. But with the threat of the coronavirus very much remaining, it’s more important than ever to implement and enforce safe working practices.
As sites fill up, distancing, protection and welfare will be critical in ensuring the construction industry doesn’t become an incubator for a second wave of the pandemic. For this post, we spoke with two major contractors who have continued to work in the crisis, to try to understand what safe working looks like in the new normal.
For all contractors, the first place to start is with the Construction Leadership Council’s safe operating procedures (SOPs). The key points of the most recent version are:
The challenges that these guidelines present are, of course, going to vary depending on the site. Space is crucial – in smaller, enclosed sites with limited access, maintaining a safe separation is likely to prove far more challenging. Other issues will tax everyone – for example, the difficulty of simply getting staff to site in shared vehicles. Both of these are reflected in the calls by the Royal Society president Venki Ramakrishnan who said:
“Not wearing a mask should be considered as ‘anti-social’ as drink-driving.
“Face coverings are widely accepted as a means of reducing spread – protecting others in case you’re spreading the virus without symptoms, so I do believe that we are moving in that direction. This may sound strong now, but the move to more general use of face coverings is gaining momentum, so it may be prudent to start thinking how it could be incorporated into our standard procedures.”
There have been many calls for the government to be more prescriptive about what companies should do to get back to work, but health and safety law doesn’t – and can’t – really work like this. At its foundation is the recognition that legislation can’t address every risk or keep pace with the change. Instead a goal is set, and the employer (being the expert) implements controls specifically appropriate to the workplace to achieve this. Where they can’t, they must implement something else to mitigate the failings.
It’s the right approach, but the problem is that with Covid-19, the employer is no longer necessarily the expert in the hazard. This is where it’s necessarily for us all to constructively engage with unions and other outside bodies to find the solution.
Can you work safely?
We’ve already discussed specifics of whether and how you can keep working safely under Covid-19, but it’s worth revisiting some key parts. First, we need to remind ourselves of the risk hierarchy:
As the restrictions are relaxed, the range of construction projects that can go ahead is becoming very broad. However, within every project the individual tasks need to be assessed. Where it’s not possible to follow the SOP guidelines in full, consider whether that activity needs to continue. If it must, take all the mitigating actions possible to reduce the risk of transmission.
The next critical area is to understand who should and shouldn’t be at work, and give workers very clear guidance. Again, we’ve covered this in more detail in our previous post, but anyone displaying the key symptoms of infection (fever, coughing) should follow the guidance on self-isolation. Those considered vulnerable, or who live with vulnerable people, should stay away from the site.
Getting to and from work
We’ve discussed the difficulties of sharing vehicles amid coronavirus restrictions, and for some contractors this is likely to be the key challenge. “We have non-drivers coming to site, so it’s not possible for them to take a vehicle each,” explains Graham Patterson, director of Glasgow-based GreenAir Environmental. “One of our sites is 45 miles down the motorway from our guys’ homes, and you can’t really drive that far with the windows fully down. They drive with a mask on, and they clean the van when they get out of it.”
But as society opens up, public transport may again become accessible. It seems highly likely that it will be mandatory to wear ‘face coverings’ when using public transport or even going outside of your own home. It’s unlikely that this will mean a P3 respirator, especially as they’re in short supply. More likely there’ll be a requirement for cotton face masks.
It should be remembered that face masks are intended to protect others – not the wearer. They act as a barrier for your inadvertent coughs and may reduce the amount of virus particles distributed by infected people. To protect ourselves we wash hands, stay at least two metres apart, and try to stop touching our face.
As soon as face coverings become mandatory they’re likely to be in short supply, but it is possible to make your own. If you’ll need a mask for long periods it needs to be light, comfortable and not too hot. The latter will only become more important as we move into summer, as sweating encourages you to touch your face. If you are, or you know someone, handy with a needle and thread, you can find patterns such as this on the internet.
Deliveries
Coordinating deliveries and collections may also pose a challenge – particularly on smaller sites. Graham Patterson explains: “The roads are quiet, but still drivers can only give you approximate arrival times. When they get on site, they have to stay in their cabs until everyone is at least two metres back..One of our sites is small, so it’s just trying to organise that.”
Patterson also has misgivings about how some of the protections may work as more trades return to site. “There’s a groundworks contractor who’s due to start on Monday and he’s on the seventh revision of his method statement to even get allowed on site. We went through four.”
“The principal contractor is being incredibly careful, and has designed a site which looks really good. It ticks every box and then some. But it might not be practical when the new contractor turns up, so we’re expecting a day of ‘this is working, this isn’t working’.
“Below it all we face simple issues such as as if anyone is not well, whoever they came to work with has to stay off as well. You could quickly have a situation where you aren’t carrying out any new inductions and you run out of staff.”
Setting up the job
There are likely to be changes to the way you set jobs up, and additional equipment needed to ensure worker safety. Washing stations will need to be front and centre. You’ll need to set them up first – even before the decontamination unit.
We’ve already seen a greater provision of welfare facilities on sites, for example more toilets and cabins to allow greater separation and regular cleaning. “We’re the principal contractor for a massive site in Manchester,” explains Patterson. “We have two welfare cabins onsite with two toilet blocks, and we also have 10 bunker bins. Each one has its own fridge, cooking facilities, TV, bed, toilet and shower area. If anyone wants to use the better cooking facilities in the welfare cabins they just take turns and clean it down afterwards.”
“We’re very lucky that there’s a small town down there and we’re able to carry on almost as normal.”
For asbestos removal, think about how the team will construct the enclosure. Is it possible to do the work and obey physical distancing? Again, the nature and size of the site will be a key factor here. When creating the plan of work, review the risk hierarchy and consider whether you need to increase some controls because the site limits what you can do in other areas.
“The only thing that could create challenges for us is when the asbestos team is building or working in enclosures,” says Johnathon Teague, project coordinator at Armac Group. “We can’t keep the two-metre distance rule then, but obviously the team is all kitted up in full respiratory protective equipment (RPE) when they’re doing that, and following strict decontamination procedures afterwards, so it hasn’t been an issue.”
Technology
As with any construction job, safely managing the risks from coronavirus will be down to effective risk assessment, and devising a method of work that implements the necessary controls. While many of these are likely to be physical, technological solutions have the potential to help.
One target area is in helping improve compliance with the physical distancing guidelines. At least two companies are offering wristbands that notify wearers if they get within two metres of each other, and which keep a log of such ‘near misses’ that can be used for contact tracing if a worker subsequently tests positive. While we haven’t had hands-on experience with these, we know of at least one Tier-one contractor evaluating them.
This is a key area of concern for directors like Patterson, particularly as more trades return to sites. “Two metres is a massive gap to stay apart, and it’s also difficult for the guys to remember that gap. You know: ‘pass me that tool, give me this.’”
Proximity sensing technology might also help monitor the safe handoff of shared resources such as tools, but those in the industry have concerns. Patterson says: “If I have to share your tool will I have to wipe it down, set it in neutral ground, walk away, you walk, pick it up, use it? That’s not working. That’s just not practical.”
Management and supervision
There’s another, more fundamental way in which technology can help. If the best protection for workers is to keep them away from the site, anything that helps do so can lower the chance of the virus’ spread accelerating again. While there’s no substitute for boots on the ground when it comes to actually doing work, the right technology can minimise the risks that managers and supervisors face, and the chances that they spread the virus to or from their colleagues.
“We’ve had to reduce the site manager visiting the site,” explains Johnathon Teague. “We’re doing a lot more video calls with the site teams to make sure everything’s going as it needs to be. The technology has been useful to help us carry on.”
In addition to tools like video calling, Assure360 Paperless is specifically designed to reduce the amount of time managers spend on site visits, and that supervisors spend in the site office. For Graham Patterson, the benefits of Assure360 have been profound. “The system itself has streamlined the company massively, but it’s helped greatly under the lockdown.”
“We’re completely paperless. It’s saved so many issues. Now we take the guys’ photographs from more than two metres away to show attendance and that they’re clean-shaven. We don’t need them to sign anything. The iPad’s in a safety case, so it gets wiped down, passed around, and the guys can acknowledge the method statement. The supervisor’s doing all his checks and enclosure inspections on Assure360, so again it’s all done at the click of a button and we don’t need to print anything off.”
About Paperless
We created Paperless as a productivity tool for the supervisor, essentially replacing legacy paper-based safety checks with an app. It reduces the time supervisors spend on paperwork by up to a couple of hours a day, allowing them to focus on supervising the job. Liberated from the office, a full-time supervisor is more likely to bring in your project safely and ahead of time.
In the days of the coronavirus, using an easily sanitised tablet also frees supervisors from a huge site folder, and the potentially contaminated office. Paperless automatically syncs with Assure360’s cloud dashboard, so every scrap of site data is instantly visible from the contract manager’s laptop. With a clear view of critical safety and performance data including stop points, smoke tests and passed and failed visuals, managers can accurately assess progress without having to regularly visit the site.
With data already synced as it’s collected, there’s no requirement for box files of site paperwork to be reviewed and archived by the office team at the end of each job. It’s all done automatically, along with the processing of exposure records. We designed this to be a massive time saver, but in the context of coronavirus, it also reduces the need for staff to come into the office, or face exposure to potentially contaminated files.
“We have no paperwork come back from site now,” Teague continues. “Everything is done electronically, which helps us monitor things on an ongoing basis. Most of our work is large scale – months at a time – and Assure360 Paperless helps us manage everything as it’s happening, rather than waiting until the job’s finished and going through a couple of hundred pages of paperwork.”
These remain uncertain times, and as construction goes back to work the protections we need will pose new challenges and hurdles. But we work in an industry built on risk assessment and its mitigation through appropriate controls. In a time when even everyday activities now carry significant risk, we’re among the best equipped to cope.
Now more than ever it’s imperative to cut paperwork and supervision overheads, while simultaneously ensuring greater compliance. Discover how Assure360 Paperless is built from the ground up to maximise efficiency and safety on site.
Call for your free demo today!
Written by Nick Garland on Wednesday July 8th 2020
Since its launch, the Assure360 Paperless app has been helping the asbestos removal industry streamline the way it works. Our digital support tool removes the burden of paperwork for site supervisors, allowing them to quickly record safety-critical checks, and apply more focus to the work of actually supervising. Already established as the tool of choice for leading LARCs, we’ve been working behind the scenes to make Paperless even better.
I’m delighted to announce the release of a major update to the app. For the new version, we’ve further improved the workflow and usability. We’ve made everything more intuitive, saving even more time for the supervisor. It’s a great update, but I wanted to pick out some of the real highlights.
Now on Android!
Perhaps the biggest news is that Paperless is now available on Android. All of our apps are still available on iOS, but by adding Android support to Paperless, we’ve made the app accessible to companies who already run Android devices on site. We’ve also lowered the cost barriers for those looking to adopt Paperless as their on-site solution – it’s substantially cheaper to buy Android tablets than iPads.
One other great benefit of supporting Android is that it opens up a far wider range of devices, including rugged tablets – sadly something missing from the iPad line up. Even in a rugged case, it’s easy to break a standard iPad in a rough site environment, so deploying a rugged device may save money and prevent downtime. And while iPads aren’t waterproof, you can get IP65-rated Android tablets – it’s a lot easier to decontaminate a device that’s dust proof and resistant to running water!
Download Assure360 Paperless for your Android device!
“I’m not the most computer-literate person in the world but I found it fairly simple to learn and do. I think it’s made my job easier in respect of the paperwork and it’s. I believe it’s quicker, too.”
Mark McGonagle, Major Works Supervisor at Asbestech
Expanded and improved site diary
This version of Paperless is about more than simply adding Android support. Centre-stage among the improvements for all users is the redesigned Site Diary. In the new app, supervisors no longer have to type entries into a text box. Now, they simply choose the right category of event from the diary menu, add photo evidence if needed, and provide any necessary extra details.
This further streamlines the recordkeeping of routine daily events. For example:
All on site – just take a photo of the team. No typing necessary
DCU set up – take a photo. No typing necessary
Compound set up – take a photo. No typing necessary
Isolation certificate – take a photo. No typing necessary
Site Diary now becomes the hub of the whole Paperless system, informing the office of what they need to know, every step of the way.
We’ve made multiple other improvements to the way the app looks and behaves. Now, smoke tests and handover certification are handled fully within Paperless. The history of a job is also laid out more clearly, making it more straightforward to review – whether that’s by the supervisor, an external auditor, or the Health and Safety Executive (HSE). There’s also a new comments box for visitors, allowing any observations from the HSE or auditors to be recorded and shared immediately.
Download Assure360 Paperless for your iPad!
We’re proud to have made our industry-leading solution even more of a timesaver, and even easier to use. We’re also excited to open up the power of Paperless to companies working with an Android user base. Use the links above to download the new app for yourself or, if you’re not yet a Paperless customer, why not drop us a line to book a free demonstration?
Written by Nick Garland on Wednesday June 10th 2020
When it comes to working in confined spaces, hot environments are the new challenge that the asbestos-removal industry needs to get its head around.
I say ‘new’, but as I wrote in an earlier article, the Health and Safety Executive (HSE)’s confined space rules changed back in 2014. The changes were subtle, though, and the minimal fanfare around them has meant that, even five years on, some confined space training courses still miss much of the point.
To recap briefly, there are two triggers that together make a work area a confined space:
In short, if the access arrangements restrict your ability to get out, or that of emergency responders to get in, and there is a risk of (frankly) sudden death, then it is a confined space, and the confined space regulations apply.
I want to focus on one of the five proscribed hazards: ‘loss of consciousness arising from increased body temperature’ – or simply, working in high temperatures. Normal body temperature is between 36.1°C to 37.2°C. If it rises above 38°C, something serious is going wrong. Heat stroke – a body temperature above 40°C -is fatal without urgent attention.
It’s important to remember that these are body temperatures – not the working environment. While humans cancool themselves when the air temperature is higher than body temperature, if they’re active, or wearing heavy clothing, much lower temperatures can prove dangerous. The same is true if there’s raised humidity – sweat is slow to evaporate when the air is already saturated.
Asbestos workers are particularly vulnerable to high temperatures, as many of the controls we introduce to address the asbestos issue make it very difficult for our bodies to deal with heat. Impervious overalls prevent effective sweating, masks stop regular hydration, and the rigmarole of exiting the enclosure is a barrier to rest periods.
Therefore, ANY asbestos enclosure where it could get hot should be considered a confined space. There are some obvious ones, such as boiler rooms and ducts with hot water or steam pipes. But there are some that come at you from the leftfield, for example any open air enclosure in the summer, along with roof voids, rooftops, soffits, contaminated land and so on.
So what do you do? You may be able to eliminate the hazard, for example by isolating a boiler. The asbestos enclosure will still have restricted access, but as the second trigger has been removed, it is no longer confined.
Of course, there will be situations where you can’t remove the risk, and if you absolutely can’t (the client wouldn’t like it is not enough!), you need to try and reduce it. There are dozens of imaginative ways you might be able to do this depending on the source of the heat:
Even after you have reduced the temperature, the risk may remain. If so you will have to monitor it very carefully, and control the residual risk. It’s here that people often overreact, or more accurately, respond with controls which don’t address the fundamental risk.
When someone says confined space, the some consultants’ knee jerk reaction is often to introduce measures like gas detection, 15-minute escape kits, harnesses, tripods and so on. However controls are only useful if they are specific to the hazard. If the risk is pockets of poisonous gas, then this could be a good design. However, if the only proscribed hazard is heat, the escape kits could make matters worse – why carry more heavy kit during an already tough job?
If a confined space is so primarily because of a heat risk, you need to develop something different. The following are pointers and areas that you should consider when designing the project.
Fit and healthy is the key. Anyone unwell or recovering from an illness will be more prone to heat exhaustion and ultimately heat stroke.
Hydration – make sure that plenty of drinking water is available, and that workers drink it before and after each work period. Don’t forget the means to access it – it’s not good enough to have a tap on site if there are no cups!
Staff need to understand how to recognise early symptoms of heat stress in themselves and their colleagues. They need to know what to do if they see these signs. It’s critical to have qualified first aiders on site to be able to spot, intervene and help in these situations.
Heat stress symptoms can include any or all of:
Heat stroke has similar symptoms, but sufferers can accelerate through them very quickly to collapse.
There are ways to monitor the health of operatives, and depending on the risk assessment some or all of these should be included in the plan
We’re not just interested in temperature, but in the effective temperature – taking into account other factors that may increase the risk for workers. For that we use wet-bulb globe temperatures (WBGTs), which factor in the effects of humidity, wind speed and infrared radiation (sunlight and other heat sources) on our ability to stay cool. Fortunately, these days we use electronic WBGT meters, which meansmean we no longer have to do all the calculations ourselves. There is no maximum safe working temperature, you will have to assess the lowest you can practically get the enclosure down to – and compare to that.
Slow, with frequent breaks. This will mean regular transiting through the decontamination unit (DCU) and an acceptance of low productivity. Regular breaks will also allow the supervisor to monitor the workers’ condition.
The enclosure should be designed to maximise the amount of cool air introduced. Consider the case of a roof void, a common example of what’s now clearly a confined space. These are enormously hot in the summer, so avoid the temptation to block the only access with a roving head! Use the natural leakiness of the roof tiles and eaves, and reverse the air-flow.
Communication and supervision become critical where workers are exposed to immediate risks, including heat. Work plans must ensure excellent communication, and the ability for 100% external supervision. There can be no lone working, and everyone should be on the lookout for symptoms in their mates.
You can’t do much about the overalls, but you might consider cool suits and air-fed masks, which may deliver cooler external air directly to the worker.
Review the normal ‘absolute no’ of entering a confined space to affect a rescue. This standard rule is to prevent would-be rescuers becoming another victim, brought down by the same gas, water, free-flowing solid or fire as their colleague.
With heat it’s different: in all but the very hottest environments (where frankly I’d be questioning whether you can control the risks at all), heat exhaustion has a slow build up with warning signs. Clearly there is a critical role outside the enclosure – contacting emergency services and making preparation for first aid – but once that is done, should the supervisor rule out helping the rescue? You will need to assess the risks of this, rather than blindly following the ‘standard’ rules.
You should always ask, “How will I get ‘Big George’ out of this work area?” The plan might involve trolleys or harnesses to help them walk, and if there is a vertical ascent, the infamous tripod.
What to do? I can’t stress enough: it’s critical to have qualified first aiders on site. Ideally both within the confined space, and up top. Heat stroke is very serious and can rapidly accelerate through the symptoms to collapse. Whilst the first aid response to heat stress, exhaustion and stroke is similar, – reduce the body temperature, liquids, salts and rest. However, if there’s any suspicion of heat stroke there should be an immediate call to 999.
When the old guidance for asbestos removal at high temperatures was withdrawn all those years ago, there was nothing to replace it. Fortunately that changed in 2014 with this revision to the confined spaces regulations – it’s unfortunate that our industry awareness, and the quality of our training, is yet to catch up.
Whatever the potential hazard – fire, heat, gas, solid or liquid – confined spaces are incredibly dangerous places to work, and we should remember that the projects we design have a direct influence on the life expectancy of our teams. The risks of confined spaces need appropriate and effective controls. Merely copying and pasting them in from the last off-the-peg training course might lead to disaster.
Written by Nick Garland on Friday April 3rd 2020
The end of March marked an important milestone for anyone working in the asbestos-removal industry: a full year of the Health and Safety Executive (HSE)’s new licensing regime. It’s been a turbulent 12 months, with initial head-scratching giving way to very real challenges for licensed asbestos-removal contractors (LARCs) and the HSE alike.
So what changed, what was it like for people on the front line, and what’s the situation now? In addition to our work helping customers successfully renew their licenses, we’ve been speaking to contacts within industry bodies and the regulator to get the clearest picture. Here’s our take on where we’ve been, where we are, and what’s coming next.
What changed?
For those who haven’t been following the saga, from the start of April 2019 the HSE began piloting a new asbestos-removal licence regime. Its intended goal was to shift some of the onus and therefore workload from the HSE to the licence holder.
Under the previous system, LARCs would submit a comparatively small amount of documentation outlining their competence, and the HSE’s inspectors would come along to assess it for themselves. It was perceived that in some cases, part of that process would involve the HSE assessor rephrasing their questions until the ‘right answer’ was given – a helping hand over the line if you like. All being well, the HSE would renew the licence, applying any conditions it found necessary.
With the new system, the HSE shifted the focus away from its own inspections, placing the onus on LARCs to provide extensive evidence backing up their competence. Key to this is a new, multi-section online form, through which the applicant provides clear evidence to show how they plan, execute and audit jobs to an exemplary standard.
The HSE’s shakeup was long overdue. Like many in the industry, I’d been calling for the abolition of the different length licences seen under the previous system. These were often – mistakenly – seen as an indicator of a contractor’s competence. Asbestos-removal licensing needed to be simplified, and the HSE needed to concentrate on improving industry standards.
On the surface of it, the overhaul was almost exactly what we’d been asking for. Out went variable length approvals in favour of fixed three-year licences without publicly visible conditions attached. And the move away from inspections promised to reduce the workload on already overstretched assessors.
Did it go wrong?
It’s hard to avoid the impression that the changes caught everyone out – including the HSE itself. Launched as a trial with little publicity, early applicants found themselves reapplying through a radically changed system, with precious little guidance on what the new requirements were. LARCs were unsure of the format and content of the evidence that the HSE was after, so the latter soon found itself struggling with the overheads of dealing with inconsistent applications, using wildly different methods of evidencing.
There were other teething problems. Rather than present LARCs with a slick online interface, the new online form actually required evidence to be submitted via emails. Many of the first applicants reported that the incoming size limit was set too low, resulting in submissions not getting through. Before long, applicants faced significant delays to their renewals.
It’s here – around the summer of 2019 – that things started getting dicey. As we continued working to ensure our customers could quickly extract the evidence they needed straight from the Assure360 system, we began hearing horror stories. Many renewals were dragging on for weeks longer than expected, with some LARCs even coming perilously close to having their licence lapse – with the potential risk of losing their business as a result.
Figures compiled by ACAD backup what we were hearing at the time. Over 2018-19 the HSE refused just two licence renewals. During 2019-20 this shot up to 14. Perhaps more significantly, there’s been an acceleration in the falling number of licensed contractors. In the three years from April 2016 to April 2019, the number of LARCs dipped by 6%. There’s been a further 6% fall in just the last 12 months.
While it’s hard to attribute these figures entirely to changes in the licensing system – especially considering the backdrop of Brexit uncertainty and an underperforming economy – anecdotal evidence suggests they were the major component.
The LARCs’ view
Among LARCs we’ve spoken to, Luke Gumbley, director of Emchia, had a fairly typical experience.
“I completed the online form from start to finish. It took me about four weeks, and I think I’d still be there now if it wasn’t for Assure360,” he says. “There were a few teething issues at the start of the new HSE process because their communication wasn’t the best, and I think over the first few months it was hard for applicants to know what evidence to present, and how to present it.”
Discover how we help Luke achieve the high standards he wants to be known for – read the Emchia case study.
Luke’s experience is typical of the kind of feedback we were getting, as customers tried to get their head around the new system in its early days. As another customer drily observed: “Change management is an art in itself.”
“What they’re trying to do is replace one or two days’ interviews with government inspectors with the information that LARCs now have to provide. And because the system’s still in its infancy, it’s not brilliant. For example: it’s not a portal you’re uploading to – you’re just emailing them.”
Many of the LARCs we’ve spoken to are in favour of the online renewals, but figures from ACAD show that they’re in the minority. While 19% prefer the new system, an overwhelming 44% say that it’s worse. There’s broader support for specific changes, however, with 37% agreeing that the new fixed three-year term is an improvement over the previous one, two or three years.
Perhaps surprisingly, some of those who experienced the new system at its most challenging are among its supporters. “While I was doing it I thought it was the worst thing in the world,” says Luke Gumbley. “Now I’m done I’ve come around on the new system. It’s helped me understand my business more and given me confidence that we’re doing exactly what’s required.”
The HSE’s view
While we speak with LARCs daily, we’re also fortunate enough to enjoy good relations with key figures within the regulator. Informal conversations revealed the HSE’s view on how the trial had gone, what could be learned, and what comes next.
A specific challenge that the HSE has experienced is the difficulty LARCs had with organising the email responses in a logical manner. This was compounded by the huge variation in the documents they used for evidence.
Obviously, the HSE can’t commercially endorse anyone, but our clients have found that we can help with this. With nearly 20% of the industry using our solution, one in five applications will be submitted on a very familiar form.
However, the ALU team recognise that LARCs are businesses, and as such they can’t give 100% of their focus to the renewal. It’s accepted that poor communication and a lack of empathy have been issues. Greater efforts are being made by the HSE to address this, but LARCs also need to improve. Our conversations revealed that many of the ALU’s emails and telephone calls go unanswered as the HSE follow up applications. Their message is to make sure that you provide the best methods of contacting you. My message is to check your spam folder!
Questions of competence
One specific area of concern for the HSE during the trial was LARCs’ wider understanding of hazards beyond asbestos. The specific example given was an apparent misunderstanding of the confined space guidance that came across during one review.
This echoes one of my concerns: that we as an industry can be too focused on the risk posed by the deadly substance we manage, sometimes to the extent that we ignore greater or more immediate dangers. I recently discussed how we, as asbestos professionals, can be blinkered when we think about risk – you can read that article here.
What’s the situation now?
The current COVID-19 crisis notwithstanding, we’ve now entered a period of more stability. The ALU sees the trial as a success, though it recognises that there has been a very steep learning curve for everyone. The trial has now ended, and the new system is the reality for all applicants.
Since autumn 2019, things have generally begun to look up. The HSE’s communication has improved, and guidance on what the HSE expects is much clearer. Today there’s far more support for LARCs as they enter the process, and we’re hearing that for most customers, renewal times are far more reasonable.
We’ve a history of supporting customers through HSE licence renewals, so we’re proud that we were able to help from day one of the new system. We worked hard to introduce and perfect a new, dedicated licensing module, so it’s rewarding that so many of the people we’ve spoken to have cited Assure360 as a major help during the turbulence of the last 12 months.
“Assure quickly enables you to extract the information which will help prove that you are complying with the HSE’s licensing criteria,” explains Clinton Moore, director of Sperion.
“When the HSE asks, for example, ‘Can you demonstrate how you carried out an audit and found something wrong, and what you did about that error and how you applied the training?’, Assure lets you record those processes and do a very simple print out to prove what those processes were and how they were completed.”
Discover how we help Sperion streamline its paperwork and extract more meaning from its site safety data. Read the Sperion case study
Phil Neville, operations director at Asbestech, agrees: “Assure360 makes it very simple to demonstrate to the HSE that we are collecting personal exposure information… and that management see and review it regularly. We can show that we use the information from it to identify trends, but also to identify our anticipated exposure levels – which we need to draw up our method statements.”
“The HSE has stated that they expect licensed asbestos-removal contractors to be ‘exemplary’. Assure360 helps us demonstrate that we are.” Read the Asbestech case study
For Emchia’s Luke Gumbley, the benefits of Assure360 extend beyond the software system itself. “With Assure360 the information I needed was at the tip of my fingers. I leaned on the Assure360 team, asking where the information was and how to present it, and they were great – even sending me links to the actual information for my business, which I could then share with the HSE.”
What’s next?
From our discussions with the HSE, customers and our professional bodies, it’s clear that there’s widespread support for the new system. However, that doesn’t mean it isn’t still without its flaws.
As I discussed during my recent appearance on the Asbestos Knowledge Empire podcast, there’s a sense that LARCs may previously have benefited from the ‘whites of their eyes’ experience of being grilled in person by HSE inspectors. Anyone who’s been through it will know it can be a daunting process, likely to expose businesses who aren’t completely on top of their processes and record-keeping.
There’s work to be done on the submission process, which still relies on email. The regulator’s ultimate goal is for a portal through which LARCs can upload all their evidence, but developing it is very much a resource-led decision and it could be some way off. In the meantime, careful use of Dropbox should help the process.
Other elements of the experience are already better. The guidance has evolved with a narrowing of the required evidence – the HSE has now been much more specific as to what it wants to see. There is also now a clear timetable to follow. You will get the invitation to reapply for your licence four months ahead of its expiry date.
COVID-19 permitting, the HSE has a 10-week deadline from start to finish, with a commitment to get the decision to you at least 2 weeks before the end. This process includes an admin check, the review itself and a buffer in the middle. So the message for LARCs is to count back from your licence expiry date:
This totals 12 weeks, leaving you only three – four weeks to reply to the invitation, pay the invoice, assemble all the evidence and submit the application. But there is no reason why you can’t be ready ahead of time – you’ll be only too aware of your licence renewal date, so assemble much of the evidence before you get the letter.
Overall, there’s a sense that while the industry has taken a step forward, not everything has improved under the new system. And for those LARCs who found themselves at the forefront of the trial, there was little in the way of support through what for some was a bruising and costly experience. But if the pain of change management was disproportionately borne by one half of the participants, it does at least seem that many lessons have been learned. The next phase of licence assessments will be much easier.
Written by Nick Garland on Wednesday March 25th 2020
Updated on 20/04/2020 10:30
Whatever your business, I’m sure you are trying to get your head around the crazy new world that we are living in.
The asbestos removal industry is pretty good at hazard identification, risk assessment and mitigation and all our personal protective equipment (PPE) is of the required grade. The other way to look at the immediate future is that we have a particular skill set, in that we clean up contaminated surfaces whilst keeping our workforce safe. As an industry our core competence may be called upon in the COVID19 national effort.
The Secretary of state for Business, Alok Sharma, supportive letter to all businesses operating in the construction sector was seen as real boost for the entire sector. This encouraged many of the Tier 1 contractors to reopen sites and insist that their subcontractors support them.
This will present significant challenges in the coming weeks as we all try and follow the latest government advice. The Construction Leadership Council have issued Site Operating Procedures. The highlights of the SOP are:
The underlying point of all this is critically we need to observe social distancing. I’m going to reword that for clarity: physical distancing. Because the ‘social’ bit makes us think that it is something we consider after work.
Physical distancing is keeping two metres away from anyone that you don’t live with – that’s likely to mean everyone you work with. The HSE will be all over whether we are succeeding and have a lot of powers to close down sites if they feel it appropriate.
I’ve been considering how – and whether – we can continue to work safely in the current circumstances, and I wanted to share my thoughts in this post. But there’s a big caveat: I am not an expert virologist. Instead I’m drawing on my experience of hazard identification and mitigation. I believe these are all areas we should be thinking of. If you have anything to add, and especially if I have said something stupid, please shout asap.
Working through the steps to the following are some of the decision / hold points that we need to consider.
Let’s start by looking at the risk hierarchy:
If our starting point is that the only ‘safe’ place is in an individual’s own home, it is possibly helpful to think of any asbestos-removal job as though the site is thoroughly contaminated with rat urine or pigeon guano. But where does ‘the job’ start and finish? We have to change how we think. Where does the risk now start? What new areas do we need to think about?
The government guidance remains that with the exception of key industries, we should be attempting to carry on. Here’s a link to the latest guidance on what should and shouldn’t go ahead. Certainly with Work carried out in people’s homes, including repairs and maintenance, can apparently continue, provided they can maintain 2 metre distance from any household occupants AND the household is not isolating or where an individual is being shielded. Here’s a link to the detailed guidance.
There are some examples of projects that will obviously be needed, where we may be remediating an existing risk, or facilitating oxygen lines in a hospital. The example of an asbestos removal job to facilitate a kitchen installation whilst is less clearcut, is not actually prohibited.
Remember that the point of physical distancing is that if we cut the number of people those carrying the infection pass it on to, by just 33%, the knock on effect over time is enormous:
A graphic which shows how social distancing can reduce the spread of coronavirus. Credit: Dr Robin Thompson/ University of Oxford, via itv.com
Individual tasks should also be assessed – and where it is not possible to follow the social distancing guidelines in full, consider whether that activity needs to continue for the site to continue to operate, and, if so, take all the mitigating actions possible to reduce the risk of transmission. I go in to suggestions below.
You need to give very clear guidance to all workers on who should and shouldn’t come to work – and if they do turn up, when to send them home. Anyone who meets one of the following criteria should not come to work:
If a worker develops a high temperature or a persistent cough while at work, they should:
I would err on the side of caution.
Typically we might have a driver and two passengers in the front of a van. Clearly this is not physical distancing. You will need to start thinking how you can achieve this. Can the workers arrive at site separately via their own transport (remembering that public transport is for critical workers now)? Many operatives don’t drive, so how do you mitigate the risk?. Can you limit the number, for example by carrying only one passenger? Maintain travelling companions (i.e. keep to the same passenger). Face away from each other and open the windows to increase ventilation. Daily disinfecting of the vehicle cabin by the site team, no eating, drinking or smoking (all of which increase the chance of touching the face).
It could mean donning RPE, but half-masks have a limit for how long you should wear them. For longer journeys you’ll need to factor in regular breaks.
As a back-up it would probably be prudent to do regular full decontamination of the vehicles back in the yard – treat this like an ‘environmental clean’ with full face RPE and dilute bleach (1:60).
Again, physical distancing! Keep two metres away from anyone that you don’t live with – i.e. everyone you work with.
Again, is it possible to do the work and obey physical distancing? The nature of the property may help or hinder this (very small flats vs larger areas). Again consider the risk hierarchy. Just as with a site posing a psittacosis risk, we would ordinarily disinfect surfaces before we start, increase ventilation, introduce strict eating, drinking and smoking procedures, and require PPE (gloves, RPE and overalls). We’d also increase our washing frequency.
The normal challenge on sites is welfare, and that’s even more the case now. Again, if we are imagining that the area is thoroughly contaminated with rat urine or pigeon guano, we would obviously wash our hands before any break. We need to be thinking along those lines – but even more so. Workers should wash their hands on arrival at the site and then regularly after that. How can our guys frequently wash their hands for the required 20 seconds? They can use hand sanitiser if you have it, but this must contain more than 60% alcohol. Possibly better is a killer spray, with one person spraying whilst the second washes their hands.
Home-brew Sanitiser Recipe
I understand that this will come out much stronger smelling and thinner than you would expect. The ingredients are expensive online – but as you apparently only need a few drops, it should last. Remember that the advice is to ‘wash’ hands for at least 20 seconds, ensuring that every nook is thoroughly rubbed clean.
I received a photo from a truck driver at one of the UK largest construction sites on the first day of the lockdown. It shows an enclosed canteen crammed with people just inches from each other – clearly madness.
The standard operating procedures published by Build UK – so hopefully this is a thing of the past.
It shouldn’t need saying, but DO NOT USE CANTEENS. Everyone should wash their hands before all breaks. There should be no crowding into the toilets – give everyone plenty of space and extra time if needed. Individuals should bring their lunch and drinking water from home – remembering that those working in a warm enclosure will need to drink plenty. There should be no eating together as a team. Stay at least two metres apart!
Clearly, we are very well protected in the enclosure, although possibly less so on semi-controlled jobs. It may be worth considering full-face powered RPE for all works as that also prevents people from touching their face. Similarly, full transit procedures for all works may be a good idea. You will also need to consider staggered use of the DCU – allow the first operative to exit, before the next one starts to transit.
Thorough external cleaning – again using the dilute bleach solution (1:60). This should be done at the end of the project and before issuing it to site.
It’s much easier at the office, but still a challenge – again, the primary focus is physical distancing, so how do you achieve this?
It may be possible to have an unmanned reception for visitors and deliveries, showing a number people can call (on their own phone) to let you know they’ve arrived. This ‘high risk area’ could be disinfected after every ‘exposure’.
It needs to be remembered that the virus can, apparently, survive on some surfaces for several days. Staff should be encouraged to wipe down surfaces with dilute bleach or a soap solution, and frequently wash their hands.
However (and it’s a biggie), the advice is still uncertain. I started by saying that the government advice is that construction can go ahead, but the Mayor of London, Sadiq Khan, has said: “My view is no construction work unless it is for a safety reason.”
If, after all of this, you decide not to keep operating and you have spare stocks of PPE – our medics are in desperate need.
Further reading:
Build UK Site Operating Procedures – Protecting Your Workforce
HSE: Coronavirus (COVID-19): latest information and advice
Thanks to all those that helped with this note.
Good luck, stay in touch and we’ll get through this together.
Written by Nick Garland on Tuesday March 10th 2020
We’ve long been admirers of the Asbestos Knowledge Empire – a series of podcasts run by Acorn Analytical Services’ Neil Munro and Ian Stone. Speaking to a cross section of health and safety and asbestos experts, the series is helping play an important role in spreading awareness and fostering asbestos expertise. So when Acorn asked if I’d like to participate I jumped at the chance.
In a wide-ranging hour-long chat, we covered subjects as diverse as how I got my start in the industry, the one-time ubiquity of asbestos, and the importance of analysts and removal contractors ‘wearing lots of hats’. We also talked in depth about the Health and Safety Executive’s new licensing regime, the problems it’s solved and the new challenges it’s created.
If you’re interested in what I had to say, or if you’d just like to hear from the industry’s other leading lights, head over to Asbestos Knowledge Empire. There you’ll be able to listen to the latest episode, and find links to follow the series on popular platforms including Apple Podcasts and Spotify.
I hope you enjoy listening as much as I enjoyed taking part!
Written by Nick Garland on Sunday February 23rd 2020
Emchia Asbestos Solutions was founded in 2016, and has quickly grown to become a major provider of asbestos services. Despite being a relatively new company, Emchia’s management team represents decades of experience, with managing director Luke Gumbley an industry veteran of more than 18 years. Today, Emchia operates from offices in Preston, Coventry and London, providing asbestos removal, land remediation and soft strip services for major clients across much of the UK.
Since its inception, Emchia has aimed to provide – and become known for – the high-quality of its services. A core strategy for growing the business was to use modern technology to reduce the administrative overheads and increase the efficiency of the business, allowing Luke Gumbley to focus the company’s resources on achieving the best outcomes.
In starting a licensed asbestos-removal contractor (LARC) from scratch, Luke faced a common challenge. While Emchia couldn’t perform licensed asbestos removal until the Health and Safety Executive (HSE) had granted it an initial 12-month licence, even getting to that stage required significant investments of time and money. As with other licensed asbestos-removal businesses, it was essential during the first year that the business performed as it said it would, and that it kept the records it would need to prove this to the HSE.
It’s often said that keeping an asbestos-removal licence is harder than gaining it, so at renewal time, LARCs such as Emchia need to be able to prove that the processes they described in the initial application have been implemented properly and remain effective. And with the HSE’s recent switch to an online, evidence-based system, businesses need additional guidance on the appropriate information and examples that the HSE needs, and how they should be presented.
From the outset, Luke chose to improve the efficiency of his business and gain greater insight into its performance through Assure360. “We had the software since we first set up the business,” he explains. “We used it for the audits and the personal monitoring. It helped us when we were setting up to keep the cost down, because we didn’t need a person in the admin team doing those tasks for us.”
As the Assure360 system has expanded, new features and apps have further helped Luke to streamline the business and ensure it performs to his exacting standards. Emchia signed up to the Assure360 Paperless app shortly after its launch, immediately reducing the paperwork burden for supervisors, and for Luke’s back office team.
“It’s user-friendly for the guys – they prefer it as it’s reduced the time they spend on inspections right down, giving the supervisor more chance to actually supervise instead of completing documents. They can get their checks done fairly quickly first thing in the morning, then they’re free to manage the site instead of having their heads buried in a folder of paper for a couple of hours.”
Crucially, Paperless allows Luke to take a daily view of the checks and activity on site, ensuring that all the equipment and processes are working as they should be. This helps Emchia avoid a major drawback of the traditional paper-based approach, that minor issues tend to stay on site until the paperwork returns to head office. “If that happens on a three or four-week job, you’ve kind of missed the boat,” Luke explains.
Assure360 has been instrumental in supporting Emchia through its initial asbestos-removal licence application, and during two subsequent renewals. After just 12 months of operating, Emchia so impressed the HSE’s inspectors that it was granted a two-year licence. When this approached its expiration, however, the business found itself among the first to experience the initial problems with the HSE’s revised, evidence-based renewals system.
“I completed the online form from start to finish,” says Luke. “It took me about four weeks and I think I’d still be there now if it wasn’t for Assure360! There were a few teething issues at the start of the new HSE process because their communication wasn’t the best, and I think over the first few months it was hard for applicants to know what evidence to present, and how to present it.
“While I was doing it I thought it was the worst thing in the world, but with Assure360 the information I needed was at the tip of my fingers. I leaned on them, asking where the information was and how to present it, and they were great – even sending me links to the actual information for my business, which I could then share with the HSE.”
Emchia completed the process, gaining a three-year licence with no conditions. “Now I’m done I’ve come around on the new system,” adds Luke. “It’s helped me understand my business more and given me confidence that we’re doing exactly what’s required. Emchia is now set up perfectly the way that the HSE wants it to operate, and I can clearly see that, and I can clearly show them the proof.”
“Every decision that’s made, whether it’s commercial or health and safety, I’m in touch with that site through Assure360. My time’s been freed up quite a bit, so I get more time to go out and manage the jobs.
“Assure360 helps me see where we can save money, or where we can do things better or improve slightly in the future. Ultimately it helps me earn a better margin doing better quality work – supporting the key way in which we’re growing the business.”
Client name
Luke Gumbley
Director
Website: www.emchia.co.uk
Written by Nick Garland on Sunday February 23rd 2020
Established in 1983, Asbestech has grown to become one of the leading asbestos and hazard-removal businesses in the UK. With a nationwide presence, supported by five regional offices, Asbestech delivers the highest quality solutions for major clients in the public and private sectors. Originally focused only on asbestos removal, today Asbestech has extensive hazard-abatement expertise spanning specialisations including lead paint and ventilation cleaning. In addition, the company has expertise in reinstatement work to replace hazardous materials with modern alternatives.
Asbestech’s mission is to build a culture of safety, quality and performance that’s unmatched elsewhere in the hazard-abatement industry. A fundamental part of this commitment is an emphasis on exemplary health and safety (H&S) practice throughout every project, underscored and supported by regular auditing and analysis.
Previously, the company’s internal auditing tool was an 18-20 page document completed onsite, analysed, then filed away for quarterly review. While effective, Asbestech was seeking a way to do more with its auditing data, improving its analysis to provide fresher and more powerful insights that could further improve site safety and the quality of the work being done.
Through a longstanding professional relationship with Assure360 founder Nick Garland, Asbestech became an early customer for the Assure360 system, principally using its powerful auditing tools and personal exposure monitoring features.
Assure360 has enabled Asbestech to dramatically improve the way it audits, interprets and improves its performance on site. “The massive advantage with Assure360 is that it covers more than our previous audit form used to,” explains the Asbestech Operations Director, Phil Neville.“With Assure360 you can do a quick site inspection, you can just do a paperwork check, or you complete an in-depth site audit of all the H&S aspects which encompasses environmental practice, quality systems and everything else.”
“The data gets fed back to a central cloud-based system, so when I open it up the first thing I see is a screen with headline charts and graphs. It’s immediately apparent if there are any trends I need to look at, if there’s any particular processes that have gone awry, or if there are individuals we need to coach.”
Neville explains that the system’s visual reporting has proved an invaluable tool in providing direction and feedback during monthly meetings with contractors and supervisors. “We can bring up the visual charts and show the teams: ‘These are the kind of things that are being picked up on site so we need to concentrate on trying to improve those.’ Because it’s pie charts and bar graphs, it’s much simpler for people to understand – rather than us just showing them a big spreadsheet full of numbers.”
Crucially, rather than relying on the time-consuming analysis of paper records to spot safety trends, Assure360 provides Asbestech with a dynamic view of where to focus improvements in process, training or support. The benefits include real-time improvements to safety and performance, helping Asbestech protect workers and building users, and deliver to the high standards that it and its customers expect.
Asbestech prides itself on having continually held full asbestos-removal licences since licensing was introduced. It recently submitted its first application under the Health and Safety Executive (HSE)’s new evidence-based system.
“The licence renewal used to be that you’d send them information such as your standard procedures and H&S manuals, and then they’d come in and spend a day or two interviewing you and going through everything in great detail,” says Neville.
Under the new system, however, the emphasis is on asbestos-removal contractors to collate and send much fuller records and evidence via email. Neville explains that Assure360 helps demonstrate that Asbestech is managing its site auditing systems well. It also helps with the ‘hot topic’ of personal exposure monitoring.
“Assure360 makes it very simple to demonstrate to the HSE that we are collecting personal exposure information, that it’s all being stored on a cloud-based system, and that management see and review it regularly. We can show that we use the information from it to identify trends, but also to identify our anticipated exposure levels – which we need to draw up our method statements. Ultimately we use it to make sure we are keeping our team members safe.”
What the client said
“The HSE has stated that they expect licensed asbestos-removal contractors to be ‘exemplary’. Assure360 helps us demonstrate that we are.”
Client name
Phil Neville
Operations Director
Related links
Website: www.asbestech.com
twitter: @asbestech
Written by Nick Garland on Monday February 10th 2020
ACAD organises three rounds of regional meetings across six regions every year. They’re an opportunity for members to come together and benefit from the latest industry updates, and a brilliant way to catch up with old acquaintances – and of course make new ones.
We always try to get to as many events as possible, and we’re delighted to confirm that Nick and Rick Garland will be at the Manchester, Bristol and Kegworth meetings on the 3rd, 4th and 5th of March respectively.
At 8:00 on the morning of each event, we’ll be running informal, open forums for an hour or so to discuss the latest developments to the Assure360 solution. We’ll be presenting our road map – including the planned release of our apps for Android – and having a general Q&A.
Feedback from our customers has been instrumental in shaping Assure360, so we’ll be keen to hear any suggestions you have for how we can enhance or improve the solution. Please do come along – we’re looking forward to being there, and meeting as many customers as possible.
Event location details:
ACAD Regional Meeting North West: March 3rd 2020, ACAD at Novotel Manchester West, Worsley Brow, Worsley, Manchester, M28 2YA.
ACAD Regional Meeting South West: March 4th 2020 at Aerospace Bristol, Hayes Way, Patchway, Bristol, BS34 5BZ – NB this event will start at 10:00am
ACAD Regional Meeting Midlands: March 5th 2020 at Meetpoint Midlands, 26 & 28 High Street, Kegworth, Derbyshire, DE74 2DA
For full information on the ACAD regional events please visit the ACAD website here.
Written by Nick Garland on Thursday January 16th 2020
We all know that the job of asbestos removal is dangerous – that’s why it’s so tightly regulated. But while the most serious risks are often found inside the enclosure, they don’t stop there. The decontamination unit (DCU) presents its own hazards – from asbestos exposure, through electrical and gas hazards, to crush injury when setting up or decamping. So what guidance is available, and how can it help keep operatives safe?
Last year the Asbestos Leadership Council (ALC) made time in several meetings to discuss DCU safety. Unfortunately they’ve made slow progress in producing guidance, and the final version hasn’t been issued. That said, I wanted to take a look at what there is so far, as it’s good stuff. The focus is on electrical and gas safety, which is particularly welcome – working practice in much of the industry is still based on very outdated facts and guidance.
I’m also adding in some additional observations based on my experience of the biggest hazards, and the safe working practices designed to mitigate them.
The guidance starts predictably enough, instructing that gas boilers should meet the required BS EN standards, that they should be installed by an accredited gas fitter, and that each appliance should be fitted with an isolating valve and flame failure device. However, it then goes on to say that all boilers situated in the clean end – rather than a sealed cupboard – should be of the balanced flue type .
For those of us who aren’t gas engineers, in a balanced flue (also known as room-sealed) boiler, the entire combustion circuit is sealed off from the room that the boiler’s in. The fresh air supply, combustion chamber, heat exchanger and exhaust gases are open to the atmosphere only, meaning that if something goes wrong, any toxic or flammable gases should be vented out of the DCU.
Insisting on this type is wise, as they’re much safer than open flue boilers which draw their combustion air from the room they’re in, but following the guidelines might mean an expensive upgrade for any older DCUs.
There are some other issues to pick up on. If the boiler is mounted in a separate sealed cupboard it is best practice for that boiler to be room-sealed anyway, but regardless the cupboard door must be closed and sealed at all times. Many times I’ve seen cupboard doors left open, sometimes for convenience, but sometimes because there is otherwise insufficient ventilation in the cupboard for the boiler to work. If the boiler only works when you leave the cupboard door open, then it’s effectively in the clean end, and must be room-sealed.
It’s important to understand that a room-sealed boiler doesn’t guarantee that combustion products like carbon monoxide (CO) can’t leak into the room. Seals can fail, so there should always be a CO alarm fitted in the clean end, adjacent to the vent to the shower compartment. Correct positioning is important – I’ve seen random locations, not all of which will be effective according to the guidance.
The guidance here pretty much summarises existing standard guidance. In brief, the gas bottle(s) should be:
Note, too, that there should be a maximum of two 16kg bottles, and that nothing spark-generating should be stored with them.
So far, so standard, but then we get to areas where I’m not sure we have much compliance. Gas bottles should be:
There’s some welcome clarity here: DCUs require mandatory 12-monthly gas-safety certificates. Some HSE inspectors are still referring to a very old note that mandated six-monthly inspections for open-flued units. This detailed guidance supersedes and clarifies this.
In day-to-day use, the gas pipework needs to be checked daily and at the end of the project – not a job that I’ve seen on many supervisor checklists. There should also be emergency procedures to follow if gas is smelled. The advice states that gas should be isolated at the end of the shift, but it then goes on to contradict itself, suggesting that if there’s no oil-filled radiator the pilot light should be left running in cold weather. Presumably this will be cleared up in the final pre-publication checks.
All vents, clearly, need to be kept clear. If you have an open-flue boiler in a sealed cupboard, that cupboard needs to be kept closed and the seals must be in good condition. In all cases the CO alarm must be checked at least weekly.
This is usually the area that gets the most attention when a job is audited, but the justification for this seems patchy at best. To my knowledge there has never been a DCU electrocution, so the previous guidance has clearly been serving us well.
This guidance states that all DCUs must regularly be electrically inspected and tested – we rarely see units that haven’t been. In fact, the biggest risk is likely to come from using the client’s mains supply if it turns out to be faulty. The moment of greatest risk is brief – when an individual is standing on the floor, but touching the metal frame of the DCU.
The guidance offers some pointers on how to eliminate electrocution risks:
However the guidance really calls for better design of DCUs to ensure better electrical separation, along the lines of a bathroom. Generally there should be layers of insulation between electricity and people, and the power for recharging masks should come from two-pin, low-voltage sockets. Where there are concerns about the quality of the source electrical supply, it’s perhaps wisest to use a single-phase generator rated below 10kVA, which doesn’t need earthing at all.
The ALC’s guidance may be useful and comprehensive, but it overlooks the most pressing DCU safety issue: the risks relating to manual handling and vehicle movements when positioning them. DCUs are heavy beasts, and it typically takes more than one person to maneuver them by hand. It takes coordination and well-designed procedures to prevent workers being trapped or injured, yet it’s all too often overlooked.
I personally know of one serious injury that has occured due to lack of concentration when maneuvering a DCU. The following is the safe working procedure that was created after the event:
When positioning, re-positioning or removing a DCU from site it is critical that it is done so safely. DCUs are heavy pieces of plant. They can cause injury by trapping operatives against fixed structures, and can become unstable if moved over rough ground.
Where necessary – a traffic marshal will use a barrier to stop traffic when the DCU is to be moved into the road to be hitched onto the waiting van.
It’s a shame that the ALC’s guidance overlooks the risks from positioning the DCU, but apart from that it does help clarify what’s necessary to ensure safety as operatives finish shifts. Well-trained staff should already understand that the risks of asbestos removal don’t end until they’ve decontaminated and exited the DCU (and beyond) – following this guidance should help ensure they stay safe while they do so.
Written by Nick Garland on Tuesday January 7th 2020
There is something quite energising about the European Asbestos Forum (EAF) conference, and this year was no exception.
The theme for EAF 2019 was Asbestos and Innovation, and while asbestos is a given in our industry, innovation is not. Certainly in the UK, the asbestos sector is the most strictly regulated industry other than nuclear, yet for decades our main control measure has been polythene sheets and tape. Our main detection method is the near-century-old technique of phase contrast microscopy (PCM). And how do we dispose of our deadly material? We bury it in the ground!
For too long, technology has seemed to be something that happened to other industries, but in the past few years there have been vast strides in control measures and medical treatment. At EAF 2019, we were given a fascinating look at a range of technological advances.
Among the first was a breakthrough process with the potential to make denaturing asbestos a workable reality – making it safe, rather than burying it for another generation to worry about. Asbetter Acids’ fascinating process pits waste acids against asbestos cement waste, with the effect that they cancel each other out. It’s a really elegant solution: the acid eats away at deadly asbestos fibres, while the cement’s alkaline nature ultimately neutralises the acid. What’s more, the end by-product can be used to make new roofing sheets – useful to replace old ones made from asbestos cement. Genius.
Marvin the robot microscope provided another eye opener, as Frontier Microscopy explained a technology with the potential to dramatically improve the speed of air testing – and the quality of four-stage clearances. The robot essentially looks like a large PCM scope. Operators conduct air tests and prepare the resulting slides as normal, but then Marvin automatically moves the optics, while some clever AI counts the fibres. Marvin uses the same rules as human analysts, and in testing he has proved himself more accurate than an average human.
Frontier created the automated technology to cope with the vast distances in Australia, where samples have to be flown back to central laboratories for analysis. This can result in big delays between an air test and being able to strike the enclosure. Doubtless Marvin addresses that issue, but I expect it could also have huge benefits in the UK.
Here, analysts are often guilty of thinking that the air test (stage three) is the most important part of the four-stage clearance. In fact, their primary focus needs to be on stage two (the visual inspection). If we were to take analysis of the air test away from analysts, they would be able to focus their attention specifically on the part of the clearance that makes the most difference to the result.
Despite the promise of new technology and techniques, it’s sobering to be reminded of the scale of the public health challenge that asbestos still presents. Professor Jukka Takala, president of the International Commission on Occupational Health (ICOH), gave a dramatic review of the latest figures describing the asbestos disaster.
And disaster it is: each year asbestos causes 255,000 deaths worldwide, and the direct global costs for asbestos-related sickness, early retirement and death are estimated at an eye-watering $1.14 trillion (£880 billion). Taken across the EU and western European countries, it’s equivalent to 0.7% of gross domestic product (GDP).
For many of us, these sobering figures are a reminder of why we work in this industry, and the scale of the challenges that face us as we try to keep workers and the public safe from this deadly material. They’re also a reminder of the importance of focused and leading-edge events such as the EAF conference – a chance for all of us to learn from some of the very best sources there are.
This year’s event concluded with the customary thanks and awards. There was a focus on Professor Arthur Frank, one of the world’s leading experts, who has dedicated his life to researching and writing on occupational health, toxicology and asbestos. Arthur was deservadly given the EAF Recognition Award – a fitting acknowledgement of the importance of his work.
All that remained was a fantastic conference dinner. Within our small industry, among a group of like-minded specialists, experts and advocates, it felt more like dinner with friends.
Don’t miss out on the latest thinking in asbestos, construction and health & safety. Check out our regularly updated list of conferences, seminars and other events.
Written by Nick Garland on Tuesday December 10th 2019
2019 marked the 20th anniversary of the UK’s total ban on asbestos, and – perhaps – the first tentative signs that asbestos deaths have peaked. Much to celebrate, then, but the year also saw upheaval in asbestos management, with the HSE’s long-overdue overhaul of the licensing regime becoming a talking point for the wrong reasons. Here’s our review of the year.
Back on 24 November 1999, the UK’s ban on importing and using asbestos finally came into effect. This year marked the ban’s twentieth anniversary, but sadly our use of asbestos is far from a historic problem. For a start, it’s endemic throughout our built environment, so in February we asked various industry experts: Is an asbestos-free world possible?
As we discovered, the reality is that there is neither the capability nor the budget to remove asbestos from the entire built environment, but is there a case for selectively removing it? In particular, more than 85% of the UK’s schools contain asbestos. In April we asked whether in this unique environment the current ‘manage in situ’ approach was good enough – read our asbestos in schools article here.
Within the asbestos-removal industry, the ban’s anniversary was undoubtedly overshadowed by the Health and Safety Executive (HSE)’s plans to overhaul the licensing system. This permissioning regime controls who can perform most asbestos-removal work, and there’s no question that it needed an update – back in 2016 I was one of many calling for a move to a single, three-year licence term, backed up by formal reviews.
In March the HSE made a bold move, introducing a three-year only licensing system in which the onus is placed more fully on the would-be licensed asbestos-removal contractor (LARC) to prove their competence. Instead of inspections, there’s a detailed online form comprising 14 sections – you can read my analysis of it here.
While there were positive elements to the new system, it quickly became clear that LARCs had little guidance on how to complete the form, resulting in huge time overheads as they dug around for information that could be relevant. For the HSE, the form’s open-ended nature meant that no two applications were alike, and LARCs quickly reported a processing backlog in which renewals were taking many weeks to complete.
From the start, I’m proud to say that Assure360 could help LARCs retrieve the proof they needed to demonstrate their competence. We moved quickly to develop a custom module, specifically designed to provide the exact information the HSE needed for each section of the form – at the touch of a button. We’ve now helped multiple clients through renewal under the new regime, and as it begins to mature and improve we’re working with the HSE to further develop our support.
2019 was the first full year for the Assure360 Paperless app, and it’s a pleasure to hear from clients how it continues to help them work more efficiently on site, and eliminate paperwork back at the office. Below we’ve highlighted just some of this feedback below – for each you can click the link to read the full case study.
Already, some 15% of all LARCs use Paperless, and more than one in ten licence applications to the HSE are submitted using the Assure360 system, but we’re not sitting still. Unique to Paperless, we’ve introduced a new Personal Monitoring feature that helps LARCs develop real strategies for personal monitoring that reflect operatives’ true exposure levels. Aside from ensuring that monitoring is effective, it ensures that monitoring programmes adapt to reflect what’s actually happening on site, helping minimise and manage exposure risks.
And what of 2020? There’s already a packed event schedule for the year ahead – you can see many of the key dates in our frequently updated events calendar. We’ll be rolling out further improvements to Assure360 and, I’m delighted to announce, introducing Android versions of all three Assure360 apps: Audit, Paperless and Incident. There’s much to look forward to, but for now let me wish you a merry Christmas, and a happy and safe new year.