This document is a revised version of Asbestos: The analysts’ guide for sampling analysis and clearance procedures, first published in 2005. It contains guidance for analysts involved in asbestos work and is the authoritative source of asbestos analytical procedures within Great Britain. The guidance has been updated to take account of legal changes, findings from HSE’s interventions, and developments in analytical procedures and methodology. It provides clarification on technical and personal safety issues, especially in relation to sampling and 4-stage clearances. Information to assess the presence of asbestos in soils and made ground is included for the first time. The guidance is also designed to assist analysts in complying with the Control of Asbestos Regulations 2012. The document should also be particularly useful HSG248 (Second edition) to several other groups, including asbestos consultants, occupational Published 2021 hygienists, safety professionals, asbestos removal contractors, building owners and people with responsibility for managing asbestos in properties and estates.

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First published 2005 Second edition 2021 (amended July 2021)

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This guidance is issued by the Health and Safety Executive. Following the guidance is not compulsory, unless specifically stated, and you are free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law. Health and safety inspectors seek to secure compliance with the law and may refer to this guidance.

CONTENTS Introduction 5 Purpose of this guidance 5 Intended audience 6 Legislation 6 Health effects 7 PART 1: ROLE AND ARRANGEMENTS 9 Chapter 1 The analyst’s role and responsibilities 10 Risk to analysts 10 Notification of work 11 Risk assessment and plan of work 12 Four-stage clearance 12 Professional standards 13 Chapter 2 Accreditation and quality assurance 14 Organisational competence 15 Quality control 15 Monitoring site work 15 Chapter 3 Competence and qualifications 18 Organisation-related 19 Health and safety 19 Function-specific 20 Ongoing/refresher 22 PART 2: SAMPLING, ANALYSIS AND CLEARANCE WORK 25 Chapter 4 Bulk sampling and material analysis 26 Introduction and regulatory requirements 26 Safe systems of work 26 Bulk sampling strategies 27 Number of samples 30 Procedures 31 Sample and site labelling 31 Methods 32 Records and reporting of sampling 33 Bulk sampling of stone materials (with small proportions of asbestos) 34 Chapter 5 Measurement of airborne fibre concentrations 35 Introduction and regulatory requirements 35 Personal sampling 35 Static sampling 37 Air sampling and analysis by phase contrast microscopy 38 Use and limitations of PCM 39 Sampling strategies including the statutory measurement method for the control limit 41 Sampling types 42 Static sampling 43 Analysis, calculation, recording and reporting of results 48 Other sampling methods 49 Chapter 6 Site clearance and certification 50 Introduction and regulatory requirements 50 Scoping and planning the four-stage clearance 52

Site clearance process and certification 53 Visual confirmation of site cleanliness and thorough cleaning 55 Remaining asbestos materials 56 Cleaning of areas after incidents or damage 57 Clearance where there is inadequate enclosure integrity 57 Chapter 7 Soils and made ground 58 Introduction and regulatory requirements 58 Differences between asbestos in soils and asbestos in buildings 59 Initial investigation to establish whether ACMs could be present 59 The asbestos risk assessment process for CAR 60 Preliminary site survey 60 Main site survey 61 Risk estimation and evaluation 61 PART 3: CONTROLLING THE RISKS TO ANALYSTS 65 Chapter 8 Personal protective equipment 66 Introduction and regulatory requirements 66 Respiratory protective equipment 67 Other personal protective equipment 70 PPE and RPE for asbestos activities 71 Summary of clothing, PPE and RPE to be worn 72 Chapter 9 Decontamination procedures 73 Introduction 73 Four-stage clearance 73 Preliminary decontamination 73 Full decontamination 77 Decontamination following bulk sampling 77 PART 4: TECHNICAL APPENDICES 79 1 Fibres in air: Sampling and evaluation of fibres by phase contrast microscopy 80 2 Determination of asbestos in bulk materials 110 Annex 1 Glossary of terms that appear in Appendix 2 144 3 Water absorption test: Method to differentiate between asbestos insulating boards and asbestos cement sheets 147 4 Fibres in air: Discrimination between fibre types in samples of airborne dust on filters using microscopy 153 Annex 1 Hierarchy of techniques and decision-making 164 Annex 2 Additional equipment required 165 Annex 3 Observations that can be made by PCM 166 Annex 4 PLM examination of mounted acetone/triacetin filters 170 Annex 5 Discrimination fibre count sheet for PCM/PLM 173 5 Four-stage clearance and decontamination unit clearance methods 174 6 Templates 195 7 Surveying and sampling for asbestos in soil and made ground 203 8 Soil and made ground: On-site sampling and measurement of airborne fibres and dust for risk assessment 218 9 Recommended core competences to be achieved via on- and off-the-job development 221 END MATTER 229 Abbreviations 230 References 231 Acknowledgements 237 Further information 238

INTRODUCTION

Purpose of this guidance This document is a revised version of the Analysts’ Guide first published in 2005. It contains guidance for analysts* involved in asbestos work and is the authoritative source of asbestos analytical procedures within Great Britain.

The guidance has been updated to take account of legal changes, findings from HSE’s Analyst Inspection Programme1 and developments in analytical procedures and methodology. It provides clarification on technical and personal safety issues; especially in relation to 4-stage clearances. Information to assess the presence of asbestos in soils and made ground is also included.

The guidance is designed to help analysts comply with the Control of Asbestos Regulations 2012 (CAR).2 It should be read in conjunction with other HSE guidance including:

■ the associated Approved Code of Practice (ACOP) and guidance L143 (current edition);3 ■ HSG210 Asbestos essentials;4 ■ HSG247 Asbestos: The licensed contractors’ guide;5 ■ HSG264 Asbestos: The survey guide;6 and ■ information on the HSE website.

All references to ‘the regulations’ in this guide are references to the version of CAR current at the time of publication. The same applies to references to ACOP L143 and other HSE regulations and guidance.

Analysts have an important role to play in the protection of people’s health and it is essential that they act competently and professionally. This document specifies the methods which should be used by analysts for the measurement and identification of asbestos. It also provides examples of templates and forms which can be used to record information. In addition, it provides instructions on other matters including clearance procedures for asbestos removal and information on personal safety for analysts such as the use of personal protective equipment (PPE), respiratory protective equipment (RPE) and decontamination processes. All the topics covered by the guide are listed in the contents page.

Although this guidance covers the sampling and analysis of suspected asbestos-containing materials (ACMs), it does not go into detail about surveying and assessment for asbestos. Surveying of premises is comprehensively covered in HSG264 Asbestos: The survey guide. Guidance on the assessment and management of asbestos in buildings is given elsewhere (ie the HSE website,7 Managing asbestos in buildings: A brief guide INDG2238 and A comprehensive guide to managing asbestos in premises HSG227).9 Industry-based guidance published by the Joint Industry Working Group on Asbestos in Soils,10 CIRIA C73311 and the SCA Blue Book12 are all considered to be compatible with Asbestos: The Analysts’ Guide.

* Note: the use of the term ‘analysts’ as used within this document depends on the context. It may refer to individual analysts or an organisation as an analyst’s employer. Analysts are individuals or organisations involved in the sampling, analysis and assessment of asbestos under the regulations. Analyst organisations may also provide a range of other advisory and consultancy services. Asbestos samples may also be taken by asbestos surveyors.

Intended audience The target audience for this document is technical and includes asbestos analysts, asbestos consultants, occupational hygienists and safety professionals. The publication should also be useful to asbestos removal contractors and supervisors, employers, building owners and people with responsibility for managing properties and estates. This publication is a guidance document but it sets out various procedures to comply with CAR2012 and the ACOP L143. Only UKAS-accredited organisations may be used for activities such as 4-stage clearance and where compliance/ conformity is required with the ISO standards 17020 and 17025. These include requirements for laboratory procedures, quality control and assurance, and impartiality arrangements. Unless specifically stated, you are free to take other equally effective action, but if you do follow this document, you will normally be doing enough to comply with the law.

Legislation CAR applies to all work activities involving asbestos. This includes all analysts’ work that disturbs asbestos. It sets minimum standards for the protection of employees and others who could be affected. CAR sets requirements for the employer to:

■ identify the presence of asbestos and its type and condition before work starts (Regulation 5); ■ assess the risk from asbestos for workers and others (Regulation 6); ■ prepare a suitable plan of work (POW) (Regulation 7); ■ make sure employees receive appropriate information, instruction and training (Regulation 10); ■ prevent employees being exposed to asbestos or, if this is not possible, to put into place the measures and controls to reduce exposure to as low as reasonably practicable (ALARP) (Regulation 11); ■ prevent or reduce the spread of asbestos to the lowest level reasonably practicable (Regulation 16); ■ arrange regular monitoring of airborne asbestos fibres (Regulation 19) where necessary; ■ make sure air testing and site clearance certification is carried out to set standards; ■ provide suitable washing and changing facilities (Regulation 23).

The regulations also require building owners to manage the risk from asbestos in non-domestic premises (Regulation 4) to ensure that asbestos does not cause harm to anyone who works on or occupies the building or premises.

The regulations apply to the self-employed as they apply to an employer (Regulation 3(1)). In addition, the people who could be affected by the work must also be taken into account (Regulation 3(3) and the Health and Safety at Work etc Act 1974).13 This includes employees of other employers, people occupying buildings and members of the public.

The identification of asbestos may also be required as part of planned construction work. Relevant roles and responsibilities for this are covered by the Construction (Design and Management) Regulations 2015 (CDM). Full details regarding this are contained within HSG L153: Managing Health and Safety in Construction14 (see also paragraph 4.3).

Employers must consult safety representatives appointed by recognised trade unions under the Safety Representatives and Safety Committees Regulations 197715 about health and safety issues. Employees not covered by such representatives must be consulted, either directly or indirectly, via elected representatives of employee safety, according to the Health and Safety (Consultation with Employees) Regulations 1996.16

Introduction

Health effects Inhalation of asbestos fibres can cause several fatal or serious respiratory conditions. Asbestos is a category 1 human carcinogen. It can cause two main types of cancer: mesothelioma and lung cancer (see Box 1.1). Asbestos can also cause asbestosis (scarring of lung tissue). Asbestos-related diseases can take 15–60 years to develop. Other less disabling lung changes such as pleural plaques and diffuse pleural thickening may be indicative of asbestos exposures but can be due to other causes. Further information on the types of disease associated with worker exposure to asbestos is given on the HSE website.17

Any work which disturbs asbestos materials will cause asbestos fibres to become airborne, putting analysts and others at risk. Asbestos is a cumulative hazardous material; the overall risk of developing mesothelioma depends on the number of repeated exposures which occur over a lifetime. However, single occupational exposures are not without risk. A safe threshold of exposure for mesothelioma has not been identified (although the possibility of a practical threshold cannot be discounted). Therefore, each single exposure gives rise to a risk of developing disease in its own right. As the disease can take several decades to develop, there is no immediate ill-health effect.

Asbestos kills more people in the UK than any other single work-related source. There are estimated to be more than 5000 asbestos-related deaths a year18 at the time of writing. These deaths are mostly the result of past heavy exposures from the manufacturing and installation of asbestos products, particularly asbestos insulating board (AIB). However, many ACMs remain in place in buildings and must be managed to reduce the exposure and risk. There is an increased risk associated with exposure to amphibole asbestos fibres (eg amosite and crocidolite) in comparison with chrysotile.19

Box 1.1 Asbestos cancers Mesothelioma Mesothelioma is a cancer of the cells that make up the lining around the outside of the lungs and inside the ribs (pleura), or around the abdominal organs (peritoneum). By the time it is diagnosed, it is almost always fatal. Like other asbestos-related diseases, mesothelioma has a long latency period from first exposure to the onset of disease, on average 30–40 years.

Lung cancer Lung cancer is a malignant tumour of the lungs’ air passages. The tumour grows through surrounding tissue, invading and often obstructing air passages. The time between exposure to asbestos and the occurrence of lung cancer is on average 20–30 years. It should be noted that there is a synergistic effect between smoking and asbestos exposure, which significantly increases the risk of developing lung cancer.

Part 1: Role and arrangements

1 THE ANALYST’S ROLE AND RESPONSIBILITIES

1.1 Analysts provide a wide range of specialist services on asbestos-related projects. These include management and consultancy services, asbestos sampling and analysis as well as asbestos removal-related activities. Their role has been developing and growing in importance. Analysts are often involved in assessments of environmental spread and contamination, traditional airborne personal and static sampling, enclosure work and reassurance sampling.

1.2 Some ‘building’ clients (see paragraph 1.22) and licensed contractors may request greater analyst involvement in asbestos removal activities. The analyst can provide a range of monitoring and support services including:

■ Work planning: — advising building clients on removal work — carrying out pre-removal inspections and bulk sampling — discussing potential issues with obtaining clearance — personal monitoring strategies for removal operatives

■ Site management and monitoring: — overseeing the smoke test — carrying out static air monitoring or reassurance air sampling — conducting extraction equipment performance testing — enclosure visual inspections — visual inspection of decontamination unit (DCU), waste and transit routes — leak testing of enclosures and investigation of ‘failures’ — measuring negative pressure unit (NPU) airflows on site — measuring negative pressure in the enclosure — visual inspections of cleanliness of equipment leaving site (eg Class H vacuums, airline RPE) — liaison with client management team, licensed contractor and asbestos consultant.

1.3 Over the last 10 years, there have been on average between 30,000 and 35,000 annual notifications of licensed work in Great Britain, each one requiring a 4-stage clearance by an analyst. The analyst clearly has an important role in ensuring that workplaces and premises are safe for reoccupation or demolition after asbestos removal work has taken place.

Risk to analysts 1.4 As there is no known lower dose threshold for mesothelioma, all occupational exposures present a risk of developing mesothelioma.20 The regulations therefore require employers to prevent exposure or reduce it to the lowest level reasonably practicable.

1.5 Analysts may provide a wide range of specialist services on asbestos-related projects. Many of these activities will involve entering an asbestos environment or directly disturbing ACMs. In all cases there is the potential for asbestos exposure.

Part 1: Role and arrangements

1.6 The nature and extent of exposure will depend on several factors including the activity, the type and condition of the ACM and the effectiveness of any controls. For example, all entry into asbestos enclosures carries a risk of exposure to airborne fibres. Analysts should avoid as far as possible entering ‘live’* enclosures while removal or remediation work is still being carried out. If entry into a ‘live’ enclosure does occur there will be potential exposure to asbestos fibre concentrations above the control limit or short-term exposure limit (STEL) (definitions are given in paragraphs 5.24–5.25).

(*Note: the term ‘live’ enclosure refers to a situation where removal work in the enclosure is still ongoing and the enclosure has not been cleaned and prepared for the 4-stage clearance.)

1.7 Enclosure entry for other reasons such as bulk sampling, clearance inspections and air sampling are likely to encounter lower airborne fibre levels. However, any direct disturbance of asbestos during these situations (eg brushing surface dust) can potentially give rise to increased short-term airborne concentrations. Bulk sampling outside enclosures or for lower hazard non- licensed ACMs can also give rise to exposure as sample collection often involves physically breaking asbestos materials.

1.8 Personal monitoring is required by Regulation 19 unless exposure is not liable to exceed the control limit. The ACOP states that employers should carry out regular personal monitoring to assess the risks, confirm that respiratory protection is adequate and that effective controls continue to be applied (see ACOP paragraphs 479–485).

1.9 It is recommended that personal monitoring is performed periodically (eg in ~5% of air sampling jobs). The personal sampling strategy should make sure that all analysts are included and that the