ARCA responses to Unite's concerns regarding ALFA

The Asbestos Removal Contractors Association (ARCA) dismisses claims by Unite, the UK’s construction union, that an app which rates the performance of asbestos workers could potentially be used to blacklist and discriminate workers.

Following inaccurate information published by the Unite union in relation to the Asbestos Labour Feedback App (ALFA), launched by ARCA on 1st September, ARCA has today written to Ian Woodland, the Unite union’s National Officer for Construction, to explain to him the checks and balances built into the system to avoid the risks he claims are present.

The ALFA app is currently only utilised to rate and provide feedback on agency labour.  Agency workers are frequently used to carry out asbestos removal work and often the competency (knowledge, skills and behaviour) of these individuals is not entirely clear to the company hiring the agency labour.

During discussions with ARCA members, they identified the quality of agency labour as the biggest problem affecting their business. ALFA is designed to address this problem and give some reassurance to ARCA members that the labour they intend to hire is competent, has the required training and qualifications, have been medically examined, and have had the necessary RPE face fits carried out.

It is made crystal clear, in the Terms and Conditions of Use and the Privacy Statement, that the purpose of ALFA is to provide legitimate and proper feedback on an operative’s safety critical asbestos removal work.  It is also made clear that the App cannot be used for any unlawful purpose.

Unite say they believe that a fully qualified workforce can be best achieved through the licensing of labour providers and a fully comprehensive competency skills card scheme.  ACAD, who have also published negative comments regarding ALFA, have said that if we want quality operatives, we must invest in training them and we must invest in qualifying them.  However, what support and investment have Unite and ACAD provided to the agency labour to achieve this end?

One asbestos labour agency has commented ‘I think it’s fair to say that ALFA is the biggest step forward in terms of demonstrating – and improving where necessary – the quality, reliability and productivity of the site based workforce that both agencies and licensed contractors will have seen since HSE regrettably removed the licensing requirements for asbestos labour suppliers.’

As part of the ALFA project, and with ARCA working closely with the main agency labour suppliers in the industry, there is over £23,000 available this year to train agency labour.  At the reduced training rates ARCA is able to offer, this could represent 350 agency operatives who will not have to pay for their own training over the next 12 months.

So far 12 agencies, over 650 agency labour operatives, and 137 licensed asbestos removal contractors have registered to use ALFA.  Over 800 ratings have been submitted.  Over 50 operatives have had 5 or more ratings and have received an overall performance rating, and there have been no complaints, other than from Unite and ACAD.

It appears that the App is achieving exactly what was intended and the concerns raised by Unite and ACAD are completely unfounded.

Copy of the letter in full

Asbestos Labour Feedback App (ALFA)

Dear Mr Woodland,

Thank you for your letter of 2 September 2020.  It is disappointing that you did not wait for a reply before tweeting inaccurate information about ALFA.  ALFA’s model is commonly used to obtain real feedback from clients.  There are many checks and balances to avoid the risks that you have set out.  I will explain these in more detail.

There are detailed terms of use and a privacy policy which apply to all persons who have access to or may be the subject of ALFA.  I have attached copies of these documents. These documents:

1. Clearly set out what ALFA may or may not be used for.  It is made crystal clear that the purpose of it is to provide legitimate and proper feedback on an operative’s safety critical work, asbestos removal work.  It is also made clear that the App cannot be used for any unlawful purpose;

2. The App is transparent and accessible.  Operatives see the feedback about themselves.  The information displayed is feedback on essential and appropriate issues such as the use of PPE, decontamination, controlled stripping of asbestos materials and waste removal, it is a long way away from the “blacklisting” situations you refer to;

3. It is up to operatives whether or not they participate in ALFA.  It’s for them to volunteer to take part in it.  If they don’t volunteer, they do not appear on ALFA.  Your letter focuses on negatives, but we know operatives see the positives of their good work being reflected in feedback other potential clients can see;

4. Feedback is not based on a one-off assessment.  It is based on all assessments over a 12-month period, and there has to be a minimum of five, and information relating to an operative’s performance only goes on ALFA when we have those assessments;

5. As mentioned, ratings are based on completely appropriate and important categories such as use of PPE/PRE, controls, waste handling and decontamination;

6. Under the Terms of Use all parties providing information agree to provide true and accurate information and not to provide details other than their own;

7. Any operative can ask for the erasure or correction of his/her information if it is inaccurate.  There is a complaint procedure set out in the terms and conditions if he/she has any concerns about the accuracy of the information   It should also be noted that an operative can ask for their profile and therefore ratings to be deleted from the App at any time and for any reason

8. This is obviously an App to provide feedback on all operatives regardless of whether or not they are trade union members. No information about whether they are or aren’t trade union members is requested or kept on ALFA. I repeat that feedback’s only sought on the merits of a person’s work

We took careful steps to make sure that ALFA was:

1. Compliant with data protection laws;
2. Could not be used to “victimise or “blacklist” a person”;
3. Struck a fair balance in making sure that there were ratings on appropriate subjects not based on a single user’s feedback and which the operatives could all see quite freely and challenge if they wish to.

There is no basis for your suggestion that it could be used for victimisation or blacklisting.  The roll out of the App will not be suspended.  We ask you to take down your tweets which incorrectly raise concerns which do not exist for the reasons already given.  As we have said we are disappointed that you did not wait for our response before posting those tweets.

Yours sincerely

Jason Davy
Asbestos Removal Contractors Association