Graham Warren, Manager at ACAD discusses the focus that is now placed on employers to ensure employees are competent to work with asbestos.
With the publication of the latest Asbestos Code of Practice (ACoP) Managing and Working with Asbestos (L143), a great debate has arisen over the impact of competency.
Although supporting legislation remains relatively unchanged, significant prominence has now been given to the matter of employee competence. The focus is now on employers to illustrate that employees are competent to work with asbestos.
Prior to publication of the latest ACoP, most of the asbestos industry was locked into a cycle of 3 day new operative/supervisor/manager training for new recruits followed by a full day’s annual refresher training.
Refresher training should have been based on a Training Needs’ Analysis (TNA) – but this was not always the case.
All training courses were certificated, which meant anyone undertaking an audit of a licensed contractor, from client organisation to the Health and Safety Executive (HSE), could simply check the expiry date of an individual’s training certificate.
Companies had to go to great lengths to ensure certificates were always available on site, particularly if they were managing lots of jobs at the same time with a flow of operatives between sites depending on workload.
Senior management were also required to validate individual training certificates to help stamp out fraudulent copies.
Do asbestos workers still need annual refresher training with the advent of the new ACoP?
Yes – but the length and method of delivery is now a lot more varied. Length of training depends on the results of the individual’s TNA. It is possible the individual may only require a short toolbox talk.
As a minimum, this needs to include reviewing where things have gone wrong and sharing good practice. On the other hand, a particularly poorly performing employee may need re-training on multiple issues almost requiring a repeat of the initial 3 day new operative training.
The key message is to maintain an up-to-date TNA on all employees coupled with a minimum standard of annual refresher training. Where work methods, equipment or the type of work change, training is required to address these more immediately than routine annual training.
Companies can conduct this process in house. The possible drawback comes in demonstrating the impartiality in assessments of employees.
ACAD can help by using our A1 assessors to conduct assessments live on site by themselves, or as part of our industry leading site audits.
Another potential drawback is that a company does not assess its employee’s competency to a sufficient level. Fortunately, ACAD and other recognised industry bodies are developing a template for the competency scheme, which will be applicable to organisations of all sizes.
What should a good audit be looking for on site?
In the short term, it should look for nothing too different to the routine, annual refresher certificates as a transition period is required for the changes. However, good things to start looking for would be evidence that companies are conducting TNA’s of employees and addressing any gaps identified.
Such assessments should also include an assessment of behaviour, as highlighted by RR877 – ‘A Commentary on routes to Competence in the Construction Sector’. Eventually, when an industry-wide approach has been refined, all organisations will go down this route, but any already on the road are doing well.
Graham Warren BSc (Hons) CoC (Asbestos)
Asbestos Control and Abatement Division (ACAD) of
the Thermal Insulation Contractors’ Association (TICA).
Tel: 01325 466704