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chris42  
#1 Posted : 22 August 2013 15:53:48(UTC)
Rank: Super forum user
chris42

We are due in the next few weeks to have some asbestos down pipes and guttering removed, by a sub contractor. The work I feel is Non Notifiable Non Licensed Work. The organisation who are to do the work has had training for their employees in the past (don’t know how long ago), but the HSE’s web site suggests there should be refresher training once a year.

The contractor felt this was not coming in until 2015, but the HSE web site :-

http://www.hse.gov.uk/asbestos/training.htm

Suggests that refresher training is required every year. The web site layout shows this information below that of Licensed work, but is not specific if it is for both licensed or non licensed work or just licensed.

The only reference I can find with regard to changes is that in 2015 is that Notifiable Non Licensed Work will require medicals and record keeping.

Should I be insisting that refresher training in the last year be taken before allowing commencement or is this only for licensed work.

Thanks for any help
Chris
RayRapp  
#2 Posted : 22 August 2013 17:42:46(UTC)
Rank: Super forum user
RayRapp

Chris

If I have read your post correctly I would be more than concerned with the comments from your asbestos removal contractor. As far as I'm aware AAT should be provided for those who may come into contact with asbestos, regardless of whether it's notifiable or not. Refresher training is annual. That said, those who will be removing asbestos materials will require a more than just basic AAT.

I would also be concerned whether the asbestos is notifiable or not. Normally I would advise the client to seek advice from the asbestos contractor. However, given some of the aforementioned concerns I would not have much faith in their judgement. Have you checked the contractors documentation, references, qualifications, etc?

Ray
chris42  
#3 Posted : 23 August 2013 09:15:20(UTC)
Rank: Super forum user
chris42

Rayrapp

Thanks for the reply, I have looked into the asbestos removal and using an asbestos survey the company had conducted by last year as to the type of asbestos, plus its condition etc using the HSE web site I am happy that this is none notifiable non licensed work.

I have just received the Method statement for the work to be undertaken (of which the asbestos is only a small part). and wanted to check the qualifications were as they should be.

The HSE web site and the way it was laid out, could be read that the annual refresher is only necessary when notifiable. Indeed even then it mentions tool box talks opposed to more formal training to a particular standard.

HSE document em2 Asbestos essentials indicates that refresher training is required every year (or more often) and covers non licensed work, but no indication if it was also intended for non notifiable work as well.

I know there are people on the forum with specialist knowledge of this subject, so thought I would ask.





John M  
#4 Posted : 23 August 2013 09:47:04(UTC)
Rank: Super forum user
John M

I would be insisting upon correct documentation to be delivered up prior to allowing any outfit on to site to work on or remove asbestos containing materials. Such documentation would include current suitable and sufficient AAT together with details of any refresher training. Only you can evaluate the sufficiency of the training provided.

In addition, I would be looking very closely at the risk assessment and method statement (not forgetting your responsibility to provide details of the work to be carried out and the hazards thereto). I would also be having a face to face kick off minuted meeting with your contractor in advance of the start date - thus setting out the requirements and control /conduct of your contractors. The MS may alert you to any shortcomings or other areas of possible concern. Look out for PPE requirements and product disposal among others.

You may feel that this is over the top, however I can assure you that the HSE will ruthlessly pursue those persons (including clients) who breach the Control of Asbestos Regulations 2012. And quite rightly so!

If you require details of recent prosecutions please feel free to PM me.

Jon

chris42  
#5 Posted : 25 August 2013 10:50:43(UTC)
Rank: Super forum user
chris42

Thanks John

Yes I insisted upon the Method statement prior to work commencing ( and a few weeks before). The method statement is at best a little "light" in terms of detail. So the issue regarding training was a phone call to clarify. Yes they are using an appropriately licenced carrier etc, it was just the training. It is possible he became confused and noted changes due in 2015 for medicals etc.

I have already put in writing I want confirmation of their qualifications to date, and possible options for refresher training if they don't have it.

The problem is the MD has already given them the contract, without any provisos (as seems to be the way of this organisation). My aim is to point them in the right direction to get them up to speed before actually doing the work. It's not my place, but seems the best option at the moment. This refresher training requirement does seem a bit wishy washy though: Tool box talk / DVD ! and still not very explicit within the HSE guidance etc, hence my question.






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