As HSE start to pilot their new slimmed down approach to Licence renewal after the electronic renewal approach of the past 3 years, ACAD, the not for profit trade association for the Asbestos Industry, provides an overview of the changes.
Removal Contractors have all got a story to tell from the face to face interviews that HSE employed to vet those wanting to renew their Licence to undertake work with Asbestos. This approach changed over 3 years ago now, and with the maximum duration Licence being 3 years, this means every Licensed Contractor in the UK who has renewed their Licence has now been through the revised approach. This revised approach demanded they submit answers to an in depth question set together with supportive documentation, this application pack was then subject to a detailed review with questioning by an experienced HSE Inspector. This step up in intensity, and also the changed process itself, caught a number of contractors off guard early in the 3 year cycle leading to gaps between Licences and a notable number of refusals, both outright and conditional, across the industry.
The impact of this new approach did coincide with a drop in the number of removal contractors, reducing from 374 in April 2019 to 355 by January 2020. But this number has since stabilised with the total number of HSE Licensed Asbestos Removal contractors remaining at 355 as of 19th April 2022. The full list can be found on the ACAD website, where, following the removal of the previous HSE website platform, ACAD now hosts the up to date list of HSE Licence Holders within our technical reference library:
The last few years also saw an end to the previous variable duration Licence term, with all successful renewal applicants gaining the full 3 year Licence term. It is thought this change is behind the expiry date profile of the industry that has a significantly lower number of renewals in 2024, currently totalling 90, compared with 115 for 2023 and an anticipated 154 for 2025. The chart above shows 3 year Licence holder expiry dates, broken down year by year. Fortunately, HSE’s evolving new approach is expected to be that bit more efficient meaning this high total should be readily manageable but the advice will remain the same, once invited to renew, ensure you submit your application in good time…
Graham Warren, ACAD Manager commented “The revised approach to Licence renewals was met with a large degree of uncertainty as it was something entirely new and nobody really knew quite what to expect. I recall all the meetings we held with HSE where we were able to gain real insight into the process which in turn allowed us to support members with great success. I firmly believe the level of support ACAD can provide to members being one of the central pillars that has contributed to the growth of ACAD through recent years”.
Fast forward to 2022 and we find ourselves in the midst of the new approach being piloted, and whilst this is still at an early stage, looks to be exactly how ACAD was predicting it to be. Namely the same sections but now with a focus on just those two recurring questions from the previous application form which closely links to your performance on site as witnessed by the HSE:
- Anything that has changed since you were last assessed?
- How you have successfully addressed any issues that arose out of a previous inspection / assessment?
Clearly the latter question necessitating a thorough understanding of all enforcing authority site visits plus a detailed review of your previous application. Graham Warren advised “I expect though the approach most would take would be to look at the HSE comment from their previous renewal and the associated section scoring to see which areas, if any, require improvement, with those which were well received and therefore perhaps falling into the “if it isn’t broke, don’t fix it” bracket answered fairly briefly around continual improvement elements”.
Whilst Licence Holders will have a process for capturing all potential learning from a site inspection, HSE maintains their own database (COIN) wherein additional nuggets of useful information can be found. ACAD continues to advise members to submit a freedom of information request to HSE to access your COIN data at to support your renewal, but with many adding this as a standard step to their internal review each year. Given the usefulness of the information that can be found within the COIN data, ACAD has asked if this could be shared with Licence holders automatically to try and make the process a little bit more efficient, but for now here’s the link:
Graham Warren went on to say “A big question remains over how to answer the first question, namely what has changed since your previous assessment? Now we all strive for continual improvement, but some areas just are what they are, for example how you arrange medicals or face fits. Would an applicant, where they have had no issues raised by HSE via an inspection/assessment and where nothing has changed just answer No or Not Applicable to a question? Doubtful…but we are once again heading into uncharted waters where the support of ACAD will once again be of real benefit to our growing membership”.
To find out more how ACAD can help you with your Licence renewal, check out our website: