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March 31, 2015

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Plans of work


By Paul Clarke-Scholes of Clifford Devlin.

The Control of Asbestos Regulations 2012 included some important changes to the way the Regulations are phrased and that, combined with the Government’s response to the Löfstedt Report, means that the Approved Codes of Practice (ACoPs) for asbestos work are all due to be reviewed.

The process has started with revisions to the Asbestos Licensing Groups (ALG) Memos. These are available to Licensed Asbestos Removal Contractors (LARCs) and provide guidance on how the HSE intend to enforce the regulations at site level.

ALG Memo 04/12 covers the latest guidance on the preparation and use of Plans of Work. For those of you that are not familiar with asbestos removal Plans of Work they are essentially a detailed risk assessed Method Statement for the work. The HSE lays down strict guidelines about how they should be prepared. A typical Plan of Work will contain the following:

  • Health and safety risk assessment
  • Inventory of equipment and materials
  • Detailed description of the methodology to be used
  • Plan and sectional technical drawings to show the position of vehicles, DCUs, NPUs, CCTVs, enclosures, vision panels, airlocks and baglocks location and sizes
  • Graphical representation of access, waste and transit routes
  • Description, volumes and condition of ACMs to be removed

The key phrases in ALG Memo 04/12 are:

Where risk assessment and planning has been thorough, amendments to plans should be minor and rare.

Many/most third parties (clients, contractors, members of the public, etc), will not be aware of the standards expected of licence holders with regards to pre-planning. This can often result in site teams making “forced” changes to enclosures, transit routes, etc. The licensed contractor must take all reasonable steps to ensure any relevant parties are aware of their requirements for notified work. This should be reflected in tender discussions and contractual agreements.

Where site teams arrive on site to find that the plan is no longer accurate, this may often indicate that initial planning was NOT suitable and sufficient and licence conditions were not met.

The implication here is that if the Plan of Work requires amendment because, for example, the scaffolders have now blocked the access route that was planned, then the LARC may be guilty of “not meeting license conditions”. There is implication elsewhere that licenses may not be renewed if multiple examples of “not meeting licence conditions” are found to be the case. HSE have indicated that they want to continue to reduce the number of License Holders as a way of improving control over the industry and this new phrase “not meeting license conditions” appears to be a new mechanism for doing so.

We need to stress to the Client that once an agreed set up has been established, operational pressures at site level are not going to be acceptable reasons for amending a work plan. Significant individual projects, by which we mean anything lasting more than a couple of days, should be reviewed shortly before commencement, ideally with the Site Supervisor due to be involved, in order to finalise the Plan of Work. HSE expect the Plan to have been written BEFORE the ASB5 is submitted and to then NOT CHANGE, when the teams arrive on site.

This is going to be very difficult to manage in the reactive world that is your average construction project. So what do we propose?

The solution lies in identifying the problem and allowing for the resources to conduct adequate planning. There will be a cost impact, but the potential problems that can be avoided are significant. If your LARC has been involved in pre-start meetings after they won the tender by providing a submission against the specification, then they will probably already be compliant. Otherwise, expect them to struggle if there are a large number of different layouts of property. If and when the HSE visit, expect all the problems that arise from a Prohibition Notice being issued – a delay to the project, an investigation from HSQE internally, perhaps even your LARC having to withdraw from the contract!

Paul Clarke-Scholes is an asbestos consultant with contractor Clifford Devlin.

This is the eighth of a series of blogs which discuss the latest issues in asbestos management – next week Paul discusses practical tips and challenges of using internal tents when removing ACMs.

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In this episode  of the Safety & Health Podcast, ‘Burnout, stress and being human’, Heather Beach is joined by Stacy Thomson to discuss burnout, perfectionism and how to deal with burnout as an individual, as management and as an organisation.

We provide an insight on how to tackle burnout and why mental health is such a taboo subject, particularly in the workplace.


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