2.16 Perhaps this will be the one single paragraph which cause all involved the most grief. It will ultimately come down to cost. The intention is admirable – rechecking a 4SC is beneficial to assess the quality of work. The implementation as described in the new guide is not practical.
I do not know of any LARC who will be willing to swallow the cost of a team of removal workers (plus the hiring cost of equipment) while an analytical company extends the time out for a quality check that would add several hours if not days onto a job. By the method described it gives me more questions and problems than it tries to solve:
- LARC – how can they account for the analytical companies extending the time for the notified job on the ASB5.
- LARC – the “better” contractors will always be selected by the analytical company for these quality checks as we would not want the hassle of dealing with a contractor who did not want us to do “our own quality check at least 4 times a year”.
- Duty Holders – some will be understanding most will not be. They will, in most cases, be the ultimate customer, so will end up paying for the analysts and LARC time (in one way or another).
- Analysts – the guide states “every analyst is audited at least four times per annum”. This won’t work for every company. Those analysts who complete e.g. 100 4SC a year will be assessed on only 4. Those who complete only 2 4SC will be “missing” 2 checks. A risk based approach with a % of jobs would be preferable to a named number.
- Analysts – there is mention of the parameters to track for these re-clearances in 2.16 – removed material, premises type, individual analyst. There is no mention of the LARC being in these parameters – why not? If they were included it would help to demonstrate that this other variable was quality checked. (see above comment about selecting the best LARC an analyst works with).
- Tenant – for any tenant a further delay in getting their area (workplace or home) back will not be appreciated.
That is mostly the problems – proposed alternatives, which has been brought up by others at NORAC meetings and from conversations with colleagues in the industry:
- Assessment after Stage 4 has been completed. This removes the majority of the timescales and cost involved for the new audit assessment guidance. It will also give a truer reflection of an analyst’s work as it will be what the original analyst perceived to be “clean and satisfactory”. The assessment analyst would have the 4SC certificate to check on site against what the original analyst has recorded.
- Amending the ASB5 process whereby it would be HSE who randomly selected the notified job that was to be reinspected by a different analyst. This would require HSE to have a list of authorised analysts on their books whereby the LARC would select the named individual analyst for the 4SC. I know of other industries where the certification body holds a list of authorised assessors e.g. in Fire Risk Assessment so it is technically possible for an independent party to hold a register of authorised works across multiple companies.
- HSE employed a team to carry out these re-clearance inspections. This would have the added benefit that it would be independent. And that all parties involved would be less inclined to argue about quality checks if it is HSE doing them.
I look forward to everyone else’s input.