Are Housing Providers doing 'Asbestos' they can?

Guest article from Joe Malone BSc(Hons) ICIOB

Group Investment Programme Manager - WM Housing Group

This is the second of a two part article which considers asbestos.  Part 1 published a few weeks ago focused on legal requirements with this article  considering asbestos management.  It is argued that a knowledge and understanding of asbestos is fundamental to being able to interpret testing reports, and potentially result in significant cost savings

 

Competence

Source: Google Images



In part one of this article we discussed how  HSG264 had placed a key focus on competence. The left hand illustration  highlights the need for competent staff to work with asbestos but what is competence? I have a P402 qualification obtained from the British Occupation Hygiene Society so would I class myself as competent to carry out asbestos surveys? Absolutely not is the straightforward answer, for a number of reasons. Competence is defined as having knowledge, understanding and experience but what is key to this concept is that you must be able to prove it by means of records and documentary evidence. The P402 in itself might prove that I have knowledge and understanding of the subject but it does not prove experience; moreover, even site experience in the form of survey work has to be regularly audited under a quality management system. The expectation now is that site surveyors have a minimum of 5% of their survey work audited for quality. Since my employer has neither an audit system nor a quality management system in place then I could not possibly prove competence and therefore have taken a business decision not to carry out asbestos surveys 'in house'. I firmly believe that there are many asbestos surveys being carried out by surveyors who would find it impossible to prove competence. Is it time to rethink your approach to asbestos survey work?



OK, but what about asbestos removal contractors, how do they prove competence? This in itself is another difficult subject area and I believe that a number of licensed contractors would also struggle to prove competence. In writing my asbestos management plan, I drafted a contractor checklist for inclusion in the appendix and I will share the basic list with you to give you a flavour of what you should be looking for in a licensed contractor.

1. They must have a current HSE license to undertake works with asbestos.

 (check license duration and number)



2. They will have a current waste carrier’s license issued by the Environment Agency. (check and record license number)

3. They will be insured to carry out asbestos removal work and will have a minimum of Employers Liability (£10m), Public Liability (£10m), Professional Indemnity (£5m) and fleet cover for the carriage of Asbestos. (Values will vary with individual business requirements)

4. Improvement or Prohibition notices to be checked and where there are recent or serious breaches you should retain the right to select an alternative contractor.

5. Ask the contractor to provide a record of waste consignment notes for the previous month so it can be checked that contractors are disposing of asbestos responsibly.

6. Request that asbestos company provide a full training record for all site staff including site supervisors so that qualifications can be checked.  All site asbestos removal operatives and supervisors will be qualified to UKATA/IATP or BOHS  category C standard (Licensed work). All three organisations are listed on the HSE website as approved partners though each in turn has a glut of affiliate partners who deliver training to this standard. Note that it is also critical to ensure that trained staff are also receiving annual refresher training.

7. Ensure your contractor agrees to provide documentary ‘self certification’ on removal of asbestos.

8. Ensure your contractor agrees to provide ‘project specific’ risk assessments and method statements (RAMS) and therefore agrees to visit site prior to supplying  RAMS on each project. Far too many supply RAMS without even visiting the site in question and this is completely unacceptable.



Source: Google Images

9. Ensure they are UKAS accredited to ISO17020. This is the internationally recognised standard for the competence of inspection bodies. ISO 17020 should not be confused with the quality management standard ISO 9001:2000: the latter is specific to quality management systems and it does not require evaluation of the technical competence of an inspection body. ISO 9001:2000 is not regarded as an acceptable alternative to ISO 17020. Shockingly many are claiming  UKAS accredited asbestos competence based on holding nothing more than ISO 9001. You can check accreditation of inspection bodies and analytical services, but clicking on this link,



10. Ensure that laboratory/analytical services are also accredited  to ISO 17025 for conducting 4-stage clearance inspections and the issuing of reoccupation certificates following asbestos removal or clearance operations.



If you do apply this checklist I get a feeling you will have a higher than expected

failure rate.

Product Awareness

I have on a number of occasions received lab test results that claim that a material defined as Chrysotile is asbestos insulating board and therefore a notifiable product that costs lots of money to remove. Now note the product description below given for AIB.



'Asbestos Insulating Boards (AIB)(trade names ‘Asbestolux’ and ‘Marinite’) weigh around 700kg/m3 and contain from 16-40% amosite (brown asbestos) or a mixture of amosite and chrysotile (white asbestos.) Crocidolite (blue asbestos) was also used in some boards up to 1965'.



You will note that AIB does not contain only Chrysotile and in any event, Chrysotile is the lower risk Serpentine rather than Amphibole type. We have repeatedly challenged given lab results and found that the claimed notifiable product was in fact non-notifiable. On the last occasion, the quoted £20k removal costs were reduced to £1500 on re-assessment. Two key points arise from this observation.

1. Good product knowledge and awareness will cut  your removal costs.



2. You absolutely have to split the removal and analysis function so analytical services are employed directly by you and completely independent of the removal/remediation company. This removes that very obvious conflict of interest.

I have only scratched the surface of what is an incredibly complex subject area but I hope the guidance given in part one & two will help you work more safely and cost effectively.

Joe Malone BSc(Hons) ICIOB

Group Investment Programme Manager


Information/opinions posted on this site are the personal views of the author and should not be relied upon by any person or any third party without first seeking further professional advice. Also, please scroll down and read the copyright notice at the end of the blog.