Asbestos. White Paper

Transcription

1 White Paper Essential reading to help you unpick the significance of the changes coming our way by Nick Garland CEO Assure360 1

2 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. 2

3 Contents Introduction from Nick Garland, CEO of Assure360 Page 5 Chapter 1: Appointing the right asbestos analyst 7 Chapter 2: Testing for asbestos 15 Chapter 3: Reoccupation certificates and clearances 29 Chapter 4: Soils 35 Chapter 5: Do analysts do project management? 41 Chapter 6: Protective equipment and decontamination 45 3

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5 Introduction Here s my summary of the draft of the new from the HSE. The HSE s new 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 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. 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. Publication of the consultation paper was a surprise when it was issued over Christmas, so stand by your beds. Nick Garland, CEO, Assure360 LETS CONNECT You can connect with Nick on LinkedIn or Twitter: 5

6 Appoint the analyst direct. Do not rely on the licensed asbestos removal contractor to do it for you. 6

7 Chapter 1: Appointing the right asbestos analyst 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. Appoint the analyst direct, and do not rely on the licensed asbestos removal contractor to do it for you. 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. Plan, plan, plan 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 want and for you to understand what you are going to get. Areas to address: Reasons for the sampling. Your aims and objectives. Where the sampling will be taken from specific reference for special arrangements (e.g. sampling at height). Making good (in case of bulks). Health and safety issues for normal occupants of the building. Timings how long will certain activities take (e.g. the visual inspection). UKAS accreditation (as before, mandatory for analytical services). How it will be reported. This last point is particularly interesting. Reports should be designed to satisfy the client s needs, not just perceived UKAS requirements. No more frustrating our reports have to look like this, it is part of our UKAS accreditation conversations. The appointment and subsequent planning phase is intended to mimic the changes first introduced in the Surveying in Planning (especially between the client and the surveyor) has become the 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. 7

8 Construction (Design & Management) regulations - CDM15 removal projects are covered by CDM15. However, the analysts guide gives us a new twist. Contrary to CDM15, the guide specifically states that the analyst will be treated as a separate contractor. All asbestos removal projects even the smallest ones - will therefore require the appointment of a Principal Contractor (PC) and a Principal Designer (PD). Many asbestos consultancies have upskilled to take on the PD role, but smaller ones may not accept the additional liabilities. It s another duty for the client appoint a PC and a PD to the project and be confident they have the skills. 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 ensuring the project is 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 first step? 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. Duty of care and consultant responsibilities 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 it 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. Secondly the guide suggests not all analysts need medicals. In my experience, site analytical work 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 AIB job, where the HEPA filter failed in the NPU. Consequently, I believe all analysts should have medicals. 8

9 The guide makes clear that two copies of the Certificate for Reoccupation (CfR) must be issued - the building controller and the licensed contractor. Not just duty of care 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: The proximity to the Control Limit. Risk assessment. The adequacy of RPE. The effectiveness of controls. Personal monitoring should be performed in 10% of cases, targeting: Disturbance sampling inside enclosures. Bulk sampling. Any live enclosure entry. How much is good enough? 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 lower than just the control limit. There is therefore no good enough - 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. Quality control Whilst the number of required audits has stayed roughly the same, other checks to be recorded and studied have increased. 4-stage clearance inspections One in five should be shadowed or blind inspected immediately afterwards: Paperwork available including the PoW. Correct PPE and RPE. 9

10 Follow correct decontamination procedure? Complete the correct checks for Stage 1? Complete adequate checks of the transit / waste routes? Spend sufficient time on Stage 2 (visual inspection) and were any identified issues dealt with appropriately? Use the correct equipment for Stage 2 e.g. access equipment, mirrors, torches and so on? Conduct adequate air sampling (location, duration, disturbance periods, analysis time and so on)? Sufficient photos. During the consultation period there were calls for making audits more specific i.e. what type of clearance was it? This would bring it into line with survey audits. Photos? The new 4-stage clearance process must include photographic evidence to support the decisions taken along the way. These will include 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 will evidence stage durations. Logs of all activities Maintain individual logs of all work completed by your analysts. Record: Pass / failures. Reasons for failures. Variance between predicted and actual visual inspection duration. Comprehensive internal review Audit of analysts performance every six months (including a review of the detailed logs). Impact on competence assessments 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 removal contractors found with the drive for competence on their 10

11 side of the fence consultancies will have to develop new sophisticated systems to collect, analyse and present data in meaningful ways. Training, qualifications and competence Common sense The guide highlights something that has been clear to me for a long time. What we ask of analysts often strays from the standard UKAS requirements: Interpretation of results and reports. Management of asbestos work. Other inspections e.g. contaminated land, non-licensed work. The guide also highlights the need for H&S training. This is critical basic training for any analyst. Passing or failing a 4-stage clearance is a stressful and intimidating situation. Consultancies should provide support mechanisms and procedures to mitigate or eliminate this. It will help ensure that analysts actions and decisions are impartial. Qualities of resilience, determination and integrity are required. The guide covers the UKAS recognised proficiency training modules. Also highlighted is requirement for sign-off by senior manager before any unsupervised work. However, competence is more than a training certificate we must ensure an employee is competent to do the job. Just because I was signed off as competent last year doesn t mean I still am. Is this project being managed? The participation of the client in the plan, plan, plan process will 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: 11

12 Spec the project, review the method, supply an analyst to run tests, provide a clearance report. 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. I cover this in much more detail in Chapter 5. STAY UP TO SPEED There s much more about competence, training and regulation from Nick at the Assure360 blog. /news Is it really common sense? So how common are these skills: Interpretation of results / reports. Management of asbestos work. Principal Designer. Personal qualities of resilience, determination and integrity. It is a rare analytical company that 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. 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. 12

13 Testimonial: Delta Services Delta staff members frequently work remotely on different sites with different clients. They needed an intelligent system to provide a single centralised platform to monitor their asbestos removal processes. With Assure360, Delta Services employees can access client data in one place at any time, wherever they are, keeping workflows up to date and seamlessly managed from start to finish. 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, MD Read the full case study at: /asbestos-testing-who-uses-it 13

14 Another key change in guidance is in dust sampling, which should be avoided except in rare and specific occasions 14

15 Chapter 2: Testing for asbestos Bulk sampling Simply put, bulk sampling is where a small amount of a suspect material is collected on site and taken to a laboratory. Powerful microscopes are used 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 : the survey guide remains the best practice manual, the new analysts guide overlaps and expands. Both need to be understood to remain compliant. An end to solo working? The guidance on single surveyor working has been significantly altered. It is now strongly recommended. In some siutations it is essential: Working at height. Confined spaces. The method demands it - e.g. shadow vacuuming has been specified. This last might be needed where you can t wet the asbestos containing materials (ACM) e.g. live electrics. This is much more forceful phrasing than the ideally in the Survey. 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. What not to sample There is specific direction on sampling strategy for some ACM types, much consistent with HSG264. The first significant change is in pipe insulation strategy. 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). 15

16 Whereas the analysts guide says: Valves or hatches or repaired areas near access routes are less likely to contain asbestos but discretionary sampling may be necessary. I am not convinced about this. 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 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 welcome guidance. 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 a blunt tool. Random swab samples where there is no visible evidence of contamination have caused no end of issues to clients. They can cause considerable alarm and remediation costs, where the reality might be a single fibre posing little or no risk. What to sample and how In traditional surveys, the number of samples taken will depend on: The extent and range of materials present. The extent of variation within the materials. Building or site circumstances. 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 fully support the increased emphasis, but it will have an impact on costs. Original architect drawings will help, but it will depend a lot on experience. The guide suggests tells that will give a clue to a change in material: 16

17 Colour changes. Surface texture change. Sound (when knocked). Evidence of repair. Temperature. None of the above can be used for positive identification, but they can give a strong indication as to when to take additional samples. What happens when access makes sampling or post sampling clean-up impractical or hazardous? These areas should be discussed with the client. On the sealing of the sampling point, the guide raises some important considerations. The technique should be agreed with the client, but some issues to bear in mind: Tape or the traditional encapsulant paint (ET150) may peel from loose, hot or damp surfaces. Water-based fillers may shrink and fall out as they dry. Foam sealants are often flammable. Sampling guidance 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). 17

18 cement Large samples are recommended (at least 5cm2) or where the water absorption test is required (9cm2). 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 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. I have served my time in the bulk lab and can testify to how irritating small samples are. But I m not sure a client would approve two 20cm2 samples from every ceiling. Something to discuss in planning. Dust samples Avoid, but where they are taken to assess spread of an incident collect a minimum of one tbsp of dust (not debris). Scrape the dust layer into a pile and transfer into a suitable labelled container. Wipes, adhesive tape and filters should not be used. Measurement of airborne fibre concentration Air testing asbestos, is the collection of a measured volume of air (litres) through a filter. A specific area is examined to count the number of fibres. This allows the calculation of the concentration of respirable fibres in the air. This is likely to mean nothing to most readers so I shall explain a few terms. Respirable Means fibres are not only breathable, but small enough that they can reach the lowest levels of the lungs where they can do the most harm. Volume Quoted in one of two ways: 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) 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. So if a room had 100 fibres floating about and you sampled a small amount of the air it would be pot luck whether 18

19 you captured any of the fibres. It wouldn t be fair to say that the air was asbestos free just that you didn t detect any. Similarly, if there were 1 million fibres floating about you would probably catch some. So LoQ imeans we don t really know how much asbestos is in the air, but it is likely less than this. Any clearer? Graticules This is the round target 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. Personal sampling 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 to: Establish that the Control Limit (0.1f/ml) is not liable to be exceeded. Aid correct selection of Respiratory Protective Equipment (RPE). Help decisions on licensable work (the sporadic and low intensity measure). The short-term exposure limit (STEL) has not been exceeded (the 10 minute STEL is 0.6f/ml). Provide medical surveillance records. Support current and future risk assessments. Check the effectiveness of control measure. Type of test Sampling rate (litres of air/min) Minimum volume of air (litres) Minimum graticules LoQ (f/ml) 4-hour control limit minute STEL RPE assessment

20 Whilst measurement against the control limit requires a 4-hour sample, there is allowance for shorter activities. 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. But only a test with a low LoQ can have any real utility. So the 10-minute test should be avoided in favour of one that can give a LoQ of 0.05f/ml or better. Clearly high risk activities should be prioritised based on the ACM, its condition or the individual s role in the method. 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: Person s name and job title. Actual work activities carried out (periods and extent). General work activity in the area. product being removed (e.g. AIB ceiling tiles). Type(s) of asbestos likely to be involved. Removal method. Type(s) of dust suppression control measures employed. Type of RPE. An opinion on the effectiveness of control measures. Other factors which may affect the result (e.g. confined location, external location, condition of the material being removed or worked on). Photo of work area (through viewing panel). FIND OUT HOW ASSURE360 HELPS The Assure360 database is designed specifically to deal with these three critical areas. Get in touch to book a demo and find out more: If any of this information is missing, the sampling will be deemed inadequate. This is a strong statement, intended to compel analytical companies to comply. It s not 20

21 suggesting a contractor receiving such an inadequate result should discount it. Just like any asbestos worker, the analyst themselves should have personal monitoring conducted on them particularly: Visual inspection and air clearance monitoring during 4-stage procedures. When collecting bulk samples. When entering live enclosures for any reason e.g. for pre-visuals. A summary of personal sampling should be kept for five years. There s no detail on what it should contain, but it should form part of health records, which must be kept for 40 years. The Assure360 app tracks exposure, compares against anticipated level and allows employers to review methods regularly to improve standards. Whenever anticipated levels are exceeded, this is treated just like any safety incident spawning an investigation and root cause analysis. Static sampling A large traditional air test which establishes the fibre levels in a general area. Used in several different situations: Clearance testing - validation for the Certificate for Reoccupation process. Background testing - establishing the baseline levels or starting point before removal / disturbance starts. Leak testing - monitoring the integrity of the asbestos enclosure during asbestos removal. Reassurance testing - used after asbestos works have been completed - to give reassurance that the area remains safe. Near-source static sampling - used during removal / disturbance to assess the general release / spread of asbestos caused by that activity. Can be used to simulate maintenance activity in a controlled manner or in very large enclosure. Far-source / perimeter sampling - conducted around the perimeter of the site, e.g. around a contaminated land project, or around a building on fire. There s no specified flow rate for static tests, but the total volume of air tested should be 480litres or more. The number of graticules counted must be High flow rates (e.g. 16L / min for 30 minutes) should be used to limit the effect of settling and increase accuracy. Exceptions to this are background and perimeter monitoring where low flow rates and very long durations are preferred. 21

22 When not to test The guide gives some pointers on when not to test. FIND OUT HOW ASSURE360 HELPS 1. During the 4-stage clearance for external works e.g. soffit removal. External asbestos removal (i.e. no roof to the enclosure) still requires a 4-stage clearance, but does not require an air test. The Assure360 database tracks exposure, compares against anticipated levels and allows 2. Where the work is of such short duration/low emission that suitable monitoring results could not be obtained in the sampling time. My reading of this is that the 10-minute test is ONLY suitable for establishing sporadic and low intensity. method review on a regular basis to improve standards. Get in touch to book a demo and find out more: 3. Personal sampling where there are good reasons for expecting that the exposures will be very low and well below the Control Limit. 4. Where adequate information is already available to enable the appropriate RPE to be provided. I have my doubts over the wisdom of the last two. We are mandated to reduce exposure so far as reasonably practical. Not testing because we don t think exposure will be high or we already use good RPE misses the point. You should always conduct the test to support current and future risk assessments and check the effectiveness of control measure. Air monitoring by Phase Contrast Microscopy (PCM) 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 advantages and disadvantages. The key plus is that the test is quick (within an hour or two when conducted on site) and inexpensive. But in high dust environments (e.g. wire-brushing, blasting or removal of ceilings) can 22

23 overload the filter making it unreadable. As it can t easily differentiate between asbestos and non-asbestos fibres, it can overstate asbestos concentration. These must be recognised 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. Retention of half the filter prior to standard analysis might be useful. 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. Caution is needed when interpreting the results from post incident air tests or ones conducted some distance from a contamination source. The time gap and physical distance between incident and test will be affected by natural dilution. Scanning Electron Microscopy (SEM) The guide details the option of using SEM analysis but it does not suggest it as a first option - only as a check if PCM fails. 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 f/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. 4-stage clearances (4SC) 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. There are exceptions - scaffolding or when the floor is an intrinsically dusty surface are the examples given. It could mean floors sheeted out before removal must be uncovered for the 4SC air test. Simple projects may become more complex and costly if this is the case. 23

24 Daily leak testing Daily leak testing is required where there are other personnel near the asbestos work. Key areas to be tested are: Enclosure openings (e.g. airlock, bag lock, additional flapped vents). Areas where there had been difficulty sealing the enclosure (e.g. pipe or cable penetrations). Areas occupied during the work. Near the exhausts of NPUs if not venting to atmosphere. 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 analysts guide. Currently leak testing (certainly daily ones) is considered an optional extra. The new emphasis is unarguably a good idea but there will be a cost impact. Two other sampling techniques are discussed in the guide: Size selective samplers These exclude larger particles allowing the analyst to focus only on respirable particles. They have some useful applications (contaminated land projects) but shouldn t be used in enclosures as high dust levels indicate inadequate cleaning. Real-time samplers These give a continuous reading of the particles in the air. Long considered the holy grail - they are still viewed with suspicion in the guide. The single paragraph discussing them suggests they shouldn t be used in place of standard techniques. I am aware that several trials are being conducted, under the watchful eye of the HSE, so opinion may change in the final version of the guide. 24

25 Testimonial: LAR 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. 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, MD Read the full case study at: /asbestos-testing-who-uses-it 25

26 A real industry first The new Assure360 app is a powerful tool that brings health and safety innovation into the 21st Century. By providing a complete package, our app will transform health and safety within construction businesses, providing detailed real-time auditing and recording across all areas of safety management. 26

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28 It is not the analyst s role to supervise or manage clearance but to validate that it has been completed successfully. 28

29 Chapter 3: Reoccupation certificates and clearances The HSE have been running a well-publicised investigation into analysts and clearance practices. It s a relatively small section of the guide, but has so many changes and is of such significance, I thought it best to give it a chapter of its own. Cleanliness of premises and plant This is the legal phrasing used to cover the duties imposed when returning an area back to normal use after some asbestos removal. See Chapter 2 for full pointers on when not to test. The one I focus on here is during the 4-stage clearance (4SC) for external works. A common example would be soffit removal. This is an area that often confuses removal companies and analysts. External asbestos removal (i.e. no enclosure) still requires a 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. 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 property that does not have bushes, trees, sheds or the neighbour s property in the way of this. It s 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. The designer needs to get imaginative. It is probably cheaper and easier to build a bigger scaffold and put a traditional enclosure on top. The 4-stage clearance process The process by which an analyst passes off an asbestos enclosure is very familiar: Preliminary check of site condition and job completeness. Thorough visual inspection inside the enclosure/work area. Disturbance air monitoring (see above). Final assessment post-enclosure/work area dismantling. All four stages should be completed by a single analytical company (accredited to ISO and ISO 17025), and preferably the same analyst. To ensure the required independence it is now strongly recommended that the analytical company is employed directly by the building owner / occupier direct. 29

30 It s a much firmer stance on the issue and could mark time on the removal contractor rolling clearance into the package and employing the analyst themselves. It s advice that consultants have given for years (me included). But it will have a cost impact - contractors always seemed to negotiate very competitive rates from analysts! The requirement that all four 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 analyst should plan the 4-stage clearance at appointment stage or before work starts. This involves 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 - the detailed hands-and-knees examination by the analyst that all asbestos and visible dust has been removed. Changes to requirements for the visual inspection There are some fundamental changes: High resolution colour photographic evidence of the various steps with time and date stamp. These should be embedded into the certificate. Prediction of the time required for the visual inspection and justification if this differs from reality. All new Certificate for Reoccupation (CfR), to incorporate the above. The photographs required are extensive - a minimum of 12, plus one for the DCU. It s more for complex enclosures. The guide includes a table in the appendices on suggested times for visual inspection - see opposite page. If the difference between the estimated and actual visual inspection duration is >20% (longer or shorter), the reason should be recorded on the CfR. It s not clear what should happen if the reason given is inadequate. This was raised during the consultation process, so should 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 30

31 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 will make massaging of these stats much harder. ACM Location Size of area or volume Complexity/ difficulty Estimated time required AIB AIB Ceiling tiles plus void m 2 Very difficult 8hrs AIB Selective ceiling tile removal m 2 Not very complex but time-consuming 3-4hrs AIB single panel Domestic cupboard, small enclosure 6-10m 3 Not very complex. Some pipes, shelf, skirting etc 15-30mins but up to 1hr AIB Soffit AIB External Panel(s) below window linear metres 20-30m 3 Not very complex but high level with mobile platform Not complex 1-4hrs 0.5-2hrs AIB Ceiling tiles plus void 25-50m 2 Quite difficult. Services, cable trays 1-4hrs AIB Ceiling tiles plus void m 2 Quite difficult. Services, cable trays 2-6hrs AIB Ceiling tiles plus void m 2 Quite difficult. Services, cable trays. Time consuming 4-8hrs Lagging/insulation Pipe insulation/ lagging Boiler room m 2 ( m 3) Complex. Various vessels, pipes, ledges 2-4hrs to 1-2 days Pipe insulation/ lagging remnants from previous removal Boiler room m 2 ( m 3) Complex. Various vessels, pipes, ledges 2-4hrs to 1-2 days debris (Lagging/AIB) Ceiling void 25-50m 2 Quite difficult. Services, cable trays. Time consuming 1-6hrs Documenting clearance 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. 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. This is an improvement, but it does raise some questions. There will be several variants, but I think this example sums it up: 31

32 Housing estate where there are 2-3 clearances in a day. DCU stored securely overnight in the central compound. 2-3 DCU inspections in a day? 1 inspection per day but how do you record it? 1 inspection at the end of the week when the project ends (as is often the case now). Time spent on clearances has dramatically increased. 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 now, more than one would be unlikely. The role of the contractor in clearance It is not the analyst s role to supervise or manage clearance, 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: All asbestos has been removed. The enclosure / airlocks are clean and dry. Sacrificial polythene has been removed. 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. If this is included in the final guidance, it would 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 with incomprehension. It would have a significant cost impact. I can t think of any logical argument against it though. The guide makes a brief foray into defining Environmental Cleans. 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. 32

33 Testimonial: Royal Mail Group Coordinating suppliers and contractors to safely remove asbestos from the Royal Mail Group s more than 2000 locations was a very daunting task for Compliance Manager, Richard Bennion. 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. Assure 360 is the solution that provides a robust approach to compliance audits of our suppliers. Richard Benion, compliance manager Read the full case study at: /asbestos-testing-who-uses-it 33

34 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. 34

35 Chapter 4: Soils There s a real difference between the HSE and Environment Agency s take on asbestos in soils. The HSE s interest starts and ends with protection of the worker and others directly affected by the project. Another much more ambitious and targeted document on this other angle is: 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. When are asbestos surveys required? 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. 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. There are other reasons: Low take-up of demolition surveys. Illegal dumping activity. The accepted practice of leaving well bonded ACMs (e.g. textured coating) in buildings to be demolished. Speculative sampling? Speculative sampling should not be undertaken. We re told to only complete soil investigation if other (desktop) analysis indicates that there is a risk: Earlier surveys. Local historic maps and records. Knowledge of pre-1990 demolition or major redevelopment. Previous uses of the site (e.g. asbestos product manufacturing, high temperature processes, heavy manufacturing, power stations, shipyards etc). The potential source of contamination is very broad and could be totally unrelated to the list given us in the guide. So I agree, don t do speculative sampling, but if there is planned ground works asbestos surveys should be mandatory. 35

36 containing materials present in contaminated land can vary from whole sheets of asbestos or sections of pipe insulation to smaller fragments. 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. This is what brings 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. Discoveries during the project may require us to revisit the assessment. Types of ground surveys - preliminary surveys The guide suggests a targeted approach. Careful examination and picking of the area. (Sieving may also help to separate the coarse fraction. Detailed procedures on decontaminating the sieve to prevent cross contamination of samples is needed.) This allows 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. The task is to hunt out asbestos and present suspect materials to the lab. To get any type of risk assessment, there needs to be an adjustment factor (suggested at x 0.1 ) to allow for the fact the ACMs were collected over a larger area. This method allows a large area of the site to be covered quickly. Principally it establishes if a main survey is needed and allows better planning. 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. Types of ground surveys main surveys 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 36

37 technique involves mixing the sample, pouring it into a conical shape, flattening it out into a cake and dividing the sample. 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). Logging on a site plan allows a register of what has been identified and can also be compared with previous site plans to better target further investigations. The activity should be done at the surface and the surveyor should not enter trenches or holes, unless properly shored up. Analysis 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 dependent on 37

38 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 be selected. Results should be reported as a weight for weight (w/w) percentage of the matrix. The current rules for hazardous waste is 0.1% w/w, or if any visible fragments of ACM are in of themselves >0.1%. This could mean a single 10p sized piece of AIB or cement in an otherwise clean load would render it hazardous waste. There is a table in appendix 2 which seems to contradict this: All asbestos waste is subject to Schedule 2 of CAR2012 and most waste is subject to the Hazardous Waste Regulations. Firmly bound asbestos asbestos cement and articles with asbestos. reinforcement does not release hazardous or respirable fibres easily. XXX does not apply. The XXX Regulations applies for all other asbestos waste. The presence of XXX indicates it is unfinished, but the guide seems to be adrift of what I understand is the hazardous waste rules. Assessment These surveys, coupled with near source and far source air testing (see Chapter 2), 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. 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. It will likely get re-worked, but it 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. 38

39 Testimonial: Breyer Group Breyer needed an intelligent system which could provide a single centralised platform to monitor all aspects of construction H&S. Assure360 s approach of configurable cloud database gave the best of all worlds. Working right out of the box, it was implemented within weeks, bespoke questions following very shortly after. 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 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 of Health, Safety and Environment Read the full case study at: /asbestos-testing-who-uses-it 39

40 There is a large disconnect between what an analytical company and a client believes is involved in a project 40 management role.

41 Chapter 5: Do analysts do project management? I touched on this subject in Chapter 1, so there will be a little overlap. Most analytical companies provide a management service. As this is not direct supervision of removal tasks it is not licensed work but what exactly does it mean? The guide argues that analytical support, in a full-time role, can ensure the work is completed safely, efficiently and compliantly. However, there is a large disconnect between what an analytical company and a client believes is involved in a project management role. I will take this opportunity to cover what the guide says and what clients expect. What the analyst hears when someone asks them to be a project manager (i.e. what the says) If it s a short job, probably just the 4-stage clearance at the end. However, on more complex projects it could be significantly more involved potentially from start to finish. Services that can be provided are: 4-stage clearance. Smoke tests. Enclosure inspections. DCU inspections. Waste and transit routes. LARC documentation (RPE, training, DOP certs). Leak testing (plus subsequent investigations). NPU efficiency. Measuring negative pressure of the enclosure. Personal monitoring. Consultation on 4-stage clearance issues before work starts.* Diary of work activities. Inspections of plant and equipment leaving site. Liaising between all parties. * Particularly useful for difficult to pass enclosures (rough dusty concrete floors, enclosures with natural water ingress etc.) The LARC, Analyst (and Client) should discuss the issue as early as possible to establish what actions can be taken to avoid clearance failures or the standard of cleaning which is reasonably practicable. The air monitoring sampling regime will differ greatly from project to project but you will recall that an earlier chapter indicated that leak testing should be mandatory for occupied buildings. 41

42 Managing these things is clearly an enormous assistance to the smooth running of the project. But one thing it isn t is actual project management and this is the source of the disconnect. What the client hears when an analyst says they will take on a project management role: The client assumes (without knowing all the details) all the above. But also expects actual Project Management - the definition of which is: the application of knowledge, skills, tools, and techniques to project activities to meet the project requirements. The five stages of project management are: Initiating Planning Executing Monitoring and Controlling Closing FIND OUT HOW ASSURE360 HELPS In other words, clients expect that the analyst will use a whole range of skills to ensure that the project is designed and executed to meet the client s requirements. They expect that analysts will monitor the process (not just the air), to ensure that it is completed on time, safely and within budget. An asbestos removal project is just a complex construction project. Therefore, to ensure that the project is designed and executed safely, the individual must have expertise in construction hazards. Unfortunately, analytical companies rarely include project management ability in their skills matrix, never mind measure it. It is notable that such skills are not mentioned With tools, tracking, dashboards and reporting, Assure360 is a simple app that brings safety management into the 21st century and makes asbestos removal efficient and safe. Get in touch to book a demo and find out more: 42

43 in the core skills detailed in the appendices of the guide. Consequently, analysts assigned to this role are typically perfectly competent asbestos monitoring technicians, but do not have the breadth of skills to manage a complex multihazard project. This is therefore a challenge to the analytical companies out there to recognise what clients hear when Project Management is sold to them and start to identify the skills required and train / recruit an appropriate workforce. The Assure360 app is flexible enough to bring out our strengths but at the same time shine a light on our weaknesses and help resolve them. Jim Marling, Romford Group 43

44 44 Summary of PPE to be worn Decomtamination required Domestic clothes possible Coverall RPE Cleanable footwear Preliminary Full Survey/other sampling: low risk Yes Single Yes Yes No Survey/other sampling: high risk No Two Yes Yes No 4-stage clearance: Stages 2 and 3 (inside enclosure) No Two Yes Yes If necessary DCU clearance No Single Yes Yes No Live enclosures No Two Yes Yes Yes Half mask or disposable APF = 20 Full facepiece powered APF = 40

45 Chapter 6: Protective equipment and decontamination What personal protective equipment (PPE) including respiratory protective equipment (RPE) should an analyst employ in the completion of their tasks? This, bizarrely, has been a thorny issue over the years. Hopefully the new guide will resolve this. Where 100% elimination of exposure is not possible, and after all measures have been taken - levels above the Control Limit are still likely, employers must provide RPE. Clearly the main risk for analysts is entry into a live asbestos enclosure (i.e. where removal is taking place). Use of CCTV or viewing panels should be used to minimise this activity. It goes further by stating analysts should not enter live enclosures at the request of the LARC to conduct pre-visuals. On first reading this, I assumed that this key service was being banned. However, I think the phrase at the request of the LARC is key i.e. if the pre-visual is planned and the analyst s method covers it then it s acceptable. Further guidance is needed. The guide goes through multiple paragraphs detailing the RPE selection assessment, but then summarises it neatly in a single table [opposite]. Highlights of the selection process would be: Face Fit Test (hints at annual re-test, or if significant change in face shape). CE marked (European standard soon to be replaced?). The individual s needs (e.g. glasses, facial hair, fitness level, piercing etc.) The work environment (e.g. temperature, need to communicate, height etc.) Other hazards (may require carbon filters or air-fed). Analysts should be trained (with annual refreshers) in: How to check masks before use (including a fit check). How to put them on. How to care for them (including storage). Fault recognition (including during use). 45

46 All RPE should be thoroughly examined and tested before issue and at least monthly thereafter. A record of inspection, examination, maintenance and defects remedied must be kept for five years. Long a requirement for LARCs I m not sure how diligently analytical companies have adhered to this. Where the potential for contamination is high (e.g. demolition surveys, under crofts, contaminated soils, live enclosure entry), lace-less boots and disposable gloves should be worn. The guide suggests rigger boots but as these often have a fur lining, they would not be easily cleanable. They are also not permitted on many sites due to the lack of ankle support. Decontamination Another bizarrely controversial area, which the guide now tells us is the minimum expected procedure relates to decontamination. With reference to their table (page 44), primary decontamination (cleaning masks, and boots) is required in all cases and wearing double sets of overalls in virtually all cases. This last item has a process in of itself: No normal clothing underneath. The top (i.e. outer ) coveralls to be removed on finishing the task (double bagged and disposed of as asbestos waste). Inner coverall can be worn to the changing facilities. Entry into a live enclosure requires full decontamination and entry into an enclosure for a 4 stage clearance requires full decontamination if necessary more on this worrying phrase later. Preliminary decontamination (enclosure entry): 1 Vacuuming the outer coverall at the edge of the enclosure; 2 Clean boots and RPE (inner stage of the airlock); 3 Clean equipment used (sample bags, torches etc.); 4 Remove the outer coverall in the middle stage; 5 If full decontamination is not required - exit the airlock and remove the RPE or if full decontamination is required proceed to the decontamination unit (DCU). Essentially the same process that LARCs should be following. I say should as a decade or two of poor practice has weakened this process significantly. 46

47 Preliminary decontamination (surveys) Cleaning / discarding gloves between samples. On completion: Coveralls should be cleaned (wiped) and discarded. Footwear (particularly the soles) is likely to require more decontamination (wiping or washing in a bucket of water). Re-useable RPE should be cleaned and retained for re-use. Disposable RPE to be discarded. All wipes, used overalls, gloves and disposable RPE to go as asbestos waste. Buckets and the double overall approach for surveys (not to mention the likely need for a DCU), require significant planning. Changing facilities and disposal arrangements for contaminated overalls and water will be required as a minimum. Use of the decontamination unit (DCU) If the analyst needs to use the LARCs DCU for full decontamination, the guide points us to the Licensed Contractors HSG247 for instruction. It also notes that the analysts should receive specific training in how to do this. However there are some differences. The analyst should change in the clean end of the DCU and emerge directly (without passing through the shower / dirty end ). Contractors, DO pass through the shower. I personally prefer the analyst s version and often encourage LARCs to re-write their standard procedures to match. The guide recognises (for the first time) the issue that female analysts face in a male dominated removal industry - swimsuits are suggested. Whilst I support this, no guidance is given on laundering. Enclosure re-entry If the analyst is due to re-enter the enclosure then the guide indicates that the RPE can be removed and the analyst can move around the site wearing the inner set of coveralls. The outer overalls and RPE would obviously be put back on to reenter. Examples when this is permitted are given: 47

48 Collecting air test pumps. Partway through an ostensibly good four stage clearance. Live enclosure entry. I have some serious concerns here, as not following immediate full decontamination after a live entry would be (in my opinion), foolhardy. Hopefully this will be cleared up in the final version. The guide gives some pointers on when full decontamination would be required: Significant or gross contamination. Outer coveralls ripped / damaged ( inner coveralls/underclothes may have become contaminated). To help the analyst decide, it suggests that the best approach would be for the company s policy to define minor contamination and advise full decontamination where contamination is not minor. Full decontamination if necessary Now we are back to my worrying phrase the following is pretty much word for word: On exiting the enclosure for any reason (e.g. clearance failure, after setting up the air sampling equipment or on the completion of Stage 3), the analyst should make a professional judgement as to whether full decontamination is going to be necessary. If full decontamination is deemed not to be necessary (which should be the case in most situations), the analyst should remove the RPE outside the airlock (place in waste bag or keep for further use as appropriate) and proceed to carry out further duties still wearing the PPE. And: Further decontamination may take place on return to the laboratory. The professional judgement of an analyst with 12 month s experience is going to be somewhat adrift of someone with five years under their belt. In addition, there have been plenty of situations in my career where I have had surprise failures. An example I gave previously was the removal of a flue pipe running up a four-storey 48

49 building. The project was in a British embassy and therefore despite it being nonlicensed work, full enclosures were used. The visual passed with flying colours but the subsequent air test gave a result of 0.5f/ml! Unbeknownst to me, the pipe was sealed with pure fibre. Therefore, if stages 2 and 3 of the 4SC had been spilt over a shift the guide would suggest I could go home without showering. I ll always maintain - full decontamination should be completed after every enclosure entry and it certainly shouldn t need to be finished off after getting back to the lab. 49

50 A final word 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. Photography: Jonathan Birch 50

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52 At our recent license renewal, the HSE inspectors were amazed by the power of the Assure360 system and couldn t believe everyone wasn t using it. Book your free demo of the Assure360 app. We re on stand C3150 at Contamination Expo enquiries@assure360.co.uk 52