Reviewing the HSG248
Asbestos Analyst’s Guide
(Second edition) 2021
Rail organisations must remain fully compliant with asbestos legislation in order to manage and control the level of risk to employees and the general public, and this includes the recently revised HSG 248 Asbestos Analyst’s Guide.
The HSG248 Asbestos Analyst’s Guide was originally published in 20051, and this revision takes into account the Analyst Inspection Programme carried out by the HSE in 2015.2 A report was subsequently produced, with this review underpinning many of the revised changes and seeking to address the issues that were identified.
Given its fire resistant and insulating properties, many depots and stations currently in use are likely to be old enough to have been constructed prior to the nationwide ban of asbestos in 1999. This would also apply to some of the older rolling stock still in use on the network.
Having been involved in the consultation for the changes to this guidance note, SOCOTEC have already made adjustments to our operating procedures, and client services, in line with many of the amendments, here we outline some of the key changes:
More detail on scoping/contract arrangements
Many problems have arisen in the past due to inadequate scoping and contractual arrangements, which has then put time and resource allocation pressures on the analyst organisation.
The HSE has proposed that the analyst will be more involved with the scoping of the work (including preparation of risk assessments and plans of work) to ensure adequate planning, agreement on four-stage clearance (4SC) requirements and allocation of resources.
This will be achieved by having a pre-start site visit and meeting between all parties to discuss each element of the proposed work, including the Licensed Contractor’s (LC) plan of work. Under the Construction (Design and Management) Regulations (CDM), it should be noted that the LC has legal duties to cooperate with the analyst and provide them with adequate information in a timely manner.
Need for better standard of cleaning by Licensed Contractors
It is the duty of the supervisor for the LC to carry out the initial visual inspection of the enclosure or work area upon completion of the abatement works. Only when the supervisor deems the area to be clean should the analyst enter the enclosure, as this reduces the level of risk posed.
It is very important that the analyst does not undertake any cleaning activities themselves, as this could be seen as a breach of the Health and Safety at Work Act. The HSE has introduced a form that the LC supervisor must complete and hand over to the analyst, confirming that they have carried out a thorough visual inspection of the work area and that it is satisfactory for the analyst to enter and carry out their own visual examination.
Improvement of the Four Stage Clearance Procedure
The main changes that are being implemented are as follows:
- Use of handover form (as referenced above)
- Prior to undertaking the visual inspection, the analyst must advise the client of an estimated time of completion. If the actual time differs by more than 20%, an explanation must be given to the client
- If any additional cleaning of the work area is required and exceeds 10 minutes, the 4SC will be failed
- Analysts breaks during lengthy visuals, every 2-3 hours with powered RPE, every one hour for non-powered RPE
- Stricter controls on analysts going through the decontamination unit and not wearing street clothes under their disposable overalls will be introduced
- A full photographic record of all four stages is to be made based on information within the revised guide
- All of the above are recorded on the Certificate for Reoccupation
Increase in quality control of analyst work
Based on concerns raised in the Asbestos Analyst Inspection Programme report, the HSE has increased the amount of quality checks required, as work should be continually assessed.
The revised guide stipulates that 5% of 4SCs should be audited and re-inspected. For individual analysts, there is a requirement that they are audited/re-inspected at least four times a year. It will also be necessary to carry out desktop reviews of at least 5% of the completed 4SC certificates.
Stronger impartiality requirements
The HSE has always advocated that the analyst should be independent from the LC. Accordingly, clients should employ the analyst directly and ensure that there are no links with the LC. This guidance strengthens these recommendations through the ‘professional standards’ section.
Improved procedure for personal sampling
Historically, sampling times for personal samples have been very short in comparison to the actual exposure times for LC operatives. No details of the work activities or materials involved were recorded, which meant that the information was not really fit for purpose.
Longer sampling periods will now be required throughout a shift, recording tasks and activities, geographical location and supervisors/teams. A template is provided by the HSE for recording this data, so over time sampling should capture the level of exposure to all operatives across a range of activities. The information gathered will benefit the LC, as data analysis should help to improve working methods and operatives’ understanding of risk potential.
Additional advice on analyst competence/refresher training
Regular refresher training is important to ensure ongoing competence of the analyst and will be in line with the Approved Code of Practice for the Control of Asbestos Regulations 2012. Any issues found during audits or re-inspections can be addressed, and in some circumstances this might require an individual to receive additional training.
New guidance for asbestos in soils and made ground
Over the past decade, there has been a significant growth in interest on asbestos in soils, and the new guide includes some information on this topic. The first part of the guidance concentrates on the sampling of soils and when this should be required. Survey types (preliminary and main survey) are also discussed, and these are supplemented by an initial desktop study to assess the likelihood of asbestos being present or previously used on site.
Additional items
Many organisations take dust and swab samples to accurately determine the presence of asbestos fibres. Interpretation of these results can be difficult, so the new guide offers guidance on this subject.
Although guidance on dust sampling techniques is given, the HSE do not recommend sampling and analysis of asbestos in settled dust except for in specific circumstances where the spread of asbestos from a substantial recent release incident is being investigated. It is also recommended that dust sampling should not be routine practice as part of an asbestos survey.
A cautious approach is required when the results of dust sampling and analysis are being interpreted. It is therefore important that valid and reasonable conclusions are reached, as inaccurate reporting could cause undue anxiety for the client and occupants of the property.
Near-source and far-source/perimeter static sampling have been introduced to provide further guidance on location and distance of air monitoring from potential fibre sources. This is particularly of interest in connection with ground work projects involving the disturbance of made-ground and in known contaminated areas.
In addition, there is a now a short section in the guidance to outline where air sampling of larger volumes may be required and the ability to use this process to achieve lower limits of quantification. This is a topic of a follow-on SOCOTEC blog – watch this space…
In conclusion
The updated analyst guide has been long awaited but now provides additional guidance to analytical organisations, licensed contractors and clients across a wide range of analytical techniques and practical applications. UKAS have set out their timescales for accrediting labs to the new guidance. Declarations of conformity are to be made to UKAS between 1 September and 1 December 2021. The transition day for all successful labs will be 1 February 2022.
Following the launch of SOCOTEC’s electronic air monitoring and clearance application, a number of the requirements outlined above have already been implemented, as such SOCOTEC clients already benefit from many of the outlined improvements, such as photographic evidence on the Certificate of Reoccupation and recording of comments where the visual inspection takes 20% longer than expected.
References:
- HSG248 Asbestos: The analysts’ guide for sampling, analysis and clearance procedures. ISBN: 978 0 7176 2875 9, HSE, published 2005.
- Report on the Asbestos Analyst Inspection Programme, HSE, published November 2018.
