Changes in Asbestos Analysis and Accreditation
You will undoubtedly be aware of the consultation the Health & Safety Commission has recently undertaken with respect to revisions to current asbestos Regulations required to implement amendments to the European Asbestos Worker Protection Directive (AWPD). Initially it was hoped that the new Regulations would come into effect from April 2006 although it now looks likely that they will not be introduced until October 2006. The changes in requirements will affect virtually all who work in the asbestos sector, and will impact upon UKAS accreditation. This letter is aimed at highlighting these impacts in order that accredited laboratories can prepare for the changes later this year. In addition this letter also highlights other changes that shall be coming into effect in the future.
1. Changes to Counting Method
1a. The change in asbestos counting method
One of the significant changes will be the introduction of the World Health Organisation (WHO) asbestos fibre counting method in place of the current European Reference Method (ERM). Under the ERM method, fibres are discounted if they touch particles greater than 3 microns wide, but under the WHO method, these fibres are not discounted. In addition, discrimination between fibre types is allowed after an initial non-discriminatory fibre count has been completed. All laboratories undertaking asbestos fibre counting shall transfer to the WHO method when the new Regulations come into force. Details of the WHO method, and on the changes from the ERM method, can be found in Appendix 1 of HSG 248, ¡® Asbestos: The analysts¡¯ guide for sampling, analysis and clearance procedures ¡¯.
1b. UKAS requirements for changeover
UKAS assessment teams have been discussing the changeover from ERM to WHO with laboratories at previous visits. Laboratories should already be preparing for this change so that when the new Regulations come into force it can be implemented seamlessly. It is the intention of UKAS that all accredited asbestos fibre counting laboratories will automatically be transferred from MDHS 39/4 to HSG 248 when the changeover occurs: No extensions to scope or additional visits shall be required (unless there are specific concerns over a laboratory¡¯s performance). However, for fibre counting to continue under accreditation UKAS shall require confidence that laboratories are familiar with the changes and shall transfer to the WHO method effectively. Therefore, in the same way that UKAS did with the identification of asbestos in bulk materials last year, I shall be asking all laboratories to sign a declaration form nearer the time to declare that they are fully prepared for the changeover. In signing this form the laboratory shall be declaring that it has implemented the following:
Full training of all relevant staff, supported by comprehensive training records
Authorisation of trained and demonstrably competent analysts for WHO counting method
Participation in RICE training round(s)
Implementation of new internal QC scheme (this should be run in parallel with existing scheme for at least 2-4 months prior to changeover).
Please consider each of the points carefully and start to introduce them into your System now if you haven¡¯t done so already.
1c. Fibre discrimination
UKAS assessment teams do not currently assess discrimination of fibres as part of the asbestos fibre counting activities. As discrimination is an integral part of the WHO method, any laboratory seeking to undertake it must first gain accreditation for it as an extension to their accredited scope. Applications should follow the usual route, using UKAS application form AC4 (available from the UKAS website ).
The expectation is that laboratories shall follow the strategy for discrimination counting as covered in the HSE document MDHS 87, ¡® Fibres in air ¡¯. This highlights the fact that discrimination decisions should be taken with caution, as there are many risks that need to be considered. In addition it states that the extent to which the method can be implemented will depend on the equipment available and upon the training of, and care taken by, the microscopist. As a consequence of this latter point the UKAS Asbestos Technical Advisory Committee is considering proposals to make both the P401 and P403 mandatory qualifications for staff authorised to undertake discrimination counting.
If you would like to apply for discrimination of fibres when the WHO counting rules come in to effect then please notify your assigned UKAS Assessment Manager of your intention at the earliest opportunity.
2. Changes to Identification Method
The current procedure for the identification of asbestos in bulk materials by polarised light microscopy is documented in Appendix 2 of HSG 248. This superseded MDHS 77, although there was very little change between the two documents except for additional QC requirements. However, Working Group 2 of the Committee of Fibre Measurement has been reviewing this method for several months, and the final draft of their work is now virtually complete: This revision will be included in the next version of HSG 248.
There will be no actual change in the method for analysing bulk materials but changes are proposed as outlined below:
o There will be greater guidance provided with respect to preparation of samples;
o Guidance will be given for the preparation required for differing materials (e.g. mastics / floor tiles will require solvent and/or combustion pre-treatment). Therefore it is expected that laboratories shall do more pre-treatment of samples;
o There will be a requirement for further preparation and analysis to confirm any ¡®No Asbestos Detected¡¯ result derived from a ¡®dry¡¯ analysis;
o There will be requirements on what needs to be recorded on laboratory worksheets, i.e. material type;
o Guidance will be given with respect to temperatures / equipment relating to preparation of samples by combustion due to the criticality of temperature on chrysotile;
o There will be additional QC requirements: 5% of samples (1 in 20) shall need to be reanalysed, regardless of the material analysed or the identity of the analyst(s);
o There will also be requirements for checks on fume extraction equipment, and for an emergency procedure to deal with spillages.
3. Qualifications
3a. Current requirements
The current requirements relating to qualifications for asbestos testing laboratories have been previously communicated to laboratories. In summary laboratories are required to have at least one person in a position of responsibility who holds a minimum qualification of the Certificate of Competence in Asbestos (CoCA) (i.e. BOHS S301 + pass in the oral) or equivalent. If only one person within a laboratory holds such a qualification and they leave then that laboratory is required to notify UKAS of this fact immediately, as required by paragraph 2.7 of the UKAS Agreement .
The only exception to this is where a laboratory only undertakes identification of asbestos in bulk materials. In this instance all authorised analysts are required to hold, as a minimum, the BOHS P401: Identification of asbestos in bulk samples . NB: Although HSG 248, 3.6 implies that the S301 (without the oral) is also acceptable this is an error and is not the case. However, the CoCA is accepted as an alternative.
3b. Air sampling, Clearance testing and Fibre counting (P403 & P404)
At the request of the HSE , BOHS developed the following two proficiency modules:
P403: Asbestos fibre counting
P404: Air sampling and clearance testing of asbestos
It has always been the intention of UKAS, at the recommendation of its Asbestos Technical Advisory Committee, to make theses qualifications mandatory requirements for analysts undertaking air sampling /clearance testing /fibre counting, as stated in LAB 30. Previous plans to introduce this requirement were delayed due to the forthcoming changes to the counting rules and hence the need to modify the modules.
The implementation date of the requirement that all authorised analysts shall hold a suitable qualification has been discussed at recent meetings of the UKAS Asbestos Technical Advisory Committee, and in the last meeting at the end of March it was agreed that the proposed date, as previously indicated on the UKAS website, shall be enforced.
Therefore, from 31 st December 2006 all analysts undertaking such work shall be required to hold the P403 and /or P404 (or equivalent).
4. Four-Stage Clearance Process
At the request of the HSE, UKAS developed an accreditation process for laboratories undertaking the 4SC process. This was based on the requirements of both ISO 17025 and ISO 17020, and a pilot was conducted between June 2004 and December 2005 to determine the effectiveness of this approach. The pilot concluded at the end of December with the accreditation of 83 successful laboratories on 31 st January 2006.
One of the requirements of ISO 17020 introduced into the assessment of the four-stage clearance process is the need for the laboratory to hold adequate liability insurance. With respect to Professional Indemnity, UKAS became aware over a year ago that policies had started to exclude bodily injury. After investigation it was determined that for PI cover to be adequate for asbestos surveying organisations bodily injury must be included, therefore this requirements has been enforced. Currently UKAS is investigating whether this same requirement also holds for laboratories undertaking 4SC. The assumption is that it does, however UKAS is currently consulting on this with its Asbestos Technical Advisory Committee, and confirmation on this has not yet been agreed. When this issue is resolved UKAS will advertise the outcome in the News section of the UKAS website.
The HSE is currently proposing changes to the Control of Asbestos at Work Regulations, one of which is a requirement that laboratories undertaking the 4SC process shall be required to hold the appropriate accreditation. The expectation, therefore, is that laboratories will need to hold accreditation for this activity to continue operations when the CAWR is implemented in October 2006. Any laboratory that wishes to undertake the 4SC process in the future, and has yet to apply to UKAS for accreditation, should contact its allocated UKAS assessment manager at the earliest opportunity to discuss.
5. UKAS Communication & Updates
In developing and maintaining its assessment processes relating to the asbestos sector UKAS greatly appreciates the input from industry stakeholders. In recent years the increase in changes has required greater communication and UKAS has responded to this by setting up a Technical Advisory Committee especially for asbestos. This Committee includes representatives from HSE, HSL, BOHS, RICS, as well as accredited laboratories and inspection bodies (including ATaC). With meetings generally taking place every 6 months this Committee has an invaluable role to play.
In recent months I was surprised to find when talking to laboratory representatives that the presence of this Committee was not more widely appreciated. To rectify this the UKAS website is in the process of being enhanced to give greater information on this Committee, This includes its specific role and membership, and will also include a summary of minutes from meetings held from the beginning of 2006. Please take the time to regularly visit this section of the UKAS website to keep abreast of future developments.
In addition to providing greater information on the Asbestos Technical Advisory Committee I am keen to update laboratories and inspection bodies on issues that could impact on their accreditation as they arise. I have therefore started to post Asbestos Updates on the News section of the UKAS website. The first Update was posted in February of this year, with an update of this posted in April. Please check this section of the UKAS website regularly to keep up-to-date with clarifications or amendments to requirements.
I hope that you found the information in this letter useful, and that it will allow you to make changes in your current systems in order to meet future requirements. Some of the information in this letter will be formalised in the next version of UKAS guidance document LAB 30, which is currently in the initial draft stage. The final draft of this document will be published on the UKAS website for consultation prior to its publication later this year.
