Inside the Danger Zone: An Asbestos Analyst’s Perspective on the Challenges of Licensed Asbestos Removals

As someone who has worked extensively in the field of asbestos consultancy for over 13 years, I’ve seen firsthand how the system is supposed to work — and how, all too often, it doesn’t. Despite the legal frameworks and licensing requirements designed to protect both Licensed Asbestos Removal Contractors (LARCs), analysts and the public from the risks of asbestos exposure, many licensed asbestos removal contractors and analysts routinely fall short of best practices.

While there are competent and ethical contractors out there, this article highlights common — and deeply concerning — issues I’ve witnessed when auditing or analysing the work of licensed asbestos removal contractors across the UK.  This isn’t finger pointing at LARCs only. Where I have flagged bad practice and failed enclosures [SM1] the solution by consultancies has often been to just send another analyst who they know will pass the enclosure, regardless of the issues raised.

A little about me, I started out in 2012 in an SEM laboratory, ironically for a company whose main discipline was asbestos removals but who also had a small SEM laboratory at their office. Soon after I moved on to a much larger consultancy where I began bulk analysis, second assisting on surveys and analytical site work. I hold the P401, P402, P403 & P404 but currently I am predominantly a senior analyst tackling larger projects and complex certificates for re-occupation.

I have worked with some exceptional supervisors whose attention to detail, communication and accountability for their team, has been spot on. I’ve also worked with supervisors who either don’t understand or do not care what their duties are. I’ve been sent into areas that are still heavily contaminated with asbestos residues despite the supervisor carrying out their pre-visual which highlights a distinct lack of training and awareness of supervisors and operatives about ACMs, what they look like, where they are found and the correct procedures for removal.

From my perspective and experience on site I feel training is a big issue with removals and it interesting to compare operatives training with the training that analysts receive. Just this year, I’ve had operatives tell me that they don’t know what AIB looks like in an enclosure and that they’ve been told they can smoke in a quilling enclosure because ‘there’s no asbestos in here’. Many supervisors still don’t seem to be on board with the standards for visual inspection despite FAAM shining a light on this aspect of training at the 4SC Workshop presentation during the Asbestos 2023 Conference. Analysts are required to have a minimum of 2 months training/shadowing with a qualified analyst, two courses across 5 days containing multiple written and practical exams. This is to be followed by a minimum of  6 training audits on different sizes and complexities and 2 final authorisation audits before sign-off to work alone within licensed removal enclosures with certificate for re-occupation. In contrast, general operatives have a 3-day course and some minimal internal sign-off prior to authorisation at best to go into a live enclosure and strip an IARC categorised Group 1 carcinogen. Is this sufficient given the operatives are stripping the material vs. an analyst who in theory only enters ‘clean areas’?

Some examples of things I have witnessed on high-profile removal project this year include:

  • The smashing out of an AIB ceiling with hammers
  • An operative tampering with the analyst’s equipment: removing the filter & O ring in personal pump. This was an operative responsible for the ‘smashing’.
  • A supervisor ‘storming’ into enclosure during the visual inspection to ask what was taking so long.
  • The removal of hard set lagging by inexperienced operatives who admitted to use of a Graco to blast thermal insulation out from under pipe brackets rather than unscrewing the bracket and cleaning carefully. Subsequently the thermal insulation ended up coating all walls around the pipes that had contained the hard set lagging in the first place.
  • Operatives walking out of live enclosures and entering straight into the clean end of a DCU, depositing dirty work gear and walking away.
  • Baby oil used on pipework to keep down fibre levels and make surfaces look clean. (Seemingly a variant on the old school use of diesel oil and hairspray?)
  • Sexist/derogatory comments made towards myself including threat to sell my phone number and stalk me on social media.
  • Supervisor acknowledgement that the 2hr supervisors visual detailed on the Handover Form had not actually been conducted.
  • Being asked to begin the CfR without a Handover Form because the supervisor hadn’t been supplied with one.

This has also been accompanied in some instances by a lack of support initially from the organisations I have been working for. I have experienced undue pressure from project managers and general pressure to overlook things and compromise on my standards and integrity.[SM2]

Improved training for Supervisors was a given requirement further to the Asbestos Network’s Appendix 01/24. This appendix, produced by the technical working group that brings together expertise from both the analytical and removal perspectives,  acknowledges the lack of guidance on the Supervisor’s Visual in HSG247 and attempts to fill that gap, providing guidance which is generally accepted as best practice to be followed. Despite this, there still seems to be a significant difference in the standard that the LARCs remove the ACMs to and the standard that the analysts work to, to pass the Stage 2 visual. This is also linked to how the job has been planned and whether the contracts manager has allocated a sensible amount of time for the supervisor’s visual in the first place.  This then breeds conflict between LARCs and analysts as analysts are perceived as being awkward/too keen/petty. Analysts are trained to enter an enclosure and look over every single surface, where the ACM was removed from and the general surfaces in the enclosure. I personally feel that many operatives mainly focus on where the ACM for removal is and the rest of the enclosure either gets a quick wipe with a dirty rag or ignored entirely. When this is inevitably picked up during a certificate for re-occupation, analysts hear phrases such as ‘it dries dirty’, ‘I’ve wiped that 10 times already this morning’ and ‘it’s a boiler room what do you expect?’. Many analysts may then feel pressured to ignore the general dust and debris to avoid conflict with the operatives. So have the changes to training post the introduction of Asbestos Network’s Appendix 01/24 been implemented and have they been effective? My experience suggests not.

I believe that a lot of the time, the supervisors are also fighting a losing battle with their own contracts managers/project managers. It’s not uncommon for a schedule of removal works to not include any time for the supervisor’s visual. The fine cleaning of the area finishes at the end of one shift and the analyst is booked at the start of the next shift for the Certificate for Re-occupation, not allowing any time for the supervisor to rectify any issues he might have found on his visual. I’ve witnessed conscientious supervisors contact their managers about issues with their plan of works, ASB5s, isolation etc to be ignored for weeks at a time on projects. When issues like this are not dealt with as required the onus is then on the analyst to stop the works until corrective action is made, leading to further conflict.

I do think a lot of the issues with removal works currently unsurprisingly come down to profit. This filters down to the supervisor and operatives who are often chasing a bonus to bring the job in earlier than scheduled. Again the analyst is in the firing line because if visuals fail it can have a direct impact on what operatives are paid.

There’s a blame culture in the asbestos industry and in removal the default seems to be to blame the analyst. Being an analyst who will ensure things are done correctly, regardless of how long it takes, usually puts me within the crosshairs of all parties often being shelved with the blame for things ‘taking too long’. I’ve also, against my better judgement and the 10-minute rule, been in enclosures far too long helping to point out areas which need recleaning to operatives, only to be chastised by LARCs and clients for taking too long on visual inspections. Damned if you do, damned if you don’t as an analyst and being a female on top leads to some very stressful situations.

Overall, I still enjoy my job, I enjoy tying all the bits together at the end of a project and producing a thorough certificate that helps the client to understand what we’ve been able to do and what we haven’t, protecting everyone from exposure has always been my main priority. I meet people from all walks of life and endeavour to build collaborative relationships on site. I try my best to educate as much as I can, particularly if the operatives are new to the industry, but there’s only so much I can do during a short term removal project. The culture and attitudes in an organisation come from the top.

In my opinion, there needs to be more accountability for anyone putting others[SM3]  at risk from asbestos exposure. Operatives themselves, analysts, occupants and members of the public are being put at risk through shoddy work practices and the prioritising of profit over safety.

Asbestos is not just an occupational hazard — it’s a public health threat. Every fibre left behind due to carelessness or cost-cutting could end up in someone’s lungs. And decades from now, those fibres could trigger a fatal asbestos related disease.

As an analyst, my job is to uphold the highest standards — not just to tick boxes, but to ensure that removal has been done thoroughly and safely. We owe that to the contractors on site, the residents or occupants of the building, and ultimately the client paying for our expertise.