Asbestos Licence renewal food for thought

The time leading up to an HSE licence assessment is always an anxious time for a licence holder no matter how efficient the business is set up and operating, very often a contractor thinks that the assessment will be a formality and a three year full licence issued as a matter of course, unfortunately even for the best prepared contractor this is not always the case and the result of the assessment is often a reduced term licence with specific conditions for the licence holder to comply with, we have listed below a number of oversights which contractors fail to take into account which can have an adverse effect at the time of assessment:

• Failure to acknowledge HSE site visit reports.
• Failure to review operative, supervisory and management competences.
• Failure to review Health and safety Policies and procedures.
• Failure to update asbestos procedures.
• Failures to maintain training, medical, face fit records etc.
• Failure to have adequate health and safety management procedures in place.
• Failure to monitor performance at both site and management level

In order to meet the assessment criteria it is important to understand the assessment process, HSE inspectors at assessment are nowadays not just looking at a contractor’s asbestos records, the process is now much more complicated, a contractor is assessed regarding the company’s attitude and knowledge regarding not only asbestos legislation but also general Health and Safety legislation, its health and safety management system, its attitude to health and safety and the measures it takes to protect its employees and provide a safe working environment for the workforce, all this is in addition to the asbestos procedures, control equipment inspections and recording processes which must be carried out.     

HSE Site visit records:

During every HSE site visit and inspection the inspector will not only assess whether the contractor is working safely with asbestos but will inspect the contractor’s general health and safety management on the site, an enforcement action is just as likely to be taken as a result of poor housekeeping on site as it is for decontaminating improperly, and of course the record and comments regarding that visit will be reviewed at licence assessment time and taken into consideration.

Management Competence:

The majority of contractors rely on their site managers / supervisors to have sufficient knowledge to set up and manage a site successfully, and, as a result very often neglect their own training in the process, this can and often does lead to a shortfall in relevant legislative knowledge which makes assessing competence very difficult indeed

It is worth noting that the majority of failures on site are down to basic errors which are generally a result of operative / supervisor lack of in depth knowledge of legislative requirements.

General Health and Safety Policies and Procedures:

Most contractors who have health and safety policies fail to realise that their policies should be adequate and relevant to the company’s operations, and refer specifically to managing the health and safety issues that arise during the course of their day to day working, at assessment the inspector is more concerned with the practical management and content of company health and safety policies and procedures than the volume of paperwork which has been generated to “demonstrate” compliance.

An Honest Assessment

Prior to an asbestos licence renewal assessment in preparation a contractor will carry out an internal review on the company procedures to assess the company’s compliance with the requirements of the licensing assessment process, at this point brutal honesty is called for regarding the accuracy of the procedures and management processes, unfortunately this is the stage where a contractor generally fails to recognise any potential shortfall in the company’s management systems by not being honest with itself, thus leaving itself open to a poor licence assessment review and possible licence limitations.

A reliable way of reviewing company procedures is by a totally independent assessment prior to the actual HSE assessment being carried out, which can be conducted by a third party such as a trade association, or an independent auditor, which ever of the two options is chosen, it must result in an honest “no strings” assessment of the company’s performance, not a tick box, but a full and frank review of how the company goes about its business complying with the various requirements of the current health and safety and asbestos legislation, then and only then can a contractor feel confident in its company management systems and have every chance of meeting the licence assessment criteria.