Competent Agency Labour in Asbestos Removal: The ALFA Approach for ARCA Members

Licensed Asbestos Removal Contractors (LARCs) are entrusted with the formidable responsibility of ensuring that asbestos removal work is carried out only by individuals who possess not just technical expertise, but also an understanding of how to put regulations into practice.

However, there remains a challenge – instances of poor performance by agency labour. This raises the question: how can ARCA members, committed to being exemplars in health and safety management, ensure that the agency labour they receive is truly competent? Enter ALFA – the Asbestos Labour Feedback App – an innovative solution that propels competency evaluation to new heights, empowering ARCA LARCs to make informed choices that safeguard both quality and safety. In this article, we examine how ARCA LARCs can wield ALFA's capabilities to champion competence and elevate industry standards.

In accordance with the Control of Asbestos Regulations 2012, LARCs are required to ensure that only competent employees engage in licensed asbestos removal work. Specifically, Regulation 18 (4) stipulates that every employer must ensure that only competent employees enter a respirator zone.

Instances of poor performance by agency labour have caused concern among ARCA LARCs. It appears that LARCs are at times supplied with agency labour that falls short of the required competence. The Approved Code of Practice defines a competent asbestos removal operative as one who has “received adequate information, instruction and training for the task being done and can demonstrate an adequate and up to-date understanding of the work, required control measures and appropriate law.  They must also have enough experience to apply this knowledge effectively.  Competence is developed over time by implementing and consolidating skills learnt during training, on-the-job learning, instruction, and assessment.”

However, there appears to be an undue emphasis on training certificates by LARCs to validate the competency of agency labour. HSE guidance is clear that a training certificate alone does not equate to job competence.

Given this, how can ARCA LARCs reasonably ensure that agency labour they receive is competent? HR professionals know that the best predictor of future behaviour is past behaviour or past performance in similar circumstances. If someone’s always done something a certain way, they are likely to do that same thing in the same manner in the future. The same is true for on-the-job performance of asbestos removal operatives.  ARCA LARCs have the advantage of being able to access past performance records through ALFA, allowing for a more confident prediction of whether the agency operative they've been allocated is, indeed, competent.

ARCA LARCs should request labour agencies to routinely supply them with ALFA performance records for each agency operative they utilise. These records offer a comprehensive analysis of an operative's performance over the past year, offering valuable insights into their likely future competence. ALFA aids ARCA LARCs in fulfilling their legal obligation of employing only competent individuals for asbestos work.  For a visual representation of a performance record, refer to the accompanying illustration.

Beyond ratings for performance criteria, the record also shows the operative's number of ratings over the last year, their assignment history, the range of LARCs they have worked for, the date of their most recent rating and their ALFA app registration date, indicators of experience and frequency of reengagement by the same ARCA LARC. Instances of agency operatives arriving late or departing assignments prematurely, a concern previously identified by ARCA LARCs, are captured under "Attendance" and "Final Rating" within the performance record. This functionality allows ARCA LARCs to identify patterns of lateness or early departure.

While some ARCA LARCs have inquired about the possibility of incorporating comments into the ALFA system, it appears unnecessary. The performance record should suffice in providing a comprehensive overview of past competency and behavioural performance, enabling fair judgments. Possibly the most revealing data resides under "Overall Impression," where ARCA LARCs rate whether they would rehire the operative. Consistently negative responses, combined with numerous criteria marked as needing improvement, strongly suggest the operative's lack of competence or suitability.

If you have any comments or suggestions to share, or seek information regarding ALFA's functionality, please don't hesitate to contact the ARCA office. We're here to discuss every aspect with you, ensuring that you make the most out of this invaluable tool. And remember, by actively requesting ALFA performance records from your labour agencies, you take a proactive step towards ensuring the competency of the agency labour you use.