» Announcement to Asbestos Inspection Bodies Regarding HSG264
04 March, 2010
IMPORTANT INFORMATION FOR ALL INSPECTION BODIES ACCREDITED BY UKAS: SURVEYING FOR ASBESTOS IN PREMISES.
Implementation of HSG264 – Asbestos: The Survey Guide (2010)
In January 2010 the HSE formally published HSG264 ‘Asbestos: The survey guide’. This document replaces and expands upon MDHS100, ‘Surveying, sampling and assessment of asbestos containing materials’. It is aimed both at people who carry out asbestos surveys and persons with specific responsibilities for managing asbestos in non domestic properties under the Control of Asbestos Regulations 2006. HSG264 covers competence, quality assurance and surveying: including survey planning, survey approach, survey reporting and the duty holders use of the survey information.
With the publication of HSG264 the existing guidance for the surveying for asbestos in premises, MDHS100, is being withdrawn.It is therefore necessary for all accredited inspection bodies undertaking surveying for asbestos activities to transfer their accredited services to the new guidance included within HSG264.
Following discussions with the Health & Safety Executive and UKAS Asbestos Technical Advisory Committee it has been agreed that UKAS will adopt the following process in implementing the guidance in HSG264:
1) UKAS shall expect that all guidance within HSG264, relevant to the accredited activities of the inspection body, will either be implemented directly or that an internal procedure is implemented that achieves at least the same outcome that the guidance is looking to achieve, subject to the approval of the UKAS assessment team.
Compliance with the guidance within HSG264 should be reviewed internally by inspection bodies and implemented as soon as practicable after the document is published.UKAS shall expect all inspection bodies to initiate this review and implementation with immediate effect.
2) Transition from MDHS100 to HSG264:Although MDHS100 has been withdrawn, all UKAS schedules covering surveying for asbestos in premises still make reference to it. UKAS is now planning the controlled revision of affected schedules in order to update the reference to HSG264.The process for this transition has been carefully considered and the decision taken to issue all updated schedules at the same time (03 May 2010) so that this does not commercially disadvantage any inspection body.
However, there are some changes / enhancements within HSG264, not previously documented in MDHS100, which UKAS shall require to be implemented.
(i) Quality and Technical manuals, controlled documents, survey data capture systems, report templates, marketing
- Inspection bodies (IBs) will need to review all documents and make necessary changes to references to MHDS100 and survey types, withdraw all controlled copies of MDHS100, and issue controlled copies of Asbestos: The Survey Guide together with amended copies of Quality and Technical Manuals as appropriate. IBs will also need to consider the content of their various web sites and marketing materials and make appropriate changes.
(ii) Contract Review
- IBs will need to review their use of caveats, both within their standard Terms & Conditions and report templates and seek agreement with clients to remaining caveats at the contract review stage;
- IBs will need to consider what specialist support services and equipment they may require for gaining full access during Refurbishment and Demolition surveys;
- IBs will need to review their reporting and approval process and may need to introduce and document a system for checking finished reports against client’s requirements;
- IBs will need to review, in conjunction with their clients, long-term contracts which reference MDHS100 as a requirement.
(iii) Training and Competence
- IBs will need to review and amend their training programme, records and authorisation criteria and may need to amend authorisations as appropriate, particularly for recent appointments with existing qualifications;
- IBs will need to consider further training of site staff in Site Risk Assessment.
(iv) Site Work
- IBs will need to review and may need to revise their survey planning procedures and instructions to ensure that a robust and adequate Plan of Work is in place to cover the site survey work. IBs will need to review and may need to revise their sampling strategies;
- IBs may need to amend their technical procedures and survey templates to ensure that sufficient detail is captured during the survey to enable materials assessments to be reported in certain Refurbishment and Demolition survey reports;
- IBs will need to review and may need to revise their procedures for gaining access and reporting inaccessible areas.
- IBs should review their standard report templates to ensure that the headings contained in the guidance are included and that materials assessment is reported as appropriate in Refurbishment and Demolition survey reports.
It should be noted that a number of the above points may require an element of retraining of technical and administrative staff.Such training shall be documented.
In determining the most efficient and cost-effective way of managing this transition, it was decided that UKAS would employ the following mechanism:
Rather than requiring an inspection body to demonstrate that the required enhancements have been addressed, either by way of an extra visit or submission of documentary evidence, acceptance of compliance will be acknowledged following receipt of a formal declaration by top management confirming that their inspection body has implemented the additional requirements of HSG264 within its management system.
All fully completed declaration forms returned to UKAS on or before 30 April 2010 will result in those inspection bodies’ schedules being updated and published on 03 May 2010 (UKAS will not be in a position to update the schedule on this date for any inspection body that fails to submit the completed form by 30 April).
Where the form has not been returned by 30 April 2010 the inspection body will continue to hold a schedule referencing MDHS100; these inspection bodies must return their completed declaration form to UKAS on or before 30 July 2010. Schedules relating to these inspection bodies will be updated and published as the declaration is received.However, this arrangement will only exist until 30 July 2010, after which date UKAS shall be withdrawing ISO/IEC 17020 accreditation for the asbestos surveying activities of any body that has failed to declare or demonstrate that they have made the necessary amendments to comply with HSG264.
3) UKAS assessment teams will include the requirements of both MDHS100 and HSG264 in their assessments between 30 January and 30 April 2010, raising mandatory findings where non-compliance with MDHS100 is identified and recommendations where the enhanced requirements of HSG264 are not being met: These recommendations shall be expected to be implemented at the earliest opportunity. After 30 April 2010 the UKAS teams’ assessments will be raising mandatory findings where noncompliance with HSG264 is identified.
Please ensure that you fully read and understand the content of this announcement, and disseminate it to your inspection body staff as appropriate.Your UKAS assessment team shall be looking to ensure that your inspection body complies with the guidance in HSG264 (as stated in point 1 above), and in particular that you have implemented the relevant requirements relating to the surveying for asbestos in premises as covered in point 2, and confirmed in your signed declaration.
If you have any queries on the above points, please contact your appointed Assessment Manager