HSG248 Asbestos: The Analysts Guide – impact on four stage clearance testing
One of the hot topics among our clients is the new Analysts’ Guide and what effect this will have on four-stage clearance testing.
When the first draft of the new Analysts Guide was originally issued for consultation, Vintec quickly adopted a number of the proposed improvements. These included adding photographs to our air monitoring reports and the four-stage clearance certificates. We also updated the way we record and report personal exposure monitoring to include all the details requested in the draft guidance. Our Analysts were issued with updated advice on entering enclosures, transiting procedures and personal decontamination. We were proud to be ahead of the curve and ready for the changes as and when they were implemented by HSE.
The main changes being implemented are:
• Introduction of the enclosure handover form
• The requirement for the Analyst to advise the client/LARC of the estimated time to complete the clearance (If the actual time differs by more than 20%, the Analyst must record the reason on the certification).
• The stage 2 visual inspection will be failed if the enclosure requires any more than ten minutes extra cleaning.
• During large visual inspections Analysts will be required to take a break every hour if wearing non-powered RPE. This is in line with HSG53: Respiratory protective equipment at work.
• Additional guidance for Analysts using the decontamination unit and a requirement to not wear street clothes under their disposable coveralls.
• A comprehensive photographic record of all four stages of the clearance.
Improvements to Scoping and Planning
In addition to the above, the new guidance proposes that the Analyst should be more involved with the planning and scoping of the removal work. This includes assisting with the preparation of the plan of work.
This is to be achieved by holding a pre-start site visit so all parties can discuss the proposed work, any foreseeable difficulties, allocation of resources and likely timescales for both removal and subsequent four-stage clearance testing.
It is unlikely that the pre-start meetings will be required for the simpler enclosures but where more complex enclosures/projects are being tackled, this new approach could prove to be invaluable.
Need for better standard of cleaning by Licensed Contractors
The Analyst will not now be able to enter the enclosure or commence testing until the LARC’s supervisor has completed and signed an enclosure handover form. The form confirms that the supervisor has completed his/her own visual inspection and is happy that all abatement works are complete and the enclosure is ready for testing.
The new guidance requires significant strengthening of the quality control for Analysts carrying out four-stage clearance testing. The new guidance requires more frequent on-site auditing of Analysts (minimum of four audits per year) as well as ongoing desktop review of completed four stage clearance certificates.
The revised guide also requires that 5% of four stage clearance tests should be re-inspected by an independent Analyst. This will require the stage two visual inspection to be repeated once the first analyst has completed his/her assessment.