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 will be answered via the HSE, where relevant, in due course and this page will be updated regularly to reflect this.
The webinar highlighted a number of technical queries. HSE continue to review these as part of preparation for the publication of the printed version of HSG248. Where appropriate modifications and corrections are being made to the document. HSE’s priority is therefore to focus on the hard copy publication, which is due before August. The online version will also be updated. All technical queries will 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]