How To Have A Successful HSE Asbestos Inspection

During the past year, Handsam Ltd have supported a number of clients through HSE site visits to examine their management of asbestos. Through delivering this support we have learned a great deal of insight into how to be successful in avoiding an HSE fine, which can be levied if the inspector uncovers any failures in management or gaps in documentation. This article will help you if you receive notification that you are to be visited, but also should be used as a guide to where your asbestos management and records should be at anyway.

Preparing for the visit

Preparing staff is key. The inspector will want to meet with the headteacher, the site manager, the business or office manager and at least one person from the trust, depending on job role. Often this will be both the Head of Estates and the Head of Operations at the trust. Ensure you prepare all these key individuals on what to say about their understanding of their role in asbestos management and how they ensure staff and contractors are aware of the locations of ACMS, but also of the key documents below.

The other crucial aspect to have prepared is paperwork. The inspector will ask to see a range of documents such as:

• Asbestos Management policy;

• Asbestos register;

• Asbestos management plan;

• Re-inspection surveys;

• Records of ACMS being monitored checked in house (these should have photographs to compare the ACMs over time);

• The accreditations of your appointed asbestos consultants;

• Training records for both the senior staff on managing asbestos (Duty Holder training) and all staff who may potentially disturb asbestos (asbestos awareness training);

• Records of all staff and other relevant persons (e.g. cleaners and kitchen staff) having read and understood the asbestos register;

• Contractor signatures to confirm they have read and understood the asbestos register;

• Hazardous waste removal/consignment notes (if relevant);

• Reoccupation survey results (if relevant); and

• We also highly recommend creating a ‘timeline’ of each document with its reference number and creator so the inspector can use it as a handy reference. This will vastly improve the number of questions they need to ask you, the amount of time they spend on site and their humour.

Make it easy for the inspector: it is best to prepare a folder of all the above for them and also then have a mirror image folder for yourselves

Please note that Handsam offer templates for many of the above documentation types (mostly to be found in the Quick Guides Library). Please contact us for details and assistance.

The inspector will also want to see records of any projects which have been undertaken at your site, including Construction Phase Plan, per-start R&D surveys, details of any asbestos removals/encapsulations etc. prepare these and ensure there are no gaps.

What to do when you receive notification from the HSE

If you receive notification that the HSE plan to visit then immediately advise your trust head office and ask for support. Also, ensure you respond back to the HSE inspector welcoming them to your site, informing them of where to park and what not to bring to site (e.g. nuts if you are nut-free). Be professional and courteous at all times. This will count for a lot on the day of the visit.

Also, please advise Handsam as soon as you can. We can then support remotely at no additional cost. If you would like us to attend site in advance or on the day of the audit then we are happy to do this for you, but this would come at an additional cost, depending on the work and time required.

On the day of the visit

The inspector’s initial chat after arrival will include them informing you of what they are attending site to do and what the potential punishments could be if they find anything wrong, usually financial, but ultimately could be more serious, although that is extremely unlikely. Don’t get unnerved by this, as it is standard, and they have to do it as part of their duty to inform you.

The inspector may well ask to see further documentation so be ready to access any documentation you may need to. These can sometimes initially feel quite tangential, such as critical incident plan, but they are checking to see if it covers responding to a disturbance of asbestos.

Please be aware that the inspector will likely ask how many staff (individuals) work at your school/academy so they can check that everyone has completed training if that is relevant. They may also ask how many pupils you have. They will also ask about regular contractor staff such as cleaners and caretakers and will want to confirm, where it is relevant, that they can be evidenced to have been informed of the locations of ACMs in areas in which they work so they do not disturb them.

The inspector will also want to walk round accessible areas and see that you have labelled the ACMs and they match with the register. They will often use this opportunity to ask more detailed questions of you or staff they may come across (for example in a kitchen which contains ACMs).

HANDSAM RESOURCES

• GM05 Managing Asbestos;

• GM23 Asbestos Safety Information Handout;

• GM27 Asbestos Management Plan; and

• Example Management of Asbestos Policy

You will commonly be asked to volunteer a member of teaching staff for the inspector to meet with. Often inspectors ask questions which are wider than just asbestos, for example around the general support for staff in terms of health and safety or if they have any concerns they would like to raise. Ensure your chosen staff member is briefed and keeps their answers short and to the point, maintaining a professional, courteous rapport with the inspector at all times.

Provided you can deliver all of the above, you will have a successful visit and avoid any further costs being levied.