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Posted By T Birchall
I understand that the HSE's new regime when granting licences to Supervisory Licence Holders (or renewing) assumes that now the SLH will have to report to the main licence holder (asbestos removal contractor). How does this work, where's the impartiality gone? Any Supervisory Licence holders ever worked for a main licence holder?
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Posted By db
Where does it say this?
The new ALG memo says that:
"a supervisor provides direct and immediate control over the licensed activity: s/he must be present on site to ensure that activities are conducted in accordance with a (suitable and sufficient) plan of work and in compliance with all legal requirements."
This seems to indicate no change - they are supervising the licensed contractors, not reporting to them.
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Posted By db
The memo refers to supervision generally- I.e. an individual employee of either license holder and not solely the supervisory license holder.
There is no suggestion that the slh role has changed in any way.
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Posted By T Birchall
Hi db, the Asbestos Licensing Unit will verbally endorse this!
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Posted By db
Verbally endorse what you've said or what I've said?
Don't get confused with the two terms. The memo refers to supervision on site - both by individual supervisors (and point 1 that you refer to specifically states INDIVIDUALS) and
Supervisory License holders who also have individual supervisors.
The memo fills a gap (or tries to) where there is little information and guidance on the role of individual supervisors within either licensed category but also clarifies the requirements for Supervision by License Holders. ALU get applications from company's who are carrying out project management on behalf of a client and are not intending to have direct supervisory control over the planning and running of a job - and have no intention of entering an enclosure.
SLH's are employed by the client (although why clients want to pay twice for two company's who've been throught the same licesne assessment is anyone's guess!). However, there should be clear guidelines as to who is ultimately supervising on site, otherwise things can get (and do get) messy. These should be sorted out in the planning stage but very rarely are - hence the memo.
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Posted By T Birchall
Managing contractors is not always as simple as what's pledged by company Directors during new licence applications or renewals.
Contractors will still bend the rules given the opportunity, areas may leak, negative pressure may drop, waste may block entry and exits, operatives may turn up unshaven, or even still drunk from the night before (weekends are typical), some materials may not have been wet stripped, air movers may be turned off too early, pre filters may not get changed as often as they should, shadow vacuuming may not happen. The list goes on.
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Posted By db
And in my experience this can still happen with an slh. Who's monitoring their supervisor?
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Posted By Dave Wilson
If you are using an asbestos licensed contactor to remove your asi and appoint a SLH to oversee them, Who would in essence be the person in the poo if anything goes wrong, as they 'DIRECT' the asi contractor. I would STRONGLY suggest that you shouldn't be using this particular asi contractor, as they should be competent in the first place.
Why pay for something twice??? if you get the right contractor in the first place then the SLH job is a non starter, I think this is the thinking behind this. Also if a SLH is only 'supervising' 4 jobs in the course of his 3 year licence, is his level of competence up to speed?
I have experience of a SLH who does not put in an ASB5 and is on site as the H&S Advisor, and has demanded that I do something and when challenged as to his status (SLH / H&S Consultant)he quickly withdraws back to his hut.
Wants the money but not the responsibility!
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Posted By gerry d
The memo reinforces the point that asbestos jobs need to be adequately supervised. The company doing the work, e.g. full licence holder must have effective supervisor(s) AND if an SLH is planned they must effect their supervisory role on behalf of their client. I can see where this may confuse due to the terminology (supervision) but, any licence holder must know their duties both for asbestos and for general health & safety. I agree that some clients who like to use an SLH may be incurring extra unnecessary cost but want the peace of mind, not to mention an unwillingness to deal with contractors direct.
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Posted By T Birchall
Very good point Gerry.
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