HSG248 Asbestos: The Analysts' Guide
posted 20th October 2021
Introduction
The first guidance under HSG248 Asbestos: The Analysts' Guide was published in 2005, giving advice to analysts involved in asbestos work. Throughout 2014 and 2015, the Health and Safety Executive (HSE) carried out an Analyst Inspection Programme, the report findings identified issues which have been addressed in the 2021 revision of HSG248 Asbestos: The Analysts' Guide. This 2021 publication is the authoritative source for British consultancies, such as The MSS Group, to follow when working on asbestos using analytical procedures.
After updating our internal procedures, we are in a strong position to summarise the changes which have occurred between the 2005 and 2021 publications. These are summarised below:
1. Higher involvement of the analyst
The early work planning and scope identification should involve the analyst to ensure an adequate risk assessment and plan of works is prepared. This will ensure that the appropriate time and resources are allocated as by the predefined site complexity and clearance work. Any other disrupting or impeding factors should be identified and resolved. A pre-removal work site visit will be beneficial for the identification and resolution of potential clearance issues. All sampling-related activities must have an adequate risk assessment and site-specific POW prepared by a competent person who has specific knowledge and understanding of the correct sampling control procedures, other risks, or site-specific issues.
2. Need for better standard of cleaning by Licensed Contractors
The analyst cannot undertake any cleaning activities or oversee the final cleaning but should direct the contractor to any need for further minor cleaning or attention to ensure successful completion of the process.
3. Improvement of the Four Stage Clearance Procedure
Increased photographic evidence is needed at each stage and within the decontamination process. A prediction must be made on the length that stage 2 will take, if this is a difference of greater than 20% in reality, a short explanation must be given as to the reason why on the CfR. Checks should be made on the effectiveness of control methods and/or RPE, specifically the 10-minute short-term exposure limit and specific short-duration activities. Separate copies of the CfR are provided to the building occupier/owner and the licensed contractor on completion of the process to ensure no uncertainty or confusion of the clearance outcome procedures. The CfR should document all of the above.
4. Increase in quality control of analyst work
At least 5% of stage-2 clearances and completed CfR should be checked by a technically competent individual. These should confirm satisfactory site procedures, practices, performances, analytical details and state any recommendations for improvements. For larger enclosures, a representative area should be audited. Furthermore, a minimum overall quality control check of 5% of re-analyses on new samples should be maintained with each analyst completing at least two quality control samples per working month. The maximum number of samples per 24 hours for an analyst before additional QC applied is 40 for category A and 20 for category B. An absolute maximum or 60 samples or 70 points has been set. At least 10 minutes and extra care should be taken for textured coating analysis.
5. Stronger impartiality requirements
The HSE has always advocated that the analyst should be independent from the LC. Accordingly, clients should employ the analyst directly and ensure that there are no links with the LARC. This guidance strengthens these recommendations through the 'professional standards' section.
6. Improved procedure for personal sampling
Personal monitoring is required unless exposure is not liable to exceed the control limit. Regular personal monitoring to assess risks, confirm adequacy of respiratory protection and effective controls are applied should occur as per the ACOP.
7. Additional advice on analyst competence/refresher training
In-house or outsourced learning programmes must be provided by the employer which cover asbestos and other health and safety issues.
8. New guidance for asbestos in soils and made ground
Over the past decade, there has been a significant growth in interest on asbestos in soils, and the new guide includes some information on this topic. The first part of the guidance concentrates on the sampling of soils and when this should be required. Survey types (preliminary and main survey) are also discussed, and these are supplemented by an initial desktop study to assess the likelihood of asbestos being present or previously used on site.
9. Dust Sampling
Dust sampling is not recommended and should not be routine as part of bulk sampling or a survey programme as it is technically difficult, surface deposits/settled dust variability, uncertainties in the statistical relevance and assessment and evaluation of risk from low fibre detection. Dust sampling should only take place in specific circumstances where the spread of asbestos from a substantial recent release incident is being investigated.
10. Far-source sampling
Far-source/perimeter/ambient sampling is undertaken on the perimeter of a contaminated or exclusion zone to provide assurance.
11. Air sampling
Airborne exposures should be assessed, and results recorded and made available to the analysts where ACMs are handles frequently. Representative personal air monitoring should be conducted on selected analysts on a periodic basis in the sample preparation/identification area. New static sampling types were introduced along with new recommended sampling parameters have been identified for personal and static sampling.
12. Bulk analysis
An extended list of equipment that can be used in sample pre/preparation, of which one or more representative subsamples may be prepared mechanically and/or chemically, and analysis. A higher level of detail is within the procedures for sample preparation and analysis. Organic solvents should be kept in smaller containers to reduce likelihood of contamination. Layered samples should be described by their appearance and each layer noted and examined as a separate entity.
13. Water absorption test
Additional information is given on the recommended methods to determine the weight percentage of water absorbed by proprietary flat asbestos boards and sheets of particular densities. The method is suitable for use on high-density AC products and medium density insulating boards, it is not sensible for use with low-density boards, lagging or friable materials or profiled sheets.
14. Fume Cabinets
Cleaning, checking, and maintaining the fume and recirculation cabinets and vacuum cleaners must have a written assessment and plan of work, should be tested every 6 months and have maintenance records kept for 5 years.
Summary
The updated analyst guide has been long awaited but now provides additional guidance to analytical organisations, licensed contractors and clients across a wide range of analytical techniques and practical applications. UKAS have set out their timescales for accrediting labs to the new guidance. Declarations of conformity are to be made to UKAS between 1st September and 1st December 2021. The transition day for all successful labs will be 1st February 2022.