HSG264 The Asbestos Surveyors Guide

Posted on July 15, 2010 with 2 Comments

The SHP reported that In January this year, the HSE published new guidance on asbestos surveying, which explicitly advocates the need to be able to demonstrate and ensure competency. Martin Gibson, Martin Stear and Jon Murthy explain how both surveyors and duty-holders can do so.

The HSE estimates that asbestos-containing materials (ACMs) are still present in some 500,000 commercial properties in the UK. No one really knows how much asbestos still remains in UK buildings but those built before 1999, when asbestos was finally banned, are likely to still contain some, with those pre-dating 1985, when blue and brown asbestos were banned, causing the most concern.

The fact that some of the 6 million tonnes of imported asbestos remains in UK premises is the reason why the ‘duty to manage’ was introduced under the Control of Asbestos at Work Regulations 2002. Now Regulation 4 of the Control of Asbestos Regulations 2006, this requires duty-holders, i.e. those who own and/or occupy premises, to manage the ACMs in those premises.

Fundamental to the need to manage asbestos is the need to find it. Since the duty to manage came into force in May 2004, the number of people claiming to be able to find asbestos has increased exponentially. This, in turn, led to an increase in demand for training – in particular, the British Occupational Hygiene Society’s Proficiency Module P402 (Buildings Surveys and Bulk Sampling for Asbestos). This is one of a number of Proficiency Modules run by BOHS, all of which provide a basic minimum knowledge in the relevant topic area, but they do not (and have never claimed to) demonstrate competency.

Surveyors who gained this basic qualification were then expected to work with more experienced Asbestos surveyors for a minimum of six months. Despite this, some of those obtaining P402 were claiming to be competent and offering their services as a lead surveyor based on this qualification but with little, or no experience.

Accreditation – that’s what you need

There are now approximately 8500 P402-holders in the UK; many of these surveyors work in organisations that are accredited by the United Kingdom Accreditation Service (UKAS) to ISO/IEC 17020, the international standard for inspection activities.

These organisations have demonstrated to UKAS that they operate impartially, have a robust and effective quality management system in place, employ competent individuals, implement a robust quality-control programme, including routine site audits and resurveys, and follow current industry guidance. That guidance was HSE publication MDHS100 up to January 2010 but is now HSG264.

UKAS accreditation provides duty-holders with the confidence that their surveyors hold qualifications such as P402 and that they have progressed to be competent, and that the organisation has a suitable quality-management system in place. With regard to UKAS accreditation, HSG264 says it is “suitable for organisations of all sizes, where the scale and volume of surveying work dictates not only individual competence but also the need for more formal and well-defined quality-management systems”. More than 130 organisations in the UK are now accredited, which has helped improve standards of competency.

However, many P402-holders do not work for UKAS organisations. Some no longer survey and some work for duty-holders who obtained the qualification for in-house reasons, but many others are sole traders, or work in small surveying businesses. This is not to suggest that these individuals are not competent; some have been surveying for many years and are very able.

For these individuals their only easily-recognised demonstration of competency is the P402 qualification (other than their CV). Any “statement of competence” that these competent individuals make is essentially the same as those individuals who also hold P402 but don’t have their experience. In other words, the competent surveyors don’t hold any easily-recognised badge that identifies that they have the necessary knowledge and experience to survey.

The HSE recognised this problem many years ago and, in February 2009, UKAS accredited a personal certification scheme. The Asbestos Building Inspectors Certification Scheme (ABICS) now certifies asbestos surveyors against ISO 17024, providing a means for those individuals who do not work in UKAS-accredited surveying companies to demonstrate their competence. HSG264 says of the scheme: “Personal certification is designed for individuals who may operate as sole traders, or in small organisations with only a few surveyors. The scheme focuses on individual competence.”

ABICS certification is a three-stage process: a review of the individual’s survey reports and CV; an assessment of their practical skills; and a panel interview, covering building design and survey complexities. ABICS certification is a badge of professional competence for individual surveyors who have demonstrated that they have both the knowledge and experience to survey any type or size of premises. It is not a new P402, nor an advanced P402, but a true recognition that the individual has achieved competency in all areas of asbestos surveying for the grade for which they have applied (Class 1 – management-type surveys only, and Class 2 – management and pre-refurbishment/demolition surveys).

Everything to prove

The overarching aim of both the HSE and the industry is that all surveyors and surveying organisations can demonstrate competency, and that those who cannot are not employed by duty-holders.

Most people would not engage the services of an electrician, plumber, or accountant without the relevant qualifications and time served, and so it should be in the case of asbestos surveyors.

This is not to suggest that UKAS and ABICS are mandatory – they are not, but competency is! There are competent surveyors outside UKAS-accredited organisations, and/or who do not have ABICS certification but these individuals will have to work much harder to demonstrate their competency. And, of course, duty-holders can make their own judgements of competence by assessing the expertise and experience of the individuals or organisations themselves – the UKAS and ABICS schemes obviate the need to do so.

Ensuring that contractors are competent to carry out asbestos surveys should be a top priority for those responsible for managing the risks from asbestos. Employing a contractor with accreditation and/or certification means duty-holders can better and more easily meet their legal requirements.

The consequences of employing an incompetent contractor, who fails to find all the asbestos in a premises, can be significant. What the contractor missed is, all too commonly, found by an unsuspecting tradesperson, who inadvertently disturbs it in the course of their carpentry, electrical, or plumbing work. Around a thousand such workers die every year from asbestos exposure.

A less deadly though still costly outcome of such disturbances is a delay in the project and an expensive clean-up operation. Loss of product, stock or furniture, as well as the safe removal of the asbestos itself, can run into millions of pounds. Civil litigation, a HSE prosecution and bad publicity can all follow, bumping up the costs even further.

If asbestos is missed and the HSE becomes involved, the duty-holder will be asked about the checks of competency they made. HSG264 states that: “Where an external ‘surveyor’ (organisation or person) is appointed, they should be competent.” The duty-holder needs to be able to demonstrate that anyone to whom they delegate duties is competent to fulfil those duties.

HSG264 built on the lessons learnt since MDHS100 was published in 2001 and strongly advocates the need for the duty-holder and surveyor to work together to ensure that the survey type and scope directly match the needs of the duty-holder.

Surveyors need to understand building construction, building services and building types, as well as how and when to gain access to cavities, voids, risers, undercrofts, etc. The surveyor should be able to advise on when a licensed asbestos-removal contractor is needed as part of the survey, and they should also have a good knowledge of legislative requirements – otherwise they will be unable to provide competent risk and control advice for any ACMs that are discovered.

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