The first long awaited draft of MDHS 100 was circulated for comment on 24 December 2007. The revision seeks to address some of the lessons that have been learned since it’s original publication in 2001. This particular guidance document was expected to be problematical, as it had already gone through 3 drafts for consultation prior to official publication.
The issues that are at the forefront of the revision are Type 3 Surveys, caveats and Surveyor competence.
The specific guidance for Type 3 Surveys, in the current document, only extends to a few paragraphs. More guidance is needed as to how thorough the intrusive inspection should be.It has long been recognised that some Surveying organisations are including caveats on their Surveys that appear not to support the spirit of MDHS 100. One of the most common being cited is that the Surveyor will not inspect any areas above 2 meters. As most ceilings are above this level, it means that ceiling voids are not included within the scope of the Survey. This lowers the cost for the organisation as they do not have to supply a 2 man Surveying Team to comply with the Work at Height Regulations, as no ladders will be needed. Initially, this lowers the cost for the Client but it can produce misleading Survey Reports for unwary Clients, which result in accidental exposures. Unfortunately, as there is currently nothing specific about this in MDHS 100, no action can be taken if the report contains a statement relating to the fact that no inspection has been undertaken above 2 meters.
Surveyor competence is also on the agenda for improvement. At present, the guidance only recommends that Surveyors have appropriate training, ie P402, and have accreditation through UKAS, NIACS or ABICS. Organisations that are accredited have more stringent requirements put upon them with regard to training which must go beyond P402, which includes Health and Safety training and demonstration of competence through auditing. In addition, these organisations must also be able to demonstrate on-going training and assessment to maintain competence. The revision seeks to introduce a recommendation for all Surveyors to have on-going training and set a standard of competence.
It should be noted that MDHS 100 is only guidance. Accredited organisations are bound under their terms of accreditation to adhere to it, but others are not. The obvious solution would be to follow the route of Asbestos Air Testing and make accreditation compulsory to assure standards. However, the HSE have confirmed they have no plans to introduce this and have instead included a section in the draft for Duty Holders on selection of a competent Surveying organisation, which puts the responsibility for ensuring Survey quality on the Duty Holder.