Current Awareness and Competence

Some PDs currently operate with a basic level of asbestos awareness training, which is designed to help workers avoid disturbing asbestos. While this is a foundational requirement, it is far from adequate for a role that involves planning, managing, and coordinating health and safety in the pre-construction phase of projects that actively involve asbestos-containing materials (ACMs). The PD needs to be able to do more than just “spot” a potential asbestos risk.

Hopefully their current competence is not likely to be limited to the basic areas of asbestos awareness such as:

* Recognising the potential for ACMs in a building based on its age and type.

* Understanding the basic health effects of asbestos exposure.

* Knowing that a refurbishment or demolition survey is required before work can begin.

* Appreciating the legal duty to manage asbestos.

As this level of awareness is not a substitute for competence in a project where asbestos is the primary focus of the work.

Required Skills, Knowledge, and Behaviours

To effectively manage projects with asbestos, PDs must possess a far deeper level of skills, knowledge, and behavioural attributes.

Skills & Knowledge

* Deep Asbestos Knowledge: A PD must understand the different types of asbestos, their properties, and how they behave in various scenarios. They need to know about different types of surveys (Management, Refurbishment, and Demolition), their limitations, and how to interpret their findings.

* Abatement & Remediation: PDs should have a solid understanding of asbestos abatement techniques, including enclosure, encapsulation, and removal methods for both licensed and non-licensed work. This knowledge allows them to effectively challenge and coordinate the work of asbestos removal contractors and other designers.

* Regulatory Expertise: Beyond a general understanding of CDM 2015, a PD must be an expert in the Control of Asbestos Regulations 2012 (CAR 2012). This includes an in-depth understanding of notifiable work, air monitoring requirements, and waste disposal regulations.

* Hazard Identification & Risk Mitigation: PDs must be able to critically assess asbestos survey reports and identify potential risks that may have been missed. They need the ability to challenge assumptions and design out risks at the earliest possible stage, for example, by specifying non-asbestos alternatives in new designs or by altering the project’s scope to avoid disturbance.

Behaviours

* Collaborative Leadership: The PD is a key coordinator. They must have the interpersonal skills to lead and facilitate communication between the client, designers, and principal contractor.

* Proactive & Inquisitive Approach: A PD must not be a passive recipient of information. They must be proactive in seeking out all relevant pre-construction information, asking critical questions, and challenging the status quo to ensure safety is the highest priority.

* Accountability: The PD must understand the potential legal and professional consequences of failing in their duties, including fines and imprisonment. This should drive a strong sense of accountability.

Key Considerations in the Project Lifecycle

The PD’s role in a project involving asbestos removal spans the entire lifecycle, but their influence is most critical during the pre-construction phase.

Pre-Construction Phase (Design & Planning)

This is where the PD’s competence is most vital. Key considerations include:

* Information Gathering: Ensure a thorough asbestos refurbishment/demolition survey is conducted and that all findings are fully understood and disseminated to the design and construction teams.

* Design Decisions: Influence design decisions to eliminate or reduce the need for asbestos removal. For example, can a new pipe run be routed to avoid an asbestos-insulated section? Can a wall containing asbestos be left in situ rather than demolished?

* Developing the Pre-Construction Information (PCI): The PD must ensure the PCI contains all necessary asbestos information, including survey reports, risk registers, and a clear plan for managing remaining ACMs. This information is crucial for the Principal Contractor to develop a comprehensive Construction Phase Plan.

Construction Phase

While the Principal Contractor takes the lead, the PD’s role continues. They must:

* Monitor & Coordinate: Ensure that the Principal Contractor is following the agreed-upon strategies for asbestos removal and that any design changes do not introduce new asbestos risks.

* Information Exchange: Serve as a link between designers and the construction team, providing clarification on asbestos-related design issues as they arise.

Post-Construction Phase

The PD is responsible for compiling the Health and Safety File. In asbestos projects, this file must be meticulously updated with all relevant information on the works undertaken, including any remaining ACMs and new materials installed. This is crucial for future management of the building and is a key part of the PD’s duty.

2. Elevating Asbestos Competence Among Principal Contractors

Secondly then let’s consider the same issue in relation to Principal Contractors. The construction industry continues to face the enduring legacy of asbestos. While the removal of this hazardous material is a highly specialised discipline, principal contractors (PCs) play a critical role in its safe management and abatement. The effectiveness of this role, however, is directly tied to their competence, a factor that  again requires careful consideration.

While licensed asbestos removal contractors (LARCs) possess a high degree of technical expertise, the overall success of an asbestos project hinges on the PC’s ability to plan, manage, monitor, and coordinate the work of all contractors. This next section of the article examines the current state of competence among PCs, the skills and knowledge required for this role, and the key areas for consideration throughout a project’s lifecycle.

Current Levels of Awareness and Competence

Many PCs likely have a basic understanding of asbestos, typically gained through mandatory Asbestos Awareness training. This level of knowledge is sufficient for general construction work where asbestos might be present, but not for projects where its removal is a planned activity. Even the common health and safety management qualifications such as CITB SMSTS and NEBOSH certificate in construction health and safety are limited in the levels of detail around asbestos work, to support the PC role.

The current level of competence often falls short in several key areas:

* Reliance on Subcontractors: PCs may assume that appointing a LARC absolves them of their own responsibilities. They often lack the in-depth knowledge to effectively scrutinize the LARC’s work plan, methodology, and control measures.

* Knowledge Gaps: There can be a lack of understanding regarding the nuances of asbestos types (e.g., friable vs. non-friable), the different types of work (e.g., notifiable non-licensed vs. licensed), and the regulatory requirements beyond general awareness.

* Reactive vs. Proactive Approach: Without a robust understanding of asbestos, PCs tend to react to issues as they arise rather than proactively managing risks from the project’s inception. This can lead to delays, cost overruns, and, most importantly, potential exposure risks.

Required Skills, Knowledge, and Behaviours

To effectively manage projects involving asbestos removal, PCs need to move beyond basic awareness and develop a more comprehensive set of skills, knowledge, and behaviours. This enhanced competence is not about making them asbestos experts, but about enabling them to be intelligent clients and effective managers of risk.

* Enhanced Knowledge: PCs should possess a deeper understanding of the Control of Asbestos Regulations 2012 (CAR), including the specific duties placed on them as a PC. They need to understand the role of asbestos surveys (management and refurbishment/demolition), the importance of clear scope definition, and the legal requirements for managing asbestos waste.

* Effective Planning and Coordination: The PC must be able to integrate the asbestos removal works seamlessly into the overall project plan. This includes coordinating the LARC’s activities with other trades, ensuring clear segregation of work areas, and managing access to the site.

* Proactive Risk Management: Instead of just reacting, a competent PC would:

* Verify competence: Scrutinize the LARC’s credentials, method statements, and past performance.

* Challenge assumptions: Question proposed methodologies, timelines, and control measures to ensure they are robust and appropriate.

* Monitor effectively: Know what to look for on-site to ensure the LARC is adhering to their method statement and safety protocols. This includes checking for proper enclosure integrity, decontamination unit setup, and air monitoring procedures.

* Robust Behaviours: Competent PCs exhibit a strong commitment to health and safety. They communicate clearly and consistently with all stakeholders, from the client and principal designer to the LARC and other contractors. They are not afraid to stop work if they have concerns and ensure that decisions are based on the hierarchy of control and regulatory compliance, not commercial pressures.

Key Areas in the Project Lifecycle

A PC’s competence is tested at every stage of a project involving asbestos removal. Focusing on these key areas can significantly improve outcomes.

Pre-Construction Phase

* Initial Assessment and Planning: The PC must ensure a thorough refurbishment and demolition survey is conducted and that the findings are used to inform the project plan. This is not simply a box-ticking exercise; it’s the foundation of a safe project.

* Procurement and Selection: The PC’s due diligence in selecting a competent LARC is paramount. This goes beyond checking for a license; it involves a detailed review of their experience, resources, and method statements.

Construction Phase

* Coordination and Control: The PC must act as the central point of contact for all asbestos-related activities. They need to ensure that the LARC’s work area is effectively isolated and that no other trades can interfere with the asbestos removal process.

* Monitoring and Supervision: Regular, competent supervision of the LARC’s work is essential. This includes checking that controls are in place and that the LARC is following their plan. The PC must also ensure that air monitoring and four-stage clearance procedures are properly executed by an independent and competent analyst.

Post-Construction Phase

* Information Management: The PC is responsible for ensuring that all records relating to the asbestos removal, including the LARC’s waste consignment notes, certificates of reoccupation, and clearance certificates, are properly handed over to the client for their Asbestos Management Plan. This is a critical step in fulfilling their duty to protect future occupants.

By encouraging PCs to develop a deeper level of asbestos competence and to actively engage in the planning, supervision, and coordination of asbestos works, we can collectively raise the standard of safety in the construction industry. This is not a luxury, but a fundamental requirement for protecting workers and preventing future tragedies.

Conclusion

Both the PD and the PC are in a prime position to influence the safety and success of a project involving asbestos removal. However, a general “asbestos awareness” is simply not enough. We recommend that FAAM members champion the need for enhanced and project-specific competence for PDs and PCs. This should include advanced asbestos training, a deeper understanding of abatement techniques, and a proactive, questioning behaviour. By continuing to raise the bar for PD and PC competence, we can significantly improve safety outcomes, reduce exposure risks, and ensure the effective management of this lethal legacy.

ARTICLE #4: BACK TO THE FUTURE

–         Article written by Cat Howard

Some closing thoughts from me.

So as we move forward, how do we improve this industry and stop the unnecessary exposure of people to this ‘evil dust’? Well I’m absolutely all for innovation and Jordan’s Marvin presents the first realistic achievable step in this area offering a potential solution to the issues we will face in this country to  lowering of the OEL in Europe given we are likely to have to follow suit sooner or later. In addition to some  straightforward developments in sampling equipment, Marvin will allow us to retain our on-site contemporaneous approach when it comes to personal monitoring and the CfR process, given it can count all slides. This frees up some time for the analyst to stop and think about the job and how crucial information is captured for that all important CfR upon completion of the works. The use of AI to capture data will also allow exploration of how we can use that data and any innovation always pave the way for more improvements the industry is screaming out for.

As an asbestos trainer and former primary school teacher I think the foundations for improvement in our industry will always lie in better education, tailored role-specific training and work on changing attitudes and behaviours. As the second article in this newsletter suggests, maybe we haven’t quite got there with training and education of the supervisors around the Supervisor’s Visual and the importance of the Handover Certificate? Also, the training of operatives ‘enough’ when we compare it to the training the analyst receives? It will be interesting to see your opinions on this through the poll so be sure to cast your opinions!

The third article from Rich Bennion is a stark reminder of what I am constantly seeing in context in the work I deliver. PMs, PDs and PCs in charge of managing the health and safety through a project that involves asbestos remediation with no solid knowledge or understanding of asbestos and sometimes even without basic asbestos awareness, because ‘that’s for people on site’. How are they reading and interpreting reports that identify the requirement for removal in the first instance and how are they ensuring remediation is being managed properly particularly on occupied sites. The likelihood is they are not. However, we don’t define their competency requirements anywhere, only that the duty holder should ensure they are competent. This brings me on to another related point: dutyholder competency. The role of the dutyholder is not appointed it is possessed by default. They sit at the top of the tree as the ‘conductor’ in the orchestra of asbestos management, but we see no definition in terms of training requirements in L143. The dutyholder of course though can and often does appoint competent people to support them but that’s potentially difficult to do if you are not competent in asbestos management as a dutyholder yourself. How do you check the competency of PDs and PCs for example? We also have a vast range of dutyholders types from those responsible for a single building or two like an industrial unit or a school for example to those within a housing association or a large NHS trust. In the larger organisations its not the dutyholder we need to train. They require some top tier senior leadership tailored asbestos briefings but it’s the appointed people we need to focus on, they implement the Asbestos Management Plan on a day-to-day and the plans though fundamentally the same as based on L143 and HSG227 deliver the requirements through processes bespoke to that organisation.

So, is a non-tailored off the shelf course for dutyholders responsible for a managing asbestos in a building or two likely to be effective? Absolutely, but any role within organisations of gathering complexity where the role involves some key responsibilities for managing the risk from asbestos during general occupation, repairs and maintenance, projects and disposal etc next level bespoke training specific to your role and organisation is key in my opinion. The most impactful training I have delivered has been in organisation where I have become embedded in supporting compliance so that I understand their activities and processes. The training content uses their own documentation, scenarios and even incidents making the training about them and how they operate and serves to encourage more effective ‘buy-in’ from the delegates. Even down to asbestos awareness, beyond the basics detailed in guidance we need to understand roles to deliver AA effectively.

Behaviours

As Article 2 shows us we cannot leave behaviours out of the equation when it comes to training and education in the asbestos industry. The Building Safety Act 2022 and its supporting guidance outline the fact that behaviours are a core component of individual competence. Professionals must not only be technically capable but also act responsibly, ethically and with safety as a priority. The inclusion of behaviours reflects lessons from the Grenfell Tower tragedy, where systemic failures were not just technical but also cultural. The Act aims to change the culture of the construction and building management sectors by promoting:

• Accountability
• Ethical decision-making
• A proactive approach to safety

The Act almost missed an opportunity to bring asbestos under its umbrella but that’s not to say we can’t adopt the same approach and education on behaviour is a must in effective training.

Almost every asbestos exposure incident and UKAS action I have been involved with investigating found its resolution in better training and education. I’m sure everyone would agree it would be nice to get that in up front and avoid both in the first instance with more effective training but have to incorporate those behaviours too. My focus over the coming year is to educate more and to educate more effectively and if we all do the same, we may just start to see that change in direction for the industry.