Changes to NAD Point Scoring System sought
The revised NAD point scoring system in HSG 248 edition 2, which awards 2 points for all NAD samples and requires a 15-minute timed analysis, has caused laboratories to struggle in meeting demand and has reduced their capacity to support clients. Since the implementation of the revised system, ATaC and NORAC have engaged in negotiations with the HSE and UKAS in order to pursue necessary amendments.
The analytical sensitivity stated in HSG 248 Edition 2, A2.6, implies an analytical sensitivity of 1ppm by mass. However, there is no research on the level of risk associated with false negatives or evidence that the changes have improved the detection of false negatives.
Over the last 12 months, ATaC and NORAC proposed an alternative procedure to satisfy the HSE and UKAS requirements, but it was partially rejected. Concerns raised in response to the counterproposal covered the technical content and input from members.
Meetings with the HSE and UKAS indicated that the changes had no significant impact on UKAS laboratories, with an average of 60 samples analysed per analyst per day. However, ATaC members reported analysing around 30 samples per analyst per 8-hour shift, indicating a significant difference.
Members also reported the need to recruit and train additional staff and expand laboratory space. The estimated annual cost per laboratory is approximately £90,000, resulting in a total cost impact of over £10,000,000 per year.
Despite requesting evidence from the HSE and UKAS to support the changes, none has been provided. References to sanctions and prosecutions against laboratories are also unverified.
The negative sampling strategy is crucial for asbestos management, but the current approach may discourage it due to increased cost and time burden. Members have expressed concerns about disillusioned staff, low morale, and difficulties with staff retention and recruitment.
Moving forward, the UKAS Technical Advisory Committee has proposed a dedicated working group to resolve these issues and develop an efficient and accurate methodology for bulk analysis.
In conclusion, the changes to the NAD scoring system and analysis timings have created challenges for laboratories and raised concerns among our members. Thorough research and evidence are necessary for effective and responsible decision-making. Collaboration and practical solutions are crucial to maintain high standards and address the impact of these changes on the industry.