Asbestos Licensing

Minutes

THE ASBESTOS LIAISON GROUP THURSDAY 22 MARCH 2001 AT 10.30AM
CONFERENCE ROOM, BELFORD HOUSE, EDINBURGH

0    Present
1    Introductions, apologies and welcome Stewart Campbell
2    Minutes of last meeting (8.12.2000) Stewart Campbell
3    Matters arising from the minutes Stewart Campbell to lead
4    HSE Information Document 282/28 Fit Testing of RPE Terry Jago
5    Clearance sampling (including visual inspection by analysts and clearance   
      arrangements when intact ACMs remain in the enclosure)     Jim Skilling / David Hayes
                                                                                              Terry Jago / Martin Gibson
6    EH51 - Enclosures (possible changes including 'double skinning') David Hayes / Tracey Boyle
7    Update on amendments to CAWR Bill Macdonald / Tracy Phillips
8    Update on Asbestos Worker Protection Directive Tracy Phillips
9    Laundering of asbestos contaminated towels Jim Skilling / June Cairns
10   Method statement aide memoire June Cairns
11   Any other relevant business
12   Date, Time, Location of Next Meeting

Present

HSE	TAs/TUs
Stewart Campbell, Chair, Health Unit, FOD	Terry Jago, ARCA
Jim Skilling, ALU	Peter Dolan, ARCA
June Cairns, ALU	Rob Blackburn, ARCA (ATaC)
Martin Gibson, Scotland Specialist Group	David Hayes, ACAD
Bill McKay, FOD Operations	Mike Wilkes, ACAD
Tracey Boyle, TD3	Jean Prentice, ACAD
Bill Macdonald, HDC	Nigel Bryson, GMB
Tracy Phillips, HDC

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Introduction, apologies and welcome

1.1 Mr Campbell welcomed everyone to the meeting and introduced Ms Prentice and Mr Blackburn, who were attending as laboratory representatives on behalf of ACAD and ARCA respectively. He tendered apologies for absence on behalf of Mr Moore, GMB, Ms Marsden, TGWU, Mr Tynan, NFDC and Dr Hermanns, HSE.

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Minutes of the meeting held on 8.12.00

2.1 The minutes of the previous meeting were agreed. Mr Campbell confirmed that in future any papers generated from the meeting (eg ALG Memos, attachments etc) yet to be finalised would clearly state if they were in draft form, that the intention was for the minutes etc to be "open" and that it would be made clear to members if this was not the case.

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Matters Arising

3.1 (2.4) TA members reported that in principle it would be possible to amalgamate the ARCA and ACAD technical committees, (currently held monthly and every two months respectively) if this would encourage HSE to renew its representation. It was agreed that the TAs would put forward a proposal for HSE to consider. Mr Campbell cautioned that if the TAs hoped for HSE to attend meetings on a monthly basis then this might prove difficult, given HSE's current resource constraints.
Action: Mr Hayes/Mr Jago

3.2 (2.5) Terms of reference for the Group had been amended and issued.
Item discharged

3.3 (2.6) Laboratory representatives had been invited to attend meetings as requested.
Item discharged

3.4 (3.8) Mr Skilling had written to the National Access and Scaffolding Confederation (NASC) and to all asbestos licensed contractors with the scaffolding information contained in ALG Memo 1/01.
Item discharged

3.5 It was acknowledged by the meeting that this important issue was a developing one and a wide ranging discussion ensued about the difficulties that were emerging as a result. The TAs were supportive of the initiative but were concerned about the actual mechanics of making the system work, given that there were insufficient licensed scaffolders to meet the demand as well as problems experienced by the industry in interpreting the contents of ALG Memo 1/01. For example, Mr Wilkes said that the first clause in the ALG memo (" which will form the framework from which an enclosure will be built for the purpose of working with asbestos") was not causing too much of a problem but that the second one ("to provide access for work where it is foreseeable that asbestos is likely to be disturbed") was not clear cut and in his view needed to be more prescriptive. Mr Jago added that whilst he accepted the need for scaffolders to be licensed if it was likely that asbestos might be disturbed, he questioned whether it was really necessary when scaffolding had been erected to give access/form an enclosure where there was no likelihood of disturbance.

3.6 Mr Wilkes explained that his company were members of NASC and in liaison with the Construction Confederation's (which supports NASC on health and safety matters) Director of Health and Safety (Suzannah Thursfield), had discussed various issues in relation to licensed scaffolders. To carry these forward, he requested that a meeting between ALU and NASC take place, but before then sought clarification on a number of points, which he would write to Mr Skilling about. In addition, he thought it would also be helpful to put to ALU a number of case studies for consideration. Mr Jago added that ARCA would also provide case studies for ALU to consider and would also like to attend the meeting.
Action: Mr Wilkes/Mr Jago

3.7 Mr Skilling acknowledged the current difficulties and had no objections in principle to the meeting proposed by Mr Wilkes and would respond to his forthcoming letter. Case studies would be welcomed and would be circulated amongst ALPIs to achieve a consistent view, before responding to the TAs. In the meantime, Mr Skilling was able to confirm that:

(a) the licence fee was the same for a scaffolding contractor (ie £515);
(b) no licence was required for ancillary work with asbestos cement;
(c) a separate scaffolding licence was not required for companies holding a full licence, who also employed scaffolders, (as part of the same company); neither was an additional condition required on their licence;
(d) a separate licence would be required if the scaffolding division was a separate legal entity (ie different Companies House registration number);
(e) 26 licence application packs had been sent by ALU to scaffolding companies.

Action: Mr Skilling

3.8 Mr Wilkes added that there was also a problem with the separate notification requirement for scaffolders, under the licensing conditions, as in most cases they wouldn't be appointed by the licensed removal contractor until the latter had got the job. As such, they would be unable to comply with the 14 day notification period, which in turn would generate waiver requests to HSE. Mr Skilling appreciated the difficulties this might present to scaffolders and would liaise with ALPIs to consider whether it might be possible to develop a flexible approach.
Action: Mr Skilling

3.9 Mr Skilling pointed out that it was not possible to extract an accurate list of licensed scaffolding contractors from ALU's database. For those companies purely involved in scaffolding ancillary work, a 4th condition was added to their licence and details of contractors falling into this category were available. However there were a number of companies with full removal licences who employed their own in house scaffolders who didn't have a 4th condition, so there was no means of identifying them as having asbestos scaffolding expertise. So, although a list of licensed scaffolding contractors could be provided, it would not be comprehensive. He acknowledged the supply shortage and sought the most reasonable way of getting through this interim period until sufficient licensed scaffolding contractors were available. Eg he hoped that where unlicensed scaffolders were encountered, they would at least have applied for a licence, thereby showing their intent; that they would have taken steps to organise training, RPE face fits etc and that more supervision of scaffolders would be provided by the licensed contractor to ensure the asbestos was not disturbed.

3.10 In response to Mr Dolan's query, he was advised that it was not the responsibility of the licensed contractor tendering for a removal job, to ascertain if already erected scaffolding had been installed by a licensed scaffolding contractor.

3.11 (4.4) Mr Skilling reported that the memo on short duration work had been slightly amended then issued as ALG Memo 2/01 and the contents incorporated into the flyer that was sent to all asbestos licensed contractors in February. In response to Mr Blackburn's query about why air monitoring would not be required, he explained that this was because the work was mainly maintenance related, and when HSL had monitored a variety of such jobs to feed into the Asbestos Essentials work, they had shown that by using LEV, cowl etc controls, the jobs could be done with little exposure. By "enclosure", what was meant was not the usual type of enclosure, thereby suggesting contamination, but a polythene tent arrangement, unsealed, without a smoke test etc in keeping with Asbestos Essentials tasks.
Item discharged

3.12 (5.1) Mr Skilling reported that the contents of ALG Memo 3/01 on site documentation had been incorporated into the flyer that was sent to all asbestos licensed contractors in February.
Item discharged

3.13 Mr Jago and Mr Dolan expressed concern about the requirement to have top copies of medicals and face fit certificates on site because of the practical difficulties involved, especially for employees working on multi site jobs. They thought it would be more practical to have copies held on site for the inspector's perusal, with the originals to follow within 7 days, for the inspector to examine. Mr Bryson mentioned the introduction of a Smart card system, although he acknowledged that this would not provide an immediate solution.

3.14 Mr Skilling empathised but reminded everyone that the problem of forgery still existed. He would discuss the issue with ALPIs in an attempt to find the best way forward. Mr Campbell took the opportunity to remind the meeting that if members had particular concerns it would be helpful to table proposals (in advance) to the meeting.
Action: Mr Skilling

3.15 (6.4) Mr Skilling reported that following further consultation with ALPIs on the issue of loaning of employees, he had put further proposals to HSE's Solicitors and was awaiting their response. The issue was still ongoing and he hoped to have it resolved by the next meeting.
Action: Mr Skilling

3.16 (7.4) Mrs Boyle thanked members for their responses and mentioned that for licensed contractors, the Working Group would produce 2 documents - one which would contain the regulations, ACoPs, and licensing guide and the other which would contain all relevant guidance. The WG had not considered how best to involve industry colleagues other than to seek their comments as revised draft documents were produced. Mrs Boyle noted the request of the TAs and GMB that they have adequate time to comment fully and that Safety Representatives be involved. In some cases the revisions to guidance would have to await the outcome of research (eg DCUs and modular units). The outline timetable for revision was 12 months. Mrs Phillips added that due to delays to CAWR, there would now be time to review the guidance contained in the two current CAWR ACoPs.
Item discharged

3.17 (9.4) Mr Skilling reported that changes to the categories for improvement contained in the Enforcing Authority Report form (ASB6) were still being considered (including Mr Bryson's suggestion "consultation with the workforce") and he would report back on this once more progress had been made. He reminded members that the new Asbestos Notification System would be introduced shortly and that in future contractors in receipt of an ALU warning letter (ie "priority visit contractors") would be informed that they were liable to receive proportionately more visits from inspectors. In response to Mr Bryson's query, he confirmed that uncontrolled dry stripping and work on or in the proximity to hot surfaces was not permitted.
Item discharged

3.18 (12.5) It was agreed to discuss the action concerning the duty to manage regulation under the separate agenda item later in the meeting.
Item discharged

3.19 (13.2) Mrs Phillips reported that the interviews for the asbestos worker risk perception project had been completed but as yet she had no information about the emerging findings. Once the report, which was due around Easter, had been considered, a decision would be taken about increasing the sample size. If the sample size was to be increased, Mr Blackburn requested that a specific question be added to the interview to establish whether or not the presence of an analyst on site made any difference to the attitudes and behaviours of the asbestos removal workers.
Item discharged

3.20 (14.2) Mr Skilling confirmed that he had included information about moisture meters in his recent letter to all licensed contractors.
Item discharged

3.21 (15.1) Mr Wilkes agreed to send Dr Gibson information on air line fed RPE.
Action: Mr Wilkes

3.22 Mr Campbell mentioned that he had received a report from France on their use of air line fed RPE and had arranged for a translation. In due course he would arrange for this to be made available to ALG members for discussion at a future meeting.
Action: Mr Campbell

3.23 (17.1) In relation to inappropriate protection for workers using asbestos substitute materials, Mr Bryson would write to ALU as soon as he had all the relevant information.
Action: Mr Bryson

3.24 (17.2) Ms Cairns confirmed that the draft minutes had been circulated for comment.
Item discharged

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HSE Information Document (ID) 282/28 Fit Testing of RPE

4.1 Mr Jago sought clarification on 2 points in the ID viz paragraph 34, which stated that "fit testing.... should ideally be done using the wearer's own facepiece" and paragraph 55, which stated that "in all cases, annual repeat fit testing would help to confirm the fit". He felt that using the wearer's own mask was not the purpose of the fit test and that HSE appeared to have changed the policy. In their training courses, ARCA conducted the tests on new respirators, not the operative's own one. As far as the frequency of the test was concerned, he had taken the view that this was a one-off requirement unless there were significant changes to the wearer's face or a different model of RPE was to be used. However, in recommending annual tests, the ID seemed to be at odds with the ACoP. Contractors needed to know whether HSE inspectors expected to see annual face fit test certificates or not - the TAs wanted a prescriptive line from HSE.

4.2 Dr Gibson explained that face fit tests were best conducted when the operative wore the RPE they normally used. This provided the most accurate assessment of face fit. However, it was quite acceptable for the test to be conducted with a new mask provided it was the same model and size to the respirator worn at work. As far as the frequency of the test was concerned, Dr Gibson said that although the ACoP didn't specify a timescale, HSE considered that a year would be a reasonable amount of time to have elapsed before repeat testing took place. The guidance therefore suggested annual repeat testing.

4.3 Mr Skilling informed everyone that previously the draft version of the ID stated that new respirators should be used for the test, but this had been changed to the current text in the light of comments received from delegates who attended 2 face fit seminars organised by Technology Division in January 2000. The seminars had been well attended (100 plus delegates) and Mr Skilling was surprised that the TAs had not therefore been aware of the subsequent changes. Mr Macdonald pointed out that one benefit from the user being tested on their own RPE was that if it wasn't being properly maintained this would be obvious. Mr Campbell added that the ID was an indication of good practice, nothing more, as its status was at the "lowest" end of the guidance hierarchy, several levels below what was required by law.

4.4 Mr Blackburn questioned the need for annual face fit testing as RPE could become damaged and this might not necessarily be detected. Dr Gibson responded that the RPE maintenance regime would address such defects, through the system of daily, monthly and 6 monthly checks. The repeat face fit test was not for that purpose but was to ensure the RPE continued to fit the user properly.

4.5 Mr Macdonald noted the points made by the TAs that there was a desire for the ACoP to be more prescriptive, but cautioned that to do so, consensus would be required. As there would be an opportunity in the near future to review the contents of the ACoP, members were invited to note this and submit their comments when offered to do so.

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Clearance Sampling

5.1 Mr Wilkes raised the problem he had encountered in some parts of the country whereby UKAS accredited laboratories refused to issue clearance certificates because intact asbestos, which was not part of the original work, remained within the enclosure. Instead, the laboratories issued reassurance but not clearance certificates. He doubted whether this practice was correct and sought views.

5.2 Dr Gibson confirmed that it was acceptable to issue a clearance certificate if asbestos, which was in good condition, but outwith the scope of the original work, remained in the enclosure. If the laboratory would not issue a clearance certificate in such circumstances, then this should be queried with them and ultimately referred to UKAS. Mr Blackburn agreed with this and was surprised to learn that some laboratories had taken a different view. Dr Gibson added that he had come across the term "qualified" or "conditional" clearance certificates and stated that these were not recognised and had no status. Either a clearance certificate was issued or was not - there was no interim position. Mr Blackburn mentioned that this had been discussed at an ATAC meeting and undertook to feedback Dr Gibson's comments to the next meeting.
Action: Mr Blackburn

5.3 Mr Blackburn said that many laboratories produced clearance certificates on site ("interim" certificates), handed these to the contractor and then produced a proper typed ("final" certificates) version in the office to give to the contractor later. UKAS had identified this practice as being a loophole in the QA process, which needed to be addressed so that only one certificate was ever issued, either the one issued on site or the one produced in the office. Mr Dolan pointed out that the industry had worked on the basis that the "final" certificate was the same as the one issued on site. The certificate issued on site was the one the contractor acted upon. Under this revised arrangement, the contractor could be placed in a difficult position if they weren't issued with a certificate on site and had to wait for the one produced in the office.

5.4 Mr Macdonald referred to HSE's Asbestos Committee where the whole issue of clearance certificates had been raised and questions asked about whether clearance testing should be done, as in some other countries, after the enclosure was dismantled. The HSE Committee were of the opinion that it was an opportune time to consider this issue from first principles and would be considering the matter in some detail. In the meantime, he would arrange to discuss the concerns that had been raised with UKAS. Mr Skilling also mentioned that he hoped to put a paper to members on this subject at a future ALG meeting.
Action: Mr Macdonald

5.5 Mr Wilkes referred to minute 10.8 from the last meeting regarding the debate as to whether the client or the contractor should engage the laboratory and requested that this be tabled for discussion at the next meeting.
Action: Ms Cairns

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EH51 Enclosures Provided for Work with Asbestos

6.1 In response to Mr Hayes' query about whether EH51 was under review, Mrs Boyle said that as the Working Group (WG) on the review of asbestos guidance had not yet considered it, she had nothing to report. She mentioned that the WG were checking whether EH57 (the problems of asbestos removal at high temperatures) could be withdrawn, as the information was inappropriate for use in asbestos work and for the generic good advice contained in it to be incorporated elsewhere (eg pottery/kiln guidance). Mr Wilkes understood the thinking behind this but pointed out the usefulness of the blunt statements on the first page of the guidance which contractors had been able to use to influence clients. Mrs Boyle confirmed that this information would feature elsewhere in asbestos guidance if EH57 was withdrawn.

6.2 Mr Jago asked about EH50 (training operatives and supervisors for work with asbestos insulation and coatings) and Mrs Boyle explained that the document was currently out of print. As there would have to be a reprint, the WG would take the opportunity to arrange for some minor amendments to be incorporated. A full review of the document would then follow. Information from the project on training currently being undertaken for the European Commission DGV would hopefully be able to feed into the review. Mr Jago asked about a rumour he had heard about the training requirement being increased to 5 days. Mrs Boyle said that no decision had been taken on this and that if there were proposals to change the training requirements, then consultation would take place.

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Update on Amendments to CAWR

7.1 Mrs Phillips explained that the two main issues to emerge from the consultation exercise were the identity of the duty holder and the scope of the premises to be included in the regulations. Following discussions with HSE Solicitors, new proposals had been drafted viz: (a) the main duty would remain on the employer in occupation but there would be an additional "duty of co-operation", which would be placed on anyone else with an interest - eg building owners, managing agents, facilities managers, architects etc; and (b) the scope of premises would be extended, if possible, to include all rented domestic property as well as non domestic property. Discussions were still taking place on the revised proposals with appropriate other Government Departments (OGDs). Once agreed and cleared with the Health and Safety Commission (HSC), a revised CD would be issued.

7.2 Because of the scope of the changes and the different audience now involved, a further full 3 month consultation period would be required and, subject to HSC's approval, the CD would be published in July. Responses would then be considered, any further changes incorporated, and hopefully, the regulations would be introduced in March 2002. As a result of the delays, Mrs Phillips explained that consideration was being given to curtailing the lead in period, so that the implementation date would be the same as originally planned. In the meantime, the awareness raising campaign would proceed as planned.

7.3 Mrs Phillips said that consideration was being given to including a new requirement in the forthcoming CD viz that organisations undertaking bulk sampling and analysis should be accredited. If this requirement was introduced, there would have to be an appropriate lead in time since not all laboratories were currently accredited to do this work. She welcomed initial views from members together with an indication of the number of organisations that might require accreditation.

7.4 Mr Jago replied that that almost every licensed contractor currently took bulk samples (with only a few of them accredited to do so) and sent these to accredited laboratories for analysis. In his view, the proposed requirement for bulk sampling accreditation would create difficulties for the industry. Mr Dolan also expressed concern about the difficulties of accrediting potentially large numbers of applicants in a short space of time.

7.5 Mr Skilling pointed out the importance of ensuring that sampling was representative and done properly, otherwise the repercussions could be significant. Dr Gibson added that whilst taking the actual sample might in itself be a simple task, ensuring that the entire sampling regime was properly adhered to was more difficult eg sufficient samples taken, procedures complied with, assessment of other materials present undertaken etc.

7.6 Mrs Phillips thanked members for their comments on this issue. She went on to explain that because of the delay in introducing the new duty to manage regulation, there would now be sufficient time to undertake a more substantial review of the L27 and L28 ACoPs. TA/TU members of the Group would have the opportunity to comment formally when these went out for consultation in August/September 2001. Although the timetable for the revisions was broadly in line with that for the re-consultation on duty to manage, for ease, there would be two separate consultation documents.

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Update on Asbestos Worker Protection Directive 

8.1 Mr Macdonald reported that negotiations on the directive had now reached a crucial stage. HSE were currently working on a negotiating line, which when agreed would be sent out for consultation with external interested parties (including ALG representatives).

8.2 The main issues to note were:- whether there should be a "de minimis" limit for low risk work as opposed to a time-based limit (2 hours); whether there should be a single control limit for all types of asbestos; whether this should be 0.2 f/ml or 0.1 f/ml on an 8 hours time weighted average or a shorter period; the possible inclusion of a "duty to manage" along the lines of the UK arrangement; and training requirements for workers.

8.3 Ms Prentice made the point that reduction of control limits to 0.1f/ml, plus the change to WHO counting rules would mean that powered respirators would no longer be effective for most licensed work, particularly for removal of AIB. Mr Macdonald said that such information was very useful as HSE needed to know about the possible knock on effects the directive might have and whether there would be difficulties in achieving compliance. Dr Gibson reminded the meeting of HSE's view which was to reduce exposure to the lowest level reasonably practical before resorting to RPE.

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Laundering of Asbestos Contaminated Towels

9.1  Mr Skilling reported that in response to an enquiry from Mr Jago, he had written to him (copied to ACAD) explaining the position and the line that HSE inspectors had been given in an attempt to clarify the position. In summary this explained that employers must supply clean, dry towels to individuals each time they left the work area to decontaminate; that employees should not take towels home to launder and that towels used beyond the clean area of the hygiene facility should be treated as contaminated. Mr Jago expressed concern about the apparent suggestion that towels were contaminated. He stressed that this had raised considerable concern amongst his members and questioned whether there was a risk.

9.2 Dr Gibson explained that during the decontamination process, there was a possibility that operatives could bring some residual contamination into the shower area. Contamination might arise from inadequate showering and then drying using the towel and also from splashes of contaminated water onto the towel hanging in the shower area. Therefore the shower must be deemed to be a contaminated area. If operatives dried themselves in the shower area, then the towels could potentially become contaminated. In response to Mr Dolan's query, he stated that if operatives followed the procedures properly, then decontamination should be effective.

9.3 Mr Skilling acknowledged that although employees should not bring in their own towels from home, this practice might occur. If this arose, so long as the towel remained in the clean end of the DCU, then it would not be regarded as contaminated. He also mentioned a project, which was due to start shortly by HSL, into the effectiveness of laundering contaminated towels and coveralls as well as the research which would examine the effectiveness of decontamination procedures. As soon as further information was available on these projects, ALG would be informed.

9.4 Mr Skilling agreed to consider the point raised by Mr Wilkes regarding scaffolders' PPE and the fact that disposable coveralls were not adequate for their work. This meant that reusable overalls would be required, which in turn would lead to laundering difficulties, given the shortage of commercial laundries equipped (and willing) to clean asbestos contaminated articles.
Action: Mr Skilling

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Method Statement Aide Memoire

10.1  Ms Cairns distributed a copy of the recently revised aide memoire on method statements, under cover of ALG Memo 4/01 (appended to the minutes). She explained that this had gone to all ALPIs, was used by inspectors to review method statements and under the new Asbestos Notification System, referred to earlier in the meeting, would be sent to contractors in future if their method statements were deficient. ALU also sent it out to contractors with their new licence.

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Any Other Relevant Business

11.1 Mr Campbell stated that an item had been raised by Mr Tynan concerning contaminated hypodermic needles. As this item had previously been raised with HSE's Construction Sector, ALU would arrange for this information to be sent to him. If it emerged that more was required, then we would consider the matter further.
Action: Ms Cairns

11.2 Mr Campbell mentioned a letter that ALU had received from an interested party raising a number of issues that might be of interest to ALG. As the letter had only just been received, there had been no time to consider it fully. ALU would now do so and if appropriate would arrange for discussion of relevant issues at a forthcoming ALG meeting.
Action: Ms Cairns

11.3 Mr Campbell reported that since the last ALG meeting, the last of the Senior Labour Inspectors Committee (SLIC) Asbestos Working Sessions had taken place (France, December 2000), which had been very interesting. Work was now underway to produce the final report which would be presented to the May meeting of SLIC. ALG members would receive copies of the report in due course.

11.4 Mr Jago requested clarification about the need for training and medical examinations for holders of supervisory asbestos licences. Mr Skilling explained that the intention of a supervisory licence was for the licence holder to have an interventionist role and be in direct control of the asbestos operations, often requiring entry into enclosures. As such, the necessary training and medical surveillance was required. If on the other hand, the work involved a quality control type role such as monitoring method statements or checking that work has been carried out to a standard that met the terms of the contract, then he did not consider this to be supervisory work requiring a licence. Mr Blackburn said that this hadn't been his understanding and asked that this interpretation be conveyed more widely, which Mr Skilling agreed to do.
Action: Mr Skilling

11.5 Dr Gibson requested information from members who had used the "iceblast" method for removing Artex. Mr Wilkes confirmed that his company had used this method but for a different job and would supply details. Mr Bryson also agreed to send information about a water based product used to remove Artex.
Action: Mr Wilkes/Mr Bryson

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Date, Time, Location of Next Meeting

12.1 The next meetings would take place on 27 June and 31 October 2001, venues to be arranged.
Action: Ms Cairns

*Post Meeting note — the 27 June meeting will be held in London, at the HSE London and South East Divisional office, St Dunstans House, 201-211 Borough High Street, London SE1; the 31 October meeting will be held in Belford House, Edinburgh.

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ALG MEMO
4/01 Asbestos Licensing Unit
Asbestos Liaison Group Memo

To: Members of the Asbestos Liaison Group

From:        James Skilling
                  Head of ALU

Date:         22 March 2001

Subject:     Method statement aide memoire
_______________________________________________________________________

1 You may be interested to see for information the attached method statement aide memoire which has been revised and which replaces the previous one produced by ALU in 1997.

2 ALU include a copy of the aide memoire when a new licence is issued and enforcing authority inspectors use it to assess the adequacy of method statements received by licensed contractors.

3 Copies of the aide memoire have already been sent to ALPIs.

JAMES SKILLING

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METHOD STATEMENTS AIDE MEMOIRE

Control of Asbestos at Work Regulations 1987

The individual aspects of work with asbestos insulation, asbestos insulating board or asbestos coating must be adequately covered in a method statement. Method statements must be specific to the work being carried out at the particular location. The following is a summary of the elements that should be considered in a method statement. To assess adequacy of method statements HSE and Local Authority inspectors may use this. The list is not intended to be exhaustive.

1 Scope of Work

Name of Client
Name of supervisor
Address of site
Number of samples taken
Type of asbestos
What form is it (eg sprayed, lagging)
Location of asbestos (eg in roof space)
Particular difficulties likely to be encountered (eg fire damage, vandalism)
Quantity to be removed (eg number of bags)
Number of employees engaged in removal work
Start date and finish date (days when work is to take place and times)

2 Hygiene Facilities

If transit facilities are proposed, give reasons why it is necessary to transit
Description of facilities
Location shown on site plan

3 Waste Disposal (descriptions of the following)

Bagging arrangements
Temporary storage for bags
Waste routes (ie separate bag lock?)
Skip location
Arrangements for transportation and final disposal.
If using own van — are they a Registered Waste Carrier and will the waste be transported in a separate sealed compartment from personnel.

4 Enclosure of Work (descriptions of the following)

Construction of enclosure - attach sketch plan showing location
Volume of enclosure
Location of airlocks
Removal of waste
Viewing panel(s) position
Warning notices

Note that if no enclosure is planned, the reasons to justify that decision must be given.

5 Control Measures (descriptions of the following)

Expected asbestos fibre concentrations
Specification of negative pressure units (ie provides 0.17 m3/s for each 100 m3 of enclosed volume - 100 ft3/min per 1000 ft3)
Number of air changes per hour.
Siting of negative pressure units
Method of smoke testing and witnessing
Type and specification of respirators to be used
Assessment of PPE required for preparatory work (eg to construct an enclosure) when material is in bad condition
Any wrapping/repair of damaged material
Maintenance arrangements for RPE and other equipment to be used
Protective clothing
Specification of vacuum cleaners (and indication of where they are to be positioned)
Examination and maintenance of control measures
Record keeping

6 Method of Work

Wrap/cut, shadow vacuum, low pressure multi-needle injection (mist spraying is not controlled wet removal)
Wet strip technique to be used* on limpet/pipe lagging
Additional local exhaust ventilation required (eg shadow vac)
Glove bags
Tools to be used (including power tools)
Non-asbestos risks (eg access equipment)
Precautions to minimise risk of heat stress

*Note: dry stripping should only be proposed where it is unavoidable. Full written justification should be provided. Without this, dry stripping will not be considered acceptable. Similarly work on or in proximity to hot surfaces is to be avoided.

7 Entry and Decontamination Procedures (descriptions of the following)

Facilities and procedure for entry into enclosure
Arrangements for :

- cleaning and vacuuming before leaving enclosure
- removal of contaminated overalls
- washing boots and respirators
- transit to decontamination
- disposal of transit overalls/footwear
- the care and use of respirators

8 Air Monitoring (descriptions of the following)

When will it be carried out?
Nature of the monitoring (locations, personal, static and/or reassurance)
Monitoring company or organisation
Name of analysts laboratory (UKAS accredited for sampling and counting?)

9 Final Clearance (descriptions of the following)

Final cleaning arrangements
Thorough visual examination
Results of air monitoring (see also 8 above)
Removal of enclosure and disposal
Use of PVA or other sealants (only on disposable surfaces)
What happens if there are unsealed surfaces in the enclosure?
What if the enclosure is wet?

10 Emergency Procedures (descriptions of the following)

Fire precautions
First aid arrangements
Minor incident procedures
Major incident procedures (including placement of rescue equipment, instructions to employees and liaison with emergency services).

11 Site Documentation

Training records (including for non asbestos work eg mewps, scaffolding, confined spaces etc)
Test certificates for equipment
Medical certificates
Method statements
Maintenance records
Site log (including daily inspection of enclosure)
Face fit test records for full and ½ RPE
Records of RPE inspection and test

12 Other Matters

Supervision of job
Visitors to site
Client requirements
Liaison with clients/employees
Special characteristics of site
Permit to work systems or formal systems for isolation of live plant agreed with client
Heat stress
Welfare (toilets and mess room facilities)
Work at height: prevention of falls, (take account of additional risks from use of PPE)
Procedures for changing the method statement

Further information may be found in the relevant Codes of Practice and Guidance Notes

Asbestos Licensing Unit
February 2001