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A guide for asbestos survey companies who want to obtain UKAS accreditation
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Unlike air fibre monitoring or bulk analysis of samples for asbestos UKAS accreditation is not a legal requirement for companies or individuals who wish to survey buildings or other assets for asbestos.
The cost burden of UKAS accreditation can be large (Approximately £1000 per day per assessor excl. VAT). The larger the company and the more office locations and laboratories you run means potentially more assessment days. UKAS has now adopted a risk-based approach to assessment which will guide how many days they deem are required and also the option for conducting remote /video call audits.
With the cost burden (administrative and financial) of conducting re-surveys and surveyor audits being substantial, obtaining UKAS accreditation is not a decision to be made lightly. But if you do want to become UKAS accredited, the suggestions in this guide should hopefully make the process easier.
It is an expensive and potentially time consuming process however UKAS accreditation will provide assurance of the standard of inspections and the ability of the company to meet their clients requirements to a consistent and high quality standard.
Many non-accredited surveyors will be quick to point out that UKAS accreditation is no guarantee of a good survey. Small companies often pride themselves on providing high quality reports with clear recommendations for clients on how to interpret the reports and how to manage any asbestos that may be present in their property, whereas larger companies producing thousands of surveys using electronic devices and software can end up producing reports with generic recommendations with little useful information.
The main driver behind UKAS accreditation is for most companies is winning new contracts. For the majority of large framework clients and even smaller ones, UKAS accreditation will be a main requirement for accepting tenders.
UKAS is currently the sole recognised accreditation body in Great Britain that can assess companies or inspection bodies against the international standard ‘BSENISO/IEC17020:2012:’Conformity assessment – Requirements for the operation of various types of bodies performing inspections’.
This can be any company or body conducting any form of inspection service. As such, the standard is written in a way that is not specific to any particular body.
To help those new to ISO standards the document ISO17000 provides terms and definitions as some of the language used can have quite specific meanings when used in the standards.
For Asbestos surveying companies UKAS have produced the guidance document RG8 – Accreditation of Bodies Surveying for Asbestos in Premises which gives specific guidance on how to comply with ISO 17020.
Most companies or freelance surveyors will already be conducting their surveys and producing reports in line with the guidance in HSG264 Asbestos: The Survey Guide and HSG248 Asbestos: The Analysts Guide. So regarding site work, there shouldn’t be much change except that you'll need to document processes to ensure consistency across surveyors. The main impact of accreditation is the need for administrative (management) systems and quality assurance systems that meet the requirements of ISO 17020 and the guidance in RG8.
If you are already certified to ISO 9001:2015 you have a massive advantage as this will prove compliance with Clause 8 of ISO 17020 (Management Systems) and means you will already have most of the systems and processes which I will cover later on already in place.
Assessments for accreditation are usually conducted by a lead assessor and a technical auditor. The lead assessor is responsible for the management of the audit and decisions on accreditation and will usually concentrate on the ISO 17020 management system. The technical assessor will witness surveying activities being conducted on site and look at the technical content of reports and related documents.
"Word of warning! From personal experience most ISO 9001 and associated audits tend to be quite short and are a snapshot of a company’s compliance and as such tend to be not as intensive and therefore easier to get through. UKAS audits are longer and will take a much more detailed look at all aspects of the management system as well as witnessing surveys, re-inspections etc being conducted on site and looking at the content and quality of survey reports.
This means that a management system that is acceptable during a ISO 9001 audit may not meet the standard required by UKAS Lead assessors and technical auditors!"
I will take a look at how to comply with the standard by going through each clause. All the ISO standards have been designed to follow a standard format with commonality of clauses although there is some variation between the disciplines. I will not be covering this in any more detail here as we want to concentrate on ISO 17020 only. I will also refer to RG8 as this has some quite specific requirements that a company will need to meet to maintain accreditation.
ISO 17020 is split in to 8 clauses and as mentioned earlier if you have ISO 9001 you will already be compliant with clause 8.
Just explain the scope of the standard and reference to ISO 17000.
Provides some Common terms and their definitions as regards use in this standard.
This is an important aspect of ISO17020 and requires inspection bodies to not allow commercial, financial or other pressures to compromise impartiality. This means identifying any risks and the control measures needed to minimise or eliminate the risk.
Risks to impartiality can be based on
Annex A of the standard provides further details on this subject and what is expected of inspection bodies.
At the consultancy I work for we have implemented an impartiality risk assessment which identifies potential risks then a risk register that details risks that currently exist. This also includes a list of potential staff conflicts of interest (relationships with employees of clients or suppliers, family relationships, etc).
This is a requirement to securely manage all information gained or created during the inspection activities and subsequent reports and certificates. Compliance with this is usually legally enforced through a signed contract (more likely with large framework clients) or for smaller or one of off surveys through a set of standard terms and conditions.
An Inspection body (Surveying company) will be a legal entity and have documentation which describes the activities it conducts. This will usually be done in a ‘Quality manual or management system manual’. For accredited bodies this may include the schedule of Accreditation.
Suitable liability and indemnity insurance.
UKAS will want evidence (usually declaration from insurer) that the inspection body is suitably covered or has reserves set aside to cover any claims that may arise from their work.
The level of insurance required will depend on the size of the jobs being conducted. Many tenders will stipulate a minimum level of cover for prospective clients.
Description of contractual conditions under which it provides inspection services – Usually a standard terms and conditions document that can be issued to clients (website, quotes, invoices etc.)
This is just having a hierarchal management structure with clear lines of reporting and detailed responsibilities to maintain the capability to provide services. Also need to document relationship to other activities other than inspection the company may undertake.
This can be evidenced using an organisation diagram.
Need to identify at least one person responsible who is technically competent and experienced in the operation of the inspection body. Larger companies may have more than one person, but if so they need to detail who is responsible for what.
Need to have a job description for every position in the company that has any involvement with the accredited activity. This includes office and admin staff. This can be done in a variety of ways, such as lists of job descriptions or contracts of employment.
The company I work for have defined a set of roles and then produced a procedure document which details the responsibilities for each role. Some of these might be assigned to one person, while others may be shared.
This is important and aligns with training needs analysis for staff.
Personnel – this is linked to the above. Requirement to identify competence requirements for staff involved with inspection activities.
The tables at the end of RG8 provides quite clear guidance on the qualifications for companies and individuals required to conduct a variety of asbestos survey and sampling activities.
This covers trainees and experienced staff. The Company needs enough people with the required competence to perform the type, range and volume of surveys they are requested too conduct.
Documented procedures are needed for selecting, training, formally authorizing and monitoring surveyors.
Training needs to cover:
As mentioned above, the level of training will depend on experience and knowledge.
Monitoring of surveyors' performance and identifying training needs – see quality assurance and auditing.
All training should be properly documented and signed by the trainer and trainee. Records and any competence checklists should be completed before the surveyor can be authorised.
Surveyors should not be paid or receive benefits in a way that might influence the quality of inspections. (e.g. paid per survey – would encourage surveyors to rush to complete surveys so they could do more per day and get paid more but would risk missing asbestos in the property they were surveying).
Suitable facilities and equipment to enable services to be provided in a competent and safe manner:
Safe equipment suitable for the task.
Staff trained to use equipment and how to work safely on site (ladders, RPE, tools etc).
Equipment requiring inspection/testing /calibration or that may influence the quality of surveys should have unique identification (asset number/ID number) and suitable records kept.
We have an asset register that contains every piece of equipment, its ID number, calibration/inspection/test dates and other relevant information. We use Microsoft SharePoint, so the test and other records can be saved and attached to each record. Equipment records are also attached to our surveying and AFM apps. Assigned equipment will flag up as being overdue inspection. I don’t use it but it may actually stop you logging a piece of equipment on a job if it is out of date (this applies to AFM more than surveying equipment).
We also have asset management procedures which detail type and specification and any maintenance /calibration/inspection/testing requirements for each category of equipment.
Equipment needs to be maintained – test /inspection/calibration records and labels show evidence of compliance. UKAS like to see next test due dates and test dates on any labels attached to equipment.
Procedures and records are required for the selection and approval of suppliers, verification of received goods and services, and appropriate stores.
We do this through an approved suppliers list on SharePoint the same as asset register to which associated documents and evidence can be attached. We have different levels of suppliers that undergo varying levels of scrutiny.
National and well known suppliers undergo little scrutiny e.g Amazon, high street chainstores etc.
Other suppliers are asked to complete a supplier questionnaire. More answers are required where the supplier has a greater bearing on technical, quality, environmental or safety elements of the services we provide. More evidence of suitability will also be required – UKAS accreditation, HSE licenses, EA permits, ISO 9001 etc, trade body membership, Construction Safety Schemes amongst many others.
All reviewed annually for ongoing suitability or archived if no longer in use (can be quickly reinstated if used again in future).
Where software for computers or other electronic devices is used (such as Flow Mobile) in connection with inspections it needs to be validated as fit for use (including any calculations), revalidated following any changes to the software or hardware used, and software updates are implemented as required.
Procedures will be required for ensuring security and integrity of data.
Computers and/or mobile devices need to be maintained to ensure they are functioning properly. (Always pays to have a back up plan such as paper survey forms in case of disaster)
Defective equipment procedures – procedure for identifying, reporting, removing from use, repair, disposal.
If defective equipment is stored it should be kept in a ‘quarantine area’ separate from other equipment, marked as defective, to prevent accidental reissue to staff.
There are a number of reasons why you may need to subcontract or outsource services.
Surveyors – Need to inform client and get their permission for you to subcontract their work (Record of agreement required as evidence).
It is up to the company to ensure the competence of the subcontractor and the conformity of their work.
My current company is the first time I have experienced the use of subcontract or freelance surveyors. We manage them by treating them the same as full time employees for quality and Health & Safety purposes so they are trained and audited and equipment is checked/inspected the same.
Samples/labs – If you don’t have your own lab or lab is at capacity, and you need to subcontract sample analysis, then you will need to get evidence of agreement with the client to subcontract the samples taken on their surveys.
You will need to get a signed agreement with the lab – estimated quantity, price, and reporting requirements (certificates, use of software like Flow Mobile Surveying, TEAMS, or Alpha tracker ™)
Ensure the lab is competent – Check the UKAS accreditation schedule (this can be done online or ask the lab for copies), what are their quality assurance procedures, participation in AIMS (Asbestos in Materials Scheme) and results for at least the last 12 months.
Where you have your own lab already, you will have to quality check a minimum of 1 in 100 samples that are sent to another lab. Where a lab has made an error or other quality issue, you may decide to increase this as deemed necessary.
There is a requirement to record and retain investigations of competence of subcontractors, which is why we just treat them the same as our own staff and therefore have audits etc to prove competence.
As detailed above lab performance is monitored on an ongoing basis with an annual review of accreditation and AIMS status plus a review of lab agreement.
Documented Survey procedures in line with requirements of HSG264, HSG248 (sampling) and RG8.
These should also cover planning of surveys and safety of inspections (to the surveyor and third parties).
Non standard methods or procedures need to be fully documented.
If clients' requests are not compatible with the guidance documents named above, the company should inform them that it is inappropriate.
All procedures and related documents need to be maintained and up to date and be available to surveyors.
For the companies I have worked at, this used to involve having folders of documents which were a nightmare to maintain as they have to be updated when documents are replaced. Many companies provide documents electronically in shared folders that can be synced when updated.
We use a folder containing all relevant documents on MS SharePoint, this is accessible using MS Power Apps on surveyors' tablets. The folder also syncs to their individual One-Drive account on their tablets. This means they always have the latest versions available on site whether they have access to the internet or not. We used to use a shared Dropbox, but this was only available when a signal was available. It also required more work keeping documents up to date.
Observations on site need to be recorded in a timely manner – written down on paper – checklists or survey sheets etc or recorded on to tablets/phones - this is to prevent loss of information or forgetting to record relevant information.
Procedures required for taking, transporting and handling samples for asbestos analysis.
UKAS accreditation will require samples taken that are of the right type, adopting the right sample frequency (both detailed in HSG248 and HSG264)
The following will also be required:
Samples double bagged in correctly labelled bags with unique identification to enable traceability. Suitable storage for samples during transport.
A process for delivery to and receipt of samples at a UKAS accredited laboratory (this includes safe transport and storage, criteria for acceptability (sample size) correct bagging/labelling, correct paperwork, booking in procedures.
Process for dealing with non-conforming samples.
If subcontracting samples you will need to ascertain the labs own sample criteria.
All samples have to be kept for six months from the analysis date before they can be disposed of to enable rechecks etc in case of queries.
Samples will need to be stored so that they can be retrieved easily if required.
Inspection records – need to be stored and retrievable (either physical copies or electronic)
Reports and certificates need to be uniquely identified and traceable to the surveyor responsible.
HSG264 and RG8 contain details of what is required in reports and UKAS will evaluate against this.
Inspection reports should clearly indicate where subcontractors have been used.
The procedure required for dealing with client complaints – Receiving, validating, investigation, taking corrective actions, implementing preventative actions, explaining to client process for dealing with complaints, response to clients and acknowledgement from the client that they are satisfied with the handling of the complaint.
UKAS assessors can be quite thorough when it comes to the handling of complaints as they can be an indicator of system failures. We have robust procedures in place, but it requires time and effort to be put in by all concerned with the handling of the complaint and failure to do so can lead to issues further down the line.
As discussed earlier if you have ISO9001 you have a head start with ISO17020 but if you don’t you will need the following in place within your management system. I will also cover some quality assurance stuff from RG8 that you will need to do that is an absolute UKAS requirement for getting and maintaining accreditation.
If you don’t have ISO 9001 then you will need a documented managements system that has a:
Needs and expectations of interested parties – need to understand who has an interest in your activities and how they are conducted–
All documents, procedures, processes, systems, records etc should form part of the management system.
I produce regular compliance reports that cover all aspects of our systems and identify areas where we might be behind – audits, calibrations, meetings, Health & Safety /Environmental performance – everything we do basically. This feeds in to compliance, operations and management meetings.
I produce regular compliance reports that cover all aspects of our systems and identify areas that require attention – audits, calibrations, meetings, Health & Safety /Environmental performance – everything we do basically. This feeds into compliance, operations and management meetings.
Internal audits
On top of this you will need to implement a programme of internal system audits that cover compliance from a UKAS point of view with the requirements of ISO 17020 and RG8. This programme has to be documented and any slippage/reasons for change noted.
Audits require time and effort to produce but they are one of the main tools for identifying non-compliance within your management system. The quality and thoroughness of these audits is usually looked at closely by UKAS assessors.
The audits need to be planned to cover all areas of the system (including processes and procedures) and be completed in a systematic manner. The planning should consider the importance of the area being audited and the results of previous audits.
Audits must be performed at least once every 12 months. The frequency can be adjusted based on the demonstrated effectiveness and stability of the system.
You'll ideally need at least one auditor who has completed UKAS 17020/17025 audit course or ISO 9001 lead auditor. Other auditors should ideally have completed at least an internal audit course or received equivalent training.
The problem at most companies is that they don’t have the resources to have an independent audit team and the people who have produced the management system and/or maintain it also have to do the audits, which makes it difficult to be objective.
"We actually subcontract these audits to another consultant to free myself and the rest of my department to concentrate on other tasks."
Vertical audits
We also do vertical audits covering surveying, bulk analysis and air monitoring.
This involves picking a start point at random such as a client, survey, bulk sample etc. and working backwards and forwards to cover all aspects of a survey from initial enquiry through planning, completing survey, report, quality checks through to invoicing.
You need to record all instances of non-conforming work (NCs)– this covers anything that has gone wrong or isn’t right (compared to procedures) – complaints, report errors/reissues, findings from audits, failed calibrations/inspections of equipment, accidents, non-conforming samples - the list is long.
Investigation of NCs needs to be recorded and ascertain the extent of the issue, its impact on the quality of results (or, in the case of accidents, injuries caused) and the root cause of the NC.
It's not enough to look at the direct cause of issue such as missing an asbestos panel in a building, i.e. the surveyor – there could be underlying issues such as the surveyor being given too many jobs, so they were rushing, the scope of work didn’t cover the area missed, no torch was issued to enable the surveyor to see, and so on.
You also need to record corrective actions taken to remedy the issue and then any preventative actions to prevent it from reoccurring.
This should then be followed up with checks to ensure actions taken have been effective (we call them efficacy checks).
Another important aspect is that investigations and resolution actions should be completed promptly.
"You need to make sure you have adequate resources to do the work required. Otherwise, you'll be non-compliant with the standard for the functioning of the system."
Review by Top Management team of performance of management system(s) looking at various inputs and outputs that can affect the system.
Meetings and attendance by senior management team is evidence of management commitment.
Have to be held at least annually. Can hold more regularly or split content of meetings across year however it is important all aspects are covered.
The topics that should be covered are detailed in ISO17020 and RG8 so I am not going in to detail here but it includes items like NC’s, audit programme and findings, results of external audits, feedback and complaints from clients etc.
"Using a standard meeting agenda containing all the required elements in the standard is a good way of ensuring your management review is compliant. Additional agenda items can then be added depending on what you want to cover. It is also important that the minutes or meeting records cover all the agenda items and associated discussions (including any meeting actions)"
This is something covered by RG8 rather than the standard but there are some very Asbestos survey/UKAS specific requirements that will need to be complied with to obtain and maintain accreditation.
Reports - On completion should be reviewed by surveyor and signed. Any amendments required should be made and reviewed before issue. Different companies have their own process – some may get a technical reviewer to approve all surveys before issue while others may just review a percentage (or none – leaving it to surveyor to check). As stated earlier, we also do random audits on surveys.
"It's important that where UKAS accreditation logo appears on a report that any activity conducted during the inspection for which the company is not accredited is clearly marked as being outside the scope of accreditation. (e.g. PRA if not on UKAS schedule of accreditation)"
Cross checks (Resurveys) – There is a requirement in RG8 that 4% of all surveys (not including re-inspections are resurveyed by another surveyor (including samples).
This is a major burden on companies and provides a variety of difficulties from gaining access to the property again, volume of samples to be rechecked in the lab reducing capacity for new samples, and resources (surveyors) to complete the work which is basically for no fee and therefore a cost to the company. During the COVID 19 lockdowns and while re-access to buildings wasn’t possible, we used techniques such as video/video calls to achieve some limited form of checking.
There also has to be a process for comparing and recording a comparison of the resurvey with the original.
At both of the consultancies I have worked for, we've created Excel spreadsheets to record how many surveys have been done, how many resurveys have been completed, and how many are required to achieve 4%, % per survey type per surveyor and per client.
The 4% is supposed to cover the different survey types (Management, Refurb, demolition inc. targeted) and property types (Domestic, commercial, Industrial) and also surveyors.
"The organisation of the resurveys would be very difficult without the use of this spreadsheet."
RG8 states the requirements for authorising new and experienced surveyor.
Trainees obviously have to complete more witnessed surveys before they can be authorised to survey. These have to cover all the survey types (see resurveys) the surveyor is expected to conduct.
If a new survey or property type is required they are not authorised for then further audits are required.
Experienced surveyors have lower audit requirements but the company has to provide a CV of previous experience as justification for this approach.
On top of this these need to be repeated annually (as far as practicable) for each survey and property type ( and all combinations thereof). This also includes re-inspections however the re-inspection element can be covered by a technical discussion during the audit of other survey types.
Again this is another administrative and resource burden and takes significant management.
Obviously the larger the company (more surveyors) and the greater variation of surveys being conducted, the bigger the burden.
One of the good things of our reporting software is that we can record all the current authorisations for every member of technical staff and if they are out of date for audit cannot be assigned that category of work until they have been re-authorised.
Under CAR 2012,HSG264, RG8 and HSG 227 (management of asbestos in non-domestic premises) the responsibility for conducting priority risk assessment is that of the designated duty holder (client, property owner etc.).
A lot of duty holders want survey companies to do the PRA on their behalf however RG8 categorically states that the information required (apart from location and extent which are visible to anyone) must come from the client or somebody who knows the occupancy and maintenance activities that occur in the building(s).
To comply with this the client needs to provide a pre agreed template of PRA scores which can be added manually on site or preloaded on to survey software or provided by somebody on site.
PRA needs to be requested to be added to the accreditation schedule and to be accredited you will need to comply with the above (and be able to provide evidence – signed agreements, score templates etc.). This will also include being witnessed conducting PRA during a site survey.
As for the PRA, this has to be requested to be part of your accreditation schedule as a separate activity.
This is another important aspect and another area UKAS assessors tend to look at in great detail. It revolves around the whole management of the survey process from initial enquiries/tenders etc and through the planning stage of surveys. It also covers the retention of records.
This is covered in the HSG 264 standard and details the information required by the survey company before conducting a survey. Again, as with everything, the larger and more complex the property being surveyed, the greater the planning required. This also covers the safety aspects of the work and resources/equipment required.
There are a variety of methods of gaining information to enable the desktop study to be undertaken –
How the review of the project is conducted will vary company to company, but the information needs to be documented and stored in a location that other staff including auditors can access it easily in the event of audits or queries (complaints, new works, etc).
In my personal experience project managers/administrators store documents on their individual device storage folders without transferring to the relevant shared company folders meaning documents cannot be found by colleagues.
We have implemented a dedicated contract review form for collating project information and recording the resources , timescales and equipment required to fulfil the work. It also records any site-specific requirements (inductions/qualifications/training etc.). It also contains project review sections. It is important that the company assesses whether they have the necessary competence to complete the requested works.
Once this is complete, the scope of work and subsequent job instructions to the survey team can be produced. This is important as a failure to provide adequate information to the surveyors is very often a contributory factor to errors and client complaints.
It is especially important in the case of refurbishment and demolition surveys where often these elements are targeted at specific areas of the site only (a particular building or room or element of a room, e.g. kitchen, bathroom, central heating, classroom, plant room etc.). It is also necessary to record the reason for the survey / the work being done on-site as this can affect the areas that may be disturbed and therefore require inspection. Levels of damage from intrusive work and need for making good, etc also need to be ascertained.
The survey company will need to demonstrate that the scope of works has been agreed upon with the client. This could be through email, quotations, statement of the extent of work confirmation etc.
The above is something UKAS look at in great detail when assessing accreditation, as the planning of the survey will have a massive impact on the quality of the inspection and subsequent reporting.
Hopefully, you will find this guide is helpful if you are considering applying for UKAS accreditation or are trying to maintain existing accreditation to ISO 17020. It is just a guide, and there are some areas where I could have gone into a lot more detail (such as the content of survey reports), or I may have missed something altogether.
The main advice I would give to anybody looking to gain accreditation for their company is that the actual completion of survey work on site and reports (especially if you follow HSE/UKAS guidance and use one of the survey software suppliers) is the simplest part of the process and it is the management system and quality assurance requirements that are the most difficult to implement especially if you don’t already have ISO 9001.
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