I originally wrote this review of the Asbestos Network technical committee’s upcoming guidance on DCU safety two years ago, and in some ways not a great deal has changed since. The guidance is still in draft, still imminent, and still missing some of the more practical direction on safety that I identified.
Part of the issue is that the scope of the guidance is limited to gas and electrical installations, but in reality the DCU represents a wider range of risks. In particular, I feel it’s now important to revisit the draft guidance in the light of Colette Willoughby’s raw and emotional testimony at FAAM last year. With the benefit of Colette’s experiences and insight, it’s clear that we must also consider analysts’ personal safety.
We all know that the job of asbestos removal is dangerous – that’s why it’s so tightly regulated. But while the most serious risks are often found inside the enclosure, they don’t stop there. The decontamination unit (DCU) presents its own hazards, including:
So what guidance is available, and how can it help keep analysts and operatives safe?
For the last two years the Asbestos Network technical committee has made time in several meetings to discuss DCU safety. Unfortunately they’ve made slow progress in producing guidance, and the final version hasn’t been issued.
I wanted to revisit what there is so far. For the most part it’s good stuff, but the way I perceive our workplace changed at the 2021 FAAM conference. Colette opened my eyes to additional risks faced by female analysts, which can and must be addressed. In this light, DCU guidelines that focus only on electrical and gas safety are missing a major opportunity to protect our colleagues.
Colette’s FAAM talk has shone a light on what should have been blindingly obvious for decades – decontaminating in the DCU represents a very vulnerable moment for a female analyst.
The Construction (Design and Management) regulations state: “Separate washing facilities must be provided for men and women, except where they are provided in a room the door of which is capable of being secured from the inside, and the facilities in each room are intended to be used by only one person at a time.”
As we know, DCUs are shared, yet their access is controlled by an external lock. Obviously this isn’t compliant. What has also become obvious, given the experiences detailed by Colette and the other female analysts she has spoken to, is that it’s simply not appropriate protection for our colleagues at a vulnerable time.
I am sure that the makers of DCUs can and should implement better solutions that give the occupant of the DCU control over entry and exit. But in the meantime, adding a simple bathroom-style bolt to all of the doors would seem like a very easy and quick solution. Clearly, there would also need to be a revised DCU procedure, as the unit would not be accessible from the time the analyst leaves it secured, until the point they leave the enclosure and fully decontaminate. During this time it would effectively become a one-person unit, but this is not that different to current, Covid-era practice, where operatives’ exit from the enclosure is staggered so as to be one at a time.
Another significant issue raised by Colette is that disposable underwear is simply not available for women. Laundering services for contaminated clothing don’t seem to be commercially available, either. Employers need to find an acceptable interim solution – such as using standard underwear or swimsuits and disposing of them after a single use.
The following is predominately unchanged from my review a year ago and concentrates on the physical issues covered (or not covered) by the guidance.
The gas safety guidance starts predictably enough, instructing that gas boilers should meet the required BS EN standards, that they should be installed by an accredited gas fitter, and that each appliance should be fitted with an isolating valve and flame failure device. However, it then goes on to say that all boilers situated in the clean end – rather than a sealed cupboard – should be of the balanced flue type.
For those of us who aren’t gas engineers, in a balanced flue (also known as room-sealed) boiler, the entire combustion circuit is sealed off from the room that the boiler’s in. The fresh air supply, combustion chamber, heat exchanger and exhaust gases are open to the atmosphere only, meaning that if something goes wrong, any toxic or flammable gases should be vented out of the DCU.
Insisting on this type is wise, as they’re much safer than open flue boilers which draw their combustion air from the room they’re in, but following the guidelines might mean an expensive upgrade for any older DCUs.
There are some other issues to pick up on. If the boiler is mounted in a separate sealed cupboard it is best practice for that boiler to be room-sealed anyway, but regardless the cupboard door must be closed and sealed at all times. Many times I’ve seen cupboard doors left open, sometimes for convenience, but sometimes because there is otherwise insufficient ventilation in the cupboard for the boiler to work. If the boiler only works when you leave the cupboard door open, then it’s effectively in the clean end, and must be room-sealed.
It’s important to understand that a room-sealed boiler doesn’t guarantee that combustion products like carbon monoxide (CO) can’t leak into the room. Seals can fail, so there should always be a CO alarm fitted in the clean end, adjacent to the vent to the shower compartment. Correct positioning is important – I’ve seen random locations, not all of which will be effective according to the guidance.
The guidance here pretty much summarises existing standard guidance. In brief, the gas bottle(s) should be:
Note, too, that there should be a maximum of two 16kg bottles, and that nothing spark-generating should be stored with them.
So far, so standard, but then we get to areas where I’m not sure we have much compliance. Gas bottles should be:
There’s some welcome clarity here: DCUs require mandatory 12-monthly gas-safety certificates. Some HSE inspectors are still referring to a very old note that mandated six-monthly inspections for open-flued units. This detailed guidance supersedes and clarifies this.
In day-to-day use, the gas pipework needs to be checked daily and at the end of the project – not a job that I’ve seen on many supervisor checklists. There should also be emergency procedures to follow if gas is smelled. The advice states that gas should be isolated at the end of the shift, but it then goes on to contradict itself, suggesting that if there’s no oil-filled radiator the pilot light should be left running in cold weather. Presumably, this will be cleared up in the final pre-publication checks.
All vents, clearly, need to be kept clear. If you have an open-flue boiler in a sealed cupboard, that cupboard needs to be kept closed and the seals must be in good condition. In all cases the CO alarm must be checked at least weekly.
This is usually the area that gets the most attention when a job is audited, but the justification for this seems patchy at best. To my knowledge there has never been a DCU electrocution, so the previous guidance has clearly been serving us well.
This guidance states that all DCUs must regularly be electrically inspected and tested – we rarely see units that haven’t been. In fact, the biggest risk is likely to come from using the client’s mains supply if it turns out to be faulty. The moment of greatest risk is brief – when an individual is standing on the floor, but touching the metal frame of the DCU.
The guidance offers some pointers on how to eliminate electrocution risks:
However the guidance really calls for better design of DCUs to ensure better electrical separation, along the lines of a bathroom. Generally there should be layers of insulation between electricity and people, and the power for recharging masks should come from two-pin, low-voltage sockets. Where there are concerns about the quality of the source electrical supply, it’s perhaps wisest to use a single-phase generator rated below 10kVA, which doesn’t need earthing at all.
As I laid out last year, another pressing DCU safety issue relates to the risks when positioning them. DCUs are heavy beasts. Moving them using a vehicle presents multiple hazards, and manoeuvring them by hand typically takes more than one person. Both approaches require coordination and well-designed procedures to prevent workers from being trapped or injured, yet these are all too often overlooked.
I personally know of one serious injury that has occurred due to lack of concentration when manoeuvring a DCU. The following is the safe working procedure that was created after the event:
When positioning, re-positioning or removing a DCU from site it is critical that it is done so safely. DCUs are heavy pieces of plant. They can cause injury by trapping operatives against fixed structures and can become unstable if moved over rough ground.
Where necessary – a traffic marshal will use a barrier to stop traffic when the DCU is to be moved into the road to be hitched onto the waiting van.
It’s important to reiterate that the scope of the DCU guidance was limited to gas and electricity issues. As such, I know I’m being slightly unfair in expanding my analysis out to other issues such as personal safety and manual handling. However, both are important issues, and as we’re not likely to get more guidance on DCUs for the foreseeable future, this seems an ideal time to provide something comprehensive whilst the bonnet is up.
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