ARCA's Continuous Improvement Approach to Asbestos Removal Site Audits

The Asbestos Removal Contractors Association (ARCA) has been at the forefront of promoting safety and compliance within the asbestos removal industry for over 40 years, with the association's Site Audit Accreditation Scheme playing a key role in this for more than two decades.

Through its commitment to continuous improvement, ARCA has been actively refining its site audit practices to ensure high standards are consistently met across the sector. By conducting regular standardisation meetings, ARCA has fostered an approach to addressing key issues, providing feedback to auditors and members, and implementing measures to enhance the consistency and effectiveness of site audits.

ARCA's site audits serve as an essential tool for assessing the performance and compliance of asbestos removal contractors. The Health and Safety Executive (HSE) recognises the value of independent audits conducted by external bodies, particularly during the licence renewal process for asbestos removal contractors (LARCs).

The HSE have clarified their approach to evaluating LARCs during the licence renewal assessment process. While HSE inspections serve as the primary source of intelligence, they also consider additional evidence, both positive and negative, about LARCs. This evidence can range from prosecutions for health and safety offences to audits conducted by the LARC itself or by external bodies.

The HSE expressed a preference for independent evidence, as it provides an unbiased assessment of a LARC's performance. Although internal audits and client audits can be valuable, the HSE finds that established trade bodies, such as ARCA, offer a degree of independence along with strong technical and regulatory knowledge. This is part of the rationale behind the HSE's decision to share notification data with trade bodies, enabling them to effectively plan and carry out site audits.

ARCA has actively addressed any inconsistencies observed in the way auditors respond to specific audit questions. Through analysis and discussions, modifications to question wording and revised guidance have been proposed to clarify the intent behind enquiries related to important aspects such as the planning of leak tests, personal monitoring, and removal procedures. By ensuring that auditors have a clear understanding of the objectives and criteria associated with each question, ARCA aims to promote accurate and consistent assessments across all audited sites.

The evaluation of on-site welfare provisions has also been a point of emphasis for ARCA. Aligning its approach with the Health and Safety Executive (HSE) operational guidance, ARCA has adopted a pragmatic stance that balances the need for good standards with the recognition of practical realities on asbestos removal sites. Auditors are instructed to consider the overall adequacy of welfare facilities, distinguishing between minor omissions that can be addressed through observations and significant deficiencies that necessitate the recording of non-compliance. This approach ensures that the welfare of workers remains a priority whilst acknowledging the challenges inherent in asbestos removal operations.

Assessing the accuracy and validity of negative pressure and air mover calculations has been another important area of focus for ARCA. Recognising the importance of effective containment and air management in asbestos removal, ARCA has provided training to its auditors on evaluating the calculation methods employed by contractors. Rather than solely relying on final figures, auditors are encouraged to adopt a thorough approach, examining the validity and documentation of calculation methods. Additionally, auditors are trained to conduct physical inspections of the enclosure to confirm that negative pressure is effectively achieved and maintained throughout the removal process.

To further support auditors in their role, ARCA has issued guidance on audit scoring, emphasising the need to focus on the overall intent and substance of requirements rather than minor technicalities. Auditors are encouraged to exercise professional judgement when making assessments, reserving non-conformances for significant issues that pose risks to safety and compliance whilst noting minor deviations as observations. This approach ensures that the audit process remains objective, evidence-based, and aligned with the principles set out in regulations, Approved Codes of Practice (ACoP), and industry guidance.

Recognising the practical challenges faced by contractors during site setup, ARCA has addressed the issue of uncapping Negative Pressure Units (NPUs). Whilst the preferred scenario involves keeping NPUs capped until the enclosure is fully prepared for smoke testing, ARCA acknowledges the occasional necessity of uncapping during the setup process. In response, the association has drafted a position statement outlining the acceptable conditions under which uncapping can occur. These include ensuring that the NPU is continuously running, workers are equipped with appropriate respiratory protective equipment (RPE), and contamination control measures are in place. By providing this guidance, ARCA aims to balance maintaining safety standards and accommodating the practical realities of asbestos removal work.

Through its efforts to refine site audit practices, ARCA demonstrates a commitment to upholding standards of safety and compliance within the asbestos removal industry. By seeking opportunities for improvement, providing guidance to auditors, and fostering consistency and professionalism, ARCA plays a vital role in safeguarding the well-being of workers, the public, and the environment from the risks associated with asbestos exposure. As a trade association for the asbestos removal sector, ARCA remains dedicated to supporting its members, promoting industry best practices, and collaborating with regulatory bodies to promote exemplary levels of health and safety management during asbestos removal work.