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Asbestos Technical Bulletin Issue 4

Since Issue 3 the following section has been updated:-

  • [4] Asbestos qualifications
  • [6] Survey Re-inspections

The updated sections reflect:

  • A change to the existing P402 qualification and an additional qualification for individuals now accepted by UKAS for Report Writing for Asbestos Surveys (P402RPT). 
  • The UKAS policy on accepting re-inspections as a separate accreditable activity
  • 4SC arrangements

Further changes documented in this 4th Issue are as a result of the recently re-issued Lab 30, and RG8, which now incorporate the testing and inspection requirements of edition 3 of the Technical Bulletin where relevant.

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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:
[1] Colour blindness testing
[2] Field blank samples
[3] Multi-site accreditation and satellite offices
[4] Asbestos qualifications
[5] Surveying for Asbestos in Marine Vessels
[6] Survey Re-inspections
[7] 4SC – Arrangements
[8] Lab 30 qualification

  1. Colour blindness testing
    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.
  2. Field blank samples
    Organisations need to define a ‘job’ to ensure field blanks are sufficiently traceable
  3. 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)
  4. Asbestos qualifications (Sept 2014)
    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.

The main providers of qualifications recognised by UKAS are the British Occupational Hygiene Society (BOHS), through its Proficiency Modules and more recently the Asbestos Testing and Consultancy (ATAC) Level 3 qualifications administered by the Royal Society for Public Health (RSPH).

In 2014 the BOHS notified UKAS of an intent to revise the P402 module to remove the requirement for candidates to submit two field reports for assessment as part of the qualification. Additionally, for those surveyors who wish to improve their report writing skills and to gain formal recognition of these skills, it was also proposed to introduce an optional report writing module. The proposed changes were reviewed by UKAS and discussed at the UKAS Asbestos TAC (August 2014). UKAS can confirm that the revised P402 qualification is accepted. The RSPH Level 3 Certificate in Asbestos Surveying remains unchanged

The title of the P402 module as of 1st September 2014 became the P402: Surveying and Sampling Strategies for Asbestos in Buildings, and the title of the optional reporting module is P402RPT: Report Writing for Asbestos Surveys.

The current P402 Refresher modules remain unchanged.

Further details on these qualifications can be found at:
BOHS: http://www.bohs.org/education/examinations/proficiency-modules/
ATAC: http://www.atac.org.uk/asbestos-testing-consultancy-association-training

  1. 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: [email protected]

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.

  1. Survey Re-inspections
    The previous technical bulletin (Issue 3) indicated that re-inspections (as undertaken to comply with Reg 4 of CAR L143) were covered by existing accreditation (to ISO/IEC 17020) and as such the requirements for appropriate use of qualified and experienced surveyors had to be demonstrated.

Following feedback from stakeholders and accredited inspection bodies (IBs’) UKAS has decided to offer Survey Re-inspections as a separate accredited activity. IBs’ will have the option to gain accreditation for this activity if so desired, however the minimum requirement for individuals to hold the P402/equivalent will still be needed. This is to be supported with documented training and authorisation. The implementation of this process is being undertaken via a self-declaration process.

The process of a re-inspection 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.

Accredited inspection bodies who decide not to conduct re-inspections under their accreditation must not claim accreditation for this activity, either through contract review or reporting processes. When conducted as an unaccredited activity suitable documented measures must be implemented by the accredited IB to ensure that aspects which affect the scope of a re-inspection (whilst being conducted on-site) are then covered by the accredited IBs’ policies and procedures, for example, if a previously non-accessed area is accessed and surveyed, or as a result of applying duty of care to previously unidentified suspect asbestos containing material. 

  1. 4SC – Arrangements
    To ensure competence is suitably witnessed during a four cycle accredited cycle, the policy for witnessing the 4SC remains as follows:-
  • To observe a 4 Stage Clearance at every scheduled assessment

Whilst recognised that potentially more complex enclosures will not facilitate all 4 stages to be witnessed in one day, a Lab is still required to demonstrate competence in the accredited activity and efforts to provide such witnessing needs to be provided to UKAS on an annual basis.
When cooperation by Licensed Asbestos Removal Contractors (LARCs) is not apparent, or when such activities are either not available during assessment or outside the normal working hours, Monday to Friday, then this needs to be reported to the Laboratory’s Assessment Manager in a timely manner. This is to enable alternative arrangements to be considered/implemented and avoid unnecessary costs and delays to the Lab’s accreditation being maintained or renewed respectively. UKAS will continue to accommodate the witnessing of the 4SC when practicable. The HSE will be informed of any instances whereby LARCs are not being cooperative.

  1. Lab 30 qualification
    Section 9 of Edition 3 of this publication (February 2014) detailed the requirements of asbestos bulk laboratories with regards to the numbers of samples/points permissible to be analysed by laboratory analysts. This has been inserted into Lab 30, edition 3. This policy continues to reinforce the requirements of HSG248, Appendix 2 section on Quality assurance (QA) and quality control (QC). Labs need to ensure their daily additional quality checks meet the requirements of both HSG248 and Lab 30 respectively.