HSE Emphasises Significant Role of External Audits in Licensing Process

Head of Asbestos Licensing Unit Highlights Value of Independent Performance Assessment

Adrian Hodkinson, Head of the HSE's Asbestos Licensing Unit, has discussed the important role of external audit schemes in the asbestos licensing assessment process, describing them as "incredibly useful" and "really, really useful" in providing HSE with additional information when making licensing decisions.

Speaking at ARCA's 40th Annual General Meeting on 3rd October 2025, Hodkinson provided detailed insights into how the HSE uses external audit data alongside its own inspection findings to build a more complete picture of contractor performance over the licence period.

"External audits are really, really useful for us," Hodkinson explained to the assembled audience. "We typically might visit a licensed contractor three times a year, so over the course of a three-year licence period, if you've got a three-year licence, we might see you nine times, sometimes more, sometimes less. Sometimes it's difficult to get to you because of where you're working, and we might only have a limited number of inspection visits to go from."

This limited direct contact means that external audits provide additional data points that help HSE form a more complete view of contractor performance over the licence period. The audits serve as an independent verification mechanism, either reinforcing HSE findings or providing valuable alternative perspectives.

Hodkinson described how external audits contribute to confident licensing decisions: "When we're seeing really good results at sites, the audits are showing really good results, it just helps us have a warm, fuzzy glow when we hand out that licence back to you to say, we've made a confident decision here that we're alright with this one."

The value of external audits extends beyond simply confirming good performance. Hodkinson explained that where HSE inspectors have limited information or have encountered poor compliance during their visits, external audits can provide important context. "Where we've got limited information, where we've had some poor inspection results, the external audits are really useful for us because they give a different perspective. We've only seen a snapshot. It might be that all the external audits are showing really good results, and that just helps us think, oh, actually, we've perhaps just landed on a couple of ones that aren't the norm and aren't necessarily representative of the way that people are managing their business."

This balanced approach demonstrates how the HSE uses multiple data sources to form fair and informed assessments of contractor capability and performance. The combination of direct HSE inspections and external audit results provides a more robust evidence base for licensing decisions than either source alone could provide.

However, Hodkinson emphasised that simply having external audits conducted is not sufficient. HSE expect to see that audit recommendations have been acted upon promptly. "I'd just like to say, though, that we like to see that they've been acted on in the same way that we expect inspection outcomes to be acted upon," he stated. "It's also good that you can ask the auditor to target particular things."

He encouraged contractors to use external audits intelligently, particularly where HSE inspections have identified specific problems or areas requiring attention. "If inspections have picked up certain problems or certain areas that need more attention, why not ask your audit provider to look at some of those issues as well in more depth when they're doing the audits. That will help you get some more information about whether any systems or improvements you've put in place are actually working."

Throughout his address, Hodkinson was careful to note that the HSE reviews external audits from various providers, not exclusively ARCA audits, though he acknowledged ARCA's strong representation amongst HSE-licensed contractors, with approximately 40% of the 362 licensed contractors being ARCA members. The format and consistency of external audits across different providers were noted as particularly valuable features that assist HSE in their work.

The HSE's emphasis on the value of external audits highlights the importance of robust audit methodologies. ARCA's Site Audit Accreditation Scheme is the only scheme that utilises completely unannounced audits, requiring four such audits per year rather than one. This approach provides a far more accurate indication of genuine day-to-day performance compared to announced audits, where contractors know the auditor is coming and can prepare accordingly. When audits are truly unannounced, they capture the reality of operations as they actually occur, not as they might be presented for inspection. ARCA is the only organisation in the sector that conducts completely unannounced audits and the only one that requires four of these annually, with satisfactory completion being a condition of retaining membership.

Hodkinson also provided guidance on improving licence applications, noting that HSE find external audit results particularly useful when they are well-documented and clearly show patterns of performance over time. The consistency and structure of audit reporting enables HSE to quickly understand a contractor's performance trajectory and response to previous findings.

Hodkinson's comments on external audits formed part of a broader update on HSE activities, including current inspection levels of approximately 800 licence inspections annually, notification requirements, common assessment findings, and upcoming policy changes.

The message to licensed asbestos removal contractors is clear: external audits are not simply a membership requirement or box-ticking exercise. They are a valuable tool that provides independent verification of performance, offers opportunities for continuous improvement, and plays a significant role in how the HSE assesses contractor competence and capability when making licensing decisions.

For contractors, the implications are equally clear. Engaging meaningfully with external audit schemes, acting promptly on recommendations, and using audits as opportunities to demonstrate continuous improvement can significantly strengthen licence applications and renewals. The "warm, fuzzy glow" that Hodkinson described when external audits confirm good performance is precisely the confidence that contractors should aim to inspire in HSE.

As the asbestos removal industry continues to evolve, with a focus on standards, competence, and continuous improvement, the role of external audits in demonstrating these qualities has never been more important. The HSE's explicit endorsement of their value provides strong incentive for contractors to engage fully with audit schemes and to view them not as burdens but as opportunities to demonstrate excellence and build confidence in their licensing applications.