Thanks Derek that is helpful,
The ISO17020 clause – that you have reproduced – does not call for, nor require, a material assessment of the condition of a hypothetical material that may or may not exist and, if it did exist, what condition it is in.
Accurate and correct reporting is just that, accurately (and correctly) reporting what you have and have not done and in this case that you have not gained access to an area but have complied with HSG264 page 17 (the ‘Default’ situation) i.e. presumed that asbestos is present, recorded this within the asbestos register, on the marked up plans and the report as an area of presumed asbestos where no access was possible and included a suitable warning for the client.
More generally the report should be easily understood and so long as it is clearly stated/recorded as an area that should be presumed to contain asbestos and should <span style=”text-decoration: underline;”>not</span> be accessed for the purposes of maintenance, or any other reason, until until an investigation has been conducted, then you have complied with both 17020 and HSG264 both technically and in spirit.
I suspect that the UKAS officer was more likely trying to reference para 45 of HSG264 on page 19 (I may be wrong) but this paragraph appears more in keeping with the comments made but is in regard to a presumption based on not sampling a visible product rather than a presumption based on inaccessibility.
Obviously I do not know the exact circumstances, there is some logic in having a default ‘high’ score for the material assessment for inaccessible areas if the material assessment is used to prioritise actions – HSG264 is split on this point though, see para 44 that says it can be used to prioritise actions versus para 128 that says, in essence, it shouldn’t. The philosophical argument could, reasonably, be moved on to the dutyholders management plan and how the dutyholder addresses inaccessible areas and locations that are recorded in the surveys that it commissions.
The ultimate judgement of the suitability of the report, in this regard, should be whether a reasonable person/client, on reading the report, will be clear that inaccessible ‘presumed asbestos’ areas are a high risk (to them) and will need to be controlled appropriately until such time as they are investigated fully.
There is more than one way to do this and many/most include a strongly worded warning in the section listing areas of inaccessibility and what this means to the client.
This is just my opinion though.