What Are The Current Asbestos Regulations? Understanding The HSG248 Guidelines
Even to this day, approximately 5,000 people die from asbestos-related diseases – such as asbestos-related lung cancer and mesothelioma – every year in the UK. This can be partly attributed to the long latency period for asbestos-related disease from the moment someone breathes in or swallows the mineral’s lethal fibres, with many incidents of asbestos exposure from prior to the ban only resulting in new diagnoses as recently as the 2020s.
Still, it is also true that new incidences of asbestos exposure can easily occur, including as a consequence of historical ACMs within a property being disturbed due to demolition, renovation, and other activities. So, safe and responsible asbestos management remains of the utmost importance today.
All this brings us onto the subject of the crucial work that asbestos analysts carry out. “Asbestos analyst” may be just one of many job titles in today’s asbestos industry, but if anything, it is a job title that might undersell the sheer breadth of what these professionals do. Asbestos analysts undertake all manner of vital and specialised tasks, ranging from management and consultancy to asbestos sampling and – of course – analysis of this notorious material.
With asbestos analysts frequently being involved in such processes as the assessment of environmental spread and contamination, as well as traditional airborne personal and static sampling, enclosure work, and reassurance sampling, they have long played an imperative part in the protection of public health and safety.
So, in that context, what is the HSG248 guidance publication, and why is it so important? Otherwise known as Asbestos: The Analysts’ Guide, this document – a PDF version of which can be downloaded for free from the Health and Safety Executive (HSE)’s website – is aimed at analysts involved in asbestos work. It is, in the regulator’s own words, “the authoritative source of asbestos analytical procedures in Great Britain.”
What are the HSG248 guidelines?
The HSE publication commonly referred to as simply “the HSG248 guide” is a revised version of Asbestos: The analysts’ guide for sampling analysis and clearance procedures, first published in 2005.
The document was updated to its current version in 2021, when changes were made including a higher level of detail on scoping/contract arrangements, improvement of the four-stage clearance procedure, and stronger impartiality requirements, to cite just a few of the alterations. These updates were made in light of relevant legal changes, findings from the HSE’s interventions, and advancements in analytical procedures and methodology.
With its chapters encompassing such crucial topics as the role and responsibilities of an asbestos analyst, accreditation and quality assurance, competence and qualifications, and the asbestos sampling, analysis, and clearance work itself, the HSG248 guide really is a comprehensive and authoritative resource for asbestos professionals.
The HSG248 guide has been put together to help analysts achieve compliance with the Control of Asbestos Regulations 2012 (CAR 2012), which is the overarching asbestos legislation in the UK.
This publication is intended to be read in conjunction with other HSE guidance, including the associated Approved Code of Practice (ACOP) and L143 (current edition) guidance document, as well as the likes of HSG210 Asbestos essentials, HSG247 Asbestos: The licensed contractors’ guide, and HSG264 Asbestos: The survey guide. The HSE website also features in-depth information that will further assist asbestos analysts’ efforts to make sure their work complies with the law.
Who are the HSG248 guidelines aimed at?
The HSG248 document is very much aimed at a technical audience, which – as the title indicates – includes asbestos analysts. However, the guidance is also relevant and useful to a broad range of other professionals, including asbestos consultants, occupational hygienists, and safety professionals.
The likes of asbestos removal contractors and supervisors, as well as employers, building owners, and people with responsibility for the management of properties and estates, can also be helped in their work when they read this publication.
What are the core knowledge requirements of the HSG248 guidelines?
There are naturally certain things that asbestos analysts and related professionals need to know in order to carry out their work safely and effectively. The HSG248 document and others available from the HSE play an integral role in ensuring such asbestos specialists are well-equipped with the most accurate, relevant, and up-to-date knowledge.
Asbestos analysts need to possess a comprehensive knowledge, for example, of the various types of asbestos and their associated risks. They also need to be well-informed on the scientific principles underpinning asbestos sampling and analysis, as well as the legal and regulatory framework that governs asbestos testing.
What does HSG248 say about sampling and analytical procedures?
Chapter four of the HSG248 publication summarises the requirements for the sampling and analysis of materials that are suspected to be ACMs. Both analysts and surveyors can carry out asbestos sampling, and there are various procedures that help ensure representative samples of suspected asbestos materials are collected, at the same time as maintaining safety.
Vital procedures to follow in the collection of asbestos samples include, but are not limited to:
- Protecting any surfaces onto which asbestos debris may fall with a sheet of impervious material, such as polythene; this helps guard against contamination and make the cleaning process easier
- Thoroughly cleaning any sampling equipment prior to reuse, to guard against any cross-contamination between samples
- Individually sealing all samples in their own uniquely labelled container, with each sample then being sealed in its own second container, such as a polythene bag
- “Making good” the sample area once sampling has been completed – in other words, ensuring it is left clean with no evidence of debris from the sampling operation
- Sealing sampling points to prevent the release of fibres; various methods can be used to reseal a sampling point, such as tapes, fillers, and encapsulants, and the method used should be pre-agreed with the client, as well as genuinely appropriate, long-lasting, and effective
- Making the client aware of situations that could prejudice the sampling organisation – for example, the given area already being contaminated with asbestos debris, and it therefore not being reasonable to expect the sampling organisation to leave the area clean
- Informing the client of situations where sampling cannot be conducted – such as if the area cannot be accessed or is dangerous, perhaps due to live electrics or the area being unstable
Alongside the information it provides on all the above, the HSG248 guide sets out the techniques and methodologies that can be key to ensuring genuinely accurate asbestos analysis.
The publication also contains information and insights into quality control and assurance in asbestos testing. This is the focus of chapter two of the document, which covers such topics as the importance of analysts and surveying organisations having robust internal quality control procedures and auditing procedures, as well as of auditing procedures being developed for each area of an analyst’s work, and records of analysts’ training being kept.
What does HSG248 say about clearance procedures and reporting?
Regulation 17 of the Control of Asbestos Regulations 2012 (CAR 2012) outlines the legal requirement for a given premises – or parts of the premises – to be thoroughly cleaned once asbestos has been removed from the affected area. It is the employer of the workers carrying out the work – in other words, the licensed contractor – that is legally responsible for such cleaning.
Once this cleaning has been carried out, the licensed contractor – normally the supervisor – will be expected to undertake a thorough visual inspection of the work area, in readiness for the “handover” of the site to the analyst for an independent multi-stage clearance procedure. The supervisor’s visual examination must be thorough enough to make sure it is completed to a satisfactory visual standard, with there being no visible dust or debris.
The licensed contractor should confirm that this process has been satisfactorily completed by completing the handover document, including the signed declaration. The document will need to be presented to the analyst, who should not begin the independent clearance process until the handover document has been received and is satisfactory.
There will be a need for the analyst to carry out their own separate, independent assessment of the premises or area(s) where the removal has taken place. This will allow the analyst to ascertain that the locations are thoroughly clean and fit to return to the owner/occupier to be reoccupied (or demolished, as the case may be).
This inspection by the analyst to establish the affected area’s fitness for reoccupation will need to incorporate a four-stage examination of the relevant locations, and the issue of a clearance certificate, otherwise known as the “Certificate of Reoccupation” (CfR). Receipt of the handover form should be recorded in the CfR.
Chapter six of the HSG248 document provides further in-depth information on the requirements and procedures in relation to site clearance and certification where asbestos removal work has occurred.
What are the Health and safety considerations of HSG248?
Part three of the HSG248 guide – consisting of chapter eight on personal protective equipment, as well as chapter nine on decontamination procedures – goes into detail on how risks to analysts’ health and safety can be controlled.
Personal protective equipment (PPE) – including respiratory protective equipment (RPE) – plays an essential role in analysts’ efforts to control their exposure to asbestos across a broad range of tasks. The relevant chapter of the HSG248 guide covers various factors of how PPE and RPE should be used and maintained to help ensure safety.
The publication also sets out in-depth information on decontamination procedures, accounting for the various circumstances in which asbestos analysts may enter asbestos enclosures or designated work areas and become contaminated in the process.
Knowing all the relevant procedures to follow for decontamination – as outlined by the HSE – will be of the greatest importance for ensuring the affected PPE and RPE, as well as the individual themselves, are thoroughly and safely cleaned. This will help prevent asbestos from being spread any further, including the risks of secondary exposure for the analyst.
The HSG248 guide also references other aspects of developing safe systems of work for asbestos professionals, including during the processes of sampling and analysis. Such measures as the use of water and/or another suitable wetting agent to pre-wet material that is to be sampled, as well as ensuring the areas to be sampled inside buildings are unoccupied as far as possible during sampling, will further help ensure the highest health and safety standards.
What roles does compliance and continuous learning have in the HSG248 guidelines?
One of the most important reasons for any asbestos analyst to consult the HSG248 document, is the profound role the publication plays in helping such asbestos professionals to comply with CAR 2012.
The HSG248 document is, of course, a guide instead of a law or a set of regulations in itself, so it is not the case that everything stated in the document is mandatory. However, in the words of HSE, “if you do follow this document, you will normally be doing enough to comply with the law.”
Violations of the UK’s asbestos regulations can incur extremely serious consequences. In the event, for example, of a dutyholder under CAR 2012 failing to have an asbestos management plan in place, they could be running the risk of being fined as much as £20,000, or imprisoned for as long as six months. Serious regulatory breaches can lead to even higher penalties, of an unlimited fine and/or a two-year prison sentence.
Something else that professionals engaged in asbestos analysis should be aware of, is the importance of continuous education throughout their careers, including so that they can keep their knowledge accurate and up to date in line with current best practices and any legal changes.
Sure enough, this is a topic that the HSG248 guide also addresses. The document states that individual training needs should be assessed and met on an ongoing basis, as and when this is required, and that it is not necessary to wait for formal “refresher” dates to address any identified needs or performance issues.
The guide goes on to state that analysts should receive refresher training in line with the requirements of the ACOP, and that refresher training should be provided annually for those whose work causes the regular disturbance of asbestos. Analysts need to be aware of any changes to guidance, ACOPs, and regulations.
Conclusion: HSG248 is an indispensable publication for asbestos analysts
We hope that this article will have helped make clear to you the value and importance of the HSE’s HSG248 publication for asbestos analysts. After all, these are specialised professionals whose work requires them to be highly knowledgeable about the various asbestos analytical procedures in Great Britain, and to carry out those procedures in a legally compliant manner.
With this document having first been published in 2005, and revised since then to take account of developments in analytical procedures and methodology as well as findings from HSE interventions, it can be very much regarded as a “living document” subject to further updates and revisions.
Are you on the lookout for accredited and licensed asbestos services in the UK, encompassing such areas of knowhow as asbestos testing, surveying, removal, training, and management? If so, we can provide you with a free and fast quote here at Oracle Solutions, when you contact us today.
Written by Jess Scott
Jess Scott has been an all-round asbestos consultant since 1996. That’s nearly 3 decades of asbestos knowledge. He spends his time sharing that knowledge with the team at Oracle and with their clients. Jess's goal is, and always has been, to use my expertise in helping people to comply with the law. This legal compliance ultimately helps to protect everyone from the harmful effects of asbestos. Jess has acted as an asbestos expert witness in legal cases and is involved in many asbestos educational activities throughout the UK.