On Monday 17th May 2021, UKAS and HSE hosted a webinar to provide detail of the revisions to its Guidance document, HSG 248 The Analysts’ Guide and the transition process for laboratories that are currently accredited for:
- Sampling of air for fibre counting
- Fibre counting (PLM/PCM)
- Fibre counting (air and/or bulk) and identification (SEM/TEM)
- 4 Stage Clearance Process
- Identification of asbestos in bulk materials
- Sampling of bulk materials for asbestos identification
- Asbestos in soils – primarily identification, but also of interest to those laboratories that retain accreditation for quantification purposes.
You can view a recording of the webinar here.
A number of questions were raised by participants of the webinar. Additional questions posed of a technical nature have since been answered by the HSE. These follow below. In addition, modifications and corrections are being made to the document where appropriate. HSE’s priority is to focus on the hard copy publication, which is due before August. The online version will also be updated. All technical queries will continue to be considered during this process. However, there may be some for which specific replies are needed, these will be provided via UKAS in due course where they were collected by us.
- When will the pdf be fixed on the HSE site https://www.hse.gov.uk/pubns/priced/hsg248.pdf all pages are blank except title? – ANSWER: This issue has been fixed as of 18th May: https://www.hse.gov.uk/pubns/books/hsg248.htm
- Can you provide a link to the recording to everyone who attended as it is not always easy to find information on the UKAS website? – ANSWER: This webinar has been recorded and can be replayed here.
- Do we read analyst = testing lab/organisation? – ANSWER: The use of the term ‘analyst’s’, as used within HSG248, depends on the context. It may refer to individual analysts or an organisation as an analyst’s employer. Analysts are individuals or organisations involved in the sampling, analysis and assessment of asbestos under the regulations.
- is the LARC guide now going to be updated? and if so what is the timescale for this? –ANSWER: Yes. HSG247 is scheduled for review and work has already started on the new technical content. This will gain momentum next work year 22/23.
- Will UKAS be providing accreditation for soil/site assessment using Chapter 7 of the new guidance? – ANSWER: There is a Development project looking at the presence of asbestos in land that has been contaminated. More information will follow in due course – late 2021.
- Are any delays to the new Lab 30/RG8 anticipated? – ANSWER: Lab 30 is in the final process of review following public consultation after an update to accommodate ISO/IEC 17025 revision. Further revision to Lab 30 expected in late 2021 when HSG248 has become more embedded, to be republished when the transition process is completed.
RG8 is not a primary document for testing purposes. Any immediate changes which come as a result of HSG 248 will be published via the Asbestos Technical Bulletin.
- What version of HSG248 will the Extension To Scope be assessed to? – ANSWER: Progression of any new applications and Extensions To Scope will be discussed on a case-by-case basis with applicants.
- Will UKAS be providing a gap analysis template with information to be used, similar to that circulated to labs for the transition to ISO17025:2017? – ANSWER: No. Doc A will support the process but labs are expected to review and detail their own requirements from a gap analysis specific to themselves.
- Will HSE and UKAS track and participate in CEN/TC 351 and its WG 5 on development of an analytical methodology (CEN/TS) on asbestos in construction products (recycled aggregate), this medium being significantly different to ‘soil’? – ANSWER: There is a Development project looking at the presence of asbestos in land that has been contaminated. More information will follow in due course – late 2021.
- For electronic collection of air monitoring data, e.g. 4SC – some IT suppliers are struggling to implement the photographs required. Is there some advice on the quantity of photographs required while suppliers try to resolve this? – ANSWER: Assessment of Labs to show efforts of each individual case and will be taken on their merits. Quality/quantity of photos is important and will vary per organisation as specific IT issues not currently known. Transition measures may need to be tweaked as aspects develop in coming weeks/months. Some labs are already incorporating photographs, so supplier support is already evident in some systems. Therefore this should not pose too significant an issue given the timeframes involved. However, as indicated in the webinar, cooperation is key and that issues are seen to be moving forward in addressing requirements, for example, for photographs in this case.
- Are Docs A and B available now? – ANSWER: No – so as not to bias input of laboratories.
- What is HSE’s view on LARC compliance elements of HSG248 2n Ed that apply to them (e.g. Handover documentation for enclosures to analysts)? When should compliance with this begin? – ANSWER: Handover form made available to LARC via the asbestos Network 2-3 years ago. LARCs therefore made aware of it and now in published Guidance.
In terms of HSE Inspectors, Inspectors are aware of the transition across to the new HSG248 and therefore won’t be expecting everyone to be following the Guidance in the next month. The transition period is ongoing. HSE Inspectors won’t be expecting this from June although changes to practice would be expected from June.
- As HSE would be expecting to see hand over forms from the LARC when HSG248 is published, should an analyst be requesting this from June? – ANSWER: The transition period is ongoing. HSE Inspectors won’t be expecting this from June although changes to practice would be expected from June.
- There is a recommendation for 5% reinspection of CoR. Is this a recommendation or a must? – ANSWER: This would be further discussed as the 5% marker is a figure also used in Inspection and there is a need for clarity on minimum expectations in testing. 5% is guidance. However, anything different from 5% would need to be justified by the laboratory. Further clarification is likely to come in Lab 30.
- Will the timescale for the further review of LAB30 mean that the new 248 update of LAB30 is published before 1st Feb 2022? – ANSWER: Lab 30 to be issued based on 17025, but looks to align to HSG248 changes by next February 2022.
- The 2nd PIR for CAR 2012 is happening soon. Is it envisaged that any changes following this review will lead to discrepancies with HSG248 Rev 2? – ANSWER: Unfortunately, this is difficult to say without knowing what these changes may be.
- if we notice an issue with the new guidance – who should we report this to? – ANSWER: Corrections can be sent to: [email protected]
- Bulk ID sample prep – does table A2.2 mean that you cannot, under any circumstances, report textured coating as NAD unless you’ve done acid prep. And you can’t report bitumen or floor tiles as NAD unless solvent prep. – ANSWER: Wet prep techniques will be required to be demonstrated in such scenarios as described, i.e. on samples where a material/product type that is being examined under a stereo-microscope is known to have the potential to contain asbestos, but is initially identified as NAD.
- We are interested in how UKAS will apply assessment of methodology against the revised guidance? For example, the guidance suggests using Toluene as a solvent treatment for mastics, etc. We view this as counterintuitive to safety as the risk of being exposed to airborne asbestos fibres from a mastic by the public versus the risk of using the highly hazardous/toxic substance by the laboratory staff seems at odds. Where will labs stand on accreditation if they do not adopt such techniques? – ANSWER: HSE have changed wording to remove references to the specific solvents toluene and cyclohexane in this NAD context.
- If a sample is analysed at Trace, just to confirm, that this is not asbestos in regard to CAR2012? ANSWER: ACOP L143 2013, para 12 guidance states “Definition of ‘asbestos’
‘Asbestos’ is the general term used for the fibrous silicates listed in regulation 2(1). Any mixture containing one or more of these fibrous silicates at more than trace amounts as defined in Asbestos: The analysts’ guide for sampling, analysis and clearance procedures (The analysts’ guide) is within the definition.”(see para A2.30 and box A2.1)
- In relation to soil analysis, will the sample mass required for an Asbestos screen and quantification that is published within the “blue book” method feature within the new edition of HSG248. Also the duration required to deem a soil sample as NAD, be specific to a soil? Currently more specific to a bulk, considering the nature of a soil matrix. ANSWER – Methods based on the now withdrawn blue book remain acceptable as far as HSE is concerned. Duration to conclude NAD indicated in A7.40. A total search time of around 20 minutes will be needed for a 1–2 litre soil sample to give a meaningful ‘non-detected’ result. The start and finish times of the search for each stage of the analysis should be recorded. The search procedure is outlined in Figure A7.4. A7.39 This appendix does not give a detailed method for measuring the asbestos mass concentration of asbestos fragments but uses sampling procedures that are compatible with other published sampling methods -samples can be further analysed after drying (or stored for further analysis) for their asbestos mass concentration (weight %) if and when required.
- I am interested in LoQ. Also how contractual elements fit with WHO counting rules i.e. any reduced LoQ (by increasing number of fields read?, other?). However, this is really difficult to query without seeing the new doc. ANSWER: HSE difficult to understand what is meant by the question. This isn’t really a change, it was possible in the 2005 version, just less implicit. Agree with UKAS that maybe we should add a sentence saying that if volume/sampling time is increased then additional flow checks are needed. The following additional note to Table 5.2 has been added: ‘for long duration sampling, periodic checking and adjustment of flow rate will be needed, see Box A1.1’