Asbestos Licensing

Minutes

THE ASBESTOS LIAISON GROUP FRIDAY 8 DECEMBER 2000 AT 10.30AM
FORTUNE ROOM, ROSE COURT, 2 SOUTHWARK BRIDGE, LONDON

0    Present
1    Introductions and welcome Stewart Campbell
2    Terms of reference Stewart Campbell
3    Asbestos licence requirements and scaffolders Jim Skilling
4    ASLIC and short duration work Jim Skilling
5    Loaning of employees Jim Skilling
6    Review of HSE guidance Tracey Boyle
7    Guidance to inspectors for licence assessment visits/meetings June Cairns
8    ALU action following site visits Jim Skilling
9    Clearance visual inspections and accountability of laboratories Terry Jago
10   Prohibition Notices - criteria for successfully appealing Bill McKay
11   Update on Duty to Manage Asbestos in Buildings Bill Macdonald/Tracy Phillips
12   Asbestos worker risk perception project Bill Macdonald/Tracy Phillips
13   Dry Stripping Martin Gibson
14   Air line fed RPE Martin Gibson
15   Site documentation Jim Skilling
16   Asbestos Worker Protection Directive
17   Any other business
18   Date, Time, Location of Next Meeting

Present

HSE	TAs/TUs
Stewart Campbell, Chair, Health Unit, FOD	Terry Jago, ARCA
Jim Skilling, ALU	Grant Beglan, ARCA
June Cairns, ALU	David Hayes, ACAD
Martin Gibson, Scotland Specialist Group	Mike Wilkes, ACAD
Bill McKay, FOD Operations	Tony Tynan, NFDC
Tracey Boyle, TD3	Nigel Bryson, GMB
Bill Macdonald, HDC	Sara Marsden, TGWU
Tracy Phillips, HDC

Introduction and welcome

1.1 Mr Campbell welcomed everyone to the first meeting of the Asbestos Liaison Group (ALG). Apologies were tendered on behalf of Neil Moore, GMB and Peter Dolan, ARCA, for whom Grant Beglan deputised. It was noted that Mr Macdonald would join the meeting later.

Terms of reference

2.1 Mr Campbell referred to ALG's draft Terms of Reference, which had been circulated previously for comment. He drew attention to the drafting notes on the latest version, which stated that the Group would primarily deal with asbestos licensing issues and invited members to comment.

2.2 TA/TU members agreed that it was acceptable for the main focus of the Group to be directed towards licensing issues, so long as this extended to include interpretation of the relevant ACoPs and allowed some scope for discussion on wider asbestos issues, if the need arose. Mr Jago and Mr Wilkes commented that they felt that the membership of ALG should also include a laboratory representative, especially since HSE no longer sat on their Technical Committees, which they regarded as a loss. Mr Bryson remarked that the TUs would be developing more expertise on technical issues so that they too could have more involvement in the development of technical standards. The TA members also felt that the meetings should take place at quarterly intervals, rather than every 6 months.

2.3 Mr Skilling said that HSE had not made a conscious decision to stop attending Technical Committees. He explained that due to internal staff changes, the nominated HSE representatives had lacked sufficient expertise to effectively contribute. He had also got the impression that in the past, HSE representatives on Technical Committees had at times been drawn into policy issues on which they were not qualified to give a decision - he saw discussion of policy issues being more appropriate for ALG.

2.4 ARCA/ACAD would consider the structure and alignment of Technical Committee meetings to encourage HSE involvement in them.
Action: ARCA/ACAD

2.5 It was agreed that the Terms of Reference would be amended to incorporate the drafting points and be reissued to members. HSE would reconsider the frequency of the meetings issue.
Action: Ms Cairns

2.6 It was agreed that a laboratory representative could attend future meetings as requested.
Action: ARCA/ACAD

Asbestos licence requirements and scaffolders

3.1 Mr Skilling referred to the memo issued at the meeting (now ALG Memo 1/01 January 2001 - appended to the minutes) which was an attempt by him to confirm HSE's line on scaffolding, following queries raised by ACAD earlier this year. He explained that previously several scaffolding companies had held asbestos licences to enable them to undertake ancillary work with asbestos, but as HSE hadn't pursued this as effectively as they might have, many scaffolders had let their licence lapse. The issue came to the fore recently when a Prohibition Notice was served on a scaffolding company, which was working without a licence on a major asbestos removal contract.

3.2 Mr Skilling added that he had consulted within HSE before issuing the note, which had also gone to Asbestos Licensing Principal Inspectors (ALPIs) and confirmed that this was now HSE's line on the matter. Mr McKay confirmed that the note merely reinforced guidance that had been produced some while back by the National Association of Scaffolding Contractors (now National Access and Scaffolding Confederation).

3.3 Mr Wilkes asked whether licences issued to scaffolding companies would be restricted to ancillary work with scaffolding or whether the contractor would be allowed to remove asbestos as well. Mr Skilling responded that such licence holders would not be allowed to remove asbestos. Their licence contained a 4th condition limiting the work to erecting, altering, maintaining or dismantling scaffolding. He added that there were a number of companies that held a full licence, who employed their own scaffolders, who were medicalled, face fit tested, trained etc. In such cases these companies could undertake asbestos removal as well as scaffolding work. He reiterated that if the company were only doing scaffolding, then their licence would include a 4th condition as previously mentioned.

3.4 In response to Mr Jago's request as to whether ALU's list of current asbestos licensed contractors could be broken down into licence categories eg full licences; project management licences; scaffolding licences etc, Mr Skilling replied that this wasn't available at present but could be looked into.

3.5 Mr Jago asked against whom HSE would take action in the event of the scaffolding contractor not being licensed. Mr McKay explained that in the recent case he'd been involved in, HSE had taken issue with the asbestos licensed contractor, the scaffolding contractor, the principal contractor and the client.

3.6 Mr Wilkes mentioned that already scaffolding companies were asking questions about appropriate PPE and RPE and about whether they must decontaminate tubes and boards. He asked what guidance ALU would provide on this and whether the licence requirement would apply to other trades such as riggers or mechanical engineers. Mr Skilling replied that as far as other trades were concerned, if the work was ancillary to work with asbestos, then they would need a licence, if it was foreseeable that they might disturb asbestos or if they were erecting enclosures. Regarding guidance to scaffolders, Dr Gibson stated that if it was foreseeable that asbestos could be damaged, then before work commenced, the contractor must have an action plan in place to deal with it. Mr Skilling added that the risk assessment would need to take into account the possibility of asbestos disturbance and the subsequent method statement would also need to include emergency procedures in the event of asbestos being disturbed. The emergency procedures should cover identifying the extent of contamination and carrying out the decontamination.

3.7 Mr Beglan thought that this would have a big impact on the industry and asked whether further guidance would be provided. Mr Skilling said that his note only spelt out what the law said and that it was unlikely that he would be arranging for ALU to provide further guidance at present.

3.8 Mr Skilling raised the issue of communicating this information to those concerned and intended to write out to each licensed contractor explaining the position. Mr Wilkes said that the TAs would get involved in disseminating the information to their members. Mr Skilling would also liaise with the National Access and Scaffolding Confederation.
Action: ALU/TAs

ASLIC and short duration work

4.1 Mr Skilling issued a memo to the meeting (now ALG Memo 2/01 January 2001 — appended to the minutes) and explained that this subject had arisen as a result of the forthcoming HSE Asbestos Essentials Task Guide due to be published soon, which was aimed at those involved in maintenance work, much of which could be done without a licence, as per the exemptions in Regulation 3 of ASLIC. As the definition of short duration work wasn't very clear in ACoP L11, Mr Skilling had attempted to clarify the position in his note.

4.2 He confirmed that in due course ALU would be amending the licence condition on notification to confirm that there would be no requirement to notify the Enforcing Authority of short duration work. He pointed out that contractors who undertook short duration work, needed to have procedures in place to ensure the threshold limits were not exceeded and reiterated the point that the time calculation started as soon as work commenced on erecting an enclosure and that dismantling, cleaning up, disposal to a skip etc were all included in the overall time calculation.

4.3 Mr Jago commented that the memo should include a statement to the effect that CAWR still applied, to which Mr Skilling agreed. The memo would also be amended to mention the fact that clearance air monitoring might not be required (Asbestos Essentials Task Guides did not refer to air monitoring because only minor work would be undertaken and tests had shown results to be below detection level) where only small enclosures had been erected. However, it would be prudent to do so particularly in sensitive situations.

4.4 Mr Skilling agreed to amend the memo and confirmed that the intention was to send it to all licensed contractors.
Action: ALU

Loaning of employees

5.1 Mr Skilling provided an update on the legal position regarding an unlicensed company which provided skilled, competent, trained, face fitted, medicalled etc operatives to licensed contractors, on demand, to supplement the latters' labour force. The operatives were employees of the unlicensed company and were paid by them, irrespective of whether they were "hired out" or not. The problem was that under Regulation 3 of ASLIC, the unlicensed company (viz the "employer") was required to hold a licence. The company did not want a licence as they had no intention of competing with licensed contractors for work - they merely wanted to set themselves up as an agency, employing skilled etc staff and supplying them to the industry as required.

5.2 HSE's Solicitor's initial reaction was that the company required a licence. However, in discussion with ALPIs, ALU had established that there was a view that there was merit in such a system and that a licence might not be necessary. At present the legal framework wasn't flexible enough to deal with this situation and since first commenting, the line from HSE Solicitors had become more fluid. ALPI opinion was mixed and it was important to get a clear and consistent line.

5.3 Mr Tynan commented that a good test would be to establish, via HSE Solicitors, which company would be liable in the event of a future ill health claim from an operative. Mr Jago judged that the operative would be covered by the "receiving" company's insurance (ie the company that had taken on the "agency" worker) and this company would be liable in the event of any future claims. He added that the company Mr Skilling had referred to had been set up to a very high standard but appreciated that this might not be the case with other companies who might also wish to go down this road. Mr Bryson expressed concern about the various permutations of employment within the industry ie self employment; subcontracting; loaning of employees; agency arrangements etc and felt that the further away the direct employer/employee links were, then the more difficult the relationship became.

5.4 Mr Skilling undertook to pursue the issue and get back to ALG once it had been resolved.
Action: ALU

Review of HSE asbestos guidance

6.1 Mrs Boyle explained that a Working Group had been set up to review and update HSE's guidance on asbestos. She handed out a document which summarised the position and detailed the proposed strategy and sought comments on the proposals. The Working Group were particularly keen to receive feedback on the presentational proposals and on whether the 4 target groups identified were appropriate (ie licensed contractors; construction/ maintenance trades doing unlicensed work; building managers/architects/surveyors; and technical professionals /consultancies/ laboratories). The review was expected to last for 18 months to 2 years.

6.2 Mr Bryson commented that one target group that were often overlooked were the workforce and the Trades Unions who represented these workers. He would like to see these and safety representatives included in the strategy as target groups.

6.3 Mr Wilkes welcomed the opportunity to comment but pointed out the importance of having sufficient time to do so as there had been previous occasions when HSE had provided insufficient time for TAs to consult their members properly. Mr Jago added that it might be useful for TAs to offer suggestions about prioritising the order in which the guidance might be reviewed.

6.4 Mr Campbell confirmed that the Working Group was internal to HSE but would consider with HSE colleagues how best to feed in industry views. In the meantime, members were asked to provide Mrs Boyle with comments on the strategy document by 31 January 2001. Further opportunities would be provided to comment on the detail of future revisions to the guidance, although it was noted that there was no intention to amend ACoPs.
Action: TAs/TUs

Guidance to Inspectors for licence assessment visits/meetings

7.1 Ms Cairns informed the meeting of the ALU project to produce an Asbestos Licence Assessment Guide for ALPIs and nominated asbestos inspectors involved in assessing applicants for new and renewal licences. She explained that the aim of the guide was to enable more effective and consistent assessment of applicants for a licence. She said that ALU had recognised the need to produce the guide because existing instructions were out of date and inconsistencies had emerged. Where possible, the guide tried to harness existing good practice.

7.2 Mr Skilling confirmed that the draft was an internal HSE document at this stage and it was hoped to be available by April 2001. However, as the final version was required to be cleared by Field Operations Directorate HQ, the end date might end up being a little later than this.

ALU action following site visits

8.1 Mr Skilling circulated a copy of the ASB6, Enforcing Authority Report form, which was completed by enforcing authority inspectors following their site visits to notified asbestos work. He explained that when these forms were received in ALU, the information from them was input to the ALU database with statistics produced thereafter. A copy of the statistical outturn covering the period April - October 2000 was also circulated to members.

8.2 Mr Skilling referred to item 6 on the ASB6 and explained that if it indicated that an enforcement Notice had been issued or a prosecution was proposed, then he would issue a warning letter to the contractor. Warning letters were also issued if the contractor had received 3 letters on the same subject (ie the categories at section 7 of the ASB6) within 2 years. He added that receipt of a warning letter placed a licence holder into ALU's "priority visit contractor" (pvc) category and as a result they were liable to receive proportionately more visits from inspectors. Licence holders whose licence number began with a 1 (ie previously held a 3 year licence and had it reduced to 1 year) were also classed as "PVCs". Contractors who fell into this category would remain there for 1 year, unless they failed to make sufficient improvement.

8.3 Mr Skilling added that future warning letters would be amended to explain to the contractor that they were liable to receive proportionately more visits from HSE.

8.4 Referring to the statistical summary, Mr Skilling drew attention to the high number of "improvements required on site" recorded as "other" and hoped to replace some of the less frequent categories, eg laboratories not accredited, with other, more relevant topics. Mr Bryson suggested that "consultation with the workforce" might be a contender to replace some less relevant topics and Mr Skilling agreed to consider this.
Action: ALU

Clearance visual inspections and accountability of laboratories

9.1 Mr Jago referred to the letter Mr Skilling had written to ACAD in July 2000 about this matter and said that the Trade Associations were still concerned about the interpretation of paragraph 76 of ACoP L28.

9.2 Dr Gibson explained that whilst each situation would be unique, contractors needed to follow the same procedure viz contractor would (a) examine the nature of the work area; (b) ensure that the area where the work was to be carried out was clean - if not would identify the debris present and arrange for a pre clean; (c) complete the work assessment; (d) draw up the plan of work; (e) enclose the area; (f) undertake the actual work; (g) visually examine the areas where it was reasonably foreseeable that contamination could occur eg transiting routes, waste transfer routes, around skips, the immediate area outside the enclosure, especially corners; and (h) clean up those areas. The contractor needed to record what had been identified and where and the areas that had been visually inspected. Analysts needed to do the same. Mr Tynan added that the contractor should draw a map of the work area which would clearly show which areas were within the responsibility of the contractor.

9.3 Mr Skilling added that the contractor needed to clarify that the action they had taken was relevant to the contract and the analyst should record which areas they had cleared. Problems only arose later when asbestos was found in areas that had allegedly been cleared.

9.4 Mr Wilkes asked what action HSE would take if a contractor did all of the above, but materials were found outside of the "immediate surrounding area" . Mr Skilling replied that if the contractor could demonstrate that they had done a thorough assessment in advance, then it would be unlikely that HSE would take action. Mr Campbell pointed out however, that in the event that the initial assessment was wrong, then it might be foreseeable that action from HSE would ensue.

9.5 Mr Jago referred to the case of an individual analyst, (rather than the company), who was prosecuted, as the company could prove that he had been trained etc and had contravened company procedures. He wondered whether this represented a change in HSE's enforcement policy to prosecute individuals rather than companies. Whilst he supported third parties being held responsible, he was concerned about individuals being held accountable.

9.6 Mr Campbell confirmed that there had been no change to HSE's enforcement policy and that it was always possible that individuals could be prosecuted. For example, there was a recent case of an analyst and a foreman in Wales, both of whom had been prosecuted as individuals, rather than their companies.

9.7 Mr Jago mentioned that the costs of air monitoring work was rising because laboratories viewed the work as problematic - they seemed to be gearing up for the work that would be generated through surveys and the new Regulation 4 under CAWR, which would be lucrative. Mr Campbell pointed out that analysts would be just as accountable for any work they undertook in relation to survey activities.

9.8 Mr Wilkes, supported by Mr Jago and Mr Beglan, felt that there should be a mechanism whereby the client employed the laboratory - not the contractor. Even though contractors chose to use several laboratories, HSE inspectors had at times questioned the relationship between the contractor and the laboratory. If the client employed the laboratory, they argued, it would remove any assertions of unethical practice. Mr Campbell noted the point and although there were several counter arguments, he felt that the issue might benefit from a more structured discussion at a future meeting.

Prohibition Notices (PNs) - criteria for successfully appealing

10.1 Mr McKay explained that over the last year he had been involved in 3 appeals against PNs issued by his staff, who were it must be said experienced, highly trained and competent. This had cost a great deal of money on legal costs and staff time. One appeal went to tribunal and was rejected and the other two were withdrawn. Whilst he understood the commercial implications of companies receiving PNs, he stressed that they should not be viewed as a punishment - they were issued in order to deal with a risk of serious personal injury.

10.2 He continued that if a contractor had a grievance and wished to appeal against receipt of a PN, then two important criteria needed to be satisfied for the appeal to be successful viz:- (a) the inspector has not made reasonable enquiries and/or (b) the inspector's decision is perverse. The inspector didn't have to be correct - his/her judgement needed to be shown to be perverse for the appeal to be successful. He stressed that if a contractor had a grievance over a PN, (ie that the inspector had not made reasonable enquiries and/or the decision to issue a PN had been perverse), it was imperative that they contact the inspector's line manager as soon as possible. If the inspector had indeed behaved incorrectly, then the line manager could deal with the PN accordingly - in agreement of course with the recipient without the need to go to appeal.

10.3 Mr Jago mentioned that last year there seemed to be a lot of PNs issued throughout the industry. He was unclear about alternatives to issuing PNs eg deferred PNs and Improvement Notices (INs) and asked what scope there might to consider this.

10.4 Mr Campbell explained that there was a variety of options open to inspectors ranging from giving advice — either verbal or written — to issuing Notices. As far as INs were concerned, these were issued where the law had been breached and improvements needed to be put in place eg for management issues, inspection records (eg RPE) etc. A PN was issued where there was imminent risk of serious personal injury - the risk didn't have to be there at the time - it could arise in the future eg if there was evidence of poor supervision. A deferred PN was issued when some other action had to take place first to make the situation safe eg the time taken to close down a complex industrial process. A deferred PN was never used to condone the continuance of a dangerous situation. In his view if deferred PNs had been issued in connection with asbestos operations, then this had probably been incorrect. Deferred PNs were not the way forward. Mr Bryson added that from his perspective, it appeared that inspectors did everything they could before they resorted to issuing Notices.

10.5 To summarise, Mr Campbell reiterated that HSE viewed Notices very seriously and hoped the industry would too. He reminded the meeting of the points made by Mr McKay and the need for contractors to talk to the Principal Inspector if they had a grievance.

Duty to manage asbestos in buildings

11.1 Mrs Phillips provided an update on the emerging outcomes of the consultation process on the above, which ended on 20 October. She explained that from the 3,000 Consultative Documents sent out, 140 responses had been received, with the Web Site having registered 3,000 hits. 96% of respondents supported the general approach advocated and 3 key issues had emerged:- (a) duty holder - view was that the current duty holder (employer) wouldn't adequately address the landlord/tenant relationship; some thought the responsibility should rest with the building owner; others thought it should be a joint responsibility between the owner and occupier; legal advice was currently being sought; (b) presumptive survey - some consultees felt that the term "visual examination" implied that it wouldn't be thorough enough; some felt that full surveys would be necessary; and (c) lead in period - comments ranged from immediately to 10 years! The majority view was that a 2/3 year period would suffice but there was concern that there were insufficient competent surveyors available to do the work.

11.2 She added that the next steps were to:- take legal advice; depending on the outcome, consult (either on a limited basis or if there was to be a significant change to the duty holder arrangements undertake wholesale reconsultation); put the proposals to the Health and Safety Commission; and then introduce, with effect from, May 2001 (although this might slip in the event of a General Election and/or if re-consultation was required).

11.3 Mr Macdonald spoke about the need for there to be a cadre of qualified surveyors able to undertake the work. Two separate avenues were being explored - one was an accreditation scheme through UKAS for organisations, who would employ surveyors. A pilot was in progress involving 40 companies and the outcome would be known in a few months. The other was by certification of individuals - RICS and BIOH were involved in developing this. As it would take time to develop standards, agree bench marking, train people etc it was understandable that the regulations wouldn't take effect for 18 months. The TAs and TUs supported the second scheme viz the certification of individuals rather than certification of organisations.

11.4 Mr Wilkes made the point that in some instances, where insulation contractors had held maintenance contracts on certain sites for many years, their site personnel might well know more about the infrastructure of the plant and buildings than the client. In these circumstances these individuals would be better placed to carry out the first stage of the survey, although not the analysis, than a trained accredited surveyor. However, they might not have the academic ability to become accredited.

11.5 Mr Macdonald also mentioned that there was a suggestion to extend the duty to "social housing" and this was being considered by solicitors. Mr Bryson raised the issue of costs and wondered whether there could be any official help with funding the costs of surveys. Eg could there be a national scheme? It seemed unfair that many people would be left to tackle the problem of asbestos in buildings which they had inherited and had been none of their making. Mr Macdonald accepted that a full, proper, intrusive survey would be expensive, although a presumptive one would be cheap. He had not been presented with this particular point before and was not convinced that this would be regarded as a priority for spending public money, but agreed to raise the issue where appropriate.
Action: HDC

Asbestos worker risk perception project

12.1 Mrs Phillips outlined the above project which was being undertaken by the Health and Safety Laboratory (HSL), the aim of which was to find out what makes asbestos removal operatives work in the way they do. Confidential face to face interviews would be conducted with workers in a cross section of companies in the Sheffield, Essex and London areas early in the New Year. The report would be available 2/3 months later.

12.2 In response to the disquiet expressed by Mr Jago about the low numbers of workers (25 operatives; 10 supervisors) to be interviewed, Mr Macdonald explained that this was due to the high costs involved in using a psychologist to undertake the interviews. Depending on the findings, consideration might be given later to increasing the sample. Mr Bryson requested that safety representatives be included as interviewees. This would be discussed outside the meeting with Mr Macdonald.
Action: HDC

Dry stripping

13.1 Dr Gibson said that although dry stripping was less prevalent than it had been, there was an issue about the quality of the wetting equipment being used and its application. For example, the wetting might not be as thorough as it should be resulting in patchy areas of dryness. Inspectors were now looking more closely at this issue - asking contractors how long it took to wet the material; what quantities of wetting agent had been applied etc. There were ways of checking on moisture levels which contractors should be doing before starting to strip asbestos.

13.2 Mr Beglan commented that this should be simple to achieve by using a moisture meter to check dampness levels and suggested that HSE include this information in forthcoming correspondence to licensed contractors. Mr Skilling thanked him for this suggestion which he would take on board.
Action: ALU

Air line fed RPE

14.1 Dr Gibson was interested in any information that TAs/TUs could provide on companies that used air line fed RPE. He was aware that there were more calls for its use. He stated that HSE made reference to it in its guidance and therefore it was an option to be considered. However, it should be noted that there was a range of air line fed equipment and some only provided the same level of protection as currently used powered full face piece respirators. Air line fed RPE was frequently used in some European countries.
Action: TAs

14.2 Mr Wilkes said that in his company it was used in special circumstances such as wet blasting where they had used a protector sabre system and he would send Dr Gibson the details. He found that air line fed equipment brought with it a different set of problems - ultimately RPE was the last resort. Dr Gibson echoed this, which was HSE's view too - the priority was to reduce exposure to the lowest level reasonably practical before resorting to RPE.

14.3 Mr Bryson was pleased that this was being considered. He said that although he acknowledged that there could be some technical difficulties and that in certain circumstances it might be inappropriate, it was the view of his TU that, coupled with maximum dust suppression, air line fed RPE gave the best protection to workers and he wanted to see it used much more.

Site documentation

15.1 Mr Skilling referred to the memo issued at the meeting (now ALG Memo 3/01 January 2001 - appended to the minutes) in which he had outlined the documentation that inspectors would expect to see on site, as a minimum. ALPIs had endorsed this list. The intention was to copy this information to all licence contractors.
Action: ALU

15.2 Mr Jago asked whether originals of medical surveillance certificates were required to be held on site. Mr Skilling acknowledged the difficulty of doing this given the transient nature of the workforce. However, given that the system was open to forgery, he advised that wherever possible the original documents should be held on site. Mr Bryson added that the TUs preferred this too.

Asbestos Worker Protection Directive

16.1 A written update on this would be issued to members once it had been checked with the author that it was suitable for issue outwith HSE.

(*Post meeting note - Please note that the memo (appended to the minutes) can be circulated outside HSE, although members should note that as the situation is a developing one, things could change).

Any other business

17.1 Mr Bryson agreed to write to ALU initially about possible problems over inappropriate protection for workers using asbestos substitute materials.
Action: Mr Bryson

17.2 Mr Campbell confirmed that the draft minutes of the meeting would be circulated for comment and clearance by members and that they would be regarded as open.
Action: ALU

Date,Time, Location of next meeting

Mr Campbell confirmed that the next meeting would take place on Thursday 22 March 2001, venue to be decided.

(*Post meeting note - please note that the next meeting, which will start at 10.30, will be held in the HSE office, Edinburgh)
Action: ALU