Beyond Compliance In order to obtain a licence to work with asbestos, an asbestos removal contractor must be able to demonstrate to the Health and Safety Executive (HSE) that they have excellent health and safety management systems, and that the required knowledge is put into practice on site. Once a licence has been obtained, the management of the Licensed Asbestos Removal Contractor (LARC) will need to monitor all of their activities to ensure compliance with all relevant legislative requirements and associated guidance. Such compliance is seen within the asbestos industry as a minimum compliance level. As asbestos removal is part of a permissioning regime, the normal forms of regulation (on their own) are considered insufficient, and the extra demands imposed by the regime are considered justified by the benefits it brings.
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arca & atac news · autumn 2020
So, the effective management of a LARC, and therefore licence continuity, depends on moving beyond minimum compliance. For example, licence holders: w must identify the hazards, assess the risks, review the extent to which health and safety is part of the process, develop effective control measures (for those hazards which cannot be eliminated) and record these in their health and safety documentation, which should be reviewed and kept up to date w must ensure that control measures recorded in the health and safety documentation cover design and hardware, systems and procedures, and human organisational factors as a collective whole; and should include the licence holder’s safety criteria and performance standards, as well as plans for improvement w must properly resource their processes for producing and maintaining health and safety documentation w must implement the control measures, review them regularly and keep them up to date with a view to continuously improving them to reduce risks w must make and test arrangements for managing emergencies and mitigating their consequences. In addition to effective leadership from top management, ARCA and the HSE would expect LARC’s to demonstrate competence at all levels of the organisation, both office based and on site. They would also expect LARC’s to make full and proper use of all information gathered from site activities, and use their findings to feed their assessments and planning of future jobs. Minimum compliance would require certain records to be kept, e.g. daily inspections of: w enclosures (including airlocks and baglocks) w hygiene facilities w vacuum cleaners w air extraction equipment w wet injection equipment (when in use) w respiratory protective equipment. This would include the reporting of defects and remedial actions taken.
