» Asbestos Technical Bulletin Issue 2
06 January, 2014
There have been numerous changes since Issue 1 and so these are not highlighted within the document. Therefore the bulletin needs to be read in its entirety.
As part of UKAS’s commitment to providing a valid accreditation service to the asbestos sector UKAS reviews its asbestos-related policies, procedures and requirements on an ongoing basis through the Asbestos Technical Advisory Committee (a list of committee members and summary of minutes are available on the UKAS website www.ukas.com). UKAS also continues to discuss the assessment of the requirements of ISO/IEC 17020, ISO/IEC 17025 and sector-related publications, to ensure a consistent assessment approach, during its regular Asbestos Technical Assessor meetings.
UKAS will publish Technical Bulletins relating to accreditation within the asbestos sector to ensure all applicant and accredited organisations are aware of any necessary clarifications, interpretations, updates or changes to UKAS policy, requirements where issues have been raised, discussed and agreed at the above meetings. The content of these bulletins will be incorporated into relevant UKAS Publications (i.e. LAB30 and RG8) at their next revision.
The following items are included in this bulletin, some of which are continued from the first bulletin issued in 2010:
- Asbestos in soils analysis – screening, identification and quantification
- Colour blindness testing
- BOHS P403 Qualification (September 2010)
- Field blank samples
- Asbestos testing – electron microscopy
- Laboratory accommodation / environment – monitoring
- Independence within the 4-Stage Clearance Process – Policy Review:
- Multi-site accreditation and satellite offices
- Asbestos testing of bulk materials – how many samples?
- 4SC Preventive action and improvement.
- Asbestos qualifications (Feb 2012)
- S301 replacement criteria for IBs
- ASBESTOS SURVEYING: Reissue of ISO/IEC 17020 and HSE Guidance HSG 264
- Surveying for Asbestos in Marine Vessels
- Survey Reinspections
1. Asbestos in soils analysis – screening, identification and quantification
It is common knowledge that testing laboratories in the UK need to be accredited to ISO/IEC 17025 by UKAS in order to provide an asbestos testing service: This is a specific requirement of CAR: 2012.However, there is an apparent degree of uncertainty regarding the mandatory status of accreditation with respect to analysis of asbestos in soil.Therefore the following points provide clarity on this matter:
- Asbestos in soil is covered by the Control of Asbestos Regulations 2012, and therefore if a laboratory is offering an asbestos testing service with respect to soil samples then accreditation to ISO/IEC 17025 is required.
- If the analysis involves removing defined pieces of asbestos-containing material (ACM) from soil samples and analysing these in accordance with HSG 248 then such analysis will be covered by standard UKAS bulk analysis accreditation. The report shall clearly state the matrix of the sample being that of the ACM. The report shall not state soil as the matrix. The contract review process completed prior to undertaking this work shall ensure the customer is aware of the remit and limitations of this asbestos in bulk material analysis. Staff undertaking the analysis must hold the BOHS P401 qualification (or equivalent) as a minimum, for all aspects of the procedure (including the selection of the defined pieces of ACM).
- If the laboratory is contracted to identify asbestos fibres in soil then it will need to employ additional preparation techniques to those generally employed for ACMs. Therefore the laboratory will have to demonstrate its competence to undertake such preparations to UKAS; where this is not included within the scope of accreditation the laboratory shall seek an extension to scope. Once this activity has been satisfactorily assessed ‘soil preparation and identification’ shall be included on the laboratory’s schedule of accreditation. This accreditation for identification of asbestos fibres will appear as a separate entry on the UKAS schedule of accreditation. The resulting reports from this analysis shall state soil as the matrix but cannot report any quantification of the asbestos content. Staff undertaking the analysis shall hold the BOHS P401 qualification (or equivalent) as a minimum.
- Analysis to establish the quantification of the asbestos content again requires additional procedures, and therefore the laboratory shall demonstrate its competence to undertake such preparations to UKAS, which could be by way of an extension to scope. Once this activity has been satisfactorily assessed, ‘soil – preparation, identification and quantification’ shall be included on the laboratory’s schedule of accreditation. Staff undertaking the analysis shall hold the BOHS P401 qualification (or equivalent) as a minimum. If the quantification involves fibre counting, then the relevant qualification should be held by the organisation as a minimum (BOHS P403 or equivalent). It is not a legal requirement for a Laboratory to hold UKAS accreditation for quantification of asbestos in soils
- If a laboratory (such as a soil testing laboratory) is visually checking soil for signs of potential ACMs for its own Health & Safety purposes, and this information is not being reported to the client, then the laboratory does not need to be formally accredited to ISO/IEC 17025, and the staff involved do not need to hold a formal qualification. Please note - This process cannot be used to report results to the customer by omission. For example, by informing a customer that a sample cannot be analysed due to its content immediately indicates the sample as containing asbestos. It needs to be reported that asbestos is suspected not confirmed.
2. Colour Blindness Testing
Staff undertaking analysis of asbestos by stereo-microscopy, polarised light microscopy and dispersion staining (e.g. in bulk materials and soils) are required to undertake a colour blindness (e.g. Ishihari) test. UKAS will not accept Ishihara tests that are available on-line, via the internet (LAB 30 April 2008 – clause 7.3.2) or by power point as this may affect the validity of the test. Organisations conducting colour blindness assessments in-house must use the correct colour plates and have a member of staff competent to accurately interpret the results. Where identified records must clearly demonstrate continuing suitability of an individual as an analyst with assigned condition.
3. BOHS P403 (post September 2010)
To clarify some queries UKAS has received, regarding the changes made by BOHS to the P403 module in September 2010. UKAS policy changed in that only the P403 is required to be held by any person undertaking both sampling / fibre counting air monitoring exercises e.g. reassurance testing, background testing, as part of a static regime of testing etc. Both the P403 and P404 are still required for any person wishing to conduct the 4SC in addition to air sampling/fibre counting.
4. Field Blank samples
It is a requirement for all organisations to ensure staff always expose, prepare, mount and retain a field blank sample for each job undertaken. Organisations need to define a ‘job’ to ensure field blanks are sufficiently traceable
5. Asbestos testing – electron microscopy
- LAB 30 clause 6.1 also applies to organisations undertaking asbestos testing by electron microscopy. Authorised staff shall be audited (including witnessing staff undertaking the testing and sufficient oral questioning) once every 12 months as a minimum.
- LAB 30 clause 3.0 – suitable PT schemes are available for laboratories undertaking asbestos testing by electron microscopy and organisations are required by both LAB 30 and UKAS document TPS 47 to participate in an appropriate scheme, where such a scheme is available. As an example, asbestos identification testing providers using SEM/EDXS (in place of PLM) should participate in AIMS. AIMS will not be appropriate for labs that undertake fibre counting by SEM/EDXS, (and only report results as fibre concentrations and then divide into classes such as amphibole, chrysotile, organic etc. (as described in the ISO 14966 method)). Rather Laboratories undertaking fibre counting (including classification/identification of fibres) should participate in the SEMS PT scheme.
- LAB 30 clause 15.1.1 and 15.1.2 – Internal QC schemes need to be established and implemented by organisations undertaking asbestos testing by electron microscopy. All authorised staff must participate in these internal QC schemes.
6. Laboratory accommodation & environment- monitoring
An organisation undertaking asbestos analysis in bulk material samples shall undertake monthly in-house air measurements within the laboratory. The Control of Asbestos Regulations 2012, ACOP para 340, requires an employer (carrying out their own measurements or employee exposure monitoring) to ensure that employees carrying out this work receive similar training supervision and quality control to those required by ISO/IEC 17025.
Section A2.8 of HSG248 (The Analysts Guide), states “When the handling of asbestos-containing materials is frequent, airborne exposures should be assessed as required by CAWR. In any case, it is recommended that regular air monitoring (on a monthly basis) is conducted in the preparation/identification area, and that the results are recorded”.
These points have recently been reviewed and discussed within UKAS, and with the HSE, in response to an appeal against a mandatory finding. The outcome of this review was to confirm the requirement that the monitoring needed to be undertaken in accordance with the requirements of A2.8 of HSG248, i.e. by determining that the concentration of fibres in the atmosphere did not exceed accepted levels. Therefore there is no change in policy for assessing this aspect and laboratories are reminded that this monitoring needs to be undertaken either by a UKAS accredited laboratory (for air monitoring / fibre counting) or in-house meeting the requirements of ISO/IEC 17025 and UKAS publication LAB 30 (with supporting documented records to demonstrate compliance).
7. Independence within the 4-Stage Clearance Process – Policy Review
The UKAS process for assessing and accrediting the 4-Stage clearance procedure was developed in consultation with stakeholders in 2004. At that time it was acknowledged that although aspects of the clearance procedure were already covered by ISO/IEC 17025, other aspects were better suited to ISO/IEC 17020 (as inspection activities). Rather than split the accreditation of this procedure between the two standards it was agreed that accreditation would be granted to ISO/IEC 17025, although the key requirements from ISO/IEC 17020 would be built into the assessment. These requirements were published within Guidance for the 4SC pilot project, and later transferred to LAB 30.
LAB 30 Clause17.2 makes it quite clear that an asbestos analyst cannot undertake clearance work for an organisation with which they have a relationship. In 2009 UKAS decided to review this policy to determine whether or not it was providing confidence in the impartiality of the 4SC procedure. As a consequence a proposal was tabled at the UKAS Asbestos Technical Advisory Committee in July 2009 to revise the existing policy. The proposal, which suggested removing the total prohibition in favour of controlled management, was discussed at length and as no consensus was reached it was agreed to allow HSE additional time to discuss this matter internally.
As one of the primary Regulators in this area, it is important to take account of the views of HSE, whose response was in favour of leaving the policy as it was, on the grounds that independence and impartiality of the analyst is seen as a key element in ensuring external influences are minimised.
The decision of UKAS following this review, taking into account the strong views of HSE and a lack of consensus with the TAC, was not to make any change to the policy as stated in LAB 30. Therefore the UKAS policy on requiring the analyst to be independent of the body commissioning the clearance remains.
8. Multi-site accreditation, satellite offices and temporary sites
Accredited organisations are reminded of the requirements within the UKAS Agreement to inform UKAS of any significant changes within their organisation and operations. Two changes to note here are key staff and location changes. This includes changes in Technical and Quality management and any changes to the operational locations. UKAS must be notified of all offices associated with the accredited organisation and confirmation that work is / is not undertaken at or away from that office (including any aspects of contract review). The Assessment Manager will then determine if this needs to be included on the schedule of accreditation and included within the 4 year accreditation cycle. UKAS must also be made aware of temporary site office / laboratories set up for longer term contracts (those >8 weeks) e.g. power stations, and sites including non-UK domicile locations. Please ensure all this information is communicated to your UKAS Assessment Manager as soon as it is known (e.g. staff notice given, contract agreed etc): If unsure of the significance of the change then please bring to the attention of your Assessment Manager. Further information on multi-site accreditation can be found within UKAS publications TPS 51 & TPS 59 (www.ukas.com)
9. Asbestos testing of bulk materials – how many samples?
This issue was discussed and documented within the UKAS Asbestos Technical Advisory Committee meeting minutes (July 2009), and these minutes are available on the UKAS website. It is included here as a reminder to those organisations undertaking bulk sample analysis. Taken directly from the minutes:
“UKAS outlined the issue that arose out of a nonconformity raised at a laboratory where staff had been processing up to 150 samples per day (each), although the lab in question had identified this as a problem, the ceiling limit on samples per analyst per day (before investigation was to be undertaken) was deemed not acceptable by the UKAS Team. The first proposed limit – 70 samples / 90 points was rejected by UKAS as unacceptable, this level of work still AVERAGED sample times as 6 mins per sample considering standard breaks in an 8 hr shift, however the laboratory struggled to understand why this was an issue. The additional QC was still being undertaken as per HSG248 however the person undertaking the QC was also undertaking 70 samples per day. It was finally agreed 50 samples / 60 points; however this lab now wants to revert back to 70 samples / 90 points (already previously rejected by UKAS). This was raised and discussed at the Asbestos TA meeting and agreed any laboratory undertaking more than 60 samples and 70 points per analyst would be subject to further investigation and the laboratory to justify the approach / acceptance of this number. This assessment policy has been implemented by all assessors since April 09 however it remains difficult for UKAS to pin this on any requirements of HSG248 (although ISO17025 has requirements with respect to pressure / influence on staff). Feedback from UKAS Technical Assessors includes more guidance in the next review of HSH248 is required and appreciated by all (both UKAS and the testing labs). Time per sample type rather than numbers of samples (this eliminates pressure on staff to multitask and complete numbers of samples and also other testing or surveying work). Assessors are requesting more reanalysis during annual visits – and are finding some issues here, amounts of cargille liquid being used is also checked as is those labs where NAD samples are not being included in the “pointing”. UKAS has already liaised with ATaC w.r.t. ATaC gathering some information from its members on what they believe to be realistic numbers per day per analyst.
Members agreed the numbers of 90 -150 samples is not possible and unfair treatment of analysts (which is what HSG248 was trying to avoid with the 40 points guidance). Members also agreed the upper limit does need to be considered.
Members agreed more guidance is needed (HSG248 app2 wording needs to be improved) and that the policy currently implemented by UKAS (i.e. 60 samples / 70 points) is acceptable.
HSE confirmed that the 40 points was intended to be the maximum, although it does not necessarily read as such. The revised HSG248 will strengthen the language and the revise the points / numbers currently documented.
UKAS will continue to assess and investigate further if laboratories consistently analyse >60 samples or >70 points per analyst per 8 hr shift”
10. 4SC – queries / complaints, preventive action and improvement
Both UKAS and accredited laboratories frequently receive complaints and queries regarding the discovery of dust / debris in an area previously cleared following the 4SC process. Not all of these complaints are justified, however, without sufficient evidence to demonstrate the area was clean at the time of issuing the certificate of reoccupation it can be difficult to resolve.
Accreditation to ISO/IEC 17025 includes the requirement to implement preventive actions and improvement initiatives. Organisations should consider implementing a re-inspection programme of analysts work (i.e. revisiting a site immediately or soon after the COR has been issued – to be undertaken more frequently than the LAB 30 requirement to audit staff) and also consider the analysts utilising visual media (photographs / video) to record the cleanliness of the area post stage 4 of the process. Traceability of the date / analyst etc relating to any photographs / video footage does need to be considered.
11. Asbestos qualifications (Feb 2012)
UKAS has previously set its policy on asbestos surveyor and analyst qualifications following input and recommendations from its Asbestos Technical Advisory Committee. This policy is stated in UKAS publications LAB30 for testing and RG8 for inspection, which require that all analysts and surveyors must hold formal recognised qualifications (in addition to demonstrable knowledge, experience and in-house training) in order to be authorised to undertake specified asbestos activities.
Previously, the main provider of qualifications recognised by UKAS has been the British Occupational Hygiene Society (BOHS), through its Proficiency Modules. However, more recently Asbestos Testing and Consultancy (ATAC) submitted a proposal to the UKAS Asbestos Technical Advisory Committee requesting that its newly developed qualifications, administered by Royal Society for Public Health (RSPH), also be formally recognised. After reviewing the course content, and feedback from a short pilot, it has been agreed that these qualifications will receive equal recognition from UKAS to the P Modules provided by BOHS.
As a consequence, as of 14 February 2012, UKAS recognised the following qualifications as suitable in providing evidence towards an individual’s competence:
- P402: Buildings Surveys and Bulk Sampling for Asbestos
- RSPH Certificate in Asbestos Surveying*
- BOHS Certificate of Competence in Asbestos
* This qualification does not include any report examination and therefore Organisations need to ensure training has been provided to allow surveyors to write/produce survey reports and determine their suitability.
Asbestos Bulk Identification:
- P401 – Identification of Asbestos in Bulk Samples (PLM)
- BOHS Certificate of Competence in Asbestos
Asbestos Air Sampling & Fibre Counting:
- P403: Asbestos Fibre Counting (PCM) (including Sampling Strategies)
- RSPH Certificate for Asbestos Analysts (Air)
- BOHS Certificate of Competence in Asbestos
Asbestos Four Stage Clearance:
- P404: Air Sampling of Asbestos and MMMF and Requirements for a Certificate of Reoccupation Following Clearance of Asbestos
- RSPH Certificate for Asbestos Analysts (Air)
- BOHS Certificate of Competence in Asbestos
Further details on these qualifications can be found at:
12. S301 replacement criteria for Inspection Bodies
UKAS requires inspection bodies to have at least 1 person in a position of responsibility holding, as a minimum, the S301 and P402 qualifications (supported by knowledge & experience). With the change by BOHS in replacing the S301 with the international qualification, W504 (2012/13) this policy was reviewed. Following a proposal considered at a previous TAC meeting UKAS will now accept the P405 in addition to P402 or RSPH qualification in place of the S301. However, only P405’s issued after February 2004 will be accepted. The S301 will continue to be accepted as previously acknowledged.
13. ASBESTOS SURVEYING: Reissue of ISO/IEC 17020 and HSE Guidance HSG 264
Notification to asbestos surveying bodies on the impact to accreditation following the reissue of ISO/IEC 17020 (March 2012) and HSG 264 (April 2012)
ISO/IEC 17020: 2012
In March 2012 the standard used for the accreditation of asbestos surveying organisations and other Inspection Bodies (ISO/IEC 17020: 1998 General criteria for the operation of various types of bodies performing inspection) was reissued.
A transition plan for bodies currently accredited to ISO/IEC 17020:1998, or in the process of being accredited, is currently in place. All ISO/IEC 17020 accreditations will need to have transferred to the 2012 version by 1st March 2015 in order for accreditation to be maintained:
Specific guidance on this was provided by UKAS in November 2012: ‘Transition Arrangements’.
HSG 264: 2012
In April 2012 HSE reissued HSG 264: Asbestos – The survey guide, replacing the first edition issued in 2010. Clarification from our colleagues within HSE has confirmed that the changes are very minor and, in summary, are as follows:
- References to the Control of Asbestos Regulations have been updated to the 2012 version;
- An addition made in paragraph 7 to confirm that prohibitions are now in the REACH Regulations 2007;
- Reference in paragraph 24 on the ABICS surveyor certification scheme has been updated to reflect the fact that it is no longer operational;
- In addition a few other minor typographical errors and updates to references, etc. were made.
The new edition of HSG 264 can be downloaded free of charge from the HSE website (www.hse.gov.uk/pubns/). Alternatively hard copies can be ordered from HSE. However, please note that as the changes are of such a minor nature that they have no bearing on the performance of asbestos surveying, UKAS will continue to accept surveyors holding official hard copies of the 2010 first edition. If this is the case then the organisation will be expected to hold at least one 2012 version (hard or electronic) within its management system.
14. Surveying for Asbestos in Marine Vessels
The UKAS process for assessing and accrediting asbestos inspection bodies was developed at the request of the Health and Safety Executive (HSE) in 2001. The subsequent pilot scheme was based on a programme to support the requirements of MDHS100 in non-domestic premises.
Current schedules of accreditation for asbestos inspection are based on the initial scheme along with subsequent guidance as issued by the HSE. These are supported by ongoing assessment by UKAS of organisations accredited to ISO/IEC 17020 of domestic, commercial and industrial categories of land-based buildings.
For marine vessels used within international waters and registered with the International Maritime Organisation (IMO) the requirements for surveying of such ‘premises’ differ from the current UK guidance as currently published in HSG 264, and which UKAS accreditation of asbestos surveying is currently based. Although UKAS recognises that UK Regulations cover the normal operation of marine vessels in UK waters and docks, separate accreditation will be required for those organisations that wish to undertake surveys of marine vessels to an accredited standard including:
- Cargo vessels
- Passenger vessels, and
- Off-Shore vessels and Facilities
as specified by the Safety Of Life At Sea (SOLAS) Convention Chapter II-1, Regulation 3.5.2 (1974 as amended) for the sole purpose of generating asbestos condition reports, (Initial, Verification and In-service, including management recommendations where appropriate).
This decision has been based on a pilot assessment which was tailored to address the specifics associated with surveying of marine vessels. This identified (amongst other aspects) that the technical competence required to undertake such surveys differed significantly from experiences associated with normal land-based building surveying.
UKAS would be willing to develop an accreditation programme for this sector to meet the needs of its customers and stakeholders (such as the Maritime and Coastguard Agency). However, it does recognise that work will be required in order to ensure the programme is fully effective in determining the competence of asbestos surveying on marine vessels, and in meeting relevant international guidelines and requirements as well the minimum requirements of ISO/IEC 17020. Therefore dependent on feedback from stakeholders, if sufficient support for such a programme is received then UKAS will look at the viability for setting up a development project and steering committee to take this forward.
Any organisation with a keen interest in participating in such a pilot programme should contact George Sanders at: George.Sanders@ukas.com.
UKAS considers marine vessels at this moment in time to mean boats/ships and (actively) mobile platforms. UKAS understands that a number of Inspection Bodies are involved with surveys within the marine sector. Therefore where IBs have been surveying fixed rigs & platforms, they will be permitted to continue to do so under 'industrial premises', so long as competence has been suitably demonstrated. However, IBs should be aware that the UKAS position may change in the future pending input from marine stakeholders if a development project and steering committee is developed.
15. Survey Reinspections
If an Inspection Body (IB) is accredited for management surveys then reinspections (as undertaken to comply with Reg 4 of CAR L143) are covered by its accreditation.
The process of a reinspection is (by strict definition) to re-assess the condition of previously identified asbestos containing materials (acms) only. Accredited IBs use standard methodologies to achieve this, as they would do in completing a normal management survey. Given survey methodologies are assessed by UKAS as part of the accreditation criteria, then an IB can produce a report in this instance which fulfils accreditation requirements.
Because the requirements for conducting reinspections fall within the criteria for a management survey, UKAS schedules of accreditation do not specifically highlight ‘reinspections’ as a separate entity.
Persons conducting re-inspections must be appropriately qualified, trained and authorised.