The HSE issued the long-awaited update of the Analysts Guide in July 2021. Since then, we have been updating our procedures, so Westland Environmental Safety comply with the updated guidance. Below are details of some of the changes Westland believes will have the main impact for our clients.
Handover Document
The analyst will not be able to proceed with the First Stage of the clearance procedure unless they receive a completed handover document from the supervisor (This confirms that the Site Supervisor has completed a thorough visual inspection and the enclosure is ready following the completion of all works as documented in the LARC’s Method Statement). The Westland Analyst will need to sign and photograph the completed handover document which will be inserted into the Certificate for Reoccupation Report. Failure to receive the document will result in a failure of Stage 1.
It is the licensed contractor’s legal duty to ensure that the work area is thoroughly cleaned
after work is completed and the area declared clear of visible asbestos materials before the independent 4-stage clearance procedure is carried out by the analyst. This includes dust and debris on all surfaces, items and equipment. The licensed contractor should complete a handover document to confirm that the area has been inspected and is visually clean. If the handover document is not available or not completed or there is any doubt regarding the cleanliness of the site, the 4-stage clearance should not be started. Receipt of the handover form should be recorded in the Certificate for Reoccupation.
Auditing
All authorised analysts need to be audited a minimum of 4 times a year this is up from once a year. Ontop of these witness audits the HSE are expecting all analytical to undertake a % of blind rechecks of the analysts’ completed Stage 2 visual inspections. The rechecks should ideally take place directly after the visual inspection undertaken by the analyst and will potentially add time to the job. There are also additional desktop audits required of the completedanalytical report. If errors are identified, the re-issue of the Certificate for Reoccupation to the Building Client and Licensed Asbestos Removal Contractor will be required (in-turn this could lead for internal training/Quality Control Actions to be taken).
10 Minute Rule
If the analyst deems there is more than 10 minutes of cleaning (remedial work to remove asbestos, fine cleaning, general dust/debris etc.) in the enclosure, the analyst must now issue a failure certificate and leave the enclosure rather than direct the supervisor/operatives to undertake the cleaning. The analyst is strictly prohibited from undertaking any cleaning works themselves as this is classed as licensed removal works. Once the remedial cleaning has been completed the analyst will need to start the clearance process from Stage 1 (The Site Supervisor will need to complete and further visual inspection and issue a signed handover document confirming the remedial work has been undertaken).
Box A5.4 Recording stage 2 additional cleaning and clearance failures on the Certificate for Reoccupation
If problems are encountered during any stage of the 4-stage clearance, the analyst should make a formal record of the situation and the discussion and action that took place to rectify them.
Stage 2 requires particular attention. If the enclosure has not been suitably cleaned, the
analyst must inform the licensed contractor that additional cleaning is required. The analyst
should make a judgement on the extent of additional cleaning likely to be necessary. The cleaning must be carried out by the licensed contractor. If the cleaning is deemed to be ‘minor’
(ie total cleaning time estimated to be <10 minutes) and is unlikely to breach the controllimit (0.1 f/ml 4-hour TWA), this can be carried out without a formal failure being recorded. The need for additional cleaning should be noted on the clearance certificate. The analyst can remain within the enclosure during remediation.
However, should the additional cumulative cleaning be estimated to exceed 10 minutes or be likely to exceed the control limit, the analyst should leave the enclosure (decontaminating as
appropriate) and issue a stage 2 failure certificate to the contractor outlining the reasons for the fail. This document will need to be signed by the supervisor as acceptance of the fail. Photographs should be taken of areas which have resulted in the clearance failure.
Following the issue of the failure the clearance process should start again at stage 1 when the removal contractor supervisor has undertaken a further visual inspection and has been assured that the area is fit for the clearance to proceed. The supervisor should issue the
analyst with a new handover document confirming that the area has been recleaned and is
suitable for independent inspection.
The analyst should make a judgement as to whether full decontamination will be necessary in these circ*mstances.
Failures
Off the back of this rule, we are expecting the amount of failed visual inspections to increase. This in turn is likely to add more time to removal projects.
Planning the work
The HSE have stated that the analytical company puts more time into planning the 4SC. This will require Westland to have access to the LARC’s method statement at least a week prior to the project. Westland will pass all the relevant information to the analyst and for more complex projects issue our own method statement to the Analyst.
The Analyst will also be allowed time before the project to review all available information to assist them with calculating the estimating visual inspection time.
Before starting the stage 4 clearance
The scope of the work should be established at the contract stage to make sure that appropriate time and resources are allocated to the job.Obtain the signed handover document from the licensed contractor confirming thatthe work area/enclosure has been thoroughly cleaned and the area has beeninspected and is visually clean.Sign and date the document.
Stage 1
Confirm scope of work.
Obtain or prepare diagram showing areas requiring clearance.
Visually check
- DCU
- enclosure surrounding areas, waste and transit routes.
- integrity of enclosure
- interior of enclosure using viewing panels/CCTV.
Estimate time through visual inspection will take and record it in the CfR.
Stage 2
Thorough visual inspection inside theenclosure.
Check:
- the completeness of the removal of ACMs from the underlying surfaces;
- for any visible debris including in the airlock and baglock (all compartments);
- for the presence of fine settled dust.
Stage 3
Air sampling inside the enclosure. Sample for 30 minutes at 16 l/min. Collect 480 litres per sample.
- Disturb surfaces at the start of air sampling:
- by sweeping floors with long-handled brush;
- by brushing other surfaces
- brush/sweep for at least 1.5 minutes per sample.
All air sample results must be <0.010 f/ml.
Stage 4
After the dismantling of the enclosure, visually inspect area where enclosure was located.
Reinspect waste and transit routes for asbestos debris.
DCU clearance process
Visual inspection of the clean end.
Thorough visual inspection of shower area and dirty end.
Air sampling in the shower area and dirty end.
Separate shower and dirty end samples should be collected where combined area exceeds 10m². Collect 480 litres.
Disturb surfaces by sweeping floor for 1.5 minutes per sample.
Estimating the length of time of the visual inspection
As part of the planning of the 4SC the project manager and analyst will estimate the time that they think a visual inspection will take. They will then allocate this time to the project and inform the client of the timescales. If the visual inspection takes 20% -/+ then this discrepancy must be justified and recorded. Records of the visual inspection timings will be documented in the Certificate for Reoccupation Report.
ACM
Location
Size of area or volume
Complexity
Estimated time required
AIB
AIB
Ceiling tiles plus void
500-600 m²
Very difficult
8 Hours
AIB
removal Selective ceiling tile
200-300 m²
time-consuming Not very complex but
3-4 hours
AIB single panel
small enclosure Domestic cupboard,
6-10 m²
pipes, shelf, skirting etc Not very complex. Some
up to 1 hour minutes but 15-30
AIB soffit
External
metres 20-40 linear
with mobile platform Not complex but high-level
1-4 hours
AIB
Panel(s) below window
20-30 m²
Not complex
0.5-2 hours
AIB
Ceiling tiles plus void
25-50 m²
trays Quite difficult. Services, cable
1-4 hours
AIB
Ceiling tiles plus void
100-150 m²
trays Quite difficult. Services, cable
2-6 hours
AIB
Ceiling tiles plus void
200-300 m²
trays. Time-consuming Quite difficult. Services, cable
4-8 hours
Lagging/insulation
Pipe insulation/lagging
Boiler room
(vessels) (150-300 m³) (pipes) 50-100 m²
pipes, ledges Complex. Various vessels,
1-2 days 2-4 hours to
previous removal remnants from Pipe insulation/lagging
Boiler room
(vessels) (150-300 m³) (pipes) 50-100 m²
pipes, ledges Complex. Various vessels,
1-2 days 2-4 hours to
(lagging/AIB) Asbestos debris
Ceiling void
25-50 m²
Time-consuming Services, cable trays. Quite difficult.
1-6 hours
Photographs & videos
Westland already issue reports with photographs. The HSE have now instructed that the photographs are time stamped and have outlined minimum photograph standards (number of photographs and what needs to be photographed). They also recommend using videos for more complex clearances.
Areas/items to be photographed (photographs should be in colour)
Stage 1
1
Skip area and waste route are free from obvious asbestos debris and waste bags
2
Transit route is clean and free from obvious asbestos debris and waste bags
3
The DCU is free from obvious asbestos debris and waste bags. Photos should be taken of the clean end, shower and dirty end
4
The areas surrounding the enclosure/work area are free from obvious asbestos debris and waste bags
Stage 2
1
The airlock and baglock are free of waste bags, materials and unnecessary equipment
2
All ACMs have been completely removed (as far as reasonably practicable) from the underlying
3
The interior surfaces inside the enclosure are free from debris and fine settled dust Sufficient photos should be provided of the enclosure including high-level surfaces (including scaffolding)
Stage 3
1
The areas are dry. Sufficient photos should be provided to cover the relevant area(s)
2
The NPUs are sealed
3
The sampling pumps in each of the sampling locations
3
The brush used for disturbance of surfaces
Stage 4
1
The former enclosure area Sufficient photos should be provided to cover the relevant area(s)
Areas/items to be photographed (photographs should be in colour)
Clean End
1
Main view of the clean end showing area is clean and free from storage debris and waste sacks
Shower area
1
Area is free from stored items, obvious debris and waste and is dry
2
Airborne sampling equipment
Dirty end
1
Area is free from stored items, obvious debris and wasteThe areas are dry. Sufficient photos should be provided to cover the relevant area(s)
2
The NPUs are sealed
UKAS
UKAS accreditation body are yet to release the latest version of Lab 30 (UKAS’s interpretation of the guidance). We have updated our procedures to best match the new guidance and will update you with any changes once Lab 30 has been released.
Personal monitoring
The new guidance places more emphasis on Time Weighted Averages. As such we have developed a form for calculating exposures over a four-hour period and have moved away from undertaking hour long personal air tests.
New Report Format
To comply with the new guidance, we have had to alter our four-stage clearance paperwork to ensure it is compliant with the new guidance. We will issue an example of this once it has been approved by UKAS.
Westland are planning to fully transition to the new guidance from W/C 17thJanuary. In the meantime, if you have any questions about how the guidance will affect you, please feel free to contact us.
