The revised HSG248 Asbestos Analyst’s Guide addresses issues arising from the Analyst Inspection Programme carried out by the HSE in 2015. James Dodgson lists the major changes.
1. More detail on scoping/contract arrangements
The HSE proposed that the analyst will be more involved with the scoping of the work (including preparation of risk assessments and plans of work) to ensure adequate planning, agreement on four-stage clearance (4SC) requirements and allocation of resources.
This will be achieved by having a pre-start site visit and meeting between all parties to discuss the proposed work, including the Licensed Contractor’s (LC) plan of work.
Under the Construction (Design and Management) Regulations (CDM), the LC has legal duties to cooperate with the analyst and provide them with adequate information in a timely manner.
2. Need for better standard of cleaning by Licensed Contractors
It is the duty of the supervisor for the LC to carry out the initial visual inspection of the enclosure or work area upon completion of the abatement works. Only when the supervisor deems the area to be clean should the analyst enter the enclosure, as this reduces the level of risk posed.
It is important that the analyst does not undertake any cleaning activities themselves, as this could be seen as a breach of the Health and Safety at Work Act. The HSE has introduced a form that the LC supervisor must complete and hand over to the analyst, confirming that they have carried out a thorough visual inspection of the work area and that it is satisfactory for the analyst to enter and carry out their own visual examination.
3. Improvement of the Four Stage Clearance Procedure
The main changes are:
- Use of handover form;
- Prior to the visual inspection, the analyst must advise the client of an estimated time of completion. If the actual time differs by more than 20 per cent, an explanation must be given to the client;
- If any additional cleaning of the work area is required and exceeds 10 minutes, the 4SC will be failed;
- Analysts breaks during lengthy visuals, every two to three hours with powered RPE, every one hour for non-powered RPE;
- Stricter controls on analysts going through the decontamination unit and not wearing street clothes under their disposable overalls will be introduced;
- A full photographic record of all four stages is to be made based on information within the revised guide; and
- All of the above are recorded on the Certificate for Reoccupation.
4. Increase in quality control of analyst work
Based on concerns raised in the Asbestos Analyst Inspection Programme report, the HSE has increased the amount of quality checks required, as work should be continually assessed.
The revised guide stipulates that 5 per cent of 4SCs should be audited and re-inspected. For individual analysts, there is a requirement that they are audited/re-inspected at least four times a year. It will also be necessary to carry out desktop reviews of at least 5 per cent of the completed 4SC certificates.
5. Stronger impartiality requirements
The analyst should be independent from the LC so clients should employ the analyst directly and ensure that there are no links with the LC.
6. Improved procedure for personal sampling
Longer sampling periods will be required throughout a shift, recording tasks and activities, geographical location and supervisors/teams. A template is provided by the HSE for recording this data, so over time sampling should capture the level of exposure to all operatives across a range of activities. The information gathered will benefit the LC, as data analysis should help to improve working methods and operatives’ understanding of risk potential.
7. Additional advice on analyst competence/refresher training
Ensure ongoing competence of the analyst through regular refresher training in line with the Approved Code of Practice for the Control of Asbestos Regulations 2012. Any issues found during audits or re-inspections can be addressed, and in some circumstances this might require an individual to receive additional training.
8. New guidance for asbestos in soils and made ground
The first part of the guidance concentrates on the sampling of soils and when this should be required. Survey types (preliminary and main survey) are also discussed, and these are supplemented by an initial desktop study to assess the likelihood of asbestos being present or previously used on site.
9. Additional items
Many organisations take dust and swab samples to accurately determine the presence of asbestos fibres. Interpretation of these results can be difficult, so the new guide offers guidance on this subject.
Although guidance on dust sampling techniques is given, the HSE does not recommend sampling and analysis of asbestos in settled dust except for in specific circumstances where the spread of asbestos from a substantial recent release incident is being investigated. It is also recommended that dust sampling should not be routine practice as part of an asbestos survey.
A cautious approach is required
Exercise caution when interpreting the results of dust sampling and analysis as inaccurate reporting could cause undue anxiety for the client and occupants of the property.
Near-source and far-source/perimeter static sampling have been introduced to provide further guidance on location and distance of air monitoring from potential fibre sources. This is particularly of interest in connection with ground work projects involving the disturbance of made-ground and in known contaminated areas.
James Dodgson is commercial director, Asbestos at SOCOTEC