Reply To: Lab 30 Edition 5 March 2022 – Draft for Consultation

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    Last one for now.

    Table 3: On-site audit section –

    The duration of the interval may be dictated by performance at the last audit – if poor then, a repeat may be required sooner (additional audits may be required). Otherwise, it may be governed by the type of sites covered i.e. to ensure a suitable site, acknowledging HSG248 para 2.16 which states ‘the auditing programme should cover a representative range of:

    • removed materials (e.g. sprayed coating, insulation, AIB, wet-blasting);
    • premises type (e.g. domestic, industrial and commercial);
    • individual analysts carrying out the clearance inspections

    This new requirement appears in HSG 248 2021 – it did not appear in the Draft version from 2015.


    I am struggling to see why the property type is its own category for audit requirements. E.g. an AIB 4SC, or pipe insulation 4SC within someone’s home is comparable to a 4SC in another property type – granted the scale may be different.

    By including property type, the number of audits increases again as it is supposed to be done on a per analysts, per material (AIB, TI, SC), and now per property type – with each analyst being audited x4 per year.

    How are the rest of the analytical companies planning their audit schedule?

    Surely if we have competent analysts who has been trained and audited to allow him/her to preform a 4SC in a commercial building for AIB we do not need to re-audit that person in a domestic property and vice versa?