Written by Nick Garland on Tuesday July 23rd 2019
Amianto Services is fast growing to become one of the leaders in asbestos removal in North West England. Founded in 2017 as part of the Carroll Group, Amianto’s strategy is to achieve growth by building and maintaining a reputation for efficiency, safety, and excellence.
Key to this is the innovative and professional approach of Managing Director Tony Loughran, an 18-year veteran of the asbestos removal industry. Under Tony’s leadership, Amianto has already achieved milestones such as Alcumus SafeContractor accreditation, and a full Health and Safety Executive (HSE) asbestos removal licence, which for those who don’t know, enables the company to undertake high-risk asbestos removal work.
While many long-established asbestos removal companies struggle with outdated systems and legacy workflows, as a new company Amianto Services was able to begin with a blank slate. Given its ambitious strategy for growth, a core challenge would be to ensure that the company’s safety-critical checks and mandatory record-keeping could be managed in a streamlined and efficient way that would scale to support the growing business.
Tony Loughran was already familiar with the advanced auditing features of Assure360, and was keen to evaluate the system’s ability to help manage the workflows involved in running and growing the company. Specifically, Tony wanted to assess whether Assure360 Paperless could help him minimise the administrative overheads faced by his site supervisors and the back office team. Another key requirement would be that any system should help Tony and his team demonstrate their competence to the HSE during their initial asbestos removal licence application.
The Assure360 team was able to quickly demonstrate that Assure360 is an effective and streamlined management solution for today’s asbestos removal industry. Integrating auditing, trend analysis, competence and training needs with accident, incident and near-miss reporting, the suite provides the essential tools for effective asbestos removal and health and safety management. In addition, Amianto Services was quickly satisfied that the new Assure360 Paperless app was the tool it needed to help manage safety-critical checks and record-keeping, both at launch, and as the company grew and scaled up its operations.
Amianto Services became a full Assure360 customer, and the Assure360 team was quick to tailor the solution to support the efficient and thorough workflows Tony Loughran wanted to implement in the business. The team offered support in the run up to the critical licence application with the HSE, after which Amianto Services was immediately granted its first one year licence with no conditions. It remains on-hand to support Amianto as it further refines and improves its operations. In particular, using Assure360, Amianto will be able to provide all the evidence that the new licence regime could possibly demand – at the touch of a button.
I’d had previous good experience with Assure360’s auditing capabilities, and thought from the outset that the suite might prove an invaluable tool as we built an efficient and streamlined asbestos removal company. The results have been fantastic – the software ticks all of our boxes, and Assure360 continues to add new features that fit really well with the way we want to work.
One of the best things about the Assure360 system is that the people are available, and always willing to help. They’re very knowledgeable, both from a programming perspective but also with their experience of the industry we work in. They’ve helped tailor the system to suit some specific requirements we had, and if anything ever comes up the team is straight on it. They were very supportive ahead of our HSE licence inspection, and the system really helped us demonstrate our competence.
As we grow, Assure360 is on hand to help train up our new staff. Assure360 Paperless is really proving its worth here, too. For us it was essential to avoid a situation where hiring more supervisors and operatives resulted in a log-jam of paperwork on site and back at the office. Paperless has helped us build smooth processes around our critical site checks and record keeping, and the app will be a fundamental part of helping us maintain quality and efficiency as we scale up.
On a personal level, I’m made up with it – and excited to think about what I can do next with our business.
● Tony Loughran
● Managing Director
Written by Nick Garland on Monday June 24th 2019
The Health and Safety Executive (HSE) is in the middle of one of the biggest shakeups of asbestos licensing since the permissioning regime was introduced. I’ve already written about what’s changing, but I want to expand more on how Assure360 is better placed than ever to help customers through the whole licence application process.
The new electronic system of asbestos licence assessments is well into its trial, with multiple organisations already having experienced it. The whole process is radically different for applicants, with much more emphasis being placed on a review of the application and its supporting evidence than on the meeting itself.
When I first heard of the change I was very sceptical – and I know some HSE inspectors have had their doubts. There are obvious advantages to testing the mettle of a potential licensee whilst the asbestos licensing principle inspector (ALPI) looks them in the eye. But there have long been concerns over consistency in the current system, with some areas reputed to be much more rigorous than others. In the new regime, assessments are triaged by a central team, which should help in this regard.
The focus is now on providing evidence to support a licence application and, as at least one HSE inspector has observed, Assure360’s entire premise is to provide information to support sensible decisions. Its power is made even clearer with the new regime. The ability of Assure360 to support the bid – whether at the basic Silver or the fuller Gold and Platinum levels – is clear.
So what can you expect from the new application form? Here’s a brief overview of each section, with an explanation of how Assure360 can help both with your approach, and with providing the evidence that the HSE expects to see. It’s worth noting that the form comes with dire warnings to anyone tempted to use a consultant to complete it: there are grave consequences, potentially including licence revocation.
The first few sections of the application form are fairly broad, asking for details on who will be in the meeting and other key individuals who aren’t going to be present. It also asks what sources of information, legislation and literature you rely on. There are no ‘correct’ answers for any of these – they establish who the controlling minds are in your business, and how you stay abreast of changes and improvements in the industry.
So what helps here? Being a member of a trade organisation helps demonstrate a commitment to higher standards, while attending regional meetings can be an excellent opportunity to share experiences with like-minded professionals. I give out updates via my monthly newsletter (if you haven’t signed up – add your email at the bottom of this page). I also publish safety alerts.
By section four, the application form really starts to test your competence as an organisation by looking at plans of work. The HSE specifically asks for two different examples, and states that they should relate to jobs that you do.
What the form doesn’t say explicitly is that despite it being only two, they should cover all of the different types of job that you do. For example, if you have completed 100 asbestos insulating board (AIB) jobs and one pipe insulation removal, don’t submit two AIB jobs. What you do if your work extends beyond two types of job isn’t entirely clear.
After Section four, Assure360 becomes invaluable in your efforts to demonstrate and evidence your competence as a licensed contractor. Without it you’ll be scrabbling around for paper evidence, but with it, everything is at your fingertips. It’s up to you how you submit evidence, either printing it off or giving the HSE a read-only link to the correct page of the system. There is even a page dedicated to the licence application, in which we’ve mapped out the correct reports against each section in the application form.
These sections are all about site and equipment checks. Ordinarily you’d provide the site files – coffee stains, spelling mistakes and all, and you’d need to scan every page and save them as PDFs. A potential pitfall is the size limit on emails you can send to the HSE. The form states a maximum 25MB, but the real limit seems to vary – with some people reporting less than 12MB.
However, with Assure360 Paperless all of the plant, equipment and site checks are at your fingertips, and you can show them to the HSE. A few clicks will allow inspectors to see absolutely all the relevant checks completed on a site. The feature isn’t just restricted to plant and equipment – it covers enclosure checks and smoke tests too. All certificates completed in the Paperless app are uploaded directly to the project file and are time and date stamped. The App even helps with spelling.
Section seven deals with respiratory protective equipment (RPE), personal protective equipment (PPE) and air monitoring. Understanding and recording this has always been a problem for the industry, but it was one of the first things that Assure360 cracked.
Within two minutes, Assure360 users can provide detailed evidence of:
Just imagine trying to explain all of that with only an Excel spreadsheet!
This section covers health records and medicals. It’s an area that we don’t yet cover, but Assure360 is developing all of the time. Coming soon there will be a full personnel management system, which will be free to all subscribers.
These sections cover leadership and management – often difficult concepts to get your head around, never mind explain in writing. Again, Assure360 is there to provide evidence to backup your words. At the touch of a button you can display exactly what you are observing on site. You can show all of the non-conformances from all of your audits, including what you did to rectify on site and, critically, what you did to ensure they wouldn’t happen again.
With Assure360’s unique benchmark tool you can also spot what the entire army of Assure360 auditors are encountering, across the country. Being forewarned of developing problems allows you to plan to avoid issues and mitigate risk. This constitutes evidence of a proactive approach to health and safety management, and demonstrates your ability to look beyond just your company. Remember that this links in with one of the questions in the form’s early sections, on how you get your health and safety information.
Using Assure360 you can illustrate how many times your contract managers, senior management and even directors attend site. It’s seconds’ work to present the data in a colourful chart showing how many audits the entire team are doing, and providing direct evidence of senior management’s attendance on site and involvement in health and safety.
The final benefit is that you can remap all of the above information to reflect training needs for the individuals across your business. More on that in the next section.
Section 11 is all about training and competence. Assure360 is built around effective auditing, and the first thing we made the data do was drive competence. Providing evidence for all your assessments and training needs analysis is extremely straightforward. Within minutes you can present:
With Assure360 you can present a competence scheme that encompasses everyone in the organisation – not just supervisors and operatives. It is so comprehensive that it exceeds the HSE’s expectations.
The final section focuses on reviewing and measuring performance. As I said, auditing is the emotional home of Assure360. Auditing with the system saves about two hours compared to the traditional paper and Excel route. Add to this the fact that the database automatically interprets and re-interprets all of the observations and it’s the health and safety manager’s dream.
When it comes to the new licence assessment system, this section represents exactly what Assure360 was designed for:
Trend analysis – company as a whole, individuals, specific competencies and non conformances
Setting health and safety targets – you can move beyond the standard ‘no RIDDOR’ and ‘no enforcement action’ to set imaginative targets and evidence trends in performance at the individual level
What’s your strategy and are you hitting it? – evidence your success through simple one-click reports
This section also covers personal monitoring, through direct assessment of the method. Assure360’s personal monitoring module can be harnessed to show how you assess every aspect of each project. Users can generate reports to show only the personals that exceeded what was expected, along with links to reveal what was done about it, the assessed root cause, and any supporting evidence.
The HSE is still testing its new licence regime, with current developments officially regarded as a pilot scheme. Doubtless the system will be revised and refined before going ‘final’, but for LARCs renewing their licence it already requires a new approach.
For companies struggling with old, paper-based systems, the licencing regime’s increased focus on excellent record keeping, analysis and management competence is a challenge. However, Assure360 customers not only have the best tool for managing all aspects of asbestos removal, but the best tool for documenting, analysing and demonstrating their competence at doing so.
Written by Nick Garland on Thursday June 13th 2019
For some years, there’s been a question mark hanging over the Health and Safety Executive’s licensing regime for asbestos removal. With variable licence periods creating confusion among clients and an unintended hierarchy being created within the industry, attempts to overhaul the system are to be welcomed by everyone.
For those who don’t know, the existing system is a permissioning regime. Would-be licenced asbestos-removal contractors (LARCs) and those who want to renew must demonstrate to the HSE that they have the necessary skills, competency, expertise, knowledge and experience of work with asbestos, together with excellent health and safety management systems. The outcome is either no licence, a three-year licence, or any period between. Additional conditions are sometimes attached.
It sounds simple enough, but there are multiple problems. While nobody is meant to infer anything about competency from a company’s licence term, in practice customers choosing a LARC often treat the full three-year licence as a prerequisite. In addition, LARCs can’t notify a project that extends beyond their licence period – that means that bidding for complex, two-year-plus jobs is effectively restricted to the 35% or so of LARCs with a three-year licence.
Against this, in recent years the HSE has been less inclined to give out three-year licences. Among other things, that’s resulted in an increased workload for inspectors as they conduct more regular licence inspections. There’s a burden for LARCs, too, as there’s a considerable cost and administrative overhead to each licence application.
It’s no surprise that the HSE wants to shake things up. It’s already started to pilot a new regime that shifts the onus away from licence inspections, and more onto LARCs to provide evidence of their competency. In the new system, first-time applicants still get inspected, whereas existing LARCs re-apply via an electronic form.
A couple of years ago I called for an end to the fixed-term licence, and the introduction of monitoring visits. Essentially if you’re good enough, you get a licence. If not – you don’t. it’s recently emerged that in the pilot scheme the HSE are moving towards just that. As ACAD’s Graham Warren explains in a LinkedIn blog post:
“Some eagle-eyed people have been asking ACAD why all renewals [under the electronic pilot scheme] seem to be issued the full three-year term. HSE have confirmed this is not some chance occurrence, but actually how the new system works.”
At renewal, companies either won’t get a licence, or they’ll be licenced for the now-standard three-years. This doesn’t necessarily mean that LARCs that would previously have received a one or two-year licence will be turned down. In all cases where a company is judged competent, the HSE will issue a three-year licence, but it may require a formal review to ensure any improvements are fully implemented. Crucially, this review period will remain confidential, unless the LARC fails to make the required improvements, so it won’t affect the LARC’s ability to compete for contracts.
The change is virtually what I called for, and it’s a vast improvement. By settling on a single, three-year period, the HSE will reduce the confusion among clients who see one and two year licences as less of a vote of confidence. Moving the major work of re-licencing onto a three-year cycle will reduce the burden for LARCs, allowing them to concentrate on making the improvements the HSE wants to see at the review meeting.
For the HSE, it means less licence inspection work, and a relief from the commercial pressures to grant three-year licences to the biggest contractors, who may previously have needed them to bid for the most complex works. A more centralised approach by the HSE (all applications are reviewed by a single team) will mean much more consistency, too.
As Graham points out in his post, there may be some interesting consequences. With clients no longer able to select LARCs by licence duration, they’re likely to look for other ways to determine which companies are working to deliver the highest standards. Being able to demonstrate fastidious record keeping, management and analysis – for example through membership of a trade body such as ACAD – will become more of a competitive edge.
Assure360 can really help here, too. Our data-based system makes it easier not only for LARCs to manage asbestos removal, but for them to demonstrate the high quality of their training, competency, and analysis of key safety factors such as exposure monitoring.
In fact the new regime fits seamlessly with the Assure360 ethos. Being a health and safety system, specifically designed by asbestos industry experts for the asbestos industry, Assure360 has always allowed you to showcase your expertise. Vast quantities of evidence are now required in advance of the licence assessment, and Assure360 customers can simply provide it by running a series of reports. The database presents all the proof that the HSE could ever ask for. And with the new Paperless solution, even site files can be viewed with real date and time stamps on the certification.
We’ve got a great track record of helping clients prepare for, and excel at licence renewal: under the existing scheme our customers have consistently proven far more likely to achieve three-year licences. Under the new regime Assure360 will streamline the process even further, as our reports are mapped against the questions the HSE are asking.
So if you’re applying for a first-time licence, or preparing to renew an existing one, why not get in touch and see how we can help?
Assure360 will be at the Contamination Expo on the 11th and 12th of September – stand J7, directly opposite ACAD. So if you’re looking for guidance and insight into the new process, pitfalls to avoid and strategies to help – there couldn’t be a better first port of call.
I will also be speaking on the first day – 12:30 – 13:00 at Theatre 21 The subject – you guessed it is the only one that matters right now, the New Asbestos Licencing system and how electronic solutions can help.
Written by Nick Garland on Wednesday May 29th 2019
We’re not alone in having wondered whether the HSE’s asbestos licensing system was entirely fit for purpose. With three possible licence durations and multiple conditions that can be attached, clients often use a LARC’s licence as a shortcut to judging competence. Re-inspection as frequently as every year creates lots of work, both for the LARC and the HSE, and doesn’t necessarily result in raised standards.
A couple of years ago, founder Nick Garland called on the HSE to settle on a standard three-year licence, backed up with formal reviews. It’s recently emerged that’s exactly what’s happening in the HSE’s electronic licensing pilot – in this article, Nick explains some of the benefits and consequences.
Note: The post below was originally published by Nick Garland on LinkedIn in 2016. You can click here to read the original post.
The licence terms awarded to asbestos contractors have reduced year on year. I examine the latest data and offer an opinion on a better way forward.
A phrase every LARC will be familiar with, as it seems to be in all letters written by the HSE. One of the principle purposes of such a regime is to:
“…maintaining and improving standards of health and safety”
The Health and Safety Commission permissioning regime policy statement
Maintain and improve standards of H&S, presumably by weeding out the incompetent and promoting best practice. But why then are average licence terms shorter now than they were? I have been in the asbestos industry since the early 1990s, and I’ve definitely noticed the change. Can we infer that the HSE’s opinion is that the industry is less safe and less competent than it was?
Licence assessments can be a very unpredictable time. All of the companies that I work with have heard of, or experienced extremely intense assessment interviews, but at the same time hear of laissez faire ones with very little detailed examination. Requests (demands) from the ALPIs is often insightful but can also be bizarrely arbitrary, with little practical application. One licence assessment ended up insisting that filing cabinets be used (rather than the perfectly acceptable system the LARC already had) – resulting in the conversion of the one and only meeting room into an archive room.
We all know anecdotally that it has become harder and harder to get the ‘full’ three-year licence from the HSE, but the latest figures are quite stark.
ALG figures, supplied by ACAD.
ALG figures, supplied by ACAD.
Excluding new licences (always one year) there has been an alarming drop of 23% in three-year licences issued in that period.
ALG figures, supplied by ACAD.
In my experience the industry, whilst there are some bad eggs, is getting much better. When I think back to the beginning of my career, where it seemed everyone had a three-year licence – the differences are remarkable. Now projects consider the wider job and recognise non-asbestos hazards. In fact, it seems a different industry with most of the stories of astonishing individual poor practice in the past.
So, if we are not getting any worse and the principle aim of a permissioning regime is to drive standards, why are the licence terms going down?
Could it simply be that there are less licensed contractors out there and the HSE want to exert more control. A tighter leash if you like? Certainly, the tone of some licence assessments and HSE visits indicate this.
The HSE tell the wider construction industry (and clients) that they shouldn’t use the licence term as a tool for selection. If the company has been given a licence (any licence) that indicates that they (the HSE) are satisfied and this should be good enough. The clients however (quite reasonably) take the view that well if you are concerned enough that you won’t give them a 3-year licence, then we are concerned too.
A licence holder can’t notify a project that extends beyond the licence expiry date.
We add then that the HSE publish the expiry date of licences – so if you track these things, you can plot a company’s standing. A client also instantly sees which companies can notify the project that they are considering. This might not seem a big concern, but very complex major works, might require 2+ years to complete – knocking out 65% of contractors.
With this in mind – are the HSE less inclined to reduce the term for a huge company? Do they back away when a downward tweak might stop a multi-million £ job in a power station? Certainly ‘the word’ is that they do.
The licence term is certainly a commercial driver.
In my opinion the HSE should remove the fixed term licence. The HSE should assess a company and give, or withhold a licence based on the interview and past performance during site visits. These licences should not expire (I hear howls of outrage).
What should replace it is a tailored review schedule for that specific contractor. Essentially, ‘Yes we are content for you to work with asbestos, but we want to see you again in 6 months, or 12 months or 3 years, just to make sure things stay on track’. A structured plan could therefore be put in place on what improvements must be implemented before the next monitoring visit.
The monitoring schedule would not be published and would not appear on the licence itself. This therefore could not be used for contractor selection. The pressure would be released from the HSE to grant 3 year licences for commercial reasons. There would be no issue of notifying jobs beyond the end of the licence expiry date – as there won’t be one. The HSE can concentrate on maintain and improving standards and do so in a much more structured way.
As I say this is an opinion piece, and I would welcome everyone’s thoughts and feedback.
I have been in the asbestos industry since the early 1990s, helping licensed asbestos removal contractors stay at the forefront of the industry.
Written by Nick Garland on Wednesday April 10th 2019
Schools are unique. In law, a school is a workplace, but the majority of people using them are children – sometimes as young as three. Despite the known vulnerability of children to pollutants, contaminants and other environmental hazards, when it comes to asbestos, schools are treated as just another workplace: they’re subject to workplace asbestos fibre limits, regulations and management approaches. And that’s a problem – both for our children, and the professionals who teach them.
Figures gathered by the National Union of Teachers’ Joint Union Asbestos Committee (JUAC) reveal that, since 1980, at least 363 of British school teaching professionals have died of mesothelioma, the cancer almost exclusively linked to asbestos exposure. An average of 19 school teaching professionals now die each year from mesothelioma – up from three per year in 1980.
There are no equivalent figures for children, but we do know that each year around 2,500 people die in the UK from mesothelioma. Giving evidence to the Education Select Committee in March 2013, Professor Julian Peto – a leading expert in occupational carcinogens – estimated that around 200-300 of these deaths are the result of childhood exposure to asbestos in school.
The shocking figures are compounded by the fact that the onset of mesothelioma typically comes decades after the asbestos exposure which caused it. While the incidence of the disease in the general population is finally thought to be nearing a plateau – 20 years after the UK banned all asbestos imports and use – there’s no clear indication that the same applies to school-related cases.
The authorities can’t claim to be unaware of this risk. Back in 2011 the Asbestos in Schools Group – a multi-agency organisation chaired by MP Rachel Reeves – was damning, its report concluding:
Forty five years ago the Department for Education [was] warned about the increased vulnerability to children from asbestos, but for financial, commercial and political reasons the warnings were not heeded. Instead asbestos materials continued to be used in science and other lessons, and schools continued to be built using large amounts of asbestos.
Unfortunately it’s not just a historic problem. Scan the news for asbestos headlines, and on any given day you’re likely to find at least one story about asbestos being discovered, disturbed or removed at a UK school. Indeed, according to MP Meg Hillier, chair of the Parliamentary Public Accounts Committee, 85% of schools contain asbestos, and the risks become greater as those buildings age.
At present, the answer is not enough. Parliament says that the government doesn’t have enough information to address the problem, and it may have a point. The Department for Education’s first school property survey did not assess asbestos, and in 2016, when a second survey aimed to collect data on the issue, only a quarter of schools responded. When a third survey closed in 2018, 77% of schools had responded. Given the importance of the information, the survey was reopened and all remaining schools were urged to respond – the final results are due soon.
There’s no doubt the government needs more information, but there is a question over whether the survey will provide it. The safe management of asbestos-containing materials (ACMs) is a school’s legal duty, and the fact that they are hardly being forthcoming with high-level information about the presence and management of ACMs is concerning. Some multi-academy trusts (MATs) couldn’t even gather information about their private finance initiative (PFI) schools, which shows a worrying lack of accountability.
The detail of what is known isn’t especially reassuring, either. Of the 77% of schools which responded within the original deadline of the most recent survey, 68% were found to be “assured by the appropriate responsible body”. It’s a singularly woolly phrase, which means nothing to asbestos professionals.
According to the JUAC, “These latest findings show that many schools are unaware of the risk or the extent of asbestos in our schools.” With the poor response to the government’s latest survey, can we be confident that this has got any better?
But while the survey leaves us in the dark, we do know that most schools contain some form of asbestos. The UK outlawed the majority of the most hazardous asbestos types in the 1980s, but the final banning of all asbestos – including asbestos cement, floor tiles, artex and so on – only came in 1999. Any school built before 2000 could – and probably does – contain asbestos.
Sophie Ward sums up the fundamental issue: “The problem is that in many cases the asbestos is decades old and in a deteriorating condition, and when asbestos is in a poor condition, it’s more likely to release asbestos fibres.”
Children’s comparative vulnerability compounds the problem. Ward adds: “If a child is exposed at the age of five, they have five times greater risk [of developing mesothelioma] than an adult exposed at the age of 30.”
Against this background, it’s instructive to look at the Health and Safety Executive (HSE) advice to schools regarding asbestos, as follows:
The duty-holder’s responsibilities include:
Those most at risk of disturbing ACMs are tradespeople, caretakers, etc. The school’s plan needs to contain provisions to ensure that information about the location and condition of ACMs is given to anyone who might disturb these materials. The duty-holder should also ensure that staff likely to disturb asbestos are suitably trained.
As the Asbestos in Schools group pointed out back in 2011, aside from the addition of caretakers this is essentially the same advice that applies to any other employer. As with other premises, ACMs assessed as low-risk are managed in situ.
In an ordinary workplace, that can work very well. Surveyed, recorded and managed properly, ACMs should pose no risk – provided the management plan ensures that they remain undisturbed. Proper management starts with a management team that has the training and experience to properly understand the risk, and design and implement appropriate controls. Even in typical workplaces, that’s a big task.
A key component is identifying the people who might come into contact with any risk, and ensuring they know what that risk is. Anyone who might disturb the asbestos must have asbestos awareness training. In a normal workplace this would be the workforce, with tight controls for visitors and contractors. However, where the ACMs are in a classroom or a school corridor, the risk extends to children. The current rules require that this ‘workforce’ is trained – but clearly it’s hard to train away the risks of play, over-excitement, or a casually swung schoolbag.
Schools are essentially small businesses: employers, with all the duties of employment. Head teachers already have daunting responsibilities: is it reasonable to also expect them to manage asbestos for vulnerable building users? And yet, since The Control of Asbestos Regulations 2012, that’s become their duty. We have to wonder if heads are aware of this sea change in responsibility: have they been trained to take on the role, and are they properly resourced to fulfil it?
Again, the Asbestos in Schools group has been damning:
There has been a lack of asbestos awareness and a lack of resources so that schools have failed to adequately manage their asbestos. Numerous asbestos incidents have occurred and the exposure of the occupants has been widespread. The Medical Research Council concluded that it is not unreasonable to assume that the entire school population has been exposed to asbestos in school buildings. Teachers, support staff and children have subsequently died.
If our schools’ managers aren’t competent to manage asbestos, and the majority of our school population can’t be considered competent around it, and the government doesn’t know the scale of the problem anyway, managed removal would seem to be the only justifiable approach. Concerning a high proportion of the UK’s 32,000 schools it would be a big, expensive, time-consuming job, but our continued failure to act poses unacceptable risks to the most vulnerable in our society, and the professionals who teach and care for them.
Written by Nick Garland on Wednesday April 10th 2019
It is – or it should be – easy to identify when you’re working at height, but when does a work area constitute a confined space? You might think it’s equally obvious, but the seemingly subtle change in the regulations that occurred in 2014 has made some dramatic changes in what is and what isn’t a Confined Space.
For a workspace to be considered confined, there must be restricted access AND risk of one of five proscribed hazards:
A basement boiler house, for example, is largely enclosed and might have restricted access, but if the heat is turned off, it’s unlikely to be a confined space for the purposes of the Health and Safety Executive (HSE) guidance.
When the HSE updated its confined spaces ACoP (approved code of practice) in 2014, it specifically added asbestos-removal enclosures to the list of ‘largely enclosed’ areas which could be considered Confined under the guidance. Since then, all enclosures should have communication and escape procedures specific to that situation. Standard enclosures can be covered by standard procedures, but as soon as you add in a loft ladder it needs to be bespoke.
Because the first (enclosed) trigger is automatic for all enclosures, the risk of stale air, hot conditions, or fire will qualify many more asbestos projects. If the hazards can’t be avoided – for example by isolating heat sources or using different equipment – the confined space code of practice needs to be followed. That does not mean escape kits and tripods on all sites – but it does mean you need to specifically address the identified hazard, eliminate or mitigate it and factor it into your emergency procedures.
Some unusual work areas will now count as Confined, whereas others that were considered to qualify do not. An open air enclosure, in the height of summer – will be Confined because of the risk of heat exhaustion. A subterranean duct might not be!
Written by Nick Garland on Wednesday March 13th 2019
What is the point of the four-stage clearance (4SC)? It’s a serious question. If the point of removing asbestos-containing materials (ACMs) is to make an area safe for the people who want to live or work there, then the 4SC isn’t just boxes to tick on a form – it’s the final, critical part of ensuring that the area is actually now safe.
As a legally mandated check, the 4SC is there as an independently executed analysis of the licensed asbestos-removal contractor’s (LARC’s) removal and cleaning processes. If we can’t trust it to work, we can’t have faith in any of our asbestos-removal framework.
The Health and Safety Executive (HSE) knows this only too well, which is why in 2014/15 it conducted a thorough study into analytical practice in the industry. Finally, the report is out – although the November 2018 publication is still marked as a draft. What does it say, what can we conclude, and what comes next? Here’s my analysis.
First, some background. The 4SC is a legal requirement after any licensed asbestos removal work. It must be conducted independently, by a qualified analyst working either for the LARC (contractually, rather than directly), or the client themselves. It’s a test of the enclosed area within which controlled asbestos-removal has taken place and, obviously, it comprises four elements:
The second stage is widely accepted as the most important part: if there is no visible asbestos (including dust of any kind) then the air test is likely to pass.
Previous studies and anecdotal evidence indicate that audited 4SCs fail more asbestos-removal work than unchecked ones, strongly suggesting that a watched analyst is more diligent. While that may only be human nature, our primary interest here is in establishing a reliable quality standard. With something this safety critical, training and procedures need to work together to ensure consistent standards across all 4SCs.
The HSE’s investigation sought to explore if and where the current systems were failing, and establish how to rectify any problems. Its first step was high-level information gathering in the form of a questionnaire sent to all (as of 2013) asbestos labs. This was followed up by 22 head office visits, and 20 site inspections during 4SCs. The very first thing this tells us is that if not actually volunteers, all of the participants had at least some warning before they got involved.
In all, approximately 70% of analyst organisations gave information, and 15% of organisations received a head office and inspection visit. When in 2017 the HSE’s Dr Martin Gibson revealed some of the early findings, he made it clear that avoiding the questionnaire did not reduce the chance of getting a visit – quite the reverse, I would hope!
The HSE reports some raw stats:
Three-quarters (75%) of the companies reported that less than 20% of all 4SCs were not up to the required standard at the first time of asking. Just to clarify, that’s a LARC’s cleanup work being found inadequate in less than one in five cases. That sounds promising, but the extremes of the scale were astonishing. Two percent of labs stated that they failed over 80% of site enclosures the first time round, whereas about 10% of analysts said that they never failed clearances!
That’s a big spread, suggesting a big variation in standards, and the HSE is keen to address it. The report insists that analysts should provide photographic evidence in clearance certificates to back up their decisions. It’s a move that has long been telegraphed – and is becoming increasingly common practice.
Nearly all laboratories reported that some remedial work was always required to allow enclosures to pass at stage two (the critical visual check). Often, where this extra cleaning was ‘minor’, it was done by the analyst. But what is ‘minor’? One analyst reported cleaning, without the LARC, for over an hour.
THe HSE makes it clear – cleaning an enclosure is licensed work, and if an analyst does it they’re breaking the law.
Let’s not mince words here: the enclosure should be clean before the analyst gets to it. Not only should the operatives have cleaned it thoroughly, but the supervisor should have done their own visual inspection – just as diligently as the analyst is about to do. If it’s not clean, the LARC didn’t clean it properly, and every time this happens it should result in a failure. Only then can work standards, and those of the individual supervisor, be tracked and rectified.
The competency, or otherwise, of supervision was questioned by several of the labs, with some questioning whether supervisors had even completed their own pre-analysis visual inspection. Looking at the situation from the other side, I know that top-quality, diligent supervisors are recognised within the industry as the gold they are.
To address these process failures, the HSE is introducing two new measures:
Together these will constitute valuable management tools for LARCs who seek to monitor and improve their processes. By tracking how many HFs are issued before an area passes the 4SC, the LARC can assess the effectiveness of its own cleaning and supervision. The percentage of enclosures passed first time could even become a target for supervisors. At the same time, analysts need to be able to back up their decisions – hence the call for photographic evidence in clearance certificates.
At Assure360, we’re keen to support these processes. In Assure360 Paperless, all enclosures are formally passed (signed on the tablet) by the supervisor, and this data is emailed to management and the analyst. Once the analyst has completed their 4SC, they also sign for a pass or a fail. Because we deal in data, not ‘smart’ forms, the team can track progress in real-time, and we can report on trends at the touch of a button.
The HSE found that the understanding of personal protective equipment (PPE), primary and full decontamination was approximate. Some analysts wore normal clothing under their coveralls, and decontamination was often found to be poor, with analysts having no written procedures or training on the subject.
The report stresses that detailed written procedures must be in place for all analytical companies. These should insist that domestic clothing must not be worn inside enclosures, and they should include clear decontamination instructions – explaining when full and preliminary decontamination procedures are appropriate. They should also be followed by practical training on decontamination procedures.
What does the HSE think is suitable in this area? Read the draft report on the ACAD website, or read my Asbestos Analysts’ Guide white paper.
The HSE didn’t generally find fault with quality control, and found that in some cases QC systems were highly sophisticated. However, there were multiple flaws in the work in practice. The HSE noted incidents including:
In some cases, the HSE’s observations led to enforcement action.
Air testing procedures also showed some poor practice – predominately where analysts rushed the counting of fibres, potentially leading to under-recording of asbestos. The HSE observed this on site, but also by studying 4SC certificates after the fact.
While some of these failings could be connected to the pressures to just get the job done, to my mind the trend reveals flaws in the auditing and implementation of the QC process. If these failings happened literally in front of HSE inspectors, then they’re likely to be normal behaviour that’s been missed or ignored by the analytical companies’ own audits.
In all, by my reading of the report there seemed to be significant questions in about a fifth of site inspections. The HSE has called for a strengthening of the processes including that:
The HSE found the practice of personal sampling to be very poor – a personal bugbear of mine. 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 high, yet provides no information to understand the result. In short, it’s near useless. Some analysts stated that licensed contractors were only willing to pay for the minimum of testing, but my experience (backed up by the report) is that LARCs don’t know what to ask for.
The Analysts’ Guide, when we finally get it, will help massively in this area, but in the meantime you can read my white paper on what’s in the draft version.
In contrast, the HSE judged background monitoring to be good, with 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. This reveals a level of ignorance that still amazes me, and which isn’t restricted to analysts and LARCs. I have been in licence assessments where an HSE inspector has stated unequivocally that the a flow rate of one litre per minute is critical, and that exceeded this will invalidate the test. Wrong, but too many people believe that the rate is set according to how lungs work.
Tracy Boyle (ex-president of the British Occupational Hygiene Society) pinned Martin Gibson down on this at November’s FAAM conference. Essentially, the higher the flow rate the better. The bigger the volume of air tested, the lower the limit of quantification you can establish. These are the most important factors, and thankfully we will get clarity on them with the new analysts’ guide.
Finally, the HSE also flagged up concerns about potential overwork and conflicts of interest within the 4SC system. Compared to when I started my career, 25-odd years ago, there seem to be fewer analytical companies working directly for the LARC. Similarly the days of multiple clearances per day are also reducing, though 30% of analysts still reported completing two 4SCs per day. While three or more 4SCs in a day was very rare, four organisations admitted that it happened on more than 20 days per year.
The HSE acknowledges that by working directly for the client, rather than the LARC, analysts will avoid conflict-of-interest problems. Its report also suggests a contractual clause specifying who pays for remedial work and retesting when an enclosure fails the 4SC, removing any pressure from the analyst on site. Whether the client is the building owner or the LARC, though, poor cleaning should mean the LARC pays.
A number of companies commented that coming to an asbestos-removal job ‘cold’ interfered enormously with their ability to make a positive impact on the project. The HSE underlined the legal duty on LARCs and their clients to cooperate with the analyst, and the report recommends that the analyst be involved from the earliest stages.
Ideally, analysts would undertake a pre-removal scoping visit to feed into the LARC’s method statement, but alternatively they’d at least receive a copy of the method ahead of time so that they don’t go blind into the job.
The report’s final recommendation is that the HSE repeats the whole exercise after it publishes the final version of the new analysts’ guide. I’ve got my fingers crossed that might finally happen this summer. In the meantime it’s worth restating that I’ve based this summary on the draft version of the HSE’s analyst report, dated November 2018. I’m given to understand that it’s essentially final, subject to a spell check.
If it helps, I didn’t find any typos.
Written by Nick Garland on Wednesday March 13th 2019
Late last year the Health and Safety Executive (HSE) revised its Plan of Work (PoW) guidance – its third attempt.
The first was pretty awful, littered with duplicated effort and illogical formatting. Unfortunately, a good slice of the industry dutifully tried to implement it.
The second, Asbestos Liaison Group (ALG) memo 04/12 (commonly referred to as the ‘aide memoire’), was a huge improvement. It concentrated the contract manager’s mind on the recognised primary focus: a PoW is a tool for the site team, to help them complete the project safely.
As the aide memoire was so effective, it was a slight surprise to me that with the backlog of other priorities, the HSE was taking another run at it. So what’s the current guidance? Here’s a link to Asbestos Regulation 7 plans of work – purpose and core principles, and here’s my attempt to summarise it, and interpret some of the more controversial elements.
The first thing to note is that the memo’s target audience is the HSE’s own inspectors, rather than licensed asbestos-removal contractors (LARCs) themselves. As an internal HSE guide, expect to read language like ‘have they considered’, rather than ‘have you considered’.
But clearly, as a document outlining the approach the HSE will take to assessing PoWs, the memo is also of huge importance to contractors. We’re also told that the guidance will appear in the the new HSG247 Licensed Contractors Guide when we get it – possibly in 2020 – so it’s doubly important.
Thankfully, item two in the introduction states that: ‘A PoW should be a practical and useful document describing a safe working method for staff to follow.’
We should keep this very much in mind, as clearly the PoW will be used by others, including managers, clients, auditors, regulators, and the analyst conducting the four-stage clearance (4SC). But if the document is produced just to please the client and the regulators, and not with your supervisor and operatives at the very forefront of your mind, then it will have failed its primary purpose.
Before we get into the specifics, it’s worth drawing attention to the HSE’s guidance on making PoW documents readable and readily understood. Sensibly, it encourages the use of diagrams, flow charts and photographs as ways to provide key information and break up pages of text.
The guidance recognises different styles of the Plan of Work, from the fully self-contained, to those that make extensive reference to standard procedures. However, it cautions against the inclusion of very standard procedures, such as the bagging of waste and enclosure materials. The HSE’s logic here is that, presented with lines and lines of text covering the mundane, the site team could miss the one line of crucial detail.
The advice here is sensible, but I’d stress that a balance needs to be struck that finds the right level of detail for the team in question. Skills and experience can vary tremendously, and some workers need more guidance on basic procedure than others. If a project will involve new starters, agency staff or short-term workers (STWs), they’re going to need fuller descriptions and more information.
The guidance is structured into appendices:
All seven contain a mix of text and simple bullet points detailing what should be considered where relevant. Remember that I’m pulling out some highlights for you to consider, rather than duplicating everything: you can find the full text here.
There is a full page of bullets in this appendix, which are mostly things that a LARC would expect as standard. There are a few however, that some might have missed in the past.
While most methods include an upper maximum, the guidance is actually calling for the number of staff that will work, both within the enclosure and in support or supervisory roles outside. This is clearly much harder to put a reliable number against, and may vary as a project proceeds.
While the guidance is still only new, I’ve already seen instances where this is being requested by the HSE inspectors. The reason is the impact on how you intend to remove the waste. Will a 1m baglock be large enough to double-bag? Are other solutions to be used – e.g. passed as part of the 4SC process?
I’m going to allow myself to go slightly off topic here because I don’t think some LARCs always understand the double-bagging process. The two bags have to add up to 1,000-gauge polythene, and the outside of the outer bag can’t have been inside the enclosure. It’s this last bit that seems to pass some by. A single wrap made from 1,000-gauge polythene fulfills the first element, but not the second – so it’s not sufficient.
This is a key point. Removal of an asbestos insulating board (AIB) is different when done from a scaffold tower than it is at floor level. The method must detail all of the elements that are different – including getting that waste to the floor.
Welfare is key, and the guidance calls for it to be detailed in the method. It doesn’t matter whether it’s a one-month or one-day job, you need to consider it, make provision and detail those arrangements. This could be temporary cabins that you or the principle contractor (PC) provide – but for very short jobs it could be the use of onsite or nearby facilities.
The biggest impact in this section is where the guidance states that a PoW should detail how long the 4SC is expected to take. If we look at the analysts’ guide (which is still in draft at the time of writing): where timings are mandated, the visual inspections alone are very lengthy. The visual for a single AIB panel is predicted to take up to an hour, and as the supervisor also needs to do this before the analyst can start – a small enclosure can easily take 3-4 hours to sign off. Boiler rooms could be days.
Contractors must essentially agree in advance with the analysts the details and duration of the personal monitoring. As readers will know this is not always easy. Often the analyst is working directly for the client and not the LARC. But it is crucial to know what you want, and to train the supervisor in what to ask for.
What will the HSE’s analyst report change? Read my analysis
Identical projects in a nursing home, an empty warehouse or a demolition site will all be very different. They’ll throw up different answers to questions such as how you segregate your works from moving traffic, or vulnerable adults and children, and whether there are special hazards such as gas vents or live plant which will need to be made safe by specialists.
You will doubtless have a standard approach, but as soon as there is a working-from-height confined-space element, the standard approach won’t fit anymore. There is rarely one answer that fits all situations, and you may have to get imaginative. Sometimes, something as simple as having harnesses on hand that you can use to assist an incapacitated worker may be enough. Remember, too, that the confined space rules changed in 2015 – you can read my analysis here.
The HSE reminds its inspectors of the minimum requirements for all drawings:
In short, this appendix is all about sequencing. It is the raw planning, unique to every site, that the HSE expects to see. It involves answering questions relating to the order in which the job will be tackled. For example, if there are multiple enclosures, are they to be run simultaneously or one after the other?
The timeline needs to include hold points – very important elements of a job such as an electrical isolation, without which work cannot start, or cannot progress to the next stage.
In the case of longer jobs, the guidance also calls for a sensible breakdown of what is expected each day. If management, or the regulator, attend site on day 10, for example, they should be able to tell if the work is on target. The HSE may compare actual site progress against the schedule to draw conclusions about the standard of planning, the efficiency of the site team, or even the quality of its work.
The Timeline should contain the method proper – i.e. “We’ll do this, then this, then this” – so the HSE acknowledges that a PoW might not need a separate control measures section. Control measures could be in the timeline, in standard procedures, or even in site drawings. However you cover control measures, the following are key elements to keep at the front of your mind.
In our industry it is very easy to be blinkered. We’re experts in asbestos, and most contract managers can draft an excellent method to deal with it. But what about other hazards? Sometimes asbestos is the least of our worries. The risk assessment should always be done first, and the control measures included in the PoW.
It’s worth stressing this because it’s simply so important. Say we are dismantling an asbestos cement roof below overhead power lines: it would be very easy to design the perfect asbestos job, which endangers the lives of everyone on site. And while that’s clearly an extreme example, we commonly do work at height, in confined spaces, or near unprotected drops and other hazards. The core thing to remember is to always keep the risk assessment in mind when designing the whole project.
Beyond this critical issue, the HSE focuses on specific areas including the following:
Most of the material in the final appendix is relatively standard: it’s common to most load lists and I won’t repeat it here. There is however one unusual nugget: just listing ‘stepladder’ or ‘tower scaffold’ is not clear enough. The plan writer should specify how many treads the ladder should have, or the size and width of tower scaffolds and their working platform height. The idea is so that the right equipment can be hired, or the site crew know to load enough components.
Overall, this is a very useful document that helps focus the Plan of Work author’s mind on what is important – putting together a comprehensive plan to ensure asbestos removal work is safe and effective.
Together with the analysts’ guide it should help bring best practice situations into the mainstream, raising the standard of the PoW, and with it the quality and safety standards we can achieve across our industry.
Written by Nick Garland on Wednesday February 20th 2019
Assure360 Paperless is a powerful tool that transforms the way asbestos removal contractors work. Like most tools, the best way to see the difference it makes is with a hands-on demonstration. That’s why we’re holding free monthly webinars, where we explore and explain all the product’s brilliant features. If you’re interested, great – you can sign up here.
At the same time, we know not everyone in our industry considers themselves technical. If you’re wondering what a webinar is – let alone how the app works – don’t worry, check out our one-minute explainer video:
Sign up for the webinar and we’ll send you a link you can follow to join in from any browser. You can sit back and watch as we walk you through the product, and if you have any questions, simply type them in as they occur to you. The Assure360 Paperless webinars usually take an hour: although we stick around for as long as there are questions, you’re free to leave whenever you like.
So why not join us for our next webinar? Just click the link above to get started.
Written by Nick Garland on Wednesday February 20th 2019
More than 19 years since it was banned in the UK, asbestos remains widespread in our private and public buildings. It’s still there because removing it all presents a huge, hazardous and expensive challenge, but also because in most cases, managing it in place has been thought to be an effective safeguard.
However, despite strict rules, lapses and disturbances are common, and both workers and members of the public are still exposed to deadly fibres. There have been calls for asbestos to be removed altogether from the built environment, but such large-scale removal would inevitably involve challenges, not least of which would be the sheer cost of safely extracting and processing millions of tonnes of highly carcinogenic materials.
Asbestos is a naturally occurring mineral which we’ve used extensively: the two together mean that there’s a background atmospheric level. It raises the question: Is an asbestos-free world possible? Would it be worth the effort? Who would foot the bill? We spoke to industry experts.
The UK banned the use and import of all asbestos under the Asbestos (Prohibitions) (Amendment) Regulations 1999. Under the Control of Asbestos Regulations 2012, parliament created a legal ‘duty to manage’ asbestos in all non-domestic premises. Duty holders must:
There’s no explicit legal requirement to remove asbestos-containing material (ACM) if it can be safely managed and contained.
The current controls – backed up by Health and Safety Executive (HSE) enforcement – have been working to reduce asbestos exposure, but it hasn’t been eliminated.
In the light of ongoing incidents, in 2013 the European Parliament called for the removal of asbestos from all European public buildings by 2028. Two years later, the All-Party Parliamentary Group on Occupational Safety and Health said that UK workplaces should be made asbestos-free by 2035.
Despite this, UK and European law remains unchanged. To explain why, industry experts point to what we’ve already learned in more than 30 years of removing ACMs: it’s a risky, expensive business. Jon Chambers, QSHE compliance manager at Interserve Environmental Services, explains that the cost of removing all asbestos from all UK public buildings would run to many billions of pounds. But there are other fundamental concerns.
“The asbestos industry would not be able to cope at its current size and scope,” says Chambers. “The current UK industry standards are very high, but with increased workloads and short timescales, it’s foreseeable that standards of work would drop, [and this would directly] affect the safety of those involved in the works, and building users.”
These concerns are shared by many in the industry, including Martin Stear, a chartered occupational hygienist and fellow of the British Occupational Hygiene Society (BOHS) Faculty of Occupational Hygiene. “Removal would need to be done properly,” he says, “otherwise we would have massive problems, and years later find out that the standards [of work] were shoddy.”
There is, however, another major problem. With up to six million tonnes of asbestos thought to remain in UK buildings, removing it all would clearly overwhelm the current landfill system’s capacity to cope.
“If we remove all the asbestos, where are we going to leave it all?” asks Dr Yvonne Waterman, founder and president of the European Asbestos Forum. “Asbestos fibres do not degrade, so putting it back into the ground and covering it up is not a long-term solution.”
For Dr Waterman, the wholesale removal of asbestos would require “the policy and regulations, the manpower, the designated areas for storing asbestos, and many innovations to remove asbestos more effectively and cheaply.”
“In this context,” she warns, “2028 is practically tomorrow.”
Dr Martin Gibson, principal specialist inspector (Occupational Hygiene) at the HSE, has underlined the problem faced by the UK specifically. Speaking at the October 2017 BOHS asbestos roadshow, he noted that the UK’s industrial revolution was the world’s first. The UK was the first country to start importing asbestos on a large scale, and it imported the most: in the 1960s and 70s the UK imported 40% of the world’s capacity to produce amosite asbestos. The UK has so much asbestos that removing it all would be uniquely difficult, perhaps impossible – that’s why it has had to become so good at managing the problem.
Clearly, the safe removal of asbestos on this scale is a considerable challenge, which begs the question of whether it’s necessary. In the UK, around 5,000 people die each year from asbestos-related illness, but it’s forecast that the incidence of mesothelioma will halve between 2014 and 2035 as the UK’s 1999 ban begins to finally impact the disease.
The HSE position relies heavily on this analysis, which plots the weight of asbestos imported against the incidence of mesothelioma over time. If it’s correct, we’re at or near the peak for mesothelioma deaths, which will begin to fall in the next few years.
However, if we look at previous versions of this chart, we find that the peak has been repeatedly pushed back as death rates continued rising. Worldwide, mesothelioma mortality is showing the same kind of stubbornness, which some argue is due to increased environmental exposure despite increasingly widespread bans.
Despite effective management, continuing environmental, occupational and accidental exposure is likely to have consequences, and removing asbestos from buildings will only have an impact on the latter two. Generally, experts agree that removal is the ideal option, but only where the process is thorough, and safe for those undertaking the work.
In Europe many countries are actively pursuing ambitious programmes of removal from the built environment. In 2009, Poland embarked on a 23-year programme of asbestos abatement which includes widespread removal. In the Netherlands, the government is moving to ban – and require the removal of – all asbestos roofs by 2024. Meanwhile, the regional government of Flanders, Belgium, is implementing an ‘accelerated asbestos elimination policy’ to remove an estimated 2.09 million tonnes of high-risk ACMs by 2040.
Although none of these quite aim for ‘asbestos free’, it could be argued that they’re the necessary precursors to more widespread and complete action. In particular, despite the earlier European Parliament call, the EU is unlikely to act for some time.
“In the near future, more efforts are to be expected from individual countries than the European Union,” thinks Dr Yvonne Waterman. “The EU will, I expect, not regulate further on asbestos until its newest members have had a chance to catch up on the existing asbestos regulations – that’s a big job already.”
As pioneering and ambitious programmes, it’s not surprising that the Dutch, Belgian and Polish schemes described above face hurdles. In Poland, environmental organisations have already criticised the slow pace of asbestos removal, complaining that inventorying was incomplete and claiming that removal – theoretically due by 2032 – would drag on until 2080 at the earliest.
Even the Netherlands’ more modest scheme shows that the experts’ concerns are well-founded. Working flat-out, the Dutch asbestos removal industry lacks the necessary capacity to deal with all asbestos roofing by 2024. Not all homeowners can afford to replace their roofs, but grants are only available for roofs above a certain size – and many of these have run out already, way ahead of 2024. For others, the only option may be DIY-removal, which is permitted with some restrictions, but which may come with a counter-productive risk of greater contamination and exposure.
Holland has targeted asbestos cement roofs – because the erosion of the roofs has been found to allow asbestos fibers to be released into the air as the cement matrix deteriorates after thirty years. Also, over the years, weathering and water runoff leads to contamination of the surrounding soil. The Dutch scheme shows a potential pitfall of removal legislation: unintended consequences. Without adequate funding, this may lead to an increase in DIY roof replacement that may make the situation worse.
There are other key issues in any large-scale removal programme: cost, safety, the lack of capacity, and the need for safe disposal of ACMs. So, aside from the insights gained in these countries’ more narrowly focused attempts, what would be needed to support a national or international scheme?
For occupational hygienists like Martin Stear, it’s about setting appropriate risk-based surveying and removal standards, then ensuring they’re properly executed. “We’ve been removing asbestos on a large scale since the 1980s, but we keep going back to the areas we’ve stripped and re-cleaning them,” he says. “Areas are found to still be contaminated due to poor removal works – and sometimes even this is wrong. Sometimes an area is clean, but a surveyor has used an over-sensitive test and found some fibres.”
For compliance managers like Jon Chambers, any talk of a 10-year programme is completely unrealistic. He stresses that the industry would need guidelines and plans in place at an early stage to allow time for the necessary growth, and the required training and investment.
Addressing the problem properly would require a structured approach, he says: “I would suggest a risk-based programme where only hazardous materials are removed. Low-risk items can safely stay in situ for longer, and be removed further down the line.”
Unavoidably, any wide-ranging asbestos-removal programme would need to be enacted through legislation, and enforced and regulated by government bodies such as the HSE. As an example, Chambers suggests mandatory asbestos management plans for all public and private non-domestic buildings. “Make it a legal requirement that plans must specify the removal of all ACMs with a risk rating above a certain level, or any damaged or friable material,” he suggests.
Yvonne Waterman suggests that the key is to look at ways of making asbestos waste harmless – “We need a safe, effective and affordable denaturisation method. I am studying several quite different ones, because that is where the future of asbestos lies – being made into safe brick fillers in the circular economy. No more waste, no more dangers for future generations.
“The legislator and the asbestos-removal sector would need to work very closely together, each supporting the other. Additionally, we would need to find a safe, effective and affordable eradication method.”
In addition to the need for political will and the inherent complexity, there’s no getting away from the fact that removing all asbestos would be a colossal expense. “It is only money that could really make it work,” says Jon Chambers. “There would be a huge cost to any large-scale removal, and I have no idea where the money could come from.”
Yvonne Waterman agrees. “Eradication is hugely expensive, and we are hardly in a flush economic period. We would all like to have an asbestos-free country, but let’s be realistic: who will pay for it all?”
In a sense, however, we are – slowly – removing asbestos from the built environment. Managing in place is only possible for so long, and as ACMs reach the end of their life, or the buildings that contain them are refurbished, gradually they’re being removed. Older asbestos-containing properties are being demolished altogether. Provided the work is done with the proper controls, to the appropriate standards, the process is constantly reducing the amount of asbestos still ‘out there’, and lowering the risk of exposure. “Over the past decades, we can see that the air quality in terms of asbestos fibres in the Netherlands is improving considerably. This proves that the asbestos ban and regulations are effective.”, says Yvonne Waterman.
We’d all like to see faster progress, and perhaps in different times there will be the political will to pay for it. In the meantime, Jon Chambers reminds us of the simple, vital reason for the industry to carry on with its work: “The removal of asbestos safely will save lives in the long run.”
Header image by Flickr user Chilanga Cement, Creative Commons
Written by Nick Garland on Sunday December 23rd 2018
Horizon Environmental Ltd is a private, independent company led by a management team with many years of providing asbestos removal and environmental services to the domestic, commercial and industrial sectors. Horizon has grown rapidly over the past five years, routinely undertaking very large complex projects. Horizon is dedicated to maintaining the highest standards in all dealings with employees, customers, suppliers and the public. It believes in upholding practices that create long-term value, and which enhance Horizon’s reputation for safety, integrity, and professionalism.
The team had grown significantly in recent years and alongside this expansion came additional asbestos removal auditing paperwork for everyone. In particular, the burden of site specific paperwork fell to the supervisors and leadership team, who were tasked with overseeing multiple asbestos removal audits and large amounts of related auditing paperwork and admin.
As an extremely competent and experienced team, with a three-year licence, they were always looking for ways to improve and be more efficient. They knew their paper system, whilst laborious was essential, but felt that there had to be an alternative.
Horizon were keen to get some support from an expert provider and find a solution that could save their supervisors time, while being easy to roll-out across the business without requiring large amounts of training. The also wanted something that could be installed without spending large amounts of money on new equipment.
Horizon decided to rollout the Assure360 Paperless app in Autumn 2018 and, following advice from the technical support team, assigned a few of their supervisors to get training and support the roll-out across the organisation. This rollout took just a matter of days.
With the introduction of Assure360’s Paperless App, the team had a digital support tool that meant Horizon’s supervisors could eliminate all their asbestos removal paperwork and record safety critical checks including everything from site registers, times sheets and inductions to exposure, RPE checks and site diaries through the app.
Not only did the team become more efficient and productive, they were able to get rid of their bulky folders with reams of paper and use their iPads instead. It was a perfect asbestos removal solution for the team and one that the supervisors believe has been transformative for the business.
One supervisor, Craig Toomer, who had over 12 years in the industry, was one of the super-users appointed to get Paperless set up. He was an ideal superuser, as he knew first-hand the amount of paperwork, rigorous tracking and time the auditing process entails. Despite how time consuming and inefficient their existing paper system was, he knew that a lot of people in the organisation were familiar with it and might be reluctant to change.
He also knew that a lot of the team were technophobes and were not 100% confident when it came to software and apps; himself included.
‘At first I was very daunted when I heard what was going to happen. I’m not very technical. I can use my iPhone but that’s about it,’ Craig said. ‘I have to say I was taken aback by how simple it was. I picked it up very quickly and now I much prefer it to paper.’
‘The extra time it gives me to supervise them makes my life so much easier. I’ve been using the Gold version, which deals with all of the personnel checks, RPE checks, timesheets, site register and exposure and can’t fault it.
‘It’s also means I have everything on an iPad rather than a huge site folder. Even on a short project it saves me a huge amount of time. I can’t wait for the full Platinum version, which will take care of plant and enclosure checks as well. I am confident it will be absolutely superb.’
Craig Toomer
Supervisor
Want to see how Assure360 Paperless could cut through paperwork and unlock efficiencies in your business? Discover more in our free monthly webinars“.
Written by Nick Garland on Thursday November 29th 2018
The inaugural FAAM (Faculty of Asbestos Assessment and Management) conference on 8 – 9 November lived up to expectation. Not just a one day seminar, this was a rigorous academic conference with internationally recognised speakers.
The asbestos conference opened with the inspiring Mavis Nye, the first mesothelioma patient to enter remission and the founder of the Mavis Nye Foundation. Her and her husband Ray, and others just like them, are the reason we do what we do and they certainly keep me going.
The keynote speaker on Friday, Dr John Moore-Gillon, shared the other side of that same story, the diseases and their treatment. He talked about his 42 years as a doctor: the first 37 years saw incremental change in treatment but the last five have seen extraordinary progress. ‘Today, there is no point in writing a textbook on cancer treatment’, he said. ‘It will be out of date before it gets to the publisher’. This was one of the stand out moments for me at conference.
We were all plunged early into a fascinating talk on how to understand raw data and translate it to actual risk. As professionals, we may believe that we can do that already – but the reality is typically that we go from the readings to an assessment via opinion and experience. Some of us may go back to WHO figures – but there is a great deal of ‘us’ in the end result. Andrey Korchevskiy and Andrew Darnton brought us back to published research. They presented a simplified method of using this data to produce lifetime risk answers and the probable extra cancer cases that would result from that exposure.
Next came three related presentations:
All three had enormous detail and on the surface were very different, but they had a common thread running through them.
Talc.
The scandal in the US has, ridiculously when we think about it, seemed so far away, almost not real. But running through all of these talks was the fact that the mineral talc is formed by exactly the same geological conditions as asbestos is. This means that most, if not all talc mines, also contain asbestos to a greater or lesser degree. The risk is recognised to an extent by the mines and quality control put in place to eliminate the contaminant. However, the techniques used are woefully inadequate resulting in an erroneous clean bill of health.
If we look as Sean Fitzgerald does with transmission electron microscopy (TEM), or scanning electron microscopy (SEM) the story is very, very different. He illustrated that with a modified preparation technique, the very fine fibres that are invisible to the standard technique are revealed.
All three talks discussed the global nature of the talc mining industry and consequently how much of the talcum powder in the world is contaminated with asbestos.
David De Vreede talked about his campaign to highlight the dangers of asbestos in talc. He was instrumental in alerting the EU to asbestos found in some of Claire’s products. The EU subsequently sent out a recall of those products back in April.
Yvonne Waterman and Jasper Kosters continued the theme of the inadequacy of standards and testing of talc used in Europe.
I guarantee everyone there was thinking about the cosmetics in their hotel room and back home.
John Addison (the John Addison) came next with his talk on amphiboles. This left me with more questions than answers – as a 30 minute talk on such a broad subject will inevitably do. Rather than there only being five amphibole species – there are in fact over 100 – and these are just the ones catalogued by Mindat.com. All of these can cleave, causing elongated fibres in the respirable range. But does this make them asbestos?
Asbestos or ‘asbestiform’ is a term we use to describe the capacity to produce hazardous fibres. The definition is as follows:
Then comes birefringence. Summarised brutally – when we pass light through a mineral suspended in special fluids, we see different colours depending on the direction that light passes through it. When specific colours are observed this is the final evidence we need for identification. Here would be a ‘positive result’ for chrysotile (Taken from HSG248).
John argues that the key test that is not always performed in the lab is durability – can the fibres be bent without breaking them – or does it splinter like bamboo? If it can’t, then even if the birefringence indicates ‘asbestos’ then John would argue that it isn’t.
However regular analytical laboratories would not have the skills, never mind the accreditation, to positively identify these rare species.
He also added that most of the soil in the midwestern states of the US contain amphibole minerals (from the last ice age). John posed the question – if they all qualified as asbestos,- where are the bodies?’
I’m not sure where that leaves us, but I am certainly going to look further.
The morning of the second day ran through analytical techniques – Phase Contrast Light Microscopy (PLM), Scanning Electron Microscopy (SEM) and it’s big brother Transmission Electron Microscopy (TEM). In talk after talk we had been told how inferior PLM was to either of the two electron methods. But, the speed of the test and the relative cheapness means that many more instant tests can be made.
Building on this, Jean Prentice reminded us all of why PLM was selected in the first place and where it sits in the analyst’s toolbox. I started my career in the early 90s. My mentor at the time still referred to visual inspections as being relatively new, before that the analyst only had an air test to pass or fail some work. Unsurprisingly, as all enclosures were dripping wet, many filthy enclosures (in the absence of a visual) would pass first time. The HSE’s position is that the most important part of the Four Stage Clearance (4SC) is the visual. Get that 100% right and the air test will probably be OK. A key feature of the airtest is therefore the speed of response. Within an hour or two of starting a PLM test, the analyst knows whether there is a problem or not. Being secondary, it is merely a final indicator on whether something has been missed in the cleaning process.
What is the purpose of the 4SC? Jean reminded us that it is in reality a quality control check on the LARCs cleaning. It is not intended as an absolute measure of how much asbestos has been left in the area – there should be none. She asked the question – would increasing the sensitivity of the air test improve standards? Would lavishing more time and money by moving to SEM analysis help? Or would this distract us from the more important stage – the visual? Something I had lost track of and represented a moment of clarity for me.
Dr John Moore-Gillon, the keynote speaker, who closed this asbestos conference, was truly inspirational. He built up his presentation, giving us real insights into the various asbestos-related diseases and the seemingly insurmountable challenges they present. The sheer scale of a developed mesothelioma tumour is daunting.
Written by Nick Garland on Friday November 9th 2018
There’s no getting around it: construction is a high-risk industry, and specialist fields such as licensed asbestos removal especially so. In the UK, the ground-breaking 1974 Health and Safety at Work Act has gone a long way toward creating a culture of safety: fatal workplace accidents have fallen six-fold in the intervening 44 years, while employer-reported non-fatal injuries fell by 58% over the 30 years to 2016/17.
Yet the nature of the industry is that accidents, incidents and near-misses still happen, with their associated toll on workers’ health and wellbeing – not to mention the emotional, financial, regulatory and reputational fallout for employers. As a licensed asbestos removal contractor, the most important assets you have are your employees and your license. What should you do to help manage and minimise the risks inherent in your work?
It’s imperative to identify the strengths, weaknesses and skill levels across your employees, at all levels in the organisation. Not only will it allow you to ensure that projects are staffed with appropriately experienced and qualified employees, it will allow you to support any identified weaknesses with corresponding strengths.
Audit, audit and audit again: only with direct observation can you truly understand behaviour. You shouldn’t just focus your efforts on the supervisors, even though they are the easiest. It’s vital to include the full workforce in a comprehensive health and safety auditing scheme – contract managers, operatives, the admin team, stores and even the SHEQ (safety, health, environment and quality) department all have enormous impacts on the smooth running of a project.
Clearly this increased observation – not to mention the analysis of the extra data – is a task in itself, so significant thought should be put making the process as effortless as possible. If the solution is complex or time consuming, it will impose barriers and won’t be implemented effectively.
Once you know in great detail what you are facing, where the weaknesses of the team are and where you need to add extra support, you can do something about it.
You are now faced with a huge opportunity. If your team is great at A, B and C – but weaker at D and E – then you don’t need to waste time on training the first three. Having a clear idea of current skills lets you plan and deliver more focused and effective training, effectively improving skills and optimising your staff development budget.
We’re back to auditing – but now we look at the same data from a different angle. All the audits you did to get a comprehensive understanding of your team are an excellent basis from which to learn valuable lessons. Say that X, Y and Z went wrong on a site. Ask Why? What can we do to make sure it doesn’t happen again? Are there any trends building up? Are there any linked underlying causes?
Having a dashboard or high-level view that allows you to see your projects globally – or all of your team at a glance – will unmask seemingly discreet linked issues. Strategies can then be designed to get ahead of these issues before they become a major headache.
Everything I’ve been saying so far should be the standard approach for any industry, but the next is particular to asbestos removal. Measuring the exposure to asbestos is another way to test the success of a project. When removing asbestos, it is inevitable that there will be some exposure for the workers you task with the job. As employers it is our moral and legal duty to measure and minimise this.
You can’t be specific enough when it comes to monitoring exposure. And with this detail – so long as it’s recorded correctly – you will be able to directly measure the success or failure of a particular method. Treat any spikes in exposure as an accident. Investigate immediately, find the cause, and change the method. Success can be rolled out to other projects, failure can be learned from to drive change.
The key is that – just like audits – a simple but clear system needs to be designed that allows you to do all of this at the touch of a button. Any obstacles means that at best it is a task that will be delayed. At worst it could be put off entirely.
The HSE tells us that the average cost per non-fatal injury is £8,200. If you include litigation (private or regulatory), the financial and reputational cost rise exponentially.
Near misses are the accidents and incidents that didn’t quite happen. Rather than a collective sigh of relief and a ‘let’s forget about that…’ we should be gathering and analysing this health and safety gold.
There is considered to be a direct relationship between the number of near misses to the number of minor and major accidents. Heinrich, Bird and the HSE have all produced accident triangles: here’s the HSE’s one:
Any accident that didn’t happen is a warning of what might have happened. If we can learn and implement change before something has occurred… well, I don’t need to labour the point.
We first have to get over the natural human response of ignoring a near miss. Who would want to get someone into trouble when no one actually got hurt? However, the correct way of looking at this is: “That was close. Right, what can we do to make sure it can’t actually happen?” It’s an education process. Encourage the reporting of all near-misses through talking, explanation and rewards: regular analysis of the data you receive will allow you to preempt accidents.
One huge advantage that every licensed asbestos removal project should have is the supervisor. You have someone on site whose primary role is to ensure the job runs safely and to plan. There are obvious competence questions here that I have dealt with earlier, but the other unavoidable issue is paperwork.
Certainly with asbestos projects there are a multitude of safety-critical checks that have to be completed every day. No one would argue with that. Importantly though, the supervisor has to record that these checks have been done. Whilst this is unavoidable, it does take time away from supervising the works, reducing the supervisor’s impact in helping to prevent accidents.
Streamlining this paperwork will release the supervisor so that they can supervise – shifting their focus more towards overseeing and ensuring workplace safety.
Asbestos removal combines many common construction dangers with the specific risks of handling a highly toxic material. You can’t entirely remove the risks from such an inherently hazardous activity, but:
Get all five nailed and you have the fundamentals of how to de-risk your business.
That’s exactly what has driven the development at Assure360. With the combination of intuitive apps and a powerful database, our entire solution is directed at streamlining and simplifying H&S effort. Audits are made easy – and the legwork required for analysis largely eliminated. Exposure monitoring is instantly analysed to allow a constructive review of the success of each method. Incidents, accidents and – importantly – near-misses can be reported directly without adding to the paperwork.
All of this gives you unparalleled understanding of your people and your projects, but in a fraction of the time. Now, with the introduction of Assure 360 Paperless – the first out-of-the box solution for the supervisor – we free them to get back to what they do best: supervising.
Want to discover more? Get in touch today to book your free demo.
Written by Nick Garland on Friday October 5th 2018
Here are some dates for your diary – Nick Garland has put together his list of upcoming events for asbestos and construction safety professionals. We’ll update this page regularly.
27 February 2019
Join our February webinar and find out why more and more supervisors and managers in the asbestos removal sector are using our latest Paperless app to streamline on-site paperwork. Created by our expert team, Nick Garland will take you through everything you need to know about the system and demonstrate how it saves teams time and money. If you’d like to register for our February webinar simply sign up and we’ll send you more information.
18 February 2019
University of Reading, Agriculture Building, Whiteknights Campus
In this free evening event chaired by IOSH vice president Michelle Muxworthy, the IOSH addresses the role and significance of asbestos in workplace cancer.
1-4 April 2019
Hilton Brighton Metropole
Occupational Hygiene 2019 is the leading conference in the field of worker health protection in the UK, focusing on occupational hygiene and the prevention of occupational ill-health and disease. The conference programme combines inspiring and thought-leading plenary sessions with scientific and technical sessions, as well as a range of interactive workshops and case studies. The conference will bring together researchers, practitioners, regulators and other experts from around the world to discuss the very latest in issues that affect health at work.
9-11 April 2019
The NEC, Birmingham
The Health & Safety Event provides the perfect networking and educational opportunity to anyone responsible for running a safe and efficient workplace, anywhere in the UK. The CPD-accredited seminar programme will feature over 130 speakers from across the world of safety, fire and facilities.
6 June 2019
Location to be confirmed
Save the date for the annual ACAD golf day and awards dinner.
11-12 September 2019
The NEC, Birmingham
Registration for the Contamination Expo Series 2019 is now live. Claim your complimentary tickets to the Hazardous Materials Expo with seven events making up the Contamination Expo Series. The Assure360 team will be on stand J7, opposite ACAD.
If you’re hosting or attending an event you’d like us to list here, please get in touch.
Written by Nick Garland on Tuesday October 2nd 2018
It’s been a fortnight since Contamination Expo 2018, and those of us that attended, exhibited or spoke have had time to decompress. I say that because, for those who haven’t done an Expo yet, it is something to behold, and leaves you somewhat dazed.
The 2018 event was a big change on previous years. Relocated to the NEC in Birmingham, it was significantly larger, having been merged with the established RWM (Recycle and Waste Management) Expo. Both changes together meant we had to plan our visit a bit more carefully, and had me wondering – would Assure360 be invisible in such a large show?
I needn’t have worried. The whole event was a great success, with our Expo Fringe meet and greet session a particularly positive highlight. Here we got the chance to share drinks, nibbles and a Q&A with customers and new contacts, and the evening evolved into some free-flowing customer feedback. The fact that we’re now in discussions with some potential new customers is a welcome bonus.
We officially launched our new app and database solution, Assure360 Paperless, which addresses one of the industry’s biggest challenges. Asbestos removal is hazardous and highly regulated, so licensed contractors need to complete – and record – a vast number of safety-critical checks. Once a project is finished, checking the associated paperwork can take the admin team days or weeks.
The onsite admin consumes hours of valuable supervisor time, but until now the only alternatives have been expensive bespoke solutions usually built on ‘smart’ forms. And while these may save time on site, they’re effectively bits of electronic paper: they don’t reduce admin.
Assure360 Paperless is the Holy Grail for the asbestos industry, solving the admin problem by applying our granular, data-based approach. When any check is converted to data, we can instantly report on just that tiny element – not an entire form. Also, as it’s data, we can automatically sense-check it – massively reducing the admin time required afterwards.
Whilst we are a data company, I am asbestos and H&S, so when we create a solution it’s with a fundamental understanding of the industry. Assure360 Paperless applies our insight, freeing the supervisor to supervise, and increasing productivity throughout all aspects of your asbestos removal projects.
Interested? Discover more about going Paperless.
At the event itself there were numerous fascinating talks, but two that stood out for me were by Graham Warren from ACAD, and Yvonne Waterman and Jasper Koster of the European Asbestos Forum (EAF).
In their talk on hidden asbestos, Yvonne and Jasper presented frankly shocking revelations of just how much of the material still comes into Europe, despite national prohibitions.The list of sources went on and on, and included items such as children’s toys, electrical goods and jewellery. My jaw dropped at the revelation that China permits products to be described as ‘asbestos free’ if they contain less than 10% asbestos.
If you get any chance to hear Yvonne and Jasper speak, you should take it. I’ll be sure to highlight any future events they’re attending in our events calendar – roll on the next EAF conference, in 2019!
In his talk, ACAD’s Graham Warren had some startling figures for the ‘average’ licensed contractor. By dividing the number of supervisors and operatives in the industry by the number of licence holders, he revealed that the average LARC has about 14 operatives, and seven supervisors. If we accept that NVQs are the industry’s baseline competence qualification, and that going through the Construction Industry Training Board (CITB) costs about £1,000 per operative and £2,000 per supervisor, the average qualifications bill works out at a minimum £28,000 per company.
But ACAD has driven through changes in how NVQs are delivered – first and foremost by creating a dedicated training centre, open to all. ACAD provides the centre and the internal QA, but anyone suitably qualified can take candidates through. The new structure looks like this:
This egalitarian structure is a striking change, and it should address the fears of traditional training providers that the big boys will steal their lunch. It also introduces another interesting angle: there is nothing to stop a LARC getting suitably qualified at a local college and taking its own folk through the process. For this to be practical, of course, that LARC would need a detailed and comprehensive competence assessment system – all Assure360 users have this by default.
If an average LARC takes its own staff through the ACAD centre, that scary £28,000 training cost comes tumbling down to only about £7,000. And if that company is a CITB levy payer, it could benefit from grants to the tune of £15,000 – potentially netting an £8,000 ‘profit’ on the process.
All in all, then, the Expo was exhausting, useful and very interesting. We’ve booked again for 2019 – see you there!
Written by Nick Garland on Thursday September 27th 2018
The data collected by Assure360 gives us unique insight into the issues our peers in the safety industry tackle during site audits and tech reviews.
Assure360 is the only community audit and compliance tool available for the asbestos removal and construction industry. With over a hundred safety professionals using the system – so far they’ve completed 4,355 audits – we are developing real insight into the challenges and issues our clients and peers face and overcome. As a result, Assure360 has the power to genuinely improve the construction industry.
It’s been a great year so far. More than 10% of all licensed asbestos removal companies now benefit from our system. The 4,000th audit was completed by one of our Gold subscribers, and in July we hit a record of 159 audits and competence assessments in a single month.
If you’re familiar with these posts, and the Assure360 system in general, you’ll know that the data not only incorporates site audits, but records tech reviews during the planning stage. This allows managers to learn from common issues picked up by their peers – before the project goes live.
We regularly share the community’s findings with our army of independent auditors through our customer newsletter (scroll down to sign up). Let me walk you through highlights from the most recent findings, covering audits and site reviews in June and July.
If we look at the overall top 10 we see that it is very much method statement focused. However, if we look a little deeper I think there are some interesting trends developing, notably around risk assessments – both during the planning and on-site phases.
The top 10 looks like this:
I’ve long championed thorough risk assessment, and the latest results see a comparative surge of issues around them. Appearing mid-table, Risk Assessments (detailed in method proper) relates to assessments at the project planning stage. Risk Assessments are all-too-often an afterthought in the asbestos industry, where in fact they should be the first thing written. Logically if you have identified, say, that there’s a noise and vibration issue involved in a asbestos removal project, the method should detail precisely how all three of these challenges are to be overcome.
A familiar example might be where asbestos insulation removal is detailed, with the detail for the actual cutting restricted to “…cut out with reciprocating saw to 1m lengths.” Methods should state the trigger time, task rotation, and when to wear hearing protection.
Risk Assessment (live services) continues to get the attention it deserves. Interestingly this relates to the site level, i.e. where site teams have not followed procedure, rather than where issues haven’t been considered in the plan.
Happily, there’s a new Assure360 development that will help supervisors. All existing Gold subscribers now get access to our new Paperless solution free of charge.
Quite simply the holy grail of the asbestos removal industry, Assure360 Paperless is a secure and powerful system for recording checks. It’s designed to save time for the supervisor, allowing more time in which to actually supervise. Why not contact us to arrange a demo?
Assure360 is not a dumb ‘smart form’ or isolated tablet application – it’s linked to a powerful cloud database. Its sophisticated system of automatic reminders and dashboards, ensures the right people deal with the issues at the right time. Meanwhile, the system encourages you to always examine the data to ask ‘what could we do to prevent this happening again?’. Everything is dealt with – root and branch, and this month’s results suggest that the approach is working.
How does this data compare with your own audits? Do you have a tool that can help you monitor and tackle these issues, saving you time and money and keeping everyone on the project up to speed?
Let us know what kind of data you’d be interested in seeing, and if you’d like a demo, please get in touch.
Written by Nick Garland on Wednesday July 18th 2018
The Grenfell disaster was, among many other things, a failure of building regulations to protect residents. It’s clear to me that the Hackitt Review had to re-learn the lessons of work health and safety, and with Dame Judith a previous head of the HSE, I awaited her review with some optimism. Here’s why I believe she has grasped the opportunity. (more…)
Written by Nick Garland on Friday April 13th 2018
The HSE’s assessment process for asbestos licences is rigorous – rightly so. Find out why so many of our clients at Assure360 are being granted three year licences, and how we could help you to get yours.
Becoming a licensed asbestos contractor (a LARC) is no easy thing. The HSE’s assessment is rigorous. They grant licenses for up to three years, but only a third of LARCs have this kind of licence – most have licences granted for periods of two years or less.
The last statistics widely shared by the HSE show the split for asbestos licences to be:
Licensed asbestos contractors (LARCs) produce method statements and documentation far more detailed and considered than their construction counterparts. They spend vast sums on training staff, and ensure levels of supervision beyond what other industries would even consider. Exposure monitoring has been a challenge, but the tests are done in line with guidance and by skilled analysts.
But when asked in the assessment:
too often the answer is a jumble of files, hard-to-decipher Excel spreadsheets, and in the worst case scenarios un-actioned paper audits. All these solutions are labour intensive – and as such tend to slip when workloads increase.
So why is assessment so challenging? Well, it’s meant to be. Asbestos is the most regulated industry after nuclear and as a ‘permissioning regime’, only the best companies should be given the stamp of approval.
With Assure360 Audit – our easy-to-use solution – all of these key tasks are made easy, and streamlined. With this treasure trove of time handed back to the team, they can focus on managing the projects. And better managed projects are more likely to be completed safely and on program. Simple.
Let’s look at the data on licences again, and this time compare all licence terms with the terms given to Assure360’s clients.
While we’re certainly not claiming all the credit for our clients’ high standards and competence – a great deal of expertise, hard work and dedication is needed from the entire team to perform to these high standards. But we feel there’s a relationship between the high proportion of three year licences amongst our clients and their ability to demonstrate competence and effective H&S management. We’re helping them to ensure that their efforts are directed at the right areas, and come licence renewal – they are able to demonstrate this fundamental understanding to the HSE.
There are other systems out there that help manage commercial aspects of projects from cradle to grave, but Assure360 is the only one designed specifically for the rigors of the asbestos licensing regime. Its effectiveness is born out by the figures and feedback from our clients and the HSE.
“The system the company has for assessing competence, conducting appraisals and supporting staff development is impressive and far better than seen elsewhere in the industry” HSE – LAR’s Licence Assessment
“We went from a new one-year licence to the full three years. Assure360 was invaluable in helping us demonstrate what we do best.” Peter Soltau SAS’ Licence Assessment
“What is particularly impressive about the system is the fact that it doesn’t just collect numbers. It presents information that allows you to make sensible decisions about the business” HSE at an Assure360 user’s recent Licence Assessment
Find out more about what our client’s think about Assure360 in these case studies.
Written by Nick Garland on Wednesday March 28th 2018
Finding asbestos contamination on a site or building project can feel paralysing. But there’s no need to panic. Here’s a simple guide to help.
The words ‘asbestos’ and ‘contamination’ are probably two of the things you least want to hear. Whether you’re involved in commissioning or designing a construction project or just occupying a building, asbestos can lead to worry, cost and delays.
Outside of the nuclear industry, the management and safe removal of asbestos is the most regulated process you can be involved in. And regulation invariably means expense – particularly if there’s regulatory infringement.
What is asbestos? As far as day to day practicality is concerned – ‘asbestos’ refers to the actual product that has been installed into a building. Because the ‘benefits’ of asbestos were so far reaching and its production relatively cheap – the type of products it was used in were virtually unlimited.
Asbestos can be found in:
And many other materials and structural elements.
Tony Rich, a respected asbestos consultant in the US, has taken and collated a vast collection of photographs of examples of materials and locations where asbestos has be found from roofing to cigarette filters
With the number of different products so extensive it’s no wonder that properties constructed before the early 1980s almost certainly contain asbestos. As the ban only came into force in 2000, even those built as late as 1999 could have some.
As we increasingly look for asbestos in soils we are finding more and more. Even if we ignore fly tipping and re-burying on site, there are several reasons why the ground we stand on can become contaminated.
Alas for many years we were not very good at finding asbestos in buildings. In defence of the surveyor, the proliferation of asbestos is huge (especially in the UK) and progressive refurbishments can cover over and conceal it. But the approach to intrusive pre-demolition surveys used to be quite weak.
The guidance on what you needed to do with asbestos once found in buildings about to be demolished was not always in concert with the hazardous waste rules. For example, it was widely accepted that Textured Coating had low asbestos content, was bonded to the surface it was painted on, and when demolished, did not constitute hazardous waste.
Buildings could be demolished without even looking for asbestos, either intentionally (we don’t want to know) or as an incompetent oversight.
Whatever the reason, if a building is demolished with asbestos still in it, that asbestos will find its way into the ground. The site itself could become contaminated and / or the subsequent rubble could be converted into secondary aggregate for other sites.
Whether you find asbestos in a building, or find it contaminating land you’re going to be building on, I’ve created a simple acronym to help remember the useful steps to take:
R – Respond calmly
2 – Two important questions to assess risk
D – Decide what you’re going to do next
2 – Two trade organisations who can help you find a licensed asbestos professional to help
If you discover asbestos, in the first instance – do not panic. As the HSE’s Martin Gibson has said – in the UK we have a long history and genuine expertise in managing the risk from asbestos. This does not always mean remove it.
With the proviso that you shouldn’t touch or disturb asbestos – the best rule of thumb when assessing the risk of asbestos in a building is to ask these simple questions:
For example, if the asbestos material is a corrugated garage roof: this is out of reach (or at least not easy to knock into) and clearly quite hard. So the risk is low.
If it is low level pipe insulation, it’s easy to touch and relatively soft. The risk is high. Simple.
You need to have as much knowledge as possible to answer these questions. And when it comes to asbestos that means a survey. This will tell you where any asbestos is and what the risks are.
The very nature of ground contamination makes the ‘problem’ an entirely different beast.
By being in the ground the material is buried and therefore hard to find. It degrades – breaking down and dispersing the asbestos fibres. Surveys have to follow a different pattern and are detailed in the HSE’s asbestos analyst guide (read my recent summary for more information). On the positive side, (especially in the UK) the ground is damp – important as wet asbestos does not get into the air too easily.
The risk assessment for ground contamination though remains essentially the same. Ask yourself two questions:
Loose insulation at the surface is high risk. Buried cement is low risk.
The next step is decide what you are going to do about it.
For asbestos in a building, providing that the material is in good condition there are plenty of options that do not include costly removal. In fact this is the HSE’s primary recommendation. If you can avoid touching, damaging or in any way disturbing the asbestos – then it is safer to manage it in situ. Even this is relatively straightforward – it involves a periodic check to make sure that its condition has not deteriorated.
If you do leave asbestos in the building – anyone who could come into contact with it should know it is there. If they could damage it through their work, they should have Asbestos Awareness training. These courses are so widely available that it is almost certain that there is a company near you that provides them. Check out the IATP or UKATA website to find a provider.
If however the asbestos is in poor condition, or it is in such a position that it could get damaged in the future, action may need to be taken. This still doesn’t necessarily mean removal but it does mean that you will need professional assistance. Options other than removal could be to protect the asbestos – help ensure it doesn’t get damaged. This can range from covering it up, painting it or to simply close and lock the door.
Again with ground contamination, we are faced with different challenges. We often only know of the existence or the contamination because digging is planned. But it could be something as simple as buried broken cement coming to the surface on a walkway. In either case some form of action is usually required. Just like asbestos in buildings though, that action could be ‘close the door’. In this case it would be to install a capping layer above the problem to seal it off. If however digging is unavoidable then some form of controlled removal will be required.
The rules on where this material goes is simple, but has huge implications:
If either of these are the case, then the material is ‘hazardous waste’ and therefore expensive to dispose of. If not at these levels, but still present, it is not ‘hazardous’, but must be disposed of at a landfill site that has an ‘asbestos cell’. Significantly less expensive, but still onerous.
Therefore a single fragment of visible asbestos can render a whole load contaminated. Careful early planning, screening and segregation becomes critical.
I have always recommended that a licensed contractor is used for any work on asbestos. This is (strictly speaking) not always legally required, as some low risk asbestos (the cement sheeting I mentioned earlier) does not need a licence. It does however need special equipment, training, medical supervision and insurance. In my experience you are much more likely to get it done right first time with a licensed contractor.
There are two main trade organisations: my one: ACAD, and ARCA. Both can offer lists of members that have passed their audit scheme. However, I would counsel that you would need more than this. Any company that operates an internal competence scheme like Assure360 gets a gold star in my opinion. Beyond that – personal recommendation (if your procurement will allow) is always the surest way to a happy outcome.
Land remediation is a specialist, complex skill that most (even licensed) contractors don’t have. The approach does not normally include enclosures, but could in the most serious of cases. Careful selection is therefore vitally important.
The final piece of advice I always offer is to become an educated client. Asbestos removal is expensive, complex and scary. Going ignorant into a contractual relationship in those circumstances is brave indeed. What’s more, CDM15 no longer allows clients to say ‘I didn’t realise’, or ‘that’s not my area’.
So, either get someone in your organisation that understands the subject (e.g. the BOHS course P405), or appoint a consultant independent of any of the asbestos project team who can be your expert advocate.
There is even help in selecting the right person: FAAM is the new faculty for asbestos professionals and commits its members to a level of expertise and an ethical code of conduct. Ask are they full members of FAAM (MFAAM)?
Expertise in asbestos land remediation is unfortunately less widespread. Whilst asbestos in the ground is a problem that has been with us for nearly as long as asbestos has, it’s been somewhat under the radar for most professionals.The introduction of the comprehensive document CAR-Soil has allowed training course to be developed often by CL:AIRE. CL:AIRE also publish a list of their members, but I don’t believe there is a formal auditing or vetting process.
Either your in-house expert or the external advocate would then be able to directly check that the project is being run safely according to the plan. In other words audit. Assure360has been specifically designed to help clients like the Royal Mail to monitor asbestos projects whether in the built environment or in the ground (no apologies for the shameless plug).
Whilst asbestos is a scary word – the Brits are world leaders in managing the risk. Get the right people around you and don’t panic.
Written by Nick Garland on Friday February 2nd 2018
Britain was the first country in the world to have an industrial revolution, and we were the first to start importing asbestos. We have imported the most asbestos of any country in the world. In fact in the ‘50s, ‘60s and ‘70s we imported 40% of the world’s capacity to produce amosite / grunerite.
We have so much asbestos that we can’t remove it all – we have to manage it.
These startling facts were shared by Martin Gibson (HSE) speaking at the European Asbestos Forum in September. They perfectly crystallise the unique situation that the UK finds itself in. The reality that we can’t remove our asbestos – only manage it – is also the foundation of all of our legislation. In essence: assess the risk and design solutions to keep people safe.
This takes a special kind of professional – one who is expert in the regulations, but who can see beyond the guidance to the purpose. They need to be able to design practical solutions rather than gold-plate and over specify.
How do you know you’re working with someone with these professional skills? Who can you trust? Asbestos is the biggest occupational health problem the UK has ever seen, yet anyone can claim to be a consultant or expert.
“We are a highly qualified asbestos consultancy firm”
“We are specialist consultants to survey and test any asbestos”
“Leading accredited asbestos management consultancy”
These are all genuine marketing lines promoting the skills and qualities of asbestos consultancies. Do they mean anything? How do we know, what confidence do we have?
The two existing professional asbestos management bodies have never been quite right. IOSH is focused on Health and Safety and BOHS has the whole breadth of Occupational Hygiene to consider. Being chartered in either does not speak to your asbestoscompetence, but there hasn’t been any real alternative
Until now.
Finally, there is a home for the asbestos professional. BOHS, with it’s shiny new royal charter has created a new faculty – Faculty of Asbestos Assessment and Management (FAAM). The launch event was back in October last year and the first few full members – myself included – were accepted into the faculty over Christmas.
https://www.youtube.com/watch?v=dLIgwq5sEL8
Now for the first time we have a home. One that insists on the maintenance of professional standards and where failure to maintain those standards will have consequences.
FAAM’s stated principles are:
FAAM will support members with
To be clear – FAAM will not be claiming that non members are incompetent, only that those who are members, have demonstrated competency, maintain that level and operate to an ethical code.
The levels of membership and the qualifications you need are:
Technician
• Level 4 – (one of P401 to P404), S301, W504, RSPH L4, or • Level 3 – RSPH Level 3 (plus written bridging exam) – OR…
Associate
• P405 or P407, or
Three from P401, P402, P403, P404, S301 or W504
Licentiate
Certificate of Competence (Asbestos)
Member
• CV, professional experience portfolio (or PEP) and personal interview
Fellow
… to follow … significant contribution to the profession
Whilst BOHS as a whole has a royal charter the new faculty does not – but there is the tantalising possibility that it might in the future.
The whole concept has excited me since it was first mooted – but I must say getting my acceptance documents through was a thrill and for the very first time there are letters I will be proudly using after my name – MFAAM. I urge all like minded professionals to apply.
Written by Nick Garland on Friday February 2nd 2018
I’m always fascinated by the insight the data gives us into the issues our peers in the safety industry tackle during site audits and tech reviews.
Assure360 is the only community audit and compliance tool available for the asbestos removal and construction industry. Over a hundred and sixty safety professionals use the system, completing, to date, more than 3500 audits. Assure360 is developing real insight into the challenges and issues all our clients and peers face and overcome. As a result, we have the power to genuinely improve the construction industry.
The system not only incorporates site audits, but records tech reviews during the planning stage. This allows managers to learn from common issues picked up by their peers – before the project goes live.
We regularly share the community’s findings with our army of independent auditors through our customer newsletter.
This time the issues that the Contracts managers faced mirrored the overall top 10:
The top 10 list looks like this:
If we look at the numbers – three of these are clearly related:
· Risk Assessment – generic assessments
· Risk Assessments – whether the identified controls are reflected in the method
· Risk Assessment (vibration)
If we also consider that electrical isolation not being in place could also be connected to a lack of adequate risk assessment – we can see the attention to detail with respect to non-asbestos hazards is by far the most common issue at 27 instances.
Improved general H&S awareness and training for the contracts managers should be considered.
The most common issues for supervisors
Assure360 allows us to drill down and identify issues faced by supervisors. This allows the teams to address targeted issues within supervisor meetings, rather than allowing company-wide concerns to cloud the issue:
The top 10 for supervisors looks like this:
1. Access Routes
2. Housekeeping
3. Tied (scaffold)
4. COSHH Assessments
5. Double hand rails (scaffold)
6. Scaffold (Fans)
7. Signing in
8. Method Statement (briefing)
9. Scaffold (Boards)
10. Scaffold (Design)
Two main issue stand out for the site teams – housekeeping / safe access routes and scaffolding. Again, these are non-asbestos general construction issues.
Assure360 is not a dumb smart form or isolated tablet application – it is linked to a powerful cloud database. Its sophisticated system of automatic reminders and dashboards, ensures the right people deal with the issues at the right time. As Assure360 always asks – ‘what could we do to prevent this from happening again?’ everything is dealt with – root and branch.
How does this data compare with your own audits? Do you have a tool that can help you monitor and tackle these issues, saving you time and money and keeping everyone on the project up to speed?
Written by Nick Garland on Friday February 2nd 2018
In 2014 / 2015, the HSE carried out their Analyst Project – or to give it its full name ‘TheAsbestos Analyst Inspection Programme’. Its aim was to examine the performance of analysts in the removal process. At the BOHS roadshow last month, the HSE’s Martin Gibson revealed the initial findings and the first conclusions – perhaps the most surprising is how it might impact on the licensed contractor.
The HSE contacted all UKAS accredited labs and asked them to complete a questionnaire – the results were extremely enlightening.
Of the 145 UKAS accredited labs not everyone responded (obviously) – more than a third of them in fact. But if they thought they would stay under the radar, they were mistaken and the team targeted them for visits just the same.
Twenty 4SC visits were planned and in all cases the analysts were told to expect the HSE. Whilst this solved the issue of turning up when nothing is happening, it did mean that the analysts would be on their best behaviour.
I have broadly split the findings into the four stages of the process. I have also tried to highlight areas in the draft analysts’ guide that is intended to correct this. A copy of my white paper summarising the guide can be obtained on the Assure360 website.
One general point to be made is that wherever I mention photos – each has to be digital and date and time stamped to prevent forgery. And as usual there is a health warning with this post – this time from Martin Gibson – he stressed that the findings did not apply to all the analysts!
Whilst the analysts were checking that the asbestos had been removed, a detailed review of the surrounding area was a different matter. Whether the general site conditions were fit to start the inspection was often ignored. The worst example was this transit route – strewn with rubble and other non-asbestos material. It should have prevented failed at Stage 1.
The new draft guide has detailed the key inspection areas for the first stage of the process (including the transit routes and the areas surrounding the enclosure). Photographs are now required to demonstrate the adequacy of the situation.
The HSE’s view is that this is the critical part of the whole process, and raised the most number of issues in the investigation.
Analysts were observed moving randomly around the enclosure. Guidance (and logic) has always had it that a methodical pattern will help avoid missing something.
20% of the analysts wore domestic clothes underneath their overalls. This would have prevented them from decontaminating properly in case of a failure. Any of my regular readers will know that I believe that full decontamination via the DCU should be followed with every enclosure entry.
Formal failure certs were not always issued when an enclosure was rejected by the analyst. Whilst I can understand the instinct not to create paperwork, these failed certs are critical for addressing the root cause – that the LARC didn’t clean it sufficiently and the Supervisor failed to identify the issue. Clearer guidance on when to formally fail an enclosure is included in the new guide.
Two analysts arrived without overalls and two were unshaven. I don’t know whether these were the same individuals, but when you remember that the analysts were expecting HSE attendance – this kind of sloppiness is shocking.
What PPE and what to wear underneath is also detailed extensively in the new guide – the handy table is reproduced in my white paper on page 44.
There were also some startling implications over the amount of cleaning that analysts do – but I will leave that till later in the piece.
There were incidents that raised questions over basic competence namely calculating fibre concentrations incorrectly (decimal point wrong). This may just be the nerves of being overlooked.
More significant, in my eyes, is that one of the analysts forgot the brush for the disturbance test. Again, when you recall that the analyst knew the HSE would be in attendance, wouldn’t the instinct be to double and triple check your equipment? A photograph of the brush is now needed in the new look Certificate for Reoccupation.
Generally, the HSE found insufficient time was spent on reading the slides – one took just nine minutes to read three slides. This compares with the 10-15 minutes per slide in the current draft analysts guide and the 10-25 minutes in the old version! Just as I was forgiving to the analyst that got the decimal place wrong, to race through this phase of the process when observed by the authorities makes you wonder ‘what normally happens?’. The new look certificate with time and date stamped photos and time declaration at the signature stage should help this.
This is where the final checks are conducted post dismantling the enclosure, but I also include decontamination and PPE.
Frequently the analysts did not wear overalls when conducting the final checks. This is obviously unwise as dismantling the enclosure can reveal hidden problems. Mostly the analysts were entirely unprepared for these unpleasant surprises including not carrying RPE. Whilst the guidance is a little clearer in the new guide – Stage 4 is missed off the handy summary table, and the reader must go hunting in the Appendix. Hopefully the final draft will be amended.
The HQ visits established that practical training for decontamination was lacking. On site this was evidenced by analysts being unsure when to decontaminate and following the incorrect DCU entry/exit procedures when they did. Much more detailed guidance on decontamination procedures is included in the new guide – including training as a core skill.
No apologies for this section, though my regular readers might think that I am a broken record. The project established what we have been seeing with the Assure360 data. Most personals air tests were very short term and usually only 10 minutes. Further, they included no contextual information – just ‘removal works’. To compound this, the analysts often reported the calculated results which were below their own Limit of Quantification (LoQ). This is next to useless to the LARC who is attempting to improve their methods. They need long duration tests, with decent (low) LoQs and detailed information over what was happening during the test. Assure360 has analysed over 5000 personal air tests and even here we are finding that approximately 10% are for only 10 minutes.
This is what I hinted at earlier – something that all analysts will already know – analysts do quite a bit of cleaning as part of the visual. What makes it startling is the implications.
I am very aware that the LARCs have views on analysts and the ‘helpful’ ones are those that pitch in to get the enclosure through the clearance. I counted myself as one of those. In the Project, many analysts stated that they conducted minor cleaning. But what constitutes ‘minor’? Well in one case it was cleaning for over an hour!
The HSE’s view of this is that >15 mins cleaning constitutes licensable work and must not be done by the analyst. What’s more – any such breach is considered, at least in part, the LARC’s fault:
HASAWA
36. (1) Where the commission by any person of an offence under any of the relevant statutory provisions is due to the act or default of some other person, that other person shall be guilty of the offence, and a person may be charged with and convicted of the offence by virtue of this subsection whether or not proceedings are taken against the first-mentioned person.
Whilst the new analysts’ guide (still draft) has been written in such a way as to take some of these findings into account (get a copy of my white paper here), some last-minute changes have found their way in.
The new Licenced Contractor Guide which I understand was complete – just awaiting a slot in the HSE schedule to publish it – will now need a re-draft. Further guidance will be included on
“It is very rare that site supervisors carry out an inspection before the analyst arrives.” Analyst – Anon
My experience however is that the good supervisors take their role seriously and complete these visual inspections. However, the required declaration by the supervisor ‘time taken on visual’ may come as a bit of a shock.
The HSE’s view is that the visual inspection is by far the most important part of the whole clearance process. If the responsibility is primarily the LARC’s – a light touch / brief visual by the supervisor won’t be acceptable. The draft analyst guide gives us very detailed suggested times for these visuals.
This table indicates that a small boiler room should be inspected by the supervisor for 2-4 hours before the analyst can start stage 1 of the process. It also begs the question if the Supervisor is conducting a visual and therefore not supervising the rest of the team – does all activity stop?
There will have to be a sea change in expectations.
Written by Nick Garland on Monday October 23rd 2017
Essential reading to help you unpick the significance of the changes coming our way by Nick Garland, CEO of Assure360.
Here’s my summary of the draft of the new Asbestos Analysts’ Guide from the HSE. I’ve been publishing blog posts on this over the last six months, and this white paper is the complete set of articles on this with some updated additional analysis.
Download the Asbestos Analysts’ Guide White Paper [PDF]
The HSE’s new Asbestos Analysts’ Guide is coming soon or so we have been confidently told for the past year. When we do get it, it is designed to help both Analysts and their clients comply with the Control of Asbestos Regulations 2012 and its ACoP.
It’s the client I am particularly aiming this summary at, but those with technical backgrounds should also find it useful. It is also for this reason that I largely don’t cover the appendices – in of themselves a whopping 178 pages long!
This is obviously a summary and clearly not intended to replace the guide. In particular, the appendices contain a lot of important detail and should still be studied to gain the fullest picture. A further note of caution, this is a review of the ‘draft for consultation’ – there may well be changes before final publication. Publication of the consultation paper was a surprise when it was issued over Christmas, so stand by your beds.
I regularly write about this and other topics relating to safety and asbestos management. I’ve been working in the industry for over 20 years, so I have a fair bit of experience to share – the good, the bad and the ugly.
Why not connect with me at LinkedIn if you’d like to talk more about this. I’d be delighted to hear from you.
Written by Nick Garland on Monday October 23rd 2017
In the fourth part of my summary of the new draft Asbestos Analyst’s Guide from the HSE – I’m concentrating on soils.
For those of you who have read either of my other summaries – this stand-alone article is a continuation.
If you want to read the first three instalments:
Part 1 – Appointing the right asbestos analyst
Part 3 – Reoccupation certificates and clearances
You can download a PDF of the complete white paper on the new analyst guidance here.
This time I am concentrating on the age old, but simultaneously new issue of asbestos in soils.
It should be remembered the HSE’s interest starts and ends with protection of the worker and others directly affected by the project. There is a very real difference between HSE and Environment Agency take on asbestos in soils. Another much more ambitious and targeted document on this other angle is:
‘Asbestos in soil and made ground: a guide to understanding and managing risk’.
CIRIA 733 must be read to gain any proper understanding of the subject.
My usual health warning – this is obviously a summary and clearly not intended to replace the Guide. The appendices contain a lot of important detail and should still be studied to gain the fullest picture. Finally, this is a review of the ‘draft for consultation’ – there may well be changes before final publication.
Asbestos surveys are required under the duty to manage and the current Construction Design and Management (CDM) Regulations. Where there is ‘a reasonable expectation that asbestos would be, present and could present a risk to workers’– surveys must be completed. This is no different for the ground.
This is an area of asbestos analytical work that has been too long ignored, but growing dramatically. Historically – poor surveys and removal projects have failed to identify or remove asbestos containing materials (ACMs). Subsequent demolition would therefore create contaminated rubble to enter the aggregate supply chain. QED. Other than poor practices, there are other reasons:
The guide specifically states that speculative sampling should not be undertaken. We’re told only complete soil investigation if other (desktop) analysis indicates that there is a risk:
However, as I said in the introduction, the potential source of contamination is very broad and could be totally unrelated to the list given us in the guide. I agree – don’t do speculative sampling, but if there is planned ground works – asbestos surveys should be mandatory.
ACMs present in contaminated land can vary from whole sheets of asbestos or sections of pipe insulation to smaller fragments. Clearly, condition will deteriorate over time, leading to the presence of fibre bundles. When lying close to the surface and especially when the ground conditions are dry, fibres can be readily disturbed and released to the air. It is this interface with the air that brings the risk to the worker.
The desktop study and subsequent survey (if deemed necessary) should determine the risk to workers doing the digging. The risk assessment should establish the locations(s) of asbestos in the ground and identify the type, product, condition and amount (e.g. areas/depths). Soil type and moisture content are also key. Adequate controls can then be designed and implemented. Clearly discoveries during the project may require us to revisit the assessment.
The guide suggests a targeted approach.
Careful examination and picking of the area *. This would allow the surveyor to present the lab with larger pieces of ACMs (about 3-5cm2) and smaller pieces of debris and fibre bundles as distinct samples.
*Sieving may also help to separate the coarse fraction (stones etc.). Detailed procedures on decontaminating the sieve to prevent cross contamination of samples is needed.
The team’s task is to hunt out asbestos and only present suspect materials to the lab. To get any type of risk assessment, there would have to be an adjustment factor (suggested at ‘x 0.1’) – this would allow for the fact that the ACMs were collected over a much larger area.
This method has the advantage that a large area of the site can be covered more quickly. Its principal use is to establish if a main survey is needed. It will also allow a main survey to be better planned.
A note of caution – the naked eye, in site conditions, is especially vulnerable to fatigue. When you add the likely requirement for wearing safety glasses – the potential for missing ACMs must be acknowledged.
The guide indicates in the appendix that the targeted method is suited to the Preliminary Survey, but the Main Survey (if needed) would employ the traditional approach.
Select the sample points and carefully map the area (including depth).
The normal approach is to reduce (using coning and quartering) a 1m2 area of soil down to a 1-2 litre or 1-2kg sample. This is a method to reduce the sample size without creating a systematic bias. The technique involves mixing the sample, pouring it into a conical shape, flattening it out into a cake and dividing the sample.
Image courtesy of Eija Alakangas, Technical Research Centre of Finland VTT Ltd.
The exercise should be repeated to get to the end sample size of approximately 1kg.
The soil type at the depth should be detailed to allow greater understanding (i.e. made ground, sandy, clay etc. will all have an influence on the final risk assessment). All should be logged on a site plan. This will allow not only a register of what has been identified – but can also be compared with previous site plans to better target further investigations. E.g. an old site plan indicates that a boiler room used to stand where a few positive samples were taken.
Whichever method is used, the guide highlights an important safety issue in that the activity should be done at the surface and the surveyor should not enter trenches or holes, unless properly shored up.
Laboratory identification of asbestos is obtained using the standard analytical methods. However, there is significantly more preparation required. Concentrations of dispersed fibres down to approximately 0.001% can be identified using the standard method – but I have found that this is very dependent on how long the analyst is prepared to look (20 minutes is suggested).
Quantification is critical to develop an assessment of risk; an appropriately accredited lab must therefore be selected. In such cases, results would be reported as a weight for weight (w/w) percentage of the matrix. Note the current rules for hazardous waste is 0.1% w/w, or (crucially) if any visible fragments of ACM are in of themselves >0.1%. This would mean (taken to extreme) a single 10p sized piece of AIB or cement in an otherwise clean load would render it hazardous waste.
I am not detailing too much that appears in the appendices in this summary – however, there is a table in appendix 2 which seems to contradict this:
The presence of ‘XXX’ indicates it is unfinished, but the guide seems to be adrift of what I understand is the hazardous waste rules.
These surveys, coupled with ‘near source’ and ‘far source’ air testing (see my second summary here), should be used to assess the risk and design the control measures.
As with all asbestos controls, the starting point is don’t disturb it, but as the land is due for remediation this is unlikely to be a solution. The guide states that where there is mostly bound asbestos in soils below 0.1% w/w, airborne levels are unlikely to exceed 0.001f/ml. However, where this is free fibre and especially in dry soils – the fibre release can be greater. Just like with standard asbestos removal suppression is a key element of any designed control.
The guide produces a flow chart to clarify the decision-making process, but I think it will get reworked before final publication. I will not reproduce it here, but the chart indicates that if samples identify asbestos that is buried and unlikely to be disturbed – it should be reported as ‘no asbestos found’ – certainly a typo. The principle will likely be that if the asbestos is buried and unlikely to be disturbed it will present no risk to the workers and therefore as the guide is only interested in these workers – we’re back to where I started – leave it alone.
Because of our historic failures, this whole area of remediation is where the future of the industry lies – as we strive for an asbestos free world.
Written by Nick Garland on Monday October 23rd 2017
With the shock of the Grenfell Tower fire still raw in our minds, Nick Garland look to echoes of the past for lessons to relearn.
“Grenfell Tower met all required building regulations – as well as fire regulations.” This is the statement from the contractor responsible for installing the cladding. The thing is, it might very well be true – but does that make it right?
In 1974, the year that the Health and Safety at Work Act (HASAWA) became law, the number of fatal injuries in British industry was 651, over six times higher than today. Pre-1974, the H&S framework had not been slack – in fact it had been highly proscriptive. The regulators set a list of targets, which industry would strive to achieve.
Simple.
The inevitable problem with this kind of approach to safety regulation comes where regulation is not drafted perfectly, so compliance to the letter of the law falls well short of what is needed. Problems that the regulator did not foresee will be missing from the guidance and therefore never complied with.
The Aberfan disaster in 1966 was a clear and horrific example of this. A previously unknown underground spring found the surface under the dramatically increasing slag heaps. The spring turned the foundations of the heap to an unstable slurry, and the whole lot slid down the hillsides killing 144 people, 116 of whom were children. The Coal Board had complied with the 1966 regulations because there had been no mention of what was required if underground springs appeared under your workplace.
Now take a look at the building regulations of today.
“External walls are elements of structure and the relevant period of fire resistance (specified in Appendix A) depends on the use, height and size of the building concerned. If the wall is 1000mm or more from the relevant boundary, a reduced standard of fire resistance is accepted in most cases and the wall only needs fire resistance from the inside.”
and
“… it is possible for some or all of the walls to have no fire resistance, except for any parts which are loadbearing.”
The Building Regulations 2010
It may be the case that the infamous cladding at Grenfell Tower was not approved as a fire proof panel. But it seems that the regulations are drafted in such a way as to suggest it doesn’t need to be. I am sure that it is more complicated than that and the height of the tower has a big influence – but the fact that cladding on dozens of tower blocks is now failing fire safety tests suggests that the regulations are at the very least easy to misinterpret.
Lord Robens, the much-criticised chairman of the Coal Board at the time of the Aberfan disaster, used this experience to revolutionise how we think about H&S. His report in 1972 directly led to the Health and Safety at Work Act 1974 and the creation of the Health and Safety Commission and the Health and Safety Executive.
This didn’t stop him from continuing to be unpopular. His most controversial idea was that those that own the hazards are best placed to assess them. This therefore is the core of the Health & Safety at Work Act (HASAWA): the simple goal to ‘create a safe place of work’. I believe this idea is ingenious because this twist harnesses the imagination and expertise of the hazard creator (the employer), allowing the regulator to stay ahead of the game.
Now comes the next touch of genius. ‘So far as reasonably practicable’ (SFARP). But what is ‘reasonable’? There is guidance to help the decision, but to a large extent it is down to the employer. But woe betide them if they fall short of SFARP, because the regulator checks, carry warrant cards and severely punish those not doing enough.
I loathe this phrase, it is lazy and misinformed. Billy Brag posted on Facebook recently – remember Grenfell Tower the next time you hear someone complaining about health and safety. Well done Billy.
‘So far as reasonably practicable’ is by contrast inspired. This clever phrase completes the circle:
1. Create a safe place of work;
2. Do all you can to achieve this and critically …
3. We will check that you do.
This harnesses the employers’ imagination, and in this age of private litigation – their fear too. ‘Is this far enough? … let’s just do that bit more…’.
The reality is – all the examples of seeming ‘H&S gone mad’ (including the famous conker ban), was the employer choosing to go the extra mile or two (rightly or wrongly). The legislation was written specifically to get this extra mile because ‘not far enough’ is just that.
If legislation can be beautiful – this is.
Dial forward to the 2014/2015 stats and the impact of the remarkable legislation can be seen. Fatal injuries in British industry have dropped by 85% and reported non-fatal injuries are down by 77% since the HSAWA became law.
This is the rub; the revolutionary legislation is the Health and Safety at WORK Act and has no bearing on domestic situations or appropriateness of design – unless it is to be a place of work. The main supporting regulation for construction that sits under HASAWA is the Construction (Design and Management) Regulations 2015. The main duty for designers in this document is:
…so far as reasonably practicable, eliminate foreseeable risks to:
Again, a gaping hole for us to slip through.
There are two saving graces: firstly common parts (areas of a building used in common – so the fire escape, foyer, lifts etc…) all count as workplaces. Secondly there are very detailed building regulations which everyone must comply with.
But now we are back to the shadow of Aberfan – if the regulators do not spot a problem and allow for it, then it is effectively invisible.
Today’s building regulations are just as, if not more, proscriptive than the legislation predating HASAWA. For those that are calling for the regulations to be reviewed – I could not agree more. The regulations should be entirely re-written, with Lord Robens’ vision at the heart – so that it is the employer, the developer – those that make the money out of our toil that have a duty to ensure that what they do is without risk – so far as reasonably practicable.
Written by Nick Garland on Saturday September 23rd 2017
In my regular feature, I take a look at the data collected by Assure360 to understand the issues our peers in the safety industry tackle during site audits and tech reviews.
Assure360 is the only community audit and compliance tool available for the asbestos removal and construction industry. With over a hundred safety professionals using the system – so far they’ve completed nearly 3000 audits and competence assessments – we are developing real insight into the challenges and issues our clients and peers face and overcome. As a result, Assure360 has the power to genuinely improve the construction industry.
The system not only incorporates site audits, but records tech reviews during the planning stage and . This allows managers to learn from common issues picked up by their peers – before the project goes live.
We regularly share the community’s findings with our army of independent auditors through our customer newsletter. Here is a taster of the most recent findings we shared covering audits and site reviews from August 2017.
If we look at the overall top 10 we see predominantly paperwork issues, that either are, or can be identified during peer reviews:
The top 10 list looks like this:
Whist the no. 1 spot is still held by the appropriateness of the method statements – there is a dramatic increase in the frequency (up nearly 40%). This may be an indication that new auditors are focusing more in this area due to these Top10s.
The next two are new to this month’s Top10 and reflect current forum threads. The former was an alarming situation:
A client of mine recently enquired why the hired DCU did not have a CO monitor in the clean end of the DCU. I think I suspected that they would say balanced flue, separate sealed unit, not needed… but they actually came back with ‘we took them out because they don’t work due to the humid conditions and the rapid airflow’.
Heres a summary of what they said:
Following an investigation into a CO poisoning case (2 operatives overcome by CO fumes within the shower system), the conclusion was that the CO alarm did activate using the test button but failed to activate when CO was emitted into the system. This malfunction was caused by the water ingression to the sensor field and simply blocked the sensor.
The BS 50292 (5.2.3.1) apparently states that alarms should not be installed next to doors, window, extractor fans or air vents – where significant air movement prevents the alarm from detecting CO.
Obviously a concern – a clear hazard (2 operatives overcome by fumes), but the detectors don’t work due to the configuration of the units. Just taking the alarms out doesn’t seem to be a solution.
Assure360 allows us to drill down and identify issues faced by supervisors. This allows the teams to address targeted issues within supervisor meetings, rather than allowing company wide concerns to cloud the issue:
The top 10 for supervisors looks like this:
Several new areas have been focused on this month with DCUs receiving significant attention. Double hand rails – whilst they have dropped a spot – actually went up in frequency (up 20%).
Similarly, contracts managers can focus on their challenges
The top 10 issues for contracts managers are:
Obviously the method statement issue dominates here – but if we look in more detail, there are three Welfare questions that are clearly linked. If we take Welfare – general facilities, canteen and provision of water together – they are in a clear second place with 16 instances. I think we are seeing evidence of our construction colleagues teaching us what to look for.
Written by Nick Garland on Tuesday September 12th 2017
You’ve heard about the benefits of using Assure360. You’ve heard what our customers have to say about Assure360. Now it’s time to find out for yourself by booking a demonstration.
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Assure360 brings asbestos and safety management innovation into the 21st century. It’s a complete safety management solution. Our customers tell us regularly that using Assure360 has revolutionised health and safety management and asbestos auditing in their organisations.
The MD of LAR, Bob Clarke, says: “Whilst initially skeptical of all such systems, now that we have been using Assure360 for a while I am totally converted. It is an incredible asset to my organisation.”
Would you like the opportunity to understand how Assure360 could do for you what it’s done for organisations such as Royal Mail Group, Breyer Group, LAR and Delta Services?
We’d be delighted to offer you a free demonstration of the platform. To book your demo just use the form on this page to contact us. If you’re coming to Expo2017, we’d happily host a demo at our stand C3150 – just let us know on the form. Or if there’s a better time for you, let us know via the form and a member of our team will be in touch to arrange a mutually convenient time for us to walk you through how Assure360 works.
Already a valued customer? You could still win – just book a demo for a colleague or professional contact and you’ll be entered into the draw as well as them.
As a thank you, everyone who has received a demo of Assure360 by 30 November 2017 will be entered into a prize draw to win an iPad 32GB Wi-Fi +Cellular. So why not get ahead with your planning for 2018 and book your demo today?
Once you try it, you may find that, like Andrew Le Marie, Group Head of Health, Safety and Environment at Breyer Group, you “couldn’t ask for any more.”
The competition closes on 30 November 2017 and the draw will be made on 4 December 2017. Entry is free and no purchase is necessary. Automated entries will not be accepted. There is one prize in total. The prize consists of an iPad Wi-FI + Cellular 32GB. The prize is as described and there is no cash alternative. The winner must have a UK mainland address to be eligible to receive the prize. Assure360 reserves the right to to disqualify entrants from outside of the UK mainland. Shipping costs are included to mainland UK addresses only. No other expenses, including travel, are included as part of the prize. The draw will be independently witnessed and the first name drawn at random after the closing date will receive the prize as detailed above. If the winner cannot be reached, Assure360 reserves the right to award the prize to a reserve winner drawn at random. For winner’s details, please email enquiries@assure360.co.uk within eight weeks of the draw date. The competition is not open to employees of Assure360, their families, agents or anyone professionally connected with the prize draw. To qualify for the draw, you need to have completed a demonstration of the Assure360 product by midnight on Thursday 30 November 2017. The winner will be notified by email or phone after the closing date. By entering this competition you are giving Assure360 permission to contact you at a future date. Entrants must be 18 years of age or over. Assure360 reserves the right to cancel the competition at any stage if deemed necessary. Entry into this prize draw is taken as acceptance of these terms and conditions.
Written by Nick Garland on Tuesday August 29th 2017
We’re exhibiting at Contamination Expo 2017 again this year. Find out why you should be going – and why you should come and talk to us on stand C3150 about your asbestos and safety management headaches.
The Hazardous Materials Expo 2017 is happening on 27 and 28 September at the ExCel Centre in London. Doors open at 10am. There’s more visitor info on the Expo website here. You can find a floorplan for the Expo here.
We’ll be hosting a stand ready and waiting to talk to your about your asbestos and safety management headaches. We’ve got more than 20 years’ experience in the industry so no matter what your challenge, you can pretty much guarantee that we’ve been there.
We’ll be holding consultation appointments on both days and offering demos of the Assure360 – our simple app that brings health and safety innovation into the 21st century. Everyone who books a demo while they’re at Expo will be entered into a prize draw to win an iPad worth £500.
We’ll also be launching our new whitepaper – ‘An Asbestos Analyst’s Guide’. This free resource offers our take on the HSE’s draft new analyst guidance. It’s essential reading to help you unpick the significance of the changes coming our way. Get your free copy when you come and see us at stand C3150.
Get in touch if you’d like to book a demo of Assure360 at the Expo
Written by Nick Garland on Monday August 28th 2017
In the third part of my summary of the new draft Asbestos Analyst’s Guide from the HSE – I’m concentrating on reoccupation certificates and clearances.
For those of you who have read either of my first two summaries – this stand-alone article is a continuation. If you want to read the first two instalments:
Part 1 – Appointing the right asbestos analyst
This time I am concentrating on the critical issue of reoccupation certificates, or for the layman – the final validation that an asbestos enclosure has been cleaned well enough.
The HSE have been running a well-publicised investigation into analysts and clearance practices, the findings have clearly informed Martin Gibson’s work here. Ordinarily I tackle bigger sections of the draft guide, but this area has so many changes and is of such significance that I thought it best to concentrate.
The latest heads-up on a release date for the finished guide, is that it should be back with Martin Gibson (the author) in September. Not sure how that translates to publication – but clearly the tanker is being manoeuvred.
Whilst I am still writing for the layman – this instalment reviews some dramatic changes that all professionals will need to prepare for.
My usual health warning – this is obviously a summary and clearly not intended to replace the Guide. The appendices contain a lot of important detail and should still be studied to gain the fullest picture. Finally, this is a review of the ‘draft for consultation’ – there may well be changes before final publication.
This is the legal phrasing used to cover the duties imposed when returning an area back to normal use – after some asbestos removal.
You might recall from the previous posts that the guide gives some pointers on when not to test. The one I repeat here is during the 4-stage clearance for external works. A common example would be soffit removal. Historically, this was an area that often confuses removal companies and analysts. External asbestos removal (i.e. no enclosure) still requires a 4-stage clearance (4SC), just not the actual air test section (Stage 3). The Certificate for Reoccupation (CfR) should be completed as normal – but this part would be struck through as N/A.
As an aside – the guidance on roofless enclosures to tackle domestic enclosures is so onerous that it is almost a statement – ‘don’t do it’. The requirement to place tarpaulin on the ground under the scaffold is virtually impossible to comply with. This should extend 2-3m beyond the footprint of the platform. It is a rare (possibly mythical) property that does not have bushes, trees, sheds or the neighbour’s property in the way of this. Guidance being guidance, you are not compelled to follow it exactly, but you must introduce something equivalent or better. Just because it’s hard to do – it can’t be ignored and the designer needs to get imaginative. I would suggest it is probably cheaper and easier to build a bigger scaffold and put a traditional enclosure on top.
The process by which an analyst passes off an asbestos enclosure is very familiar:
All 4 stages should be completed by a single analytical company (accredited to ISO 17020 and ISO 17025), and preferably the same analyst. To ensure the long since required independence it is now “strongly recommended” that the analytical company is employed directly by the building owner / occupier direct.
This is a much firmer stance on the issue and potentially marks time on the removal contractor rolling the clearance into the package and employing the analyst themselves. This has been the advice that all consultants have given for years (me included). I can hardly argue against it now – but it will have a cost impact – contractors always seemed to negotiate very competitive rates from analysts!
The requirement that all 4 stages must be completed and passed, with a failure at any point leading to the issue of an incomplete certificate remains. As does the requirement to carry out a separate inspection and clearance of the decontamination unit used by the asbestos removal workers.
The guide stresses that the analyst should plan the 4-stage clearance ideally at appointment stage, but certainly before work starts. This would involve specific conversations with the LARC about issues that could disrupt or impede the process. Sufficient time must be allowed for the 4-stage clearance and particularly the visual inspection. This last (for the layman) is the detailed hands-and-knees examination by the analyst that all asbestos and even visible dust has been removed.
There are some fundamental changes:
* With time and date stamp. The photographs required are quite extensive and would be a minimum of 12, plus one for the DCU. Substantially more for complex enclosures. The unspoken implication is that date and time stamped photos would prevent fraudulently forged certificates.
The guide includes a table in the appendices on suggested times for visual inspection:
If the difference between the estimated and actual visual inspection duration is >20% (longer or shorter), the reason should be recorded on the CfR. However, it does not state what should happen if the reason given is inadequate. I am aware that this was raised during the consultation process, so hopefully it will be clarified later.
The analytical company should build up a data set of estimated and actual times to enhance/improve their service in the future. This should also allow internal (or UKAS / HSE) investigation on the reasons stated for variance. Questions could be asked if significantly lower visual times are recorded. The date and time stamped photos would make massaging of these stats much harder.
Separate copies of the CfR should be provided to the building occupier / owner and to the LARC ‘promptly’ on completion of the process. This may cause issues for entirely electronic systems that do not produce completed certificates on site.
The clearance certificate for the DCU is a mandatory part of the process irrespective of who has employed the Analyst. i.e. if the contractor is not employing the analyst directly for the CfR, they do not have to pay separately for the DCU element of the test. Whilst this is a good improvement, it does raise some additional questions – there will be several variants, but I think this example sums it up:
** this number of clearances might not be possible anymore – see below.
Time spent on clearances has dramatically increased (a very good thing indeed!). When I started my career in Manchester in the early ‘90s, four and five visuals in a day were not uncommon. Given the recommended visual times – more than one would be unlikely.
The guide finally ends debate on correct use of PPE – more on this later, but as entry into enclosures for 4SC procedures:
carries a risk of exposure and contamination, the Analysts entering enclosure should only be wearing appropriate RPE and PPE. No other clothing should be worn.
It is not the analyst’s role to supervise or manage the above, but to validate that it has been completed successfully. Cleaning the enclosure therefore remains the responsibility of the contractor. The analyst should not start the 4-stage clearance until the contractor has conducted their own thorough visual inspection and is satisfied that:
Sealant / encapsulant should not have been applied at this stage.
I have heard talk that the time spent by the supervisor on this visual inspection should be the same as for the analyst. This was not detailed in the draft guide and I do not know whether this will be in the final version, inserted into the Contractor’s Guide when that comes out – or left out completely. If it is brought forward, it would of course prove to be a dramatic change. Supervisor visual inspections can often be quite cursory – the suggestion that this should increase to 1-2 days for a large complex boiler room, will probably be met in some quarters with incomprehension. Guidance on this key element of the job has been a long time in coming. Clearly it would have a significant cost impact.
The guide makes a brief foray into defining “Environmental Cleans”. I understand that this was met with such opposition in the consultation process that it will be dropped. Martin Gibson (HSE author of the guide), clarified his thoughts at a BOHS seminar. Areas with the occasional tiny spec of suspected asbestos debris should not be considered licensed work, and therefore wouldn’t require a 4-stage clearance. As I say this whole section is likely to be dropped or heavily re-written.
Much, much longer clearances, possible transforming changes to the role of the asbestos supervisor and a courageous definition for environmental cleans. A shorter chapter this time, but I think you’ll agree possibly the one with the most dramatic implications.
Find out more about how Assure360 can help you with asbestos management – book a demo and you could win an iPad.
Written by Nick Garland on Wednesday August 23rd 2017
The data we collect through the Assure360 app gives us unique insight into the issues our peers in the safety industry tackle during site audits and tech reviews.
Assure360 is the only community audit and compliance tool available for the asbestos removal and construction industry. With over a hundred safety professionals using the system – so far they’ve completed nearly 3000 audits and competence assessments – we are developing real insight into the challenges and issues our clients and peers face and overcome. As a result, Assure360 has the power to genuinely improve the construction industry.
The system not only incorporates site audits, but records tech reviews during the planning stage and . This allows managers to learn from common issues picked up by their peers – before the project goes live.
We regularly share the community’s findings with our army of independent auditors through our customer newsletter. Here is a taster of the most recent findings we shared covering audits and site reviews from July 2017.
The top 10 list looks like this:
Changes from last time is that accuracy of the drawings has dropped lower as has double handrails. Dropping out of the top 10 completely COSHH assessments, electrical isolations and firefighting equipment. A new observation – at number 1, is the appropriateness of the method. This is a new question in the App – where the auditor makes a judgement of whether a better, safer, more efficient method could have been designed.
Assure360 allows us to drill down and identify issues faced by supervisors. This allows the teams to address targeted issues within supervisor meetings, rather than letting company wide concerns to cloud the issue:
The top 10 for supervisors looks like this:
The two interesting additions to the list is double hand rails and housekeeping. Both are traditional H&S issues rather than asbestos specific, and might indicate widening expertise or awareness from the auditors. Also a new question in the system is Method Statement Briefing. This is where a supervisor has had to be moved or replaced – has there been sufficient hand-over and has the new site management taken full charge of the site?
Similarly, contracts managers can focus on their challenges:
The top 10 issues for contracts managers are:
HAVS and the associated vibration risk assessments seem to be an issue at the moment. Also the refining of the question set, with more options with regard to how a method statement is being written – has changed how issues are being recorded. This will help with more detailed root cause analysis.
Written by Nick Garland on Tuesday August 1st 2017
I’m always fascinated by the insight the Assure360 app gives us into the issues we’re all tackling during site safety audits and tech reviews.
Because Assure360 is the only community audit and compliance tool available for the asbestos removal and construction industry and there are more than a hundred safety professionals using the system we have the potential to really improve safety in the construction industry.
The system incorporates site audits and records tech reviews during the planning stage so managers can learn from common issues picked up by their peers – before the project goes live.
Here is a taster of the most recent findings we shared covering audits and site reviews from May 2017.
If we look at the overall top 10 we see predominantly paperwork issues, that either are, or can be identified during peer reviews:
The 10 most common non conformance issues in May 2017
The top 10 list looks like this:
Compared to last time we published the data, we can see some differences:
Assure360 allows us to drill down and identify issues faced by supervisors. This allows the teams to address targeted issues within supervisor meetings, rather than allowing company wide concerns to cloud the issue:
The most common issues for supervisors in May 2017
The top 10 for supervisors looks like this:
This last is normally the responsibility of the Contracts Manager, but we can see from this that the auditors are attempting to improve the skills at all levels.
Assure360 is not a dumb ‘smart form’ or isolated tablet application – it is linked to a powerful cloud database. Its sophisticated system of automatic reminders and dashboards, ensures the right people deal with the issues at the right time. As Assure360 always asks – ‘what could we do to prevent this from happening again?’ everything is dealt with – root and branch.
This month’s results would indicate that the approach is working.
How does this data compare with your own audits? Do you have a tool that can help you monitor and tackle these issues, saving you time and money and keeping everyone on the project up to speed?
Let us know what kind of data you’d be interested in seeing.
Written by Nick Garland on Tuesday August 1st 2017
In the second part of my summary of the Asbestos Analyst’s Guide from the HSE – I’m concentrating on asbestos testing (both bulks and air).
This is a stand-alone article, but you may also want to read the first instalment published earlier this year – New analyst guidance: appointing the right asbestos analyst.
This is a review of the ‘draft for consultation’ – there may well be changes before final publication. We still don’t have a release date for the final publication of the guidance, and we are already at the end of the promised June. However, the consultation was a surprise when it was issued over Christmas, so stand by your beds.
Whilst I am writing this for the layman – this instalment reviews some dramatic changes that all professionals will need to prepare for. It comes with my usual health warning – this is obviously a summary and clearly not intended to replace the Guide. The appendices contain a lot of important detail and should still be studied to gain the fullest picture.
The first section I will deal with in this instalment is analysis in bulk materials – or ‘bulks’ for short.
Simply put, this is where a small amount of a suspect material is collected on site and taken to a laboratory. Powerful microscopes are used along with special techniques to investigate the sample. This is the only sure fire way of determining whether a material contains asbestos and ultimately what risk it presents.
Bulk Sampling and asbestos surveys are required under the duty to manage (CAR 2012, Regulation 4) and under the current Construction Design and Management (CDM) Regulations.
Whilst HSG264 – Asbestos: the survey guide remains the best practice manual, the new analyst guide overlaps and takes things further in some areas. Both will need to be understood to remain compliant.
The guidance on single surveyor working has been significantly altered. It is now ‘strongly recommended’. The guide goes further by stating that some situations make it essential:
We should take note – as this is much more forceful phrasing than the ‘ideally’ in the Survey Guide. The need to work from height in most or all surveys would seem to preclude solo working completely. Clearly, if single ‘man’ teams are now officially frowned upon, it will have an impact on prices.
The guide gives specific direction on sampling strategy for some ACM types. Mostly the advice is consistent with HSG264, but again with some exceptions. The first significant change is in the recommended strategy for pipe insulation.
HSG264 tells us:
“In general, one sample should be taken per 3m run of pipe with particular attention paid to different layers and functional items (valves etc). ”
Whereas the Analyst Guide says:
“Valves or hatches or repaired areas near access routes are less likely to contain asbestos but discretionary sampling may be necessary.”
Clearly a totally different approach, which I am not convinced about. Only the other week I attended a site where all the asbestos had been removed, except near the valves.
Another key change in guidance is in dust sampling, which should be avoided except in ‘rare and specific occasions’. Dust sampling should not form a routine method or approach when surveying. Low numbers of asbestos fibres in dust are to be expected in buildings which contain or have contained ACMs. Due to the sensitivity of the method, very low levels of fibres can be detected. However, the guide tells us the random presence of low numbers of asbestos fibres in dust is not significant and represents “inconsequential risk”. It also tells us – in the absence of any ‘visible’ suspicious asbestos debris and fragments, extensive cleaning or abatement works will not be necessary
This is very welcome guidance indeed. Asbestos occurs naturally in the air of all our industrial cities. The sensitivity of the bulk analysis process is likely to find even the smallest trace. Because such testing merely determines presence and not risk, it is too blunt a tool. Random swab samples, where there is no visible evidence of contamination have caused no end of issues to clients. A report containing such information can cause considerable alarm and remediation costs, where the reality might be a single isolated fibre posing little or no risk. See the section towards the end of this article on SEM and ‘Real Risk Assessments’.
In traditional surveys, the number of samples taken will depend on:
The guide states that the number of samples should not be restricted by cost or contractual arrangements as this could lead to poor choices and false assumptions. This is much stronger guidance than previously published. I must stress that I fully support the increased emphasis, but it should be recognised that it will have an impact on costs.
Help can be obtained from original architect drawings, but will depend a lot on experience. The guide suggests ‘tells’ that will give a clue to a change in material:
None of the above can be used for positive identification, but they can give a strong indication as to when to take additional samples.
Consideration should be made where access makes sampling or post sampling clean-up impractical or hazardous. These areas should be discussed with the client. This is a continuation of the plan, plan, plan mantra of the survey guide.
On the sealing of the sampling point, the guide raises some important considerations. Specifically, it recommends that the chosen technique should be agreed with the client. Some issues to bear in mind:
Safety alert!
On this last issue, there was a serious safety alert on the asbestos forum where some foam sealant used in an enclosure spontaneously ignited via static electricity.
Spray coatings The guide suggests pre-injected with surfactant around the sampling area. It cautions against sampling damaged areas that show evidence of previous repair – whilst easier and safer, it may not be representative.
Pipe/thermal Full depth samples using a core sampler, but placing a wipe inside the tube before sampling and withdrawing the sampler through another wet wipe. This creates a plug at either end.
Insulating board/tiles The guide warns of proximity to live electrics, where pre-spraying might be hazardous. It also warns that a large sample is needed if the water absorption test is planned to determine AIB or cement (see below).
Asbestos cement Large samples are recommended (at least 5cm2) or where the water absorption test is required (9cm2). Asbestos cement is defined by CAR 2012 as a material, which is predominantly a mixture of cement and chrysotile and which when in a dry state, absorbs less than 30% water by weight. This leads to the Water Absorption test which is detailed in Appendix 3 of the draft guide.
Textured coatings Again large samples are recommended as asbestos is typically non-uniform (at least 20cm2). Areas of thicker material and/or ridges should be targeted. Two samples per surface or one per 25m2.*
Dust samples Avoid, but where they are taken to assess spread of a specific incident a minimum of one tablespoon of dust (not debris) should be collected. Scraping the dust layer into a pile and transferring into a suitable labelled container. Wipes, adhesive tape and filters should not be used.
* I have served my time in the bulk lab and can testify to how irritating small samples of textured coating are. However, I am not sure how a client would take to two 20cm2 sample from every ceiling. Certainly, something to discuss in the pre-survey planning.
In layman’s terms, air testing. For asbestos, it is the collection of a measured volume of air (litres) through a filter. A specific area is examined (number of ‘graticules’ – see below), and the number fibres counted. This allows the calculation of the concentration of respirable (again see below) fibres in the air.
As the guide was intended for the use of clients as well as analysts and the above is likely to mean nothing to most readers – I will start by explaining a few terms:
Respirable
In this case means not only breathable, but small enough that they can reach the lowest levels of the lungs where they can do the most harm.
Volume
Results are quoted in one of two ways – the first is by far the more dominant. f/ml or f/cm3 – i.e. number of respirable fibres counted for every millilitre or cubic centimetre of air drawn through the pump. 1ml is the same volume of air as 1 cm3.
Limit of Quantification (LoQ)
This is an oft used phrase that is little understood outside the analytical world. Results are often stated as less than the LoQ (e.g. <0.01f/ml). LoQ is a statistical way of determining what would be “fair to say”. E.g. if a given room had 100 fibres floating about and you sampled a small amount of the air – it would be pot luck whether you captured any of the fibres, but it wouldn’t be ‘fair’ to say that the air was asbestos free – just you didn’t detect anything. Similarly, if there were 1 million fibres floating about – you would be near certain of catching some. Therefore, LoQ is a statement that:
we don’t really know exactly how much asbestos is in the air, but it is less than ‘this’
Any clearer?
Graticules
This is the round ‘target’ that the analyst can see when analysing the filter through the microscope. The target is moved randomly a set number of times and the number of fibres falling within that target are counted. The graticule is a specific area, and so if we know how many targets have been inspected, we know the precise area of the filter that has been analysed. Clearance tests would include 200 of these random movements, personals can have less. Therefore, if only 100 graticules are used this means ½ the time to analyse the sample but double the LoQ.
The guide details the two main types of air testing – personal and static.
Where we test the fibre levels near to an individual’s face. The asbestos approved code of practice tells us what we should use this type of test for.
Whilst measurement against the control limit requires a 4-hour sample, there is allowance for shorter activities. It must be noted that when the time to access the enclosure and decontaminate following completion of a morning’s shift is factored in, a 4-hour task is a rare beast indeed.
In my opinion, all the above are important, but the last three have the most practical use. The removal contractor should be aiming for higher standards than the control limit to help drive performance. But only a test with a low LoQ can have any real utility. Therefore, the 10-minute test should be avoided in favour of one that can give a LoQ of 0.05f/ml or better.
My Assure360 database is designed specifically to deal with these three critical areas.
Clearly high risk activities should be prioritised – this may be related to the ACM, its condition or the individual’s role in the method. So, if a single test is to be completed it should be the operative scraping the pipe, not the one doing general spraying duties.
The analyst must record detailed observations about the operative during the testing:
The guide specifically states that if any of this information is missing, the sampling will be deemed inadequate. Now this is a very strong statement indeed. I think it is intended to compel analytical companies to comply, rather than suggest to a contractor to ignore them.
Just like any asbestos worker, the analyst themselves should have personal monitoring conducted on them particularly:
A ‘summary’ of personal sampling should be kept for 5 years. There is no guidance on what this summary should contain. But the data should form part of the health records, which must be kept for 40 years.
My Assure360 database tracks the exposure, compares it against the anticipated level and allows the employer to review methods on a regular basis to improve standards. Whenever the anticipated levels are exceeded, this is treated just like any safety incident spawning an investigation and root cause analysis. These new-look certificates would come into their own at this stage – perfect evidence for the investigation. Upload them as a permanent link to the record. With nearly 4000 personals on the system now – it gives users a great deal confidence when setting and reviewing levels.
This is the large traditional air test, where we establish the fibre levels in a general area. Used in several different situations:
There is no specified flow rate for static tests, but total volume of air tested should 480litres or more. The number of graticules (targets) counted must be 200+. However, the recommendation is that high flow rates (e.g. 16L / min for 30 minutes be used to limit the effect of settling and increase accuracy. The exceptions to this are background and perimeter monitoring – where low flow rates and very long durations are preferred.
The guide gives some pointers on when not to test.
I have my doubts over the wisdom of the last two. We are mandated to reduce exposure so far as reasonably practical, therefore not testing because we don’t think exposure will be too high – or we already use good RPE – seems to miss the point. You should always conduct the test to ‘support current and future risk assessments’ and ‘check the effectiveness of control measure’.
This is the name of the standard technique used to calculate airborne fibre concentrations. Paragraphs 5.10 & 5.11 give a great deal of detail on this, which I do not intend to reproduce here.
The technique has its advantages and disadvantages. Probably the key plus is that the test is quick (within an hour or two when conducted on site) and by comparison to the alternatives – inexpensive. Disadvantages are that high dust environments (e.g. wire-brushing, ‘blasting’ or removal of ceilings) can overload the filter making it unreadable (occluded). As it can’t easily differentiate between asbestos and non-asbestos fibres, it can overstate asbestos concentration.
These must be recognised and factored in when designing the sampling strategy. Careful selection of sampling periods/volumes or sequential samples (i.e. multiple tests run after each other, adding the results) should be considered. Another important strategy (where results may be skewed by non-asbestos fibres) would be the retention of half the filter prior to standard analysis. In the case of a ‘high’ result from the first half, the duplicate can be sent for a much more accurate Scanning Electron Microscopy (SEM) test – see below.
Caution should also be observed when interpreting the results from post incident air tests. The time gap between the incident and the test will be affected by natural dilution.
Whilst the guide details the option of using SEM analysis. It does not suggest it as a first option, but only as a check if PCM fails. However, in the case of blasting, where occluded filters are near certain, or very low LoQs are desirable, SEM testing should be considered. SEM can obtain LoQs as low as 0.0005f/ml and are much less vulnerable to overloaded filters.
One interesting service that is beginning to be available is ‘Real Risk Assessment’. The phrase was coined by Charles Pickles of Lucion referring to long duration air tests in normal (occupied) areas. Analysis by SEM would give very low limits of detection. Results could then be directly comparable to the World Health Organisation lifetime risk levels. This would finally measure chronic low level exposure and allow a genuine understanding of the long-term risks. Such accurate results could validate existing management techniques and prove that occupants are not being exposed, or, used to improve the plan.
In the case of 4-Stage Clearances (4SC), the guide indicates that the original floor surface should not be covered at the time of the air test. It does say that there are exceptions, but the only examples given is scaffolding or when the floor is an ‘intrinsically dusty surface’. This could be interpreted as meaning – floors sheeted out before removal must be uncovered for the 4SC air test. Hopefully clarification will be in the final version as many simple projects may become more complex and costly if this is the case.
The guide states that daily leak testing is required where there are other personnel near the asbestos work. Key areas to be tested are:
Testing should be a combination of short and long duration – short just after removal commences, with longer duration following on after.
This is very clear direction that was lacking in the original 2006 analyst guide. Currently leak testing (certainly daily ones) is considered an optional extra. The new emphasis is unarguably a good idea – but the cost impact on projects will be significant.
Other than the PCM and SEM, two other sampling techniques are discussed in the guide:
In my next feature I’ll be looking at how we can start preparing for new legislation.
Written by Nick Garland on Friday June 2nd 2017
We’ve just released an updated version of the Assure360 app – here’s how it helps to turn auditing into meaningful improvements in safety.
Our app was born to help companies manage asbestos removal projects (the most regulated UK industry after nuclear), so compliance is critical. But the structure also encourages the auditor to examine ways to improve. The app identifies good innovation on site as well as allowing the user to record aspirational best practice identified elsewhere. The combination of the app and the cloud database, instantly links audit findings with actions. Whether the observation is something that has gone wrong, innovative best practice, or a lesson learned from external sources –the sophisticated workflow process makes sure no one forgets.
The audits completed on the free app are the most comprehensive available, developed by myself over the past decade. They are uploaded directly to a database in the cloud, where the system interprets them for you. Non-conformances are presented to the designated managers for them to close out. It even reminds them if the due date expires. The high-level dashboard not only shows the immediate information required to spot trends, track close-out and develop strategies for improvement, it also allows a structured walkthrough so that you can showcase how you go about managing H&S to clients and regulators. A warts-and-all approach, where ‘challenged’ sites are discussed, becomes real evidence of proactive management.
Multiple organisations can participate in the process. The company themselves will obviously take the lead – but customers and trade organisations can also complete audits on the free app. The cloud structure can be designed so these 2nd and 3rd parties can view their audits and relevant internal inspections too. As all the audits are on the same system, close-out of non-conformance and learning from best practice is streamlined.
With the help of the army of auditors who use it, Assure360 has been evolving since its creation. As findings are anonymously shared on the central cloud database – this means that users constantly and automatically learn from others in their own sector and beyond.
Assure360 now covers safety auditing in every workplace and is so flexible it can be tailored to any industry, language or country. This flexibility was a key demand from our users who have been an integral part of the research and development. Continuous feedback, active participation, innovation and plain bright spark ideas have allowed us to design the experience to match not just what users need, but what they want.
We are still very close to our roots, but now the asbestos industry can start to learn from other sectors.
Read my feature on LinkedIn to find out more about what needs to change in safety auditing.
Written by Nick Garland on Tuesday May 30th 2017
For decades, the HSE’s requirements have not been well communicated, or have been described in terms frequently misunderstood by the industry. The license holder (or the prospective one) has too often been left to work it out for themselves.
It takes a courageous removal company to stand their ground when presented with the opinion of the inspector on the spot. To be fair, there is no manual that the HSE can pull off the shelf describing the perfect asbestos removal company. But this ad hoc, local, opinion-led approach has produced a host of different solutions:
Whilst some of these questions are new to the last few years, exposure monitoring has been causing licence holders problems for my entire career.
But why is this so difficult? The LARCs – licensed asbestos removal consultants – do manage health and safety, producing method statements and documentation far more detailed and considered than their construction counterparts. They spend vast sums on training staff, and ensure levels of supervision beyond what other industries would even consider. Exposure monitoring has been a challenge, but the tests are done in line with guidance and by skilled analysts, perhaps just not frequently enough – but done.
So why do these questions become so difficult to answer in a licence renewal meeting?
First, there is no 100% right answer and nowhere to look for advice, beyond asbestos specialised health and safety consultants (like myself). The trade organisations can also pitch in with this, but the independents are too few and far between to help everyone. However, as all industries can tell you, parachuting in a consultancy to ‘identify and solve underpinning problems’ sometimes leads to superficial solutions. The way I have always approached it is to become embedded in that company – almost as a part time H&S manager or officer. This degree of understanding is vital for crafting solutions.
Second, the nature of licence renewal is often adversarial, with the future of the company on the line. This does not lead naturally to a relaxed environment where ‘business as usual’ can be showcased.
So, how can Assure360 help?
Firstly, all reputable asbestos removal companies conduct audits. These are sometimes conducted on Excel, or iAuditor (an interface with Excel) but often on paper. The problem with these solutions is that they tell you little beyond high level non-conformances and it can be challenging to extract meaningful trends. The paper version (or a PDF) is often a cul-de-sac, with non-conformances trapped on the paper, hidden in a file.
When asked – ‘How do you manage H&S?’, too often the answer is a jumble of files, hard to decipher Excel spreadsheets, and in worst case scenarios un-actioned paper audits.
Not so with Assure360. The audits completed on the free App are the most comprehensive available, developed by me over the past decade.
A warts-and-all approach, where ‘challenged’ sites are discussed, becomes real evidence of proactive management.
One client, Rob Wasson from Delta Services, recently contacted me after a licence renewal. He told me: “When I demonstrated the Assure360 system to the HSE, it made me proud of all that we had achieved.”
That degree of confidence and enthusiasm can only be massively influential at renewal time.
The new question that the HSE can nail us with is how do you ensure the competenceof your workforce?
Competence is a tricky customer and can be a complex thing to measure – after all, just showing them the training certificates is not enough. I’ve written previously on our blog about what to look for in a good competence scheme. Assure360 however does it all for you. The same comprehensive audits are just interpreted in a different way.
The beauty of this is that you have already done the work. So instead of one more job that your overstretched team are asked to do – it is a matter of moments.
In my experience when helping a licence holder prepare for the HSE, the one thing that they are least confident with is exposure monitoring. Often there has been plenty of ‘personals’ done (though sometimes not). Sometimes these are compiled into an Excel spreadsheet, though often not. When asked ‘how are these used?’ it is frequently met with a pregnant pause.
In some ways, the LARCs have been led up an exposure monitoring blind alley. People in asbestos removal often only have a vague understanding of what exposure monitoring is for (you can read more on this in my earlier article here). They get provided with dozens of 10-minute ‘personals’ that tell us next to nothing. The feeling of ‘what is the point of this beyond keeping the HSE happy?’ has some justification.
The approach that Assure360 has transforms every personal monitoring test into an assessment of how successful the method was.
With 360, ‘the point’ is clear – it has a direct impact on the improvement of methods.
Assure360 is specifically designed to address all the challenges I have identified in my nearly 25 years in the industry. For the past two years, it has been helping LARCs improve themselves and with that, the industry.
Ken Johnson from Delta Service recently told me: “The moment I saw the system demonstrated I knew it was an absolute must for us. It ticked so many boxes – all the areas that the entire industry seems to struggle with.”
The central theme is simplicity, Assure360 is a system, one that you follow, implement and operate yourself. Just by doing so you gain greater understanding of the management of your company. You operate it yourself (no expensive consultants) and everyone contributes – this simultaneously saves money and strengthens your health and safety culture.
To find out more how we can help, contact us today on 0845 226 4318
Written by Nick Garland on Thursday May 25th 2017
Here’s Nick Garland’s summary of the draft of the new Asbestos Analyst’s Guide from the HSE and what it suggests for hiring the right analyst.
The HSE’s new Asbestos Analysts Guide is coming soon or so we have been confidently told for the past year. The current tentative publication date is June 2017, but I have heard that even this is likely to slip. When we do get it, it is designed to help both Analysts and their clients comply with the Control of Asbestos Regulations 2012 and its ACoP.
It’s the client I am particularly aiming this summary at, but those with technical backgrounds should also find it useful. It is also for this reason that I largely don’t cover the appendices – in of themselves a whopping 178 pages’ long!
This is obviously a summary and clearly not intended to replace the Guide. In particular, the appendices contain a lot of important detail and should still be studied to gain the fullest picture. A note of caution, this is a review of the ‘draft for consultation’ – there may well be changes before final publication.
The early stages of the guide cover the critical areas of how to appoint an analyst and what quality control measures should be implemented by the consultancy.
This is the first time we have been given strong guidance on this subject, though it has long been the perceived best practice. This contractual relationship is critical to ensure independence and the control you will need
With this starting point, the HSE then require you to discuss the project in detail with the consultancy. The aim is to ensure that the consultancy understands what you the client wants and for you understand what you are going to get.
Areas to address:
The wording for this last point is particularly interesting. Reports should be designed to satisfy the client’s needs, not just perceived UKAS requirements. The frustrating ‘our reports have to look like this, it is part of our UKAS accreditation’ or ‘no we can’t give the data in that format, because…’ should all be a thing of the past.
The whole appointment and subsequent planning phase is intended to mimic the changes first introduced in the Surveying Guide in 2012. Planning (especially between the client and the surveyor) has become the major route to success. It is intended to get around the issue of “why do I never get what I asked for?” – the answer normally being “you didn’t ask for it…”
Underlying everything in CDM15. Asbestos removal projects are covered by CDM, this is a long-accepted fact. However, the analysts guide gives us a new twist. Contrary to the wording in CDM15, the guide specifically states that the analyst will be treated as a separate contractor. This has dramatic implications, as all asbestos removal projects – even the smallest ones – will therefore require the appointment of a Principal Contractor (PC) and a Principal Designer (PD).
Many of the asbestos consultancies have upskilled to take on the PD role, but the smaller ones may not accept the additional liabilities. This then is another duty for the client – appoint a PC and a PD to the project – and be confident that they have the skills to do it. This could be an asbestos consultancy that can accept the wider duties or a specialised PD that has the expertise in asbestos.
A key client responsibility in CDM15 is to ensure that the project is being run safely. Without this engagement and contractual control, ensuring safety would be largely impossible. Even then, without some expertise, you replace ‘ensure’ with ‘hope’.
The advice I always give clients is simple – become an educated one. Either train someone in your organisation or appoint a consultant independent of the asbestos project teams to be your expert advocate.
Employers must prevent or minimise exposure and as with all guidance, the phrase ‘so far as reasonably practicable’ is used. It also suggests that ‘live’ enclosure entry should be avoided – as this could lead to exposure above the Control Limit and with it, mandatory asbestos medicals.
I take two things from this: firstly, the pre-visual, much loved by contractors, is being officially frowned upon, and secondly the guide is suggesting that not all analysts need medicals. In my experience, site analytical work (clearances, leak air testing and so on), inevitably leads to exposure above the Control Limit at some point. I have two examples from my past, both seemingly very low risk that led to high personal exposure. The first, a contractor was removing a cement flue with hidden pure fibre in the flanges – a surprise failure at stage 3. The second was a straightforward Asbestos Insulating Board (AIB) job, where the High Efficiency Particle Air (HEPA) filter failed in the Negative Pressure Unit (NPU). Consequently, I believe all analysts should have medicals.
The guide makes clear that two copies of the Certificate for Reoccupation (CfR) must be issued – the building controller and the licensed contractor.
Personal exposure for analysts should be air tested (personals rather than static). The purpose of personal monitoring is not ‘merely’ duty of care and the data must be used for:
It gives direct guidance that personal monitoring should be performed in ~10% of case, targeting:
Whilst the control limit is highlighted, I find the other element more interesting. Minimise so far as reasonably practicable, risk assessment and effectiveness of controls drives the responsibilities of the employer much, much lower than just the control limit. There is therefore no ‘good enough’ and we should be striving for ever lower exposure. This has an impact on how long we run the tests for and what Limit of Quantification / Detection we set.
Whilst the number of required audits has stayed roughly the same, other checks to be recorded and studied have increased:
Approximately 5% should either be shadowed or blind inspected immediately afterwards:
During the consultation period, I know that there was some call for making the audits more specific – i.e. what type of clearance was it? This would bring it into line with survey audits.
The last bullet will be new to those that have not read the draft guide. The new 4-stage clearance process must include photographic evidence to support the decisions taken along the way. These will include such things as proof that the enclosure was free from gross contamination and dry before the visual inspection took place. The time and date stamp on the photos is intended to evidence the stated durations of each stage.
Maintain individual logs of all work completed by your analysts. These logs should record:
Six monthly auditing of Analysts’ performance (including a review of the above detailed logs).
Essentially the guide is calling for audits to record significantly more detail. Once we are collecting more we will have to do more with it. This will drive assessment of competence and training to new levels.
The difficulty is that a huge amount of data can be very time consuming to process. Just as the removal contractors found with the drive for competence on their side of the fence – the consultancies will have to develop new sophisticated systems to collect, analyse and present the data in meaningful ways.
The guide immediately highlights something that has been clear to me for a long time. What we ask of our analysts often strays from the standard UKAS requirements into other areas:
The guide also highlights the need for H&S training, in my opinion – critical basic training for any analyst.
We must also recognise that the very act of passing or failing a 4-stage clearance is a potentially stressful and intimidating situation. Consultancies should therefore provide support mechanisms and procedures to mitigate or eliminate. This will help ensure that analysts’ actions and decisions are impartial and independent. Personal qualities of ‘resilience’, ‘determination’ and ‘integrity’ will be required.
The guide covers the UKAS recognised proficiency training modules. Also highlighted is the requirement for sign-off by senior manager before any unsupervised work. However, the regulations tell us that Competence is not just a matter of a training certificate – we must ensure an employee is competent to do the job. But as I cover in my competence blog pieces – we can’t just leave it at that – just because I was signed off as competent last year doesn’t mean I still am.
The required participation of the client in the plan, plan, plan process is likely to expose a longstanding industry misunderstanding. When a client hears ‘Project Management’ they expect:
Initiating, planning, executing, controlling, and closing the work of a team to achieve specific goals and meet specific success criteria. The primary challenge of project management is to achieve all the project goals within the given constraints.
However, in most cases, Analytical Consultants mean:
Specify the project, review the method, supply an analyst to run air tests, provide a report after the clearance
The client sees the latter as a given, and assume that the asbestos consultancy’s definition of project management is the same as for other areas of construction. This disconnect from expectation and delivery leads to much of the dissatisfaction in the industry.
So how common are these skills:
It is a rare analytical company that even has these as categories on the skills matrix, never mind measures or audits them. They tend to be what we assume an analyst can do, without training. Managers have often described it to me as a ‘gut feeling’ about an analyst that leads them to promote them to a more senior role.
The guide’s focus on soft skills and project management presents a challenge to labs. Most companies currently do not even identify these soft skills in their competence matrix, never mind measure them.
The clear steer is that to be ‘competent’ (i.e. knowledge, skills and experience) an analyst needs to go far beyond just the ability to operate within a UKAS environment. We see far reaching implications for training and competence – a consultancy’s approach in this key area should form a key part of the selection process.
Get in touch with us to discuss how Assure360 can help with:
Written by Nick Garland on Wednesday May 24th 2017
The Assure360 app collects a huge amount of data and this gives us unique insight into the issues our peers in the safety industry tackle during site audits and tech reviews.
Our app is the only community audit and compliance tool available for the asbestos removal and construction industry. With more than one hundred safety professionals using the system – so far they’ve completed more than 2000 audits – we are developing real insight into the challenges and issues our clients and peers face and overcome. As a result, Assure360 has the power to genuinely improve the construction industry.
The Assure360 system incorporates site audits and also records tech reviews during the planning stage. This allows managers to learn from common issues picked up by their peers – before the project goes live.
We regularly share the community’s findings with our army of independent auditors through our customer newsletter (you can sign up to this at the bottom of this page). Here is a taster of the most recent findings we shared covering audits and site reviews from January 2017.
If we look at the overall top 10 we see predominantly paperwork issues, that either are, or can be identified during peer reviews:
The top 10 list looks like this:
Whilst there are some favourites here, Risk assessments (site specific) indicates that the auditors are trying to come to grips with that age-old problem of generic risk assessments. Assure360 will automatically record this with an action to identify and resolve the underlying issues.
Whilst on the surface – ASB5 (present and accurate) seems alarming, I am aware that this is being used to track when teams are not on site when they should be.
Assure360 allows us to drill down and identify issues faced by supervisors. This allows the teams to address targeted issues within supervisor meetings, rather than allowing company wide concerns to cloud the issue:
The top 10 for supervisors looks like this:
Again, for supervisors there are some familiar hurdles to overcome. But some surprising issues are being targeted as well. Vehicle inspections – when taken together – is the most common issue.
Similarly, contracts managers can focus on their challenges:
The top 10 issues for contracts managers are:
How does this data compare with your own audits? Do you have a tool that can help you monitor and tackle these issues, saving you time and money and keeping everyone on the project up to speed?
Let us know what kind of data you’d be interested in seeing and book a demo.
Written by Nick Garland on Tuesday May 23rd 2017
Breyer Group has over 400 employees and more than 60 years’ experience specialising in roofing, construction, responsive repairs and maintenance. They are one of the industry’s leading principle contractors, operating from their headquarters in Romford, Essex and a network of locally based offices.
As a large company with multiple offices, more than 400 members of staff, working on many sites with different clients, Breyer needed an intelligent system which could provide a single centralised platform to monitor all aspects of construction H&S. Breyer historically audited their sites using a bespoke tool. However, the system did not extend to tracking accidents and incidents, which had to managed separately. Significant development costs were becoming an obstacle to improvement. The support contract for the internal system also expired in two months, meaning the solution needed to be implemented quickly.
Assure360’s approach of configurable cloud database gave the best of both worlds. Working right out of the box, it was implemented within weeks, bespoke questions following very shortly after. Not only did it replace all of the functionality that the in-house system had, it went further bringing in accident and incident tracking too. The tried and tested audit tool meant that actually recording observations became quicker. Reporting via the Cloud platform – instead of being time consuming and labour intensive – was speedy and intuitive. The Cloud approach also gives visibility to all those that need it – site managers all the way up to the board.
“Assure360 has been a breath of fresh air since we started using it. The system is very easy to use, but at the same time powerful and comprehensive. We were able to create our own bespoke questions, so even though it is an off the shelf solution – working right out of the box, it has been configured to what we need.
“360 allows us to quickly and easily audit sites along with report, track and investigate H&S 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. What is even better is that the system is so easy to use, it is no longer me and my team that ‘do H&S’ – all of the contracts managers and directors participate.
“Assure360 allows me to do my job – manage H&S and improve the safety culture of the company. In short – we couldn’t ask for any more.”
Andrew Le Marie
Group Head – Health, Safety and Environment
Written by Nick Garland on Thursday April 27th 2017
The data shows that the licence terms awarded to asbestos contractors have reduced year on year. But in my view, standards in our industry are improving. So what’s going on? And is there a a better way forward for asbestos licensing?
A phrase every LARC will be familiar with, as it seems to be in all letters written by the HSE. One of the principle purposes of such a regime is:
“…maintaining and improving standards of health and safety”
The Health and Safety Commission permissioning regime policy statement
Maintain and improve standards of H&S, presumably by weeding out the incompetent and promoting best practice. But why then are average licence terms shorter now than they were? I have been in the asbestos industry since the early 1990s, and I’ve definitely noticed the change. Can we infer that the HSE’s opinion is that the industry is less safe and less competent than it was?
Licence assessments can be a very unpredictable time. All of the companies that I work with have heard of, or experienced extremely intense assessment interviews, but at the same time hear of laissez faire ones with very little detailed examination. Requests (demands) from the ALPIs is often insightful but can also be bizarrely arbitrary, with little practical application. One licence assessment ended up insisting that filing cabinets be used (rather than the perfectly acceptable system the LARC already had) – resulting in the conversion of the one and only meeting room into an archive room.
We all know anecdotally that it has become harder and harder to get the ‘full’ three-year licence from the HSE, but the latest figures are quite stark.
ALG figures, supplied by ACAD.
ALG figures, supplied by ACAD.
Excluding new licences (always one year) there has been an alarming drop of 23% in three-year licences issued in that period.
ALG figures, supplied by ACAD.
In my experience the industry, whilst there are some bad eggs, is getting much better. When I think back to the beginning of my career, where it seemed everyone had a three-year licence – the differences are remarkable. Now projects consider the wider job and recognise non-asbestos hazards. In fact, it seems a different industry with most of the stories of astonishing individual poor practice in the past.
So, if we are not getting any worse and the principle aim of a permissioning regime is to drive standards, why are the licence terms going down?
Could it simply be that there are less licensed contractors out there and the HSE want to exert more control. A tighter leash if you like? Certainly, the tone of some licence assessments and HSE visits indicate this.
The HSE tell the wider construction industry (and clients) that they shouldn’t use the licence term as a tool for selection. If the company has been given a licence (any licence) that indicates that they (the HSE) are satisfied and this should be good enough. The clients however (quite reasonably) take the view that well if you are concerned enough that you won’t give them a 3-year licence, then we are concerned too.
A licence holder can’t notify a project that extends beyond the licence expiry date.
We add then that the HSE publish the expiry date of licences – so if you track these things, you can plot a company’s standing. A client also instantly sees which companies can notify the project that they are considering. This might not seem a big concern, but very complex major works, might require 2+ years to complete – knocking out 65% of contractors.
With this in mind – are the HSE less inclined to reduce the term for a huge company? Do they back away when a downward tweak might stop a multi-million £ job in a power station? Certainly ‘the word’ is that they do.
The licence term is certainly a commercial driver.
In my opinion the HSE should remove the fixed term licence. The HSE should assess a company and give, or withhold a licence based on the interview and past performance during site visits. These licences should not expire (I hear howls of outrage).
What should replace it is a tailored review schedule for that specific contractor. Essentially, ‘Yes we are content for you to work with asbestos, but we want to see you again in 6 months, or 12 months or 3 years, just to make sure things stay on track’. A structured plan could therefore be put in place on what improvements must be implemented before the next monitoring visit.
The monitoring schedule would not be published and would not appear on the licence itself. This therefore could not be used for contractor selection. The pressure would be released from the HSE to grant 3 year licences for commercial reasons. There would be no issue of notifying jobs beyond the end of the licence expiry date – as there won’t be one. The HSE can concentrate on maintain and improving standards and do so in a much more structured way.
As I say this is an opinion piece, and I would welcome everyone’s thoughts and feedback.
I have been in the asbestos industry since the early 1990s, helping licensed asbestos removal contractors stay at the forefront of the industry.
Let me know what you think. Drop me a line using the email at the bottom of this page.
Written by Nick Garland on Monday January 23rd 2017
The Romford Group provides a comprehensive refurbishment and maintenance service including the removal of asbestos and re-insulation covering the Home Counties and Central London. The Group now has an annual turnover of approximately £5 million.
The Company is renowned for it’s friendly hands-on management approach and we are committed to giving our clients a good quality finish, on time and competitively priced.
All of our labour and specialist sub-contractors are carefully selected and maintain the Company’s personal approach when working in occupied premises.
The Romford Group operates across London and in various UK counties and uses a range of different teams of operatives and subcontractors for onsite project delivery.
The company needed a way to synchronise the management of client projects between their in-house employees and outsourced onsite teams. The company also needed a system that presented all of the employee training and competence information easily and clearly.
With the changes in requirements from the HSE, the company needed to increase the data it routinely monitored to maintain its reputation for high health and safety standards.
The Romford Group began using Assure360 in 2015 and now consider it an absolutely integral tool for the successful functioning of their business. Not only has it improved communication and progress tracking between in-house and outsourced teams, it has also provided a means of tracking their employees’ training in order to shine a spotlight on areas of potential weakness and transform them into strengths. The Assure360 system also helps the Romford Group to track the competency and effectiveness of their outsourced teams, helping to ensure they are collaborating only with others who meet their own high standards.
The dashboard approach focuses attention on high level trends and allows a proactive approach.
“We have been using the Assure360 system since early 2015 and have found it to be invaluable in developing the business. Nick and the team were able to quickly implement the system for us and whilst it took us a little while to get the hang of things it is now an integral part of our business. It is flexible enough to bring out our strengths but at the same time shine a light on our weaknesses – and help resolve them. The Assure360 System really helped with our recent license renewal, and whilst the HSE made some suggestions on ways to improve it even further, it clearly impressed them. We had no hesitation in renewing our contract.”
Jim Marling
Divisional Manager
Written by Nick Garland on Monday January 23rd 2017
Horizon Environmental Ltd is a private, independent company led by a management team with many years of providing asbestos removal and environmental services to the domestic, commercial and industrial sectors. Horizon has grown rapidly over the past five years, routinely undertaking very large complex projects. Horizon is dedicated to maintaining the highest standards in all dealings with employees, customers, suppliers and the public. It believes in upholding practices that create long-term value, and which enhance Horizon’s reputation for honesty, integrity, and safety.
With the rapid growth of the company, came a demand for increased management control and supervision. The traditional approach of auditing on paper did not allow the company to identify trends, understand competence or even close-out non-conformances in a timely fashion.
The management team at Horizon needed a faster way of tracking, recording and sharing their data. The company had also built a reputation for its high standards of delivery and wanted to be able to track the effectiveness of their subcontractors to ensure this reputation continued to grow. Being able to demonstrate to its clients maintenance of these high standards was critical.
The Horizon team have found the use of the Assure360 system transformative. It provides a simple, centralised place to manage their audits effectively and has huge time-saving benefits for busy senior staff members. It is also simple enough that staff new to computer systems can also quickly master it. This has allowed senior supervisors to participate fully in the H&S management system.
The app also provides easy tracking and reporting data, helping to ensure the company can spot and resolve any issues early on and remain on track with targets and deadlines.
“We have now been using the Assure360 system to manage our audits for nearly two years and I must say that it certainly does everything we need – helps us accurately manage competence, close out audits, measure trends and highlight re-occurring non conformances. The audit app is so easy to use that even my busiest contracts manager completes reports – as does my senior supervisor. The home page gives an instant health-check and reports are all done at the touch of a button. When you factor in the time saved – it has been a bit of a no-brainer”
Ben Ives
Managing Director
Written by Nick Garland on Monday January 23rd 2017
Woods was originally formed in 1994 to provide high quality asbestos remediation services across the South East of England. It now operates nationally across five offices located in Harlow (HQ), Milton Keynes, Wellington, Pontyclun (South Wales) and Rhyl (North Wales) delivering asbestos solutions to a broad range of market sectors procured through competitive tender, sole source arrangements or long-term frameworks.
To evolve with the rapid expansion of the business, Woods needed a system which would allow their managers – based at five different UK locations – to easily track and monitor all aspects of their client projects, from health and safety record keeping to competence assessments. Senior management based at the head office also needed to spot company-wide trends and be able to support and assist the regional teams in a proactive manner.
They needed a single system reading from one dataset, but accessible across the country – allowing both a regional and national approach when needed. And they needed to track overall success rates in order to highlight any areas which could be improved and ensure overall effectiveness of the teams.
The Assure360 system was rolled out to Woods management staff across the board, and has proved to be indispensable in allowing managers an easy and efficient platform on which to record, share and track the the H&S success of their projects. The ability to measure all aspects of H&S, exposure monitoring, competence monitoring and training needs analysis has saved significant admin time. It also reduces the chance for human error with its reporting functionality. This helps managers to easily provide accurate reports to senior managers, which in turn give a great overview of where the company is succeeding and where it can invest time and energy in improving.
“In my role as Compliance Manager I use Assure360 all the time. I find it invaluable, simplifying every task from health and safety recording, competence monitoring, close-out of audits, exposure monitoring and reporting to senior management. The Assure360 Support Team are very responsive and actively encourage feedback. I feel as though the system is continually improving and evolving to match exactly what I need.”
Louise Morley
Compliance Manager
Written by Nick Garland on Friday December 23rd 2016
Royal Mail have been collecting, processing and delivering letters and parcels in the United Kingdom for over 500 years. It’s the UK’s pre-eminent delivery company. The workforce of 139 thousand postmen and women and support staff delivered some 17 billion items in 2015-16, using thousands of vehicles and operating from more than 2000 buildings across the UK.
The buildings vary greatly in size from the smallest of vehicle workshops to huge mail centres. As well as varying in size there is a broad age range for their sites.
It’s a huge infrastructure, and coordinating suppliers and contractors to safely remove asbestos from the Royal Mail Group’s more than 2000 locations was a very daunting task for Asbestos Compliance Manager, Richard Bennion. Coupled with this, there was a requirement to protect Royal Mail Group’s good name and reassure the huge workforce that asbestos and asbestos removal was being managed safely.
Royal Mail Group required a system that would allow a very detailed look at how safely its asbestos specialist suppliers were operating, whether their work adequately protected the workforce and properties, and simplify the KPI measurement process.
Assure360 allows a layered approach to auditing so that internal managers can audit as well as getting its external asbestos consultants to inspect. The result is a large number of inspections and training sessions for the Royal Mail Group team – effectively making them an expert client.
The dashboard gives access to everyone that needs it – including the contractors themselves, who can view their own audits at the touch of a button.
The audit findings drive Royal Mail Group’s KPIs and the contractor assists with the close-out of non-conformances. They are therefore participating in their own KPI process – making contractor review a straightforward, conflict free process.
Not only this, but Assure360 also tracked competencies at an individual contractor level, making it easy for Richard to confidently choose a high-quality contractor that he knew was up to the task.
“The Assure360 database allows us to take a top level view of all of our asbestos removal contractors, directly comparing and contrasting them against each other. The audits are detailed but at the same time easy to complete. Inspections can be carried out by our own team, or selected partners – so we aren’t tied to a single consultant. Reports can be produced at the touch of a button. Assure 360 is the solution that provides a robust approach to compliance audits of our suppliers.”
Richard Bennion
Asbestos Compliance Manager
Written by Nick Garland on Friday December 23rd 2016
LAR are a HSE licensed asbestos removal contractor operating on both a national and international scale. The award winning company is at the forefront of the UK industry with regards to health and safety, training and industry best practice.
As a business LAR work extremely hard to ensure they remain at the forefront of the industry with regards to H&S, quality and performance. The company continues to invest heavily in staff development and training and has been recognised as being one of the industry’s front runners with regards to operatives, supervisors and management completing the ARCA Competency Scheme. In line with new guidance LAR have also moved the business to a more proactive approach to staff development and have invested a significant amount of effort in developing an industry leading Training Needs Analysis system. The efforts the business puts into its own development has recently been recognised by its Trade Association ARCA by being awarded with the Gold Training Award, the National Training Award and ARCA Gold Site Audit Award, where special recognition was achieved by securing this award for the 2nd consecutive year.
LAR’s heritage is major construction, but has specialised in asbestos removal for the last 30 years. LAR have been part of the growth of the asbestos industry and have evolved with it.
LAR work in all sectors of the built environment including:
As an established company with national and international clients, LAR knew their product was top quality, but success brings its own problems. With approximately 100 site staff the amount of auditing that is required to keep on top of quality and safety is enormous.
A new system was required to gather the information simply, process the data and create a suite of reports that allow the management of H&S to be integrated seamlessly with the operations and the quality management system.
LAR began using Assure360 in early 2016 as a way of keeping all their compliance and auditing data in one easy-to-access place which could be updated by all staff members involved by the project at any time. The system now drives most of the quality management functions evidencing and supporting BSI compliance.
Since LAR started to use Assure360 it has grown – helping with more departments, in particular the exposure monitoring, competence and training needs analysis.
“Whilst initially skeptical of all such systems, now that we have been using Assure360 for a while I am totally converted. It is an incredible asset to my organisation. All the tools and reports allow me and my team to really understand safety in our company, helping us drive through improvements. If licence renewal was brought forward to tomorrow – it would hold no fears for me. I would be 100% confident that Assure360 would make showcasing LAR’s high standards easy.”
Bob Clarke
Managing Director
“LAR have been utilising Assure360 since the start of 2016. The system has streamlined the way in which we work from both collecting data and also a reporting perspective.
We have showcased the system to a number of clients during tender interview/presentations and they have been impressed with the information we are able to report on. The most notable feedback we have had to date was from the BSI assessors who were undertaking a two day audit of our quality, environmental and H&S management systems, they made a specific reference within their close out report, noting the improvements the Assure system had made to our business from previous years. I would also note that when we have approached the Assure360 team with ideas or improvements, they have been quick to make changes to meet our businesses requirements.”
Steve Hannah
Development Director
“Assure 360 is simple to use, yet the output of information that links the competency, audit and health and safety has provided us with valuable data that has assisted LAR in improving various aspects of the business. At the press of a button, the visual reports are effective and give real time information button that LAR Senior Board and external auditors have found useful, effective and easy to understand. We find the Status/Actions Required/Due Dates useful tools in ensuring that the correct staff members are notified of, and deal with issues – ensuring effective and timely close off that can all be managed centrally. A real time saver that produces valuable information that assists in improving health, safety and competence that would benefit any business.”
Alison Brooks
Quality & Audit Manager
Written by Nick Garland on Friday December 23rd 2016
East Coast Insulations (ECI) was one of the first licensed asbestos removal companies in the country, starting operations at the same time as the regulations in 1983.
As the largest company in the region ECI provides asbestos removal, management, surveys and thermal insulation throughout Norfolk and Suffolk. ECI is by far the longest established asbestos licensed firm in the area.
ECI is a family-run business and continuously invests in its staff training and development program, priding themselves on keeping up to date with the latest regulations, guidelines and Approved Codes of Practice from the HSE to provide top quality service.
H&S management has changed dramatically over ECI’s 34 year history and managing the continual development and training of a large team comes with its own challenges. It was becoming increasingly time consuming and difficult to manage training records and subsequently, to manage whether training budget allocations were being maintained or used effectively.
Maintaining the close knit family approach and yet stay cutting edge was the brief.
In 2014, ECI was one of the founder members of the the Assure360 system. Our training-needs-analysis reports were integrated into the company, allowing delivery of training courses to provide in-depth understanding of the team’s strengths and weaknesses. Not only has this allowed them to invest in training in the right areas to round out their business, the staff training tracking also eliminated wasted time as they now only invest in the training courses which are needed. The detail that it provides, also allows the company to internalise training – getting operatives with particular strengths to help those with weaknesses. This allows the company to make a saving in recouped working hours and unnecessary training course fees.
“We’ve been using the Assure360 system for over two years and whilst it took a little time for us to exploit its full potential it is now an invaluable tool in helping us manage the company.
The audit tool is very easy to use and gives us an extremely detailed understanding of the jobs and how they are running. The staff competence system paints a clear picture of our team’s strengths and weaknesses (operatives, supervisors, contracts managers, stores and admin), allowing us to react accordingly. And the exposure monitoring solution is remarkably powerful but still easy to use. It saves us time and effort. The HSE’s response at our recent license renewal was that they had never seen such a powerful and comprehensive system.”
Jason Boast
Managing Director
Written by Nick Garland on Friday December 23rd 2016
Delta Services is one of the leading asbestos removal contractors in the UK. With over 22 years experience in asbestos removal, Delta Services provide asbestos abatement services to a wide variety of clients ranging from NHS Trusts, universities, hotels and large retail chains to small businesses and private individuals.
As a prominent member of ACAD they value their reputation in the industry.
As a large company with staff members who frequently work remotely on different sites with different clients, Delta Services needed an intelligent system which could provide a single centralised platform to monitor their asbestos removal processes in one place.
Like all asbestos removal contractors the administration of exposure monitoring and audits is a constant labour intensive problem that required a solution.
Managing Director of Delta Services, Ken Johnson, had not been expecting to find a tool that could reliably manage all the company’s clients workflow in one place, allowing his staff access to universally up-to-date client project data wherever and whenever they needed it. After seeing a demonstration of Assure360, however, he knew he had found a tool which could do this, and much more.
With Assure360, Delta Services employees could access client data in one place at any time, wherever they were, keeping workflows up to date and seamlessly managed from start to finish. This also dramatically reduced the risk of important information being lost or duplicated. .
The system has streamlined all of the processes that most removal contractors wrestle with on a daily basis – making doing business so much easier.
“The moment I saw the system demonstrated I knew it was an absolute must for us. It ticked so many boxes – all the areas that the entire industry seems to struggle with. Nick and his team fundamentally understand the challenges and has designed a product specifically for us, allowing my company to improve and showcase our strengths. At our recent license renewal, the HSE inspectors were amazed by the power of the system and couldn’t believe everyone wasn’t using it.”
Ken Johnson
Managing Director
Written by Nick Garland on Friday October 21st 2016
Amazingly it is now a full week after the inaugural Contamination Expo – I don’t think any of us knew quite what to expect – and that included the organisers! 200 Exhibitors, 3000 registered delegates and rumours that the HSE were going to attend (I know at least one inspector was there, because he came to see us…).
Whilst I have been around the asbestos and H&S industry for nearly 25 years, the Assure360 solution is very new – so it did actually feel like the right place for us to be.
Not only did we exhibit, but I presented a seminar – ‘Competence Systems, the Good the Bad and the Ugly’. The 30-minute tutorial outlined what competence means within the asbestos industry and why we should care.
We were also up for the asbestos innovation award. Shortlisted from the 200 exhibitors – the judges came to the stand, and I had to convince them on the uniqueness of the system. We nearly got over the line first – but in the end still delighted to get the runners up slot.
For those of you that are not familiar with Assure360 – it is a solution for the asbestos removal, analytical and training community. It takes existing tasks that everyone does already, makes them easier and transforms them so that they solve multiple needs.
From the single audit application, the cloud database allows the user to comprehensively manage H&S from an HSE licensing or UKAS point of view. It provides Competence Assessments, TNAs and it even transforms exposure monitoring from just a duty of care exercise to a technique that actively improve standards. All at the touch of a button.
For the trainer – it provides incredibly detailed TNAs – ensuring that time is not wasted on the initial exam at the start of the course. Allowing a truly bespoke offering.
Our many customers extol its virtues with such comments such as:
“At our recent license renewal, the HSE inspectors were amazed by the power of the system and couldn’t believe everyone wasn’t using it.”
Ken Johnson, Managing Director, Delta Services
“Assure360 is now integral to how we work. Our BSI assessors were really impressed by the system, noting all of the improvements it allowed us to introduce.”
Steve Hannah, LAR
As I say – an exhausting but rewarding experience and we have already booked our stand for next year.
To learn more or book a demo call us on 0845 226 4318.
Written by Nick Garland on Thursday September 15th 2016
Assure 360 uniquely allows you to audit asbestos projects, measure competence, complete Training Needs Analysis, and record exposure monitoring in one, time-and-money saving cloud based system.
We’re pleased to announce that not only will we be exhibiting at the exciting Contamination Expo 2016, but we have been shortlisted for the Asbestos Innovation award.
The expo is to be held at London’s Excel arena and Nick Garland, our founder will be giving a seminar ‘Competence Systems, the Good the Bad and the Ugly’. The 30-minute seminar will outline what competence means within the asbestos industry and why we should care (including the regulatory imperative). It will cover the various ways to observe and measure it, the pitfalls and the benefits that can be gained from a well-designed system. It will close with a short demonstration of how Assure360 ticks all the boxes and why we get testimonials like this:
At our recent license renewal, the HSE inspectors were amazed by the power of the system and couldn’t believe everyone wasn’t using it.”
Ken Johnson
Managing Director
Delta Services
It’s a must for all senior management in the asbestos industry wanting to make a difference.
Nick will also be on our stand, to answer any questions. It is well worth popping by the stand, where Nick will be able to demo the highlights of the system
Our many customers extol its virtues with comments like:
“The home page gives an instant health-check and reports are all done at the touch of a button. When you factor in the time saved – it has been a bit of a no-brainer.”
Ben Ives
Horizon
“Assure360 is now integral to how we work. Our BSI assessors were really impressed by the system, noting all of the improvements it allowed us to introduce.”
Steve Hannah
LAR
“The HSE’s response at our recent license renewal was that they had never seen such a powerful and comprehensive system.”
Jason Boast
East Coast Insulation
Visit our website to learn more, or book a demo.
Get your free tickets HERE and visit us at stand 854.
Written by Nick Garland on Monday June 27th 2016
The draft guidance that was doing the rounds last year on blasting techniques (whether that is Quill, Torbo or ice) has now been released as ALG meeting minutes, rather than a full ALG Memo. I am not too sure on where that places it in the regulatory framework, but it is clearly guidance that shouldn’t be ignored. There a few changes to the February 2015 draft that prompted my original summary.
The following piece is an update on the main points to be aware of.
The memo starts with the recognition that blasting may be required in a few rare occasions, but also declares that the process should only be considered as a last resort and not a go-to silver bullet. It also insists that the use of the process (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 are declared and justified:
Clients are normally the main driver as to why blasting is being considered (“I want an asbestos free building”). It would therefore be wise to involve them in the decision process, explore whether the reasons for that desire outweigh the added hazards and ultimately justify why it is required. The guidance states that robust processes should be in place to ‘prevent misuse’. Or put another way – review of the justification and sign off by senior management. The technique must also be declared on the ASB5.
The guidance suggests the following controls:
** Wet Vacs may be problematic guidance as they do not typically have HEPA filters but the moisture in the ‘garnet’ will damage a standard vac.
These controls will considerably increase time, plant and materials and with them costs. It is difficult to imagine a client stomaching the substantial increase.
I can almost hear the echo of ‘It’s only guidance’, which it is, but the imperative is to implement something equivalent or better and the suggested controls are quite specific and difficult to argue against. As it must be declared on the ASB5, the likely increased chance of an enforcement visit will mean that Ignoring the document will be a high risk card game with your license as the stake.
Find out how we can help you with asbestos waste management – call us on 0845 226 4318
Written by Nick Garland on Tuesday November 17th 2015
This is a summary and critique of the brand new guidance produced by ARMI on Competence in the Asbestos Industry. I will try to reduce the 28 pages into something more concise and give my spin on the wording to help clarify. Reading this summary would hopefully allow you to fully implement ARMIs suggestions, and/or help navigate the full document if you want to read more (available at http://www.armi.org.uk/Download/ARMI_Competency_Guidance.pdf).
The guide starts with an explanation of what competence is and a statement that most contractors will be assessing it anyway. However this existing assessment may be entirely informal and subconscious (a vague understanding of – you wouldn’t ask John to do X because of Y).
‘The ability to perform a task to a specified standard’
‘The skills, abilities, knowledge and behaviours that lead to successful performance.
Understanding what skills are required, what skills are held by an employee and whether there is a gap between.
As the roles and duties you expect of an employee change, the skills (or Competencies) also change. Similarly Competencies also change if we change the way the job is to be done. Due to a variety of reasons, an employees’ Competence will change as time progresses – in either direction.
Consequently Competence assessment must be continuous to identify shortfall and inform training.
It must be remembered that training here does not mean set piece refresher courses, but a variety of tools to bridge the skills gap identified. It could be a formal training course, but equally it could be:
The guidance goes on to identify the clear regulatory basis that requires employers to conduct a structured Competence system. The document explains that you can get external assistance in performing some or all of these duties. However before you rush to an expensive external consultant – it states correctly that the duty can’t be delegated. Essentially what this means is that if a largely external system fails to deliver, it will be the employer in the dock.
As you are already at the Assure360 site – just click on Home tab to see how we can provide a simple, cost effective solution. Assure360 allows an employer to run an internal Competence system without creating extra work or recourse to expensive consultants.
Image taken from the ARMI Guide
Steps 1 & 2 establish the skill set required and agree the standards have almost certainly already been completed. Your company H&S Policy and Standard Procedures, if correctly written will be tailored to your precise circumstances, describing the precise duties you expect of those individuals.
The ARMI’s guidance document goes into some detail on what could be seen as a standard set of Competencies for the industry. However, unless we all rewrite our H&S Policy and Standard Procedure documents to match ARMI’s guidance they are unlikely to ever be the ‘standard’ Competencies. They do however broadly map out what you would expect.
The guidance raises two important points that I would wish to echo and highlight. Competencies are role based not title based, recognising the fact that employees are often a blend of roles. i.e. a senior Operative might have some Supervisory duties. Similarly in a small removal company a lead Supervisor might have key Management duties. This is a key point and useful to stress.
Secondly the guidance recognises how critical teamwork and communication is at all levels in the organisation, going some way to identifying what this looks like at different levels in the organisation:
Core duties – i.e. Competencies that everyone from the operative to the MD should have):
Supervisory duties – as above, plus:
Management duties:
This aspect of teamwork and communication as a Competency is largely overlooked by the majority of removal companies and could contribute enormously. Strategies on how to promote these should be sought, but the guidance does not help with this.
Step 3 (Collect Evidence) and to a lesser extend Step 4 (Produce Training Needs Analysis or TNA) are the ones that will cause most issues with Licence Holders. Unfortunately other than tell you of some sources for gathering the required information the guidance crucially falls short:
However, other than little more than these bullet points there are no clues on how to:
In fact just adding these tasks to an already full workload may be an ‘ask’ to far.
To be fair the guidance does repeatedly say, ‘many of these tasks are already being done by licence holders’, the problem is existing measures typically do not gather the kind of information needed to create a detailed understanding of an employee. The trick remains – to transform the tasks that are already being done into an exercise that automatically provides the competence assessment.
An employee must be deemed competent to do a task and until they are, they need to be supervised. This has most impact with new starters (including agency); whether this is an experienced supervisor/manager or someone fresh to the industry – they will have little idea on how you as an organisation do things and you will have no idea of their Competence. Induction into company H&S policies and procedures is therefore critical and a high level of supervision must follow.
Next on the cycle comes produce TNAs. TNAs are an old problem, and as most training organisations know actually getting a TNA for an employee is a rare event, getting one long enough in advance to plan appropriately has until recently been almost unheard of. Nowadays I do know of several companies that complete TNAs in advance and submit these to the training providers.
The guidance seems to suggest that creating TNAs is an additional exercise over and above Competence Assessments. It identifies who assessors should be and what competencies they should have. Essentially this comes down to Supervisors and Line Managers as the in-house experts best placed to do this. Having TNAs as an extra task, added to a busy workload, will have the almost inevitable result of it not happening at all.
Again the trick is to make the process automatic. Direct observation should produce a competence assessment, which by its nature (looked from the other side) is a TNA. But the guidance does not tell us this bit.
This is obviously the act of closing the gap. We’ve identified the strengths and weaknesses (competencies), we’ve developed the training requirements (TNA), and this is merely the delivery of that plan. What the guidance makes clear though is that training is not just the annual refresher and can take the form of toolbox talks, practical sessions and even informal chats.
Essentially what this means is that; once we know (in detail) what weaknesses an operative, supervisor or manager may have, we can be much more imaginative in addressing those needs:
Many of these are issues, which if we recognise them, can be dealt with internally.
A senior operative; if he excels in the skill to be imparted can deliver training. Supervisors can become key mentors, contracts managers can learn from each other.
Equally if you understand the weaknesses on site, you should know your strengths, the industry has an awful lot of expertise and this is by no means restricted to training organisations. Good ideas, innovation and excellent performance should be identified, reinforced and shared.
Increased supervision is effectively ‘on the job training’. An identified slip in performance in an experienced operative or a new starter can be tackled by mentoring. Just because a new employee comes to us qualified and experienced, we do not know their level of Competence. Equally we should be near certain of their lack of competence in our own company procedures. This support can be seen as simultaneous training and assessment.
Or rather – start again. It should be noted, though, that the guidance correctly identifies that ‘establish roles’, and ‘agree performance standards’, won’t normally need to be returned to on a regular basis. As the collection of evidence and consequent identification of training needs is continuous, the cycle should just keep rolling. The guidance document does note that infrequently completed tasks may need to be tested via simulations to ensure competence is maintained. A good example of this could be emergency procedures or fire drills.
There should also be a formal review (minimum annually) – or employee appraisal. The competence, and TNA assessments that have been completed throughout the year, should be used as part of this exercise. Events that should trigger reviews:
The guidance is an effective definition of what competence is and gives pointers to how Licence Holders (LHs) can design their own systems to fulfil the requirements. It also identifies many tasks typically already done by LHs that can provide evidence of Competence and therefore inform TNAs and training.
Essentially as a guide to creating a competence system it does work. However the process it describes is a colossal amount of work.
The ARMI guide starts by creating separate performance criteria and matrices for every role. In of itself, this could be a few weeks work. It then describes a host of evidence sources that (admittedly companies do at least some of). However it gives no guidance on how to streamline the process of analysing the ‘big data’ this would produce. All H&S managers in the asbestos industry know that a PDF audit report can be a dead end and is lucky to be closed out, never mind trends identified. iAuditor can produce Excel exports but these are incredibly labour intensive to analyse. Typically the ‘degree of granulation’ achievable is to supervisor level and no further, leaving the majority of the staff un-assessed. Essentially to administer the competence system as described would require a dedicated full time individual.
As I say the guidance does explain the concept, gives sound guidance on where to start. But it leaves us hanging with the slight echo of ‘pick the bones out of that’.
However, there is help beyond the guidance. New commercially available systems streamline this process into a ‘click-of-a-button’ solution – my assure360 database and app is one.
Written by Nick Garland on Monday September 28th 2015
Transiting is the simple process that operatives follow to exit an enclosure. It is the moment where they remove PPE and if they get it wrong, expose themselves to increased asbestos. It is therefore critical. However, when I audit removal projects in the UK, I often come across an almost wilful disregard of this guidance. The poor procedure is reinforced by large training providers (I am thinking of one in particular) that actively train incorrect procedure to delegates.
The guidance is clear:
So why do over 10% of audits completed by myself and others (using my Assure360 system), record instances of PPE removed in the dirty stage or even in the enclosure itself?
The reasons we hear from the individual operatives, supervisors and their management, typically include ‘well you wouldn’t want to take all that contamination to the outside’ or ‘well the middle stage is a buffer’ or most common of all ‘well I went on a training course last week and they told me…’. All of these demonstrate a fundamental lack of understanding as to why the guidance was written as it was.
Correct risk assessment at the moment of transiting should tell us quite clearly who is most at risk – the operative. Therefore what is transiting for? The primary purpose is to ensure that an operative exits a hazardous environment safely. It has a secondary purpose – to ensure that in exiting, – that hazardous environment stays confined. The dirty stage (it’s nick name is such for a reasons) is the most hazardous part of the airlock system, so why should we be asking operatives to remove any PPE here? Removing PPE in the enclosure is clearly slightly insane.
If we lose sight of who is most at risk, it would allow us to think that the secondary purpose is the main one. On the shaky foundations of this ignorance and with the confidence that ‘well it’s only guidance’ brings, we get the poor procedures we so often see.
If the primary purpose was indeed keeping the hazardous environment confined, whilst allowing workers to exit – then a buffer zone or sacrificing PPE early to keep ‘us civilians’ safe, seems sensible.
My frustration, as a professional, comes when major training companies, who frankly should know better, actively teach removal of overalls in the dirty stage of the airlock, sometimes they even council throwing them back into the enclosure. This is directly apposed to guidance and demonstrates a lack of understanding and competence in the trainer. I know of several examples where the employer has designed the correct (guidance led) transit procedures – only to find that their employees have been de-trained at great expense. This misleading training undermines the company’s efforts to protect its workers and potentially induces enforcement action.
I therefore challenge the industry as a whole and training providers in particular to reconsider transiting in light of what it is actually for – protecting the employee.
Find out how we can help you with asbestos waste management – call us on 0845 226 4318