This is an update on what HSE are looking for:
The analyst project started by HSE early this year and involves an initial questionnaire relating to procedures and how many 4 stage reoccupation test the laboratory conduct. HSE will then pick 25 laboratories at random who they will visit. This will be an office visit looking at procedures, asking pertinent questions and taking away samples and slides for re-analysis by the Health and Safety Laboratory (HSL).
HSE are also looking at the ASB5 notification system. They will choose to visit asbestos removal contractors on the last day of the licensed asbestos work so that they can assess the analyst carrying out the 4 stage reoccupation test.
An ATaC member, has recently had an office visit by HSE as a part of this project and below are some points that were raised. Remember, the visit by HSE is nothing like a UKAS audit. The HSE are the enforcing authority and if necessary enforcement action could follow.
The meeting was all very friendly and frank, and they said the basic aim was to ensure the new HSG248 would be fit for purpose, but also to consider the health of analysts, as HSE are aware that ASLIC is 30 years old, and potentially there is a point around now where analysts maybe affected by mesothelioma. They discussed decontamination for analysts, but in the main it was gaining information for statistical analysis.
The main points are as follows:
- They asked for copies of:
- Decontamination procedures.
- Most recent UKAS audit report.
- Personal testing programme for analysts and also LARCs i.e. what we do.
- The last 10 certificates of reoccupation carried out by one analyst, to consider times per stage for a spreadsheet! They say they need more detail on times taken to do certain types of work.
- Discussed decontamination i.e. no street clothes. The point was raised about the fact that they had lost one female analyst due to this, and they shared some information that one female analyst had raised a complaint as the LARC allegedly put the CCTV in the DCU, which while they could believe, they could not believe this wasn’t spotted and sorted out.
- They talked numbers of clearances and failures, and which stages failed, and whether re-cleaning for say an hour would be fail. Also asked % enclosures needing remedial works.
- Statistical analysis of analysts – age, how long they stay in work, wider parts of their role etc. Interested in staff retention, how long analysts stay in the job. I don’t think they are worried about us as employers, rather statistics for ill health.
- On personal monitoring they stated they thought sampling periods were not long enough, and intimated that LARC would have to employ directly & regularly analyst to carry out air monitoring, as LARCs records were not very consistent across the industry.
- They asked about pricing for works e.g. hourly, or day rates, and asked our rates, and what they though other companies rates were. A discussion was held about a reasonable minimum costs to meet requirements of UKAS.
- Asked about number of clearances per day.
- Asked about % works direct for a LARC and % for client, and how or if this had changed recently.
- They asked whether they though LARCs put analysts under pressure on site. On this they said not, other than usual supervisor moans, and that they wouldn’t work with or for LARCs who would do this. They did raise the issue of intimidation by some HSE inspectors which they seemed perturbed at this until the company provided proof. They were taken aback at the transit route issues and agreed this was not an analyst issue rather one for the LARCs and were astonished at the flow rate question (i.e. why 12 l /min when 8 is ‘normal’!). They did question why there was thirst to find something, anything, and whey they could just say everything is OK. The company did suggest that it appeared, that some inspectors were trying to get fee for intervention. The HSE assured the company that this was not the case with analysts, though they agreed that on some inspections this could be perceived as the case. They also said they had ‘softened’ their approach on this, as their usual tactics are more ‘forceful’, and they shouldn’t assume the analyst has done anything wrong.
They said I was the 6th office they had seen, and another team were doing similar visits. Statistics on this project will appear in 2018. They ask leading questions (they never ask a question they don’t know the answer to) and they weren’t trying to catch us out rather sussing out opinions.
The company also raised the obstruction by LARCs on UKAS assessment visits.