EMS (Environmental Management Solutions) is an ISO17020 UKAS accredited asbestos consultancy based in Hereford, with offices in Worcester, Cardiff & London. Established in 2003 and working throughout the public and private sector in the UK & Europe, EMS offers a full range of services in addition to surveys including asbestos management plans, asbestos awareness training, project management, consultancy and asbestos removal services. EMS is also able to provide asbestos air monitoring, bulk sampling and analytical services accredited to ISO17025 from our Cardiff office and has in-house laboratories located in both Hereford and Cardiff.
EMS has recently been awarded a place on CHIC’s Compliance Audit Services Framework for Asbestos Management Auditing.
EMS has summarised everything you need to know about the latest HSG248 Asbestos guidance below.
What is HSG248?
HSG248 is the HSE published guidance for analysts involved in asbestos work. It is the authoritative source of asbestos analytical procedures within Great Britain.
HSG248 guidance is primarily designed to assist analysts in complying with their legal obligations, however, also useful to asbestos consultants, occupational hygienists, safety professionals, asbestos removal contractors, building owners and facilities managers.
When Was the New HSG248 Guidance Published?
The new guidance was published in July 2021, with UKAS requiring submissions from analytical companies on how they will ensure compliance by the 1st December, 2021. Analysts are required to work to the new standard by 1st February, 2022.
Why Was It Updated?
HSG248 Edition 1 guidance was updated following observations and an extensive study by the HSE. This study found many areas that require significant improvement in analytical methodology and practises.
HSG248 Edition 1 was long overdue an update; the draft version of Edition 2 was originally dated for publication in 2016. The draft was released for review in 2015 but it has taken until 2021 for the new HSG248 guidance to released.
The new HSG248 guidance provides clarification on technical and personal safety issues. The main areas covered include further clarification regarding sampling and 4-Stage Clearances. In addition, new information on sampling soils for asbestos is included.
What Does HSG248 Cover?
HSG248 covers a range of topics and HSE guidance for asbestos laboratories. It is a document mostly used by specialists in the asbestos industry. Topics include:
• Sampling of asbestos materials
• Bulk analysis of asbestos samples
• Air sampling & fibre counting
• Clearances following asbestos removal
How Does This Affect Me?
HSG248 Edition 2 attempts to bring responsibilities in line with current CDM regs and therefore puts more onus on giving the client more responsibility.
The Client is Responsible! What Does This Mean?
A key change associated with the updated HSG248 guidance is the role of the client versus the role of the asbestos removal contractor in providing an analyst on site.
HSG248 Edition 2 recommends the analyst should be appointed by the client not the removal contractor wherever possible. Clause 1.22, states:
‘It is strongly recommended that the analyst for site clearance certification is independently sourced and employed by the building owner or occupier (ie building client) in control of the premises. This arrangement should:
• create a clearer and healthier contractual situation on site;
• help avoid any potential conflict of interest (perceived or real) that may arise should the analyst be employed by the removal contractor;
• give added assurance that the inspection process is undertaken impartially and objectively, as required by International Organisation for Standardisation (ISO) 17025;
• enable the independent analyst to be involved in resolving any problems (between the building client and contractor) that may arise.’
What Does This Look Like on Site?
HSG248 Edition 2 states that the analyst should be involved from early in the process to help design the project and agree the outcome. This is the main and crucial difference in the new HSG248 guidance, compared to the previous edition.
The process should be client & consultant led from the start of project to the end of project, and not contractor led as has previously often been the case.
In addition, there is also a requirement for the client [building client] to receive copies of the paperwork, regardless of who employs the asbestos analyst.
Air Testing
Changes for the Analyst Onsite
There are a number of key changes that will affect the analyst on site in the new HSG248 guidance. These include:
• Handover forms [from removal contractor to analyst] are now mandatory, failure to provide one will result in the clearance failing.
• Analysts must estimate the time for the clearance. Should this time estimate differ by more or less than 20%, they must also explain why and any mitigating circumstances
• More photographs are required, and these must also be date and time stamped
• Analysts are not allowed to undertake any cleaning or assist in anyway; any cleaning of more than 10 minutes should result in the analyst failing the enclosure.
• Actual results will be reported and not just the ‘less than clearance limit’ to provide clarity and transparency associated with results
Changes In Quality Control Monitoring
There is a significant increase in quality control monitoring to be undertaken by the analyst company, on their own analysts associated with the new HSG248 guidance, including increasing witnessed and revisit audits.
Witnessed Audits will be increased from 4 per year to 5% of all Four Stage- Clearances completed in an annual period. Additional desk top audits of paperwork are also required.
Sampling
Textured Coating
The new HSE HSG248 guidance states that when surveying, a minimum of two samples of textured coating should be taken from each surface, for example walls and ceilings. This differs considerably from the previous HSG248 guidance which stated that one sample must be taken for every 25m2. The new guidance also suggests that larger samples should be taken.
Other Changes to Sampling Protocols
There are some further significant changes associated with the new guidance, these include:
1. Vinyl floor coverings and bitumen
It is very commonplace for samples of bitumen and vinyl floorings to be tested as one sample. The new guidance sets out that these should now be treated as separate samples and therefore they will be charged and reported as such.
2. Dust
Dust should not be routinely sampled for asbestos containing materials. The new guidance discourages sampling dust unless there is a specific reason, for example, if the exercise is to detect the spread of asbestos from a recent, significant release. If asbestos fibres are detected in settled dust, careful analysis and evaluation of the risk is required. Samples with a low number of fibres should not necessarily trigger extensive environmental cleans.
3. Asbestos in Soils
HSG248 contains the first official guidance on the sampling and testing for the presence of asbestos in soils. The guidance follows the procedures set out for contaminated land investigations with a desk study carried out initially, followed by a preliminary investigation and a main survey if required. The guidance also sets out how samples should be prepared for testing.
Lab Testing
Are There Any Laboratory Changes?
As part of the new HSE HSG248 guidance there are some key laboratory changes which will affect analysts.
• There is now a reduction on the maximum number of samples an analyst can test per day and there is a increased requirement for quality control checks.
• Negative asbestos results now count as double due to the length of time required to analyse a negative sample.
• There is also a requirement for increased record keeping. These include details of the matrix of the sample, including the layers or textures where appropriate.
• Analysts are also required record more information regarding sample preparation and record how much time each sample takes to analyse.
