When it comes to asbestos consultants in Australia there is only one single licence classification, the Asbestos Assessor Licence. The requirements of which are not harmonised among all of the states and territories. The licence is only a requirement for consultants conducting air monitoring and clearance inspections on friable asbestos removal work. All other work required by an asbestos consultant can be carried out by a competent person. So, what does it take to be a competent person? What does it mean to be an LAA? And, do we need to overhaul the systems of licensing and qualification in this sector?
What Is A Competent Person
SafeWork defines a competent person as:
"In relation to carrying out clearance inspections of asbestos removal areas under WHS Regulation clause 473—a person who has acquired through training or experience the knowledge and skills of relevant asbestos removal industry practice and holds: − a certification in relation to the specified VET course for asbestos assessor work, or − a tertiary qualification in occupational health and safety, occupational hygiene, science, building, construction or environmental health. For all other purposes—a person who has acquired through training, qualification or experience, the knowledge and skills to carry out the task."
By the above definition, an experienced builder, a university graduate, a laboratory technician, an asbestos labourer, or anyone who has sat an asbestos course qualifies as a competent person. Quite often is the case with consulting firms, graduates are shown the ropes on a few simple air monitoring jobs, clearance inspections, shown how to sample a wall and ceiling, and off they go! Better firms will put their graduate or junior consultants through internal and external training, buddy them with senior consultants etc until they find their feet.
What Is A Licenced Asbestos Assessor
As previously stated, the asbestos assessor licence is only a requirement for consultants conducting air monitoring and clearance inspections on friable asbestos removal work. There is no licence requirement for non-friable work or asbestos surveys etc. Many people view the LAA licence as a badge of experience, the holders of which are experts in the field of asbestos. In reality, you have a vast range of experience levels. There are people I know who are LAAs and I wouldn't want them anywhere near my project. Conversely there are people I know who do not have an LAA licence and are vastly more knowledgeable and experienced than any LAA licence holder.
There was also a mass push by individuals (e.g. sole traders) and companies (e.g. pushing graduates with less than 6 months experience) to get LAA licences in NSW during the Loose Fill Investigation program. This was viewed by many as easy money, and I know of many people who went and sat the RTO approved course (CPCCDE5001), got some dodgy references and obtained their asbestos assessor licence. Many of these individuals then branched out to offer air monitoring and clearance services (why not?).
Example
I can remember one individual who fits this brief and will remain nameless. Years ago, when I was completing some asbestos removal works, the LAA had setup and was ready to take off. I mentioned that they had left the end caps on their air monitoring cowls. The conversation went as follows:
Me: 'mate, you've left the caps on your cowls'
LAA: 'yeah mate, it's called closed cap monitoring'
Me: 'what the f*#k is that?'
LAA: 'those little holes are the size of your nostril'
Me: 'have you seen how big my nostrils are? And have you read the membrane filter method? Take the caps off'
As the conversation continued, I also found out the monitoring units were out of calibration and they didn't own a rotameter (possibly why they didn't understand the purpose of the hole in the end cap). This person had obtained their LAA for Mr Fluffy inspections and had no specific asbestos consulting experience prior to the Mr Fluffy project. It is unknown how many jobs were monitored and cleared in this way.
What Can We Do
In my personal opinion, I think we need to implement new licence classes or categories. Volumetric air sampling is something that is relatively easy to be trained in, and with companies looking to get their junior consultants doing more pump runs, there tends to be a push for them to obtain the LAA licence early, some would argue when they are not truly ready to consult on friable jobs.
And on the other hand you have asbestos surveys, which to be completed properly require a consultant with years of field based knowledge and experience. At the moment, there is no required training or skill level to be deemed competent at conducting an asbestos survey and developing a register. Any 'competent person' (as per the above description) can do so.
I would think a basic fix to the issue would be to have 4 licence categories:
1 - Asbestos Air Monitoring - The quickest licence to obtain, minimum 3 months on the job training (assisting an already qualified consultant) with reputable references and a requirement to complete training course CPCCDE5001.
2 - Asbestos Clearance Inspections - The next licence to obtain. Requirements being at least 12 months experience (assisting an already qualified consultant) with reputable references and a requirement to complete training course CPCCDE5001.
3 - Asbestos Surveyor - Requirements being at least 3 years experience, displayed survey experience, reputable references and completion of training course, e.g. (BOHS) IP402 – Surveying & Sampling Strategies for Asbestos in Buildings (or similar).
4 - Asbestos Management - Applicants must have obtained all 3 other licence categories and have 10 years asbestos specific industry experience. In addition to this applicants must sit a training course, e.g. (BOHS) IP405 – Management of Asbestos in Buildings (or similar). The holders of these licences are required for the sign off of any technical investigation, management or survey reports where recommendations are provided for the management or remediation of asbestos.
I would also love to see an Asbestos Consultancy Company Licence, similar to what we have for asbestos removal companies, where a licence is obtained through an application and the company must have at least one manager listed on the licence who is qualified in the Category 4 - Asbestos Management.
Obviously, this is all a speculative proposition, however there is a need in the asbestos consulting industry to professionalise each field of services in a way that suits the needs of our consulting firms in order to develop consultants, without the ability to 'fake' or fast track experience. I also believe that as asbestos registers are mandatory for businesses, it is important that we develop a system of competency in this field to ensure an adequate product is being delivered across the board.
Love it or leave it, but all things in life must develop and change.