Asbestos Licensing
Minutes
THE ASBESTOS LIAISON GROUP WEDNESDAY 23 JANUARY 2002 AT 10.00AM
FORTUNE ROOM, ROSE COURT, 2 SOUTHWARK BRIDGE, LONDON
(21 May 2002, Edinburgh; 24 September 2002, Rose Court, London)
Present
| HSE | TAs/TUs |
|---|---|
| Pam Waldron, T/Head of Health Unit | David Hayes, ACAD |
| Jim Skilling, ALU | Mike Wilkes, ACAD |
| June Cairns, ALU | Jean Prentice, ACAD |
| Liz Standen, ALU | Terry Jago, ARCA |
| Martin Gibson, Scotland Specialist Group | Peter Dolan, ARCA |
| Tracey Boyle, TD3 | Rob Blackburn, ARCA (ATaC) |
| Martin Stear, TD3 | Tony Tynan, NFDC |
| John Claxton, FOD Operations, Norwich | Neil Moore, GMB |
| Ian Gooday, HDC | Leonie Wingrove, TGWU |
| Owen Yorath, HDC |
Introduction, apologies, welcome etc
1.1 Mr Skilling welcomed everyone to the meeting, which he chaired until Mrs Waldron was able to attend later. He explained that since the last meeting Mr Campbell had been promoted to HSE Director, Scotland and that Mrs Waldron would continue as Head of Health Unit until the end of March 2002. He welcomed Liz Standen, ALU, Martin Stear, TD3, who would replace Tracey Boyle, Ian Gooday and Owen Yorath, HDC and Leonie Wingrove, TGWU. Apologies for absence were tendered on behalf of Tracy Phillips and Bill Macdonald, HDC, Robbert Hermanns, SSG and Nigel Bryson, GMB.
1.2 The Group wished to record their thanks to Mr Campbell and to Mrs Boyle for their contributions over the last year and to wish them well.
Minutes of the meeting held on 31.10.01
2.1 The minutes of the meeting were agreed.
Matters Arising
3.1 (3.1) The action on Mr Bryson to put forward proposals for a smart card
scheme was discharged as the item was remitted to substantive agenda item
4(3).
Item discharged
3.2 (3.4) Information about inappropriate protection for workers using asbestos
substitute materials was still awaited.
Action: Mr Bryson
3.3 (3.6) Mr Gooday reported that discussions with UKAS on the matter of
"interim" clearance certificates was still ongoing. HSE would agree
the position with UKAS and report back to the Group.
Action: Tracy Phillips
3.4 (3.13) Mr Skilling thanked members for their comments on draft ALG Memo
9/01 on the hiring of employees, the final version of which was issued in
December 2001. Mr Dolan was concerned that not all licence holders were aware
of the requirements and felt that many of them were still hiring labour from
unlicensed "agencies". Mr Skilling acknowledged this difficulty
and agreed to consider how best to promulgate the information to licence holders.
In the meantime, ACAD would provide a list of unlicensed "agencies"
they knew of who provided this service.
Action: ALU/ACAD
3.5 (3.14) Ms Cairns reported that HSL hoped to complete their research on
laundering of contaminated towels and overalls by the end of January 2002.
Emerging findings on the work done so far on towels, seemed to accord with
the line already taken by HSE (ie towels used solely in the clean end of the
DCU could be deemed as uncontaminated). Once the report had been cleared with
ALU, ALG would be informed of the findings.
Action: Ms Cairns
3.6 (3.16) Mr Skilling reported that liaison with the Environment Agency/SEPA
would be taken forward by Mrs Standen. The matter was remitted for further
discussion under agenda item 8(1).
Item discharged
3.7 (3.17) Mr Skilling thanked Mr Wilkes for compiling the report on his
experiences of using the Protimeter moisture meter. Dr Gibson explained that
the next step would be to have discussions with HSL about the level and type
of tests to be undertaken and to draw up appropriate protocol. Mr Wilkes'
report would usefully feed into this process. The timescale would depend on
HSL's work commitments, but Dr Gibson hoped that the project would start in
a few weeks time and take approximately 3-6 months to complete.
Action: Dr Gibson
3.8 (4.1) Mr Skilling thanked members for their comments on the draft ALG Memo 8/01 on supervisory licence holders (SLH), the final version of which had been issued in December 2001. Mr Blackburn had been unable to comment on the draft at the time and was unhappy about certain aspects of the final version. He felt there was still a grey area as far as analysts were concerned, as to whether the action they took on site could be deemed as having a direct influence over the removal contractor, thereby requiring the analyst to have a supervisory licence. He felt there were contradictions in the memo (in particular paragraphs 5 and 6). Eg in carrying out quality control work, if an analyst encountered a defect which compromised the integrity of the enclosure, or found a bag of asbestos waste incorrectly stored etc, and gave instructions for the deficiencies to be remedied, would this not require them to hold a supervisory licence as the action taken could be interpreted as having a direct influence over the removal contractor? He also disagreed with the view that method statement preparation could be undertaken by non licence holders.
3.9 Mr Skilling reiterated the HSE view which was that an SLH would be expected
to take a proactive approach and play a far more interventionist role than
merely one of reacting to adverse situations on site. In his view, the situations
described by Mr Blackburn would not require a supervisory licence, otherwise
it could be argued that all analysts (and HSE inspectors) would require a
licence, which would be inappropriate. However, he acknowledged the difficulties
and agreed to review the memo in consultation with Mr Blackburn and Dr Gibson.
Action:Mr Skilling /Dr Gibson /Mr Blackburn
3.10 (4.2.2) Ms Cairns referred to the ALU exercise to amend the standard
licence conditions with effect from 1.4.02 and the ALG Memo 1/02 on this,
which had been issued to members in January 2002. She reported that to date
ALU had completed half of the exercise. A number of points were clarified
and it was confirmed that the issue of unlicensed "agencies" would
be progressed as previously discussed (see minute 3.4).
Item discharged
3.11 (4.3.2) Ms Cairns gave members a copy of the Asbestos Licence Assessment
Guide (ALAG), issued under cover of ALG Memo 2/02. She explained that the
ALAG had still to be processed by FOD Editors but because of the further delay
that this would have incurred, it had been decided to issue it in its current
form. The ALAG had been issued to inspectors earlier in January and was now
being used by them. Following the editing exercise, the document would appear
in a different format on HSE's intranet, however the "technical"
content would be unchanged. The ALAG was issued to ALG for information (not
consultation), although members would have an opportunity to discuss its contents
at the next ALG meeting, by which time, they would have had an opportunity
to familiarise themselves with it.
Action: Ms Cairns
3.12 (4.4.2) Regarding Dr Hermanns' presentation at the last meeting questioning
the need for asbestos workers to have mandatory chest X-rays every 2 years
and the fact that the guidance to appointed doctors was at odds with the Ionising
Radiations (Medical Exposure) Regulations 2000, Mr Skilling reminded members
that comments on this subject would be welcome. Mr Jago said that this matter
had been discussed at the ARCA regional meeting. The consensus view was that
if mandatory chest X-rays were discontinued, it would be viewed unfavourably
by workers, who regarded a "clear" chest X-ray as a positive sign
and took comfort from it. Mr Wilkes agreed and pointed out that if, in the
future, mandatory chest X-rays were dispensed with, then there would be a
need for effective publicity to carefully explain the reasons for the change.
The letter received by Mr Jago from an ARCA member would be copied to Dr Hermanns.
Mr Moore asked that GMB be involved in further discussions.
Action: Dr Hermanns
3.13 (7.1.2) Mr Skilling reported that he had written to the National Access
and Scaffolding Confederation (NASC) in November 2001 to clarify the outstanding
issues regarding asbestos licences for scaffolders. However, NASC still had
some queries and a discussion with representatives from NASC, ALU and HSE
Solicitors, would be arranged to resolve the matter. Thereafter, ALU intended
to revise draft ALG Memo 7/01 and produce a number of articles for various
trade publications. The latest list of licence holders (31 as at 21.1.02)
restricted to undertake scaffolding and associated work, was distributed to
members.
Action: Mr Skilling
3.14 (7.3.3) The item on personnel certification and accreditation schemes
for surveyors was remitted to substantive agenda item 4(1).
Item discharged
3.15 (8.1.2) The item on duty to manage was remitted to substantive agenda item 7.
ARCA/ACAD Joint Technical Committee Issues
4.1 Personnel certification of individual surveyors to EN45013
4.1.1 In response to the Trade Associations' request for an update on this issue, Mr Gooday said that a meeting of all interested parties was scheduled for week commencing 4 February 2002. It was intended that a working group would then be set up to develop a new standard for certifying bodies who wished to certify individual surveyors. The standard was to be in place by April 2002. It was confirmed that the participant organisations (so far, BIOH, RICS, BRE, ARCA, ACAD, ATaC) would need to fund their own involvement, although HSE would fund UKAS's involvement.
*NB Post meeting note — meeting arranged for 8 February 2002.
Action: Ongoing (HDC)
4.2 BIOH P402 written examination
4.2.1 Concern were raised by the Trade Associations following complaints received from students about the written P402 examination, which included allegations that questions were often very specific, misleadingly worded, ambiguous, had no right answer, etc. The exam style also penalised those candidates unused to taking examinations. Training providers had no input to the questions and never saw examination papers. Ms Prentice had written to BIOH about this but had not received a reply. Mr Blackburn was also concerned about the way in which the course was marketed by BIOH, which inferred that passing the exam meant the individual was competent.
4.2.2 The meeting agreed that successful completion of P402 formed only a
part of the personnel certification scheme — not all of it. Also, if
training providers aligned the courses to the syllabus, there was no need
for them to see examination papers. One way forward might be to invite a representative
from BIOH to attend a meeting of the Committee for Fibre Measurement (CFM).
Before then, it was agreed that ARCA and ACAD would write to Mr Skilling by
7 February 2002 setting out the problems and he would raise the matter at
the next CFM meeting.
Action: ARCA/Mr Hayes (by 7.2.02)
4.3 Main Contractors Group (MCG) and construction skills cards
4.3.1 Mr Jago explained that in the construction industry, the MCG had established a Health and Safety Charter. It stated a requirement for a one card training system for construction and that all schemes relevant to construction should be part of the Construction Skills Certification Scheme (CSCS). Their proposal was to open a new category of card for Hazardous Waste Removal Operatives, which would replace the Trade Associations existing training cards. As ALG had previously discussed the issue of smart cards, from which training records, medical examinations and face fit tests could be obtained, the Trade Associations considered it an ideal opportunity to pursue this possibility, which would satisfy both MCG and HSE's requirements.
4.3.2 It was agreed that Mr Jago would provide Mrs Standen with the details
for her to progress.
Action: Mr Jago/Mrs Standen
4.4 Disclosure of licence holder information from ALU to third parties
4.4.1 Mr Jago referred to an incident involving one of his members' clients, who obtained enforcement information about them by phone from ALU. The incident had caused embarrassment to the ARCA member. Mr Jago asked whether such enquiries should instead be referred to the HSE web site rather than being left to the interpretation of an individual?
4.4.2 Mr Skilling said that he had investigated the incident and had written
and spoken to the MD of the company concerned. He explained that previously,
enquirers had to personally call into the office to view the public register
of enforcement notices, but that now this information was available on the
HSE prosecution and notices web site. Whilst ALU staff could disclose factual
information from the internal ALU database, this would only provide asbestos
related information and might not provide the enquirer with the full picture.
ALU would review its disclosure procedures - one possibility might be that
in future callers would be referred to the HSE web site.
Action: ALU
4.5 Employment status, the self employed and licence requirements
4.5.1 Mr Jago was aware that there were a number of self employed people in the asbestos industry and sought clarification on whether such individuals needed to be licensed when working for a licensed contractor.
4.5.2 Mr Skilling referred to Regulation 3 of ASLIC "...an employer
or self-employed person shall not undertake any work with asbestos insulation
etc, unless he holds a licence..." Therefore, if an individual was truly
self employed ie he didn't take instructions from anyone, directed his own
work, was paid a fee for the work, then they would require a licence. If on
the other hand, an individual was brought in to supplement labour and worked
under others' instructions, then irrespective of tax and insurance arrangements,
that individual would be regarded in health and safety terms as an employee.
This issue had also been discussed at the September 2001 ALPI conference,
where the same line had been agreed. He added that none of the current licence
holders were self employed, although there were a number of sole traders who
held licences. Mr Moore supported this stance, as in his view there was a
misuse of the self employed status in the construction industry. Mr Jago agreed
to forward a letter from an HSE inspector on this subject, which ALU agreed
to look into.
Action: Mr Jago/ALU
4.6 Training requirements for non asbestos personnel required to enter enclosures
4.6.1 Mr Jago asked about HSE's policy on the training requirements for non asbestos personnel to enter enclosures to perform emergency or specialist tasks.
4.6.2 Mr Skilling said that the first consideration should be whether it was necessary to enter the enclosure in the first place. He was concerned that some situations were alleged to be emergencies when this was not the case. If a genuine emergency arose, then training would not be appropriate. Instead the individual would have to be accompanied and closely supervised to ensure the risks of disturbing asbestos were well controlled. The individual would need appropriate RPE (although there would be no time for a face fit test) and personal protective equipment. They would need a colleague or a buddy system to help decontaminate (but might not necessarily require full decontamination, depending on the assessment of the situation).
4.6.3 If possible, before the individual entered the enclosure all work should have stopped for an hour or so to allow the fibre levels to drop, with NPUs continuing to run so that the overall risk was reduced. Whilst endorsing Mr Tynan's point about the importance of training, Mr Skilling stressed that it was only in real emergency situations that he would dispense with the need for training in favour of the individual being accompanied and closely supervised to ensure the activity was well controlled.
4.7 Artex — clarification of procedures for removal
4.7.1 Mr Tynan asked what HSE's policy was on the removal of Artex as it had been alleged to him by an NFDC member that across the country different standards applied.
4.7.2 Dr Gibson confirmed that HSE's policy was that asbestos containing Artex should be removed before demolition or refurbishment. The material was licensable and work with it was required to be done by a licensed contractor. Preferred methods for removal included steam, rehydration gel and wet blasting (for residuals). The use of abrasive power and pneumatic tools were to be avoided because of the higher levels of exposure likely to occur.
4.7.3 Mr Blackburn referred to work with asbestos containing Artex (drilling) that one of his company's clients (unlicensed) were to undertake on 70 houses. He was concerned that HSE had agreed that rather than use a licensed contractor, that the work could be undertaken under the ASLIC short duration exemption. Mr Skilling said that if the company intended to work on only one property a week, then it might be possible to comply with the exemption, but this would require considerable monitoring by the company to ensure that the work (including the preparation and clearing up) did not exceed the time limits and that the individual(s) concerned were not exposed again within 7 days. He thought it would be unusual for the work to be undertaken in this way as normally more properties would be worked on at any one time, which would exceed the short duration time limits.
Asbestos Management Guidance
5.1 Mrs Boyle reported that she had received six responses so far on the
draft HSE Guidance Document on the above, all of which had been positive.
She reminded members to let her have comments as soon as possible and apologised
for the short timescale which was due to her having to complete as much of
the task as possible before starting maternity leave. It was intended to issue
the guidance to coincide with the introduction of the CAWR 2002 Regulations.
ACAD commented that this was a good piece of guidance.
Action: TAs/TUs
ALU Update
6.1.1 Mrs Waldron referred to draft ALG Memo 7/01 on asbestos licensed scaffolders and was concerned to find that the draft had been "leaked" outside of ALG. She reiterated ALG's policy which was that draft ALG Memos were only circulated to ALG members, and their Technical Committees, should members wish to consult. Draft Memos were not for general circulation. However, once finalised and cleared, ALG Memos were treated as open disclosable documents. She was particularly concerned that in this instance, not only had the Memo been passed on, but that it had been retyped and the draft status and some appendices had been removed.
6.1.2 Mr Wilkes pointed out that when ALU emailed draft documents, they sometimes
"lost" the watermark bearing the "draft" status. This
might be due to software incompatibility, in which case ALU might have to
reconsider its system for sending out draft documents in future.
Action: All to note
6.2 Carbon monoxide poisoning within enclosures
6.2.1 Mr Skilling raised the issue of non asbestos risks and referred to
an incident where three asbestos operatives were rescued from an enclosure
after being overcome by carbon monoxide fumes. As he had issued an ALPI memo
on this, he sought views on whether an ALG Memo would be helpful. The meeting
agreed that it would be. ALG members would be given 2 weeks to comment on
the draft, from the date of issue. (Post meeting note - draft ALG Memo 3/02
issued on 7.2.02).
Action: Mr Skilling/All (by 21.2.02)
6.3 Provision of respirators and charging a fee for their use
6.3.1 Mr Claxton referred to Section 9 of the Health and Safety at Work Act, which made it clear that employers could not charge employees for equipment. Inspectors had received complaints from employees about having money (approx £300) deducted from their wages to pay for their respirators. When this had been investigated, it transpired that the money had been retained in the form of a deposit, returnable when the employee returned the respirator to the employer. HSE Solicitor's opinion was that a fully refundable deposit was not a charge as covered by Section 9, HSWA, therefore there was no legal reason why an employer could not levy one. The employer could not charge employees for disposable elements, such as filters or seals, nor charge for normal wear and tear. Whether there was a refundable deposit or not, the employer was responsible for maintenance of the equipment.
6.3.2 Mr Jago thought that the situation described by Mr Claxton or a variation
of this (money deducted from the employees final wages if they left without
returning the respirator) was common practice. Mr Wilkes commented that new
employees to his company sometimes wanted it bring their own RPE with them.
Company policy did not permit this as the equipment might be defective. Mrs
Waldron acknowledged the Trades Unions' concerns that this practice might
begin to be applied to other PPE and asked members to make discreet enquiries
to find out what was actually happening in the industry.
Action: Trade Associations
6.4 Quality of disposable overalls for asbestos removal operatives
6.4.1 Mr Claxton referred to the fact that there was a vast difference in the quality and cost of disposable overalls that were available on the market, although they all purported to comply with the Type 5 CEN standard. Mr Jago said that the industry would support better standards if these were defined in the ACoP. Mr Blackburn added that there was a difficulty in that if overalls were made from breathable material they let in fibres. On the other hand, if the material didn't let in fibres, then it was uncomfortable to wear.
6.4.2 The meeting agreed that there needed to be a basic standard for overalls
for asbestos workers. Mrs Boyle agreed to explore whether some work on this
might be taken forward under the HSL project that was looking into the effectiveness
of decontamination arrangements and PPE.
Action: Mrs Boyle/Mr Stear
6.5.1 Mr Skilling introduced this by explaining that the matter had been discussed at the September 2001 ALPI conference. In summary, the meeting had agreed that the evidence pointed towards the need for an enclosure to do this work, unless the assessment could justify the work being done without one. There had been a number of recent queries raised by inspectors and it seemed appropriate to discuss the issue with ALG, perhaps with a view to developing some guidance on the matter.
6.5.2 Dr Gibson had produced some overheads of the factors to be considered
when undertaking this work and invited comments. There were a number of comments
raised (eg reference to a lockable skip; need for clearance testing if a full
enclosure was used, including visual testing; difficulties of using a full
enclosure as negative pressure would not always be possible). Members were
invited to comment direct to Dr Gibson by 8 February 2002.
Action: All (by 8.2.02)
6.6 Project to review asbestos training providers
6.6.1 Mrs Standen circulated details about this project to ALG members (appended to the minutes). The aim of the project was to investigate current standards of training and certification provided for asbestos workers and to facilitate the consistent provision of asbestos training by drawing up a set of training criteria for training providers.
6.6.2 It was hoped that the project would be completed by the end of June
2002. In response to Mr Jago's query about whether the end result would lead
to approved or accredited training providers, Mrs Waldron responded that it
was too early at this stage to predict how this might develop in the longer
term.
Action: ongoing
Health Directorate Update
7.1 Duty to manage
7.1.1 Mr Gooday reported that the CD on the revised proposals was published on 21 November 2001, for responses by 19 February 2002. To date twenty replies had been received, with the main comments relating to the proposed duty holder and lead in time. The awareness raising campaign was on track and the speaker's pack to be used by intermediaries at future workshops as part of the campaign was being tested that day by HDC staff. 217 intermediaries had been signed up so far.
7.2 Revised L27/L28 ACoPs
7.2.1 Mr Gooday explained that the draft CD on proposed changes to L27 and L28 had been cleared by the HSC at their meeting held earlier in the month, subject to one change. It was now intended that, following HSC approval, the CD would be published by the end of February 2002, with a 3 month consultation period.
*NB Post meeting note — it will now be published on 27 February with responses required by 22 May 2002.
7.3 Control of Asbestos at Work Regulations 2002
7.3.1 The introduction of the CAWR 2002 Regulations, complete with three ACoPs was now scheduled for September 2002. The serious concerns expressed by Mr Moore about the overall slippage in the introduction of the regulations and the associated lead in time were noted.
Any other business
8.1 Trade Association/Environment Agency Forum
8.1.1 Mr Jago explained that the Trade Associations had written to the Environment
Agency (EA) with the aim of establishing a liaison forum between them and
EA. He wondered if HSE would also wish to be involved. It was agreed that,
in liaison with Mr Jago, Mrs Standen would contact EA and SEPA (Scottish Environment
Protection Agency) to gauge whether there would be sufficient interest to
set up an ALG sub group on waste management.
Action: Mrs Standen
8.2 Face fit testing
8.2.1 Mr Jago referred to a letter he had received from an ARCA member asking for clarification of the frequency of face fit testing and whether testing was required annually or not.
8.2.2 Mr Skilling reminded members of the previous ALG discussion on this
matter (minutes 4.1 to 4.5 of the 22.3.01 ALG meeting). The current ACoP guidance
(which recommended repeat tests when there were significant changes to the
wearer's face or a different model of RPE was to be used) took precedence
over the HSE Information Document 282/28 (which recommended annual repeat
fit testing). ALG members would have the opportunity to formally submit their
comments on this when the L27/L28 CD was issued.
Action: Trade Associations (in due course)
Date, time, location of next meetings
9.1 The dates etc of meetings were confirmed as follows:
-
10.00am, Tuesday 21 May 2002, Belford House, Edinburgh
-
10.00am, Tuesday 24 September 2002, Rose Court, London
Action: Ms Cairns
Appendix
HSE Project to review asbestos training courses in GB
Introduction
This briefing has been circulated to let ALG members know about the Asbestos Licensing Unit's (ALU) plans to research the current level of training provision for asbestos industry operatives, supervisors and managers.
Background to Project
ALU have received numerous anecdotal accounts of some training providers giving poor training to asbestos workers. These have come from employers, inspectors and members of the ALG. This project sets out to investigate these accusations and should provide the information that we need to set a 'baseline' for asbestos training provision.
Aims
To investigate the current standards of training and certification provided for asbestos workers (operatives, supervisors and managers) in the asbestos removal industry;
To facilitate the consistent provision of asbestos training by drawing up a set of training criteria for training providers which will achieve compliance with the training requirements of the Approved Code of Practice (ACOP) L28 and regulation 7 of The Control of Asbestos at Work Regulations 1987 (as amended).
Objectives
1 To gather information about
the current form and content of training courses from all known training providers;
2 To establish whether there are any common standards
or criteria used by training providers on which training
courses are based;
3 To compare current training provision with that
laid out in the current ACOP L28;
4 To determine the essential objectives that should
be included at the different levels of training to meet the
requirements of ACOP L28;
5 To form detailed guidance on training in the new
asbestos removal contractors' composite guidance.
Methodology
| Stage 1 | to gather intelligence about existing asbestos courses from all known external training providers (approximately 20) and 3 known in-house providers. The information will be gathered by Health and Safety Laboratory (HSL) researchers via a series of question sets. |
| Stage 2 | to summarise the type of training provided and to categorise the core topics covered for each type of course. |
| Stage 3 | to compare the core topics with the topics covered in the L28 ACOP to determine where the differences lie. |
| Stage 4 | to draw up a list of key objectives (based on the topics in L28) that should be included in the 3 different types of training courses (operatives, supervisors and managers) which could then be incorporated into the new guidance. |
| Stage 5 | Help to set up a working group made up of training providers and members of the Asbestos Liaison Group. This group could discuss the best way of providing delegate with certificates, and creating a monitoring and review system that will seek to ensure consistent use of the key objectives in asbestos training courses. |
Project workers
Liz Standen, Inspector in ALU will be the project manager. Liz Standen and Jim Skilling, Head of ALU will carry out a pilot exercise to test the question sets on one medium sized training provider before handing over the interviewing role to representatives of the HSL.
Feedback
A summary of the findings of the report will be presented to the ALG and representatives of the training providers for comment. All data will be anonymised.
Timescale
The project timescale is currently under negotiation with HSL. The pilot interview was carried out on 17 January 2002. It is anticipated that the rest of the interviews will have been completed by the next ALG meeting (21 May 2002), but that the report from HSL will not be available until 30 June 2002 at the earliest.
If you have any queries about the project please contact Liz Standen or Jim Skilling at ALU.
Liz Standen
Asbestos Licensing Unit
Tel 01224 252514
22 January 2002
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