Revised Analysts Guide will have a impact on Asbestos Removal Work
The revised guidance contained within the second edition of HSG 248 ‘Asbestos: The Analysts Guide’ (amended July 2021), which is due to be implemented from the 1st of February 2022,
will have an impact on the way analysts and licensed asbestos removal contractors (LARCs) cooperate to plan and complete licensed asbestos removal work.
LARCs should take note of the likely implications. Consultancies may start to implement this guidance from the 1st Of December, and as such you may start seeing; more failures (because of the reasons given below); additional audits; additional personnel turning up midway through a clearance to review stage 2, either during or at the start of stage 3. Should there be issues identified then works will stop until those issues have been dealt with. This may include additional cleaning and re-starting of the 4 Stage Clearance process.
LARCS should be aware that the HSE / UKAS have issued the following instructions:
- Analysts will formally fail* a CfR (Certificate for Reoccupation) if there is no handover form available at the commencement of the CfR process.
- Analysts will formally fail* a CfR if there is more than 10 minutes of additional cleaning required to bring the area to the required standard to pass stage 2 of the CfR; this is irrespective of the size of the area.
- Analysts are expressly forbidden from carrying out any cleaning, however minor.
The CfR requires more information to be recorded than previously. It also requires extensive photographic evidence to be included within the CfR, all of which will take additional time.
The biggest impact will probably be on “one day jobs”. Although the contractor may be ready for the CfR to commence at some point during the day, if there are any issues during the CfR which require additional work, then there will be little time available to complete the additional work and the CfR on the same day. ATaC are advising that LARCs to speak to their clients (predominantly housing associations) to allow these types of jobs to be carried out over 2 days in future.
There is a requirement for increased quality assurance checks of CfR stage two visual inspections. This will mean there will be more internal auditing carried out by laboratories of their analysts on site, and potentially more time will be required to do the clearance because of this.
LARCs should also be aware that that the requirements for planning and scoping of a CfR have also changed considerably. Planning the 4SC is seen as an integral part of the planning process of the asbestos removal project, and not just an afterthought. Planning and sharing of information will allow the analyst to assess the works and provide the LARC with a realistic time frame for the CfR to be completed. The LARC can then use this information in his own planning with regards to timescales and costs.
Finally, LARCs should be aware that HSG 248 contains additional guidance on Analyst impartiality, particularly where there are shared links between the contactor an analyst that could influence the analyst’s impartiality. It is strongly recommended that the analyst for site clearance certification is independently sourced and employed by the building owner or occupier (i.e., building client) in control of the premises.
None of the above should materially affect the duration of a properly-planned, correctly-documented, and well-presented asbestos removal project and enclosure. However, absence of any of the above could add significant delays to the CfR process.
*a formal “fail” of a stage of a CfR does not necessarily mean that an analyst will leave site. It will however be a formal record of failure to meet the required standard and will prolong the CfR further.