With the HSE’s electronic licence assessment process now nearly three years old, the original pilot companies are going through the process again. The promise for the new system was that licensed asbestos removal contractors (LARCs) would feel the pain only on their first time through, with all subsequent renewals being much more straightforward. Only time will tell whether the HSE’s view of simplicity matches ours.
But assuming the process has bedded down into an initial, intense assessment, followed by more of an ongoing ‘light touch’, what is certain is that the regulator will be focused on what’s new. This will range from any changes you have made internally, through the findings of any HSE visits, and crucially the results of your own audit programme.
And as anyone that’s been through the licence process will know, while the HSE values a well-managed internal audit programme, external audits are near-mandatory – and huge store is put on their findings.
First off, it’s important to explain that I’m a huge supporter of internal audits. Without looking for yourself, it is easy to fall into the trap of running your company with blinkers on. This wilful blindness will lead to poor practice through ignorance, and a degree of shock when others – such as the HSE – see something that you haven’t.
The key is that these internal audits need to be effective. Significant pitfalls to avoid would be:
The weaknesses in both come because it is human nature to see what you expect to see. If you always have the same auditor, they’ll always spot the things they’re great at spotting. The things they’re not so good at spotting will always get missed. When marking your own homework it is difficult to spot your own mistakes!
Contracts managers (CMs) who audit their own jobs will be particularly vulnerable to this. The takeaway is not necessarily to (as some would say) avoid CM auditors, it is rather to ensure that you’re aware of their limitations, and that you look for these in the results. Whether audits are conducted by a CM or a regular internal auditor, if they typically don’t find anything wrong, it’s unlikely to mean there isn’t anything to find. In fact, it should be seen as a warning. A blend of auditors makes for a healthy system. A LARC can benefit most from the eyes and interpretation of the CMs, the MD, and even supervisors themselves.
This last group is often underused for auditing, but while they don’t realise it, supervisors audit every job. Often they even record their findings – for example your supervisor’s pre-start check is an audit of the RAMS (risk assessment method statement) against the reality they are faced with.
It’s important to use this data, and so recording it needs to be easy. Assure360 is specifically designed to streamline all aspects of construction safety, so we allow supervisors to complete pre-start checks digitally – with the data automatically contributed to the internal audit system.
Assure360 also allows safety tours, so any time that the CM and MD complete a site visit they can record any issues they see. Again, this flexibility helps record and highlight issues that typically get resolved there and then, and would otherwise be forgotten by the time an audit rolls around. Finally – uniquely to Assure360 – we help avoid the ‘snow blindness’ sometimes caused by over-reliance on internal audits. All our users get to see benchmark data from the many thousands of audits already completed on the system – letting you learn from other people’s lessons.
External sets of eyes
It’s clear that a well-managed internal audit programme is crucial for health and safety. So what does an external expert add? Their key role is to provide a check and balance on your own observations – allowing you to recalibrate.
The HSE knows all too well the limitations of internal audits, and approaches them with a pinch of salt. For the purposes of licence assessment, it needs some sort of external verification of the evidence submitted. In the past this would have been HSE visits – and lots of them. But with budgets as they are, we’re not seeing the dramatic step up in inspections that would be needed. In fact the numbers are down again – continuing the trend of the last four years:
| HSE Annual Report 2017 / 2018 | HSE Annual Report 2019/2020 | HSE Annual Report 2020/2021 | |
| Asbestos visits | 1,000 | 900 | 860 |
| Inspectors | 1,066 | 1059 | 1045 |
| Proactive inspection visits | 20,000 | 13,300 | 14,880 |
To supplement its own visits, the HSE will therefore be focusing its attention on what other external eyes have spotted – and that means the finding of external auditors.
The first round of the new licence assessment required LARCs to submit three internal and three external audits conducted in the six months before application. With the HSE’s licence assessment now focused solely on what’s new and what’s changed, these audits will take centre stage.
All of which brings us back to a subject I wrote about earlier in the year – the increasing importance of the external auditor. In any healthy auditing ecosystem – and explicitly in the three-and-three minimum outlined by the HSE – the independent auditor presents a vital, fresh perspective on the otherwise closed feedback loop of internal audits.
Fundamentally, external auditors improve the overall quality of an audit system in multiple ways:
Independent audits should always be seen as a vital check, regardless of how we’re licensed, but the HSE’s increasing reliance on them may well be about to drive up demand as the industry begins its second rotation through the new system. To the handful of existing quality auditors, we need to add other skilled and experienced professionals, able to help protect and improve the safety standards to which we all aspire.
If you know my history, you’ll know this is an area I feel strongly about. Through Assure360 I’m determined to help improve auditing standards in our industry, which is why we’re continuing to offer Assure360 as a free-of-charge service to suitably qualified independent auditors. Whether or not the end client is using Assure360, this means the auditor will benefit from:
The system is even more appealing if the client happens to be an Assure360 customer. In these cases, all audits will automatically read across to the client’s slice of the system, allowing:
We’re keen to expand the group of selected, quality auditors who use Assure360 to simplify their audits, and improve the depth and clarity of their reporting. If you’re interested in joining them, why not get in touch to understand more about how Assure360 can support you?
“Assure 360 auditing software has made my auditing process seamless, and provides a quality audit for my clients in an easy-to-read format. The system is very stable. Nick and the team are on hand to provide support when required. It is very rare to find such experts in the field running and operating great software.”
Craig Ablett, Consulo Health & Safety Ltd
“I just find it so, so easy to use, so simple. It doesn’t take up half the time of my own audit system – where I’m uploading photos, copying and pasting information. It’s none of that, it’s quick. It’s a great app really.”
Chris Pedley, CP Safety
“It’s the benchmark we should all be working to. It covers just about everything you could want on an asbestos audit, along with general health and safety.”
Dave Philips, D&N Asbestos Advisory Services
“I’m an absolute fan. When I turn up on site, I’m not carrying pens, paper and clipboards. It’s just user friendly, it’s so easy.”
Paul Beaumont, BIACS
“My clients aren’t just getting a box-ticking exercise, they’re benefitting from my expertise and feedback, and the software’s ability to help produce actionable information.”
Chris Pedley, CP Safety
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