ARCA COVID 19 Update
ARCA spoke with the HSE yesterday to obtain an update regarding issues faced by members … please read the following update for information and guidance
Yesterday ARCA spoke with the HSE to obtain an update regarding issues faced by members as a result of the disruption to our well established and 'normal' way of working. To give some context to some of the information and guidance below, there is currently no mechanism for the HSE to waive legal requirements. They have the opportunity to not enforce in certain circumstances or apply the test of 'as far as reasonably practicable', which allows for some flexibility to their approach to enforcement at the moment, that approach will be a practical and pragmatic approach. It is important to note that this approach only applies to issues that do not significantly impact upon health and safety.
ARCA has dealt with many, many, phone calls over the last few days to assist members to make sense of how the asbestos removal and management industry needs to adapt to continue to function in the midst of the COVID-19 (Coronavirus) outbreak.
ARCA wants to provide members with the fullest and most accurate advice possible, however the situation is ever evolving and changing fast.
The information below represents what ARCA knows at the moment and represents a snapshot in time. Any changes or updates will be notified to members as and when available.
Members have reported that appointments for medical examinations are being cancelled or are impossible to book, they are asking what they should do in these circumstances. There is a mechanism in existence whereby a questionnaire can be obtained from the medical practitioner / clinic remotely, and filled in remotely, and a medical issued once this has been reviewed and approved. In practice there is unlikely to be anyone who has the form or is qualified and available to review the questionnaire, given the more immediate need for medical resources elsewhere. It is recommended that members retain evidence that they have attempted to obtain a medical, such as an email stating that the clinic is unable to provide a medical at this time, and then arrange for a medical to be carried out in the future when there is availability. In practice this is likely to be weeks or possibly months.
ARCA has spoken to three of the major suppliers of consumables, and the picture with regards to coveralls is mixed. What is clear though is that these companies have been, and are still, only supplying existing customers. Some have been rationing the number of coveralls, others have emptied their stocks to their existing customers. Supplies are low particularly for coveralls, Sundstrom filters, and gloves. It is unclear when the next container loads of coveralls will arrive.
If members haven't already, look at ways to use your coveralls more economically. This can be done by using direct connection procedures, which should be used anyway when possible, or re using coveralls (re using within the same enclosure) when possible. Obviously if they become torn in any way they should be replaced with a new pair.
Also, if you don't have your usual colours of coveralls to distinguish between different types of work (e.g transiting, asbestos removal, general) you can use any colour combination as long as it is reflected in your plan of works and the overalls are type 5/6. If you only have one colour of coveralls you can differentiate them by putting a strip of tape on the back or sleeve.
HSE have confirmed that the old method of using nylon coveralls, which are then reused following laundering, is acceptable if a suitable laundry can be identified or established to launder the coveralls. ARCA has been advised by one supplier that hooded nylon coveralls with elasticated cuffs are not available. If hooded coveralls can be found then cuffs can be sealed by taping.
ARCA is trying to identify whether any such laundries still exist in the UK, if located details will of course be made available.
HSE have confirmed that the existing guidance on this is still applicable and it is available here.
If members can source suitable reusable coveralls, setting up your own laundering facility may be an option.
The asbestos licence renewal process will continue as normal. However, invitations to renew will be sent out 4 weeks earlier than previously, so now approximately 21 weeks in advance of the renewal date. This is to allow more time for submission. HSE will still be aiming to process the application in 10 weeks.
Many of the HSE ALU staff are working from home and licence renewal assessment is an activity that can be carried out remotely, so will continue as normal.
HSE are scaling down their admin teams in the HSE offices, with more staff working from home, so a paper copy of the licence will not be put in the post. An electronic copy will be sent by email which can be printed off. HSE Asbestos Licence holders will continue to be listed on the HSE website.
Applications for waivers will be considered in line with current guidance.
There would appear to be sufficient scope within the current guidance to allow the HSE to make the right judgement call as to whether a waiver is appropriate or not.
At the moment the guidance on face fit testing includes the cleaning regime to be used when cleaning and disinfecting the face-piece between uses. Until some assurance can be given that this method is suitable for removing risks associated with exposure to COVID-19 virus, which is essentially a new virus which we know little about, ARCA suggests that all should be wary of using a face piece which has been used by others recently, unless confident in the disinfecting process.
There is also a question of whether the act of conducting the face fit test infringes upon the social distancing which the Government is advising everyone to practice. ARCA has spoken to HSE about this and is awaiting HSE's opinion. Therefore, ARCA suggests avoiding carrying out face fit tests at the moment.
New NNLW / ASB 5 Notification System
Several issues with HSE's new ASB5 notification system have been reported to ARCA. All of these issues have been forwarded to the HSE and ARCA has been assured that HSE are working to fix the system.
Statement Issued by CSCS Regarding the Impact of COVID-19
CSCS has released a statement regarding the impact COVID-19 is likely to have on CSCS card applications. You can read the statement, and any further guidance issued by CSCS, at www.cscs.uk.com/covid19 . This process will also apply to CSCS card partner schemes such as the ARMI Skills Card.
Many of the ARCA staff are now working from home, with a skeleton team in the office each day which we rotate in two distinct groups who are isolated from each other. ARCA has sufficient IT connectivity and the ability to forward phone calls to remote locations to ensure we can continue to provide members with our services. Please do not hesitate to get in touch if ARCA staff can help in any way, on 01283 566467.
Update posted 20 March 2020
UK Government advice on COVID 19 is available here
NHS advice on COVID 19 is available here
General guidance on COVID 19 is available on the IOSH Website