On the 17thand 25th November ATaC held regional meetings at ARCA HQ Burton and ARCA training centre Rayleigh. The purpose of the regional meetings was to discuss a number of issues relating to analytical work in the asbestos industry and a chance to meet members for the first time.
1) Working at height
2) The HSE analyst project
3) Air flow through enclosures
4) New HSE App
5) Decontamination procedures for analysts
6) Reassurance air testing
7) RSPH training courses
Working at height
There is a possibility that working at height would be highlighted as a risk with both testing laboratories (4 stage reoccupation test) and inspection bodies (surveying).
It was discussed at both meetings, and agreed, that wherever possible working at height should be avoided. When this was not possible the analyst or surveyor who it will affect should:
a) Check that the equipment (ladder, podium, tower scaffold etc) has been checked by a competent person before using it. Analysts conducting a 4 stage reoccupation test must understand that when on site they are under the direct supervision of the Licensed Removal Contractor’s (LRC) supervisor so a check of his inspection records is important.
b) Look for ‘Scafftags’ on scaffolding to ensure the scaffold has been checked by a scaffold inspector. This should be undertaken every 7 days.
c) Ladders have not been banned and in some cases they are the most appropriate equipment for undertaking a task. They should only be used for short duration work. (taking asbestos samples)
The HSE analyst project
Colin Seditas explained why the analyst project had come about. HSE in the past had not inspected the work undertaken by the analysts. Reports from HSE inspectors from the Fields Operative Division (FOD) had highlighted poor practice from analysts in particular when decontaminating. (Analysts with their day clothes on under their coveralls)
With this and other issues (time spent conducting visual inspections on stage 2 of the 4 stage reoccupation test) the HSE decided to inspect the work undertaken by analysts in particular the 4 stage reoccupation test.
A letter/questionnaire was sent to every UKAS accredited testing laboratory with questions relating to their work.
From these, 25 laboratories were chosen where inspectors would either visit the laboratory or inspect their work on site. The office visits were planned so the lab agrees a time and date. Contractors and analysts would not be alerted of an onsite visits from the HSE. When an ASB5 notification goes into HSE the length of the job with times on and off site are in place so an inspector could choose to visit the asbestos removal works on the last day to inspect both the LRC and the analytical company conducting the 4 stage.
When the HSE have completed this project a report on their findings would be published on HSE web site.
Air flow through enclosures
Although analytical companies do not build enclosures they are often on site as Project Managers so must understand what is required in relation to enclosures and airflow.
The problem with larger enclosures is that the airlock is not big enough to allow the amount of air in to create 8 air changes. Extensive work undertaken by Richard Anderson and the Health and Safety Laboratories (HSL) has found that creating additional openings in the enclosure (bag locks) would allow more air in and thus create the 8 air changes required by the ACOP through the enclosure.
The ACOP also states that an enclosure <120 Cubic Metres in size must have a minimum of 1000 Cubic Metres of air per hour going through it.
LRC are now measuring the airflow through enclosures with an anemometer so that the correct size NPU is applied to the enclosure.
Guidance on this will be issued shortly.
The HSE have produced a mobile phone app for builders who wouldn’t normally attend asbestos awareness courses and therefore may not be aware of the asbestos present or the associated risks. Both meeting agreed that it was a good idea but would not replace the need for good asbestos awareness training.
Analyst decontamination procedures
The problem associated with decontamination stems from the variations on decontamination that seem to be used. Analysts visiting a site may get confused and in some cases not be able to follow their own procedures as the ‘H’ type vacuum cleaner, bucket of water for mask wash and boot cleaning, red bag for disposing of coveralls are not in the place described in guidance HSG248 and HSG247.
Both meetings agreed that when a 4 stage reoccupation test is booked, the person taking the call must ask specific questions in relation to decontamination so that the analyst conducting the 4 stage is fully aware of the procedures used on site before he/she gets there. If there is still confusion ask the LRC supervisor to go through their procedures for entering and exiting enclosures.
Reassurance air testing.
Concerns were raised about reassurance air testing at both meetings by a number of the attendees. It seems that if a LRC had attended a site to clean up a small amount of asbestos debris he would ask for a reassurance air test before the area is reoccupied. This test is a static air test with no disturbance.
It was agreed that the static air test was a complete waste of time and does not mean the area is safe for reoccupation. A disturbed air test would allay fears of any significant asbestos fibres concentrations being present.
Colin Seditas will be looking into this and discussing it with HSE.
RSPH/ATaC training courses
Some attendees and other ATaC members were not aware that RSPH qualifications were equivalent to the BOHS ‘P’ series. Below is a table that should clarify this. Additionally, ATaC are at present running a pilot scheme for their qualification equivalent to CoCA. ATaC hope to make this qualification available in the new year.
|RSPH/ATaC qualification||BOHS qualification|
|RSPH Level 3 in bulk analysis||P401|
|RSPH Level 3 in surveying||P402|
|RSPH Level 3 Analyst (Air) One course||P403P404 Two courses|
There we a few concerns about LRC not allowing UKAS on site to inspect the 4 stage reoccupation test. This could result in UKAS withdrawing the accreditation on the laboratories schedule.
This had been discussed previously with UKAS and they said if this became a real issue the laboratory should report the LRC to them and they would take it up with HSE. Cooperation is a requirement of their licence.
Additional ATaC regional meetings are being planned for 2015 so don’t forget to check the ATaC blog!
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