plans of work
Troubleshooting Plans of Work ‘Planning’ is a subject causing considerable challenges for many licensed contractors and attracting frequent criticism from the Health and Safety Executive (HSE). This brief article is intended to help contractors critically review their own approach, but it may also be of interest to clients and others with an interest in assessing plans, and health and safety management. Regulation 7 of the Control of Asbestos Regulations requires employers to prepare a written plan before any asbestos work is carried out. Standard licence conditions require the production of a “suitable and sufficient” plan, prior to notification of work, and state that the plan must be followed on site. Licence conditions mean that written plans must be at the heart of licence holders’ safety management systems: plans should clearly show what senior management expects a site team to do. The quality of planning is likely to be a major focus of licence assessments and inspections. There is a problem when gaps open between actual practice and “paperwork”: asbestos removal is a practical job and it is a challenge to ensure that Plans of Work (PoW) are seen to help and guide the removal process. The key to closing this gap often lies in engaging relevant staff (particularly contract managers, supervisors and auditors) in the on-going development of the planning process.
30
arca & atac news · winter 2020
Format and Quality Guidance “Asbestos Regulation 7 Plans of Work – Purpose and Core Principles”, which can be read alongside ALG memo 04/12, aids format and content for a suitable Plan of Work (this guidance is referenced at end of article). Templates may be useful for those preparing the plan but are not necessarily helpful for those being asked to use the finished plan. Following one format cannot guarantee that a plan will be “suitable and sufficient”: for example, the required section on air management might have been completed, but the contents might be incorrect or difficult to follow; a sketch may be included but it does not reflect site reality etc. In addition, any one particular format is likely to suit some types of jobs more than others. Regardless of format, any reader should be able to quickly identify what the particular challenges are for this job and how management have decided these will be tackled. Where jobs are straightforward and simple, the plan should be. The main emphasis should always be on the quality of the information being given, not the format. Do reviews / audits focus on format or quality? Has the company format(s) been developed with input from those who need to use it? Can a list of quality criteria be developed (with input from users) to help determine good / bad plans?
