Monthly Archives: November 2013

Consultation on the new CDM Regulations

CDM Regulations 2014 CDM Coordinator

Judith Hackett, Chair of HSE, recently addressed the Westminster Legal Policy Forum (5th December 2013) and had the following to say about the CDM (Construction (Design and Management) Regulations).

“2014 will also see us embark upon some changes to CDM as part of the guidance overhaul. It will not significantly change the technical standards which underpin the Regulations – they are not controversial and have stood the test of time. We are simply intending to streamline their delivery. “The revision which we are preparing to consult upon is underpinned by four priorities: simplify the package to make them easier to understand and comply with; achieve satisfactory transposition of the parent Directive; improve their accessibility for small sites; improve standards of worker protection through the above. “Overall we believe that the revised package will deliver significant savings to businesses through the streamlining of processes and the removal of the CDM co-ordinator role will be much more accessible to those involved on small construction sites due to the simpler structure of the regulations. The production of guidance has the needs of small businesses at its heart to deliver satisfactory transposition of the parent Directive and improve worker protection. “Current plans are for the revised Regulations to come into force in April 2015 and formal consultation is expected to start early in 2014.”

The facts on the proposed CDM changes

The question which follows on from this is what does this mean to you as our clients and to us as your CDM Coordinators?  I’ll try to answer this as simply as I can by first presenting some facts.

  1. The government (rather than the industry or HSE) seem keen to see the role of CDM Coordinator disappear from the regulations.
  2. The directive from Europe does not explicitly state that the role of CDM Coordinator is required
  3. The directive does not state that the application of the regulations is restricted to larger projects
  4. The directive applies,technically, to ALL projects including domestic ones which perhaps just have a single contractor at site.

All of us are used to the spin doctors presenting information in a way that sounds positive but hides some important facts.  A headline that reads ‘CDM Regulations slashed’ plays out very well like this.  The subheading which reads ‘and all domestic and small projects now under CDM’ doesn’t have quite the same cachet.

So, where are we headed?

The likelihood is that the CDM Coordinator role might no longer exist by early or mid 2015.  The likelihood is also that CDM will apply to many, many more projects that it does currently including all domestic projects.  The outcome looks to us like large sites doing something very similar to current arrangements and smaller site doing the best they can while the smallest of sites get hit by a flurry of Fee For Intervention (FFI).

The CDM Regulations have not always been popular, we’re under no illusion about that.  But, they have been effective and are now pretty well understood by everyone involved in the process and that’s the key benefit and the problem which they set out to tackle.

A change of this magnitude upsets the system to such an extent that you wonder what good might come of it bar a brief headline trumpeting the slashing of another regulation linked to elf and safety.

We’ll keep you updated but expect some CDM changes in 2015.

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800100

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Please complete the form below and we promise to respond within 24 hrs. If you need more urgent help just call 01453 800109 and ask for Andrea.

Posted by Roger Hart

Jeremy Clarkson and Judith Hackett (Chair of HSE) make strange bedfellows…

We were interested to see a press release from Judith Hackett, current chair of the Health and Safety Executive in which she praises the writings of one Jeremy Clarkson – perhaps the most vocal critic of the “elf n safety” culture.

Personally, we’re delighted that she’s tackling this straight on.  We have countless moans and groans from ou varied mix of clients and have to say we agree with all of them when they tell us that health and safety can be a pain.

A little knowledge can be a dangerous thing but we do get the blame for everything and sometimes (just sometimes) that’s not fair – read on to find out more and if you’d like to speak to a health and safety consultant who is also a “normal person” then please give us a try, just call 01453 800100 to talk or contact us using the links at the top of this page.

and on that bombshell…

Jeremy Clarkson has never been shy about offering an opinion on health and safety, and I’ve not often agreed with him.

But consider these latest comments in the Sun: “Like many people, I’ve spent the past few years lambasting the clipboard wielding health and safety morons who are turning this country into a risk averse nanny state. But the truth is the real culprits are actually the insurance companies.”

What sparked his wrath is a civil court case in which an insurance company is contesting a compensation payout to a teenage girl who was knocked down and injured by a motorist. The driver’s insurers, he says, have argued that the girl should have been wearing a high viz jacket and in doing so are in danger of setting a precedent that means “every single pedestrian will be told that they can’t go out at night unless they’re dressed up like a riot policeman”.

Is he right? Certainly others will look at the result and worry about what they might need to do now to reduce their risk of civil claims.

We see this all the time in everyday life. Every cup you take away from a coffee shop these days has a warning that the contents are hot. All because somebody sued after being burnt by a drink. Is it really necessary? No, of course not. Coffee should be hot. Is it health and safety? Absolutely not.

But these sort of stories often end up with health and safety getting the blame for something which has nothing to do with the actual regulations. And they are not just stories. They have unintended consequences – activities get watered down because people are nervous about getting sued and want to minimise all risks, not matter how trivial. Others conclude it is just not worth the hassle and abandon events altogether.

I’d like to think that in a small measure, Jeremy Clarkson has picked up on some of the work we have been doing to bust the health and safety myths apart, and the encouragement we have been offering people to question who is really causing this risk aversion.

So if you are reading Jeremy, you made my day. If you want to get me into that reasonably priced car, I’d be happy to show you what managing risk means.

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800100

Contact form

Please complete the form below and we promise to respond within 24 hrs. If you need more urgent help just call 01453 800109 and ask for Andrea.

 

Posted by Roger Hart

Flail/ chain cutter attachments for brush cutters / strimmers

Chain flail brushcutterWe work with a number of landscaping businesses and we have known for a long time now that the use of the flail like attachments which can still be found is highly dangerous and should always be avoided.

The HSE has now made progress through Europe to get the use of these attachments banned.  the original accident which alerted authorities to the danger was a fatal incident in Sweden in 2010 when a link of the chain failed and flew at very high speed killing a nearby worker.

Please check to ensure that you do not have any of these types of attachments in use and use this article to spread the word amongst your peers, the risks are very serious and their use could result in a fatality – read on for more information or if you would like to speak to a consultant about these risks and how we can work with you please contact us on 01453 8000100

Health and Safety Executive – Safety alert
Department Name: Operational Strategy Division – Agriculture and Waste Recycling Sector
Bulletin No: OPSTD 1-2013Note: this bulletin replaces Bulletin No. OPSTD 3-2011 and Bulletin No. FOD CON 3-2010
Issue Date: 12 November 2013
Target Audience:
  1. Suppliers and users of portable hand held brush cutters in arboriculture and the agriculture and construction industries
  2. Relevant trade associations
Key Issues: The European Commission (DG Enterprise and Industry) has required Member States to prohibit the placing on the market of flail-type cutting attachments consisting of several linked metal parts (e.g. chains) for portable hand-held brush cutters. Non-standard metal brush cutting accessories fitted to petrol driven brush cutters can fail catastrophically in-service.There is a risk of death or serious injury to operators and others in vicinity from ejected metal components. These accessories are manufactured from more than one component and rotate at high speeds.Suppliers of such equipment should immediately discontinue supply of flail-type cutting attachments for portable hand-held brush cutters. Anyone using them should discontinue use of any non-standard metal cutting accessory immediately and consult the brush cutter manufacturer for guidance.

Introduction:

Brush cutter with typical manufacturers’ cutting attachments

A serious risk has been identified with this type of attachment for brush cutters. This problem was first identified in Sweden a few years ago (see below). In 2010 a fatal injury occurred in the UK following which the UK obtained voluntary agreement from the UK distributor to stop supply of this particular device. The UK also issued a safety alert to warn industry, workers and the public of the risk of this type of device and ask that they no longer be used.

Previously, Sweden had warned Member States about the sale of brush cutter attachments of various types and origin that were made up of linked parts (e.g. an attached chain) instead of the single one-piece metal blade or nylon string dispenser supplied by the manufactures of the brush cutter.

The harmonised standard EN ISO 11806 does not cover this type of device as only nylon strimmers and single piece metal brush cutting blades are in scope for fitting to the basic brush cutter.

Portable, hand-held, combustion engine driven brush cutters are commonly used for cutting weeds, brush and similar vegetation, and are frequently utilised in ground-clearance operations, including those connected with construction work, using a variety of standard cutting attachments.

The Health and Safety Executive (HSE) has become aware of a dangerous practice involving the fitting of non-standard accessories, not approved by the manufacturers, to brush cutting machines. In particular, HSE are aware of the UK supply of chain flail attachments comprising a cutting head incorporating lengths of metal chain. This alert is relevant to any metal brush cutter accessory manufactured or assembled from more than one component.

Background:

Chain flail attachment with two chains

In contrast with dedicated chain flail machinery, brush cutters typically lack the robust guarding arrangements required to control the risk from articles (including fragments of chain) being ejected with high energy. The guarding supplied with brush-cutters is predominantly aimed at protecting the operator from inadvertent contact with the cutting accessory.

The fatal incident involved the use of a twin-chain attachment, similar designs have also been encountered having 4 chains, swinging metal blades and one which utilises shot lengths of chainsaw cutting chains as the cutting implement.

Flail attachment fitted to the brush cutter

The presence of a CE mark should not be regarded as a reliable indication that such attachments are safe to use.

Issues

  • The high output shaft speed of a brush cutter creates the potential for significant energy to be transferred to the cutter head. The chains affixed to non-standard cutter heads are subject to high stresses and impacts during normal use, and the risk from breakage and ejection of chain components at high speed is significant.
  • The use of non-standard cutting attachments not approved by the manufacturer may, because of their geometry and mass, induce excessive stresses which could result in premature failure and possible break-up of the brush cutter, thereby increasing the risk of injury from any ejected component.
  • Manufacturers’ original cutting equipment such as nylon cords, metal cutting blades and saw blades are designed to be used in combination with specifically designed safeguarding systems. The chain flail attachments are not supplied with any compatible safeguard/deflector.
  • The harmonised standard for specifying the safety requirements for such machinery, EN ISO 11806, excludes from its scope brush cutters equipped with metallic blades having more than one part (such as chain links.)

Decision of the European Commission

Following a Safeguard Action brought by HSE under Article 11 of 2006/42/EC, the European Commission – advised by the Machinery Committee, required Member States to prohibit the placing on the market of flail-type cutting attachments, consisting of several linked metal parts (eg chains), for portable hand-held brush cutters, see European Commission Decision on the marketing of flail-type cutting attachments for portable hand-held brush cutters link to external website

Action required:

Users

  • Any brush cutters fitted with flail or similar non-standard attachments, consisting of several linked metal parts (eg chains) should be taken out of service immediately and the attachments removed and replaced with the manufacturer’s approved accessory.
  • Manufacturers’ advice should be followed as to the appropriate combinations of cutting tools and guards. Such advice is typically available within the instruction books accompanying the machine.

Suppliers

  • UK suppliers should immediately cease the supply of cutting attachments consisting of several linked metal parts (eg chains) whether or not intended for “professional use.”

Relevant legal references:

Note: The EU Commission is of the view that chain flail attachments are interchangeable equipment within scope of the Machinery Directive as listed in Art 2(b)

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800100

Contact form

Please complete the form below and we promise to respond within 24 hrs. If you need more urgent help just call 01453 800109 and ask for Andrea.

Posted by Roger Hart

CSCS Cards, changes are planned, how will you be affected?

CSCS Cards and construction sites

Almost all of our clients have had experience – good and bad – with the CSCS scheme. It has become a key requirement for any person wishing to enter a construction site and this includes those staff (ourselves included) who only enter to observe others.

The scheme has faced some criticism in the past for the limited number of trade qualifications which it recognises and moves are afoot to address this.  Unfortunately, additional changes will mean that those applying for a basic ‘green card’ will face a requirement for further qualifications, read on to find out more.

The current system

Depending on the level of card required, the individual had to pass a health and safety touch screen test and provide details of trade qualifications.  The touch screen element is relatively straightforward and can be completed at a number of locations around the country – many of them test centres linked to driver licensing and similar – for a list look here; http://www.cscs.uk.com/cscs-cards/health-and-safety-test

The difficulty with the CSCS scheme has always been in recognising qualifications with many highly experienced site managers and other professional not being in possession of the required NVQs and other formal qualifications which the system requires.

CSCS Green Card

Due to this difficulty many people have given up and gone for the simpler option – known as the “construction site operative” version. To get the green card you only need to pass the touch screen test. However, the CSCS has identified that this is being misused and is planning to make obtaining one a lot more difficult.

Changes to the CSCS Scheme

From July 2014, anyone applying for an entry level green card will be required to achieve a knowledge-based qualification, “Health and Safety in a Construction Environment”. There’s also talk that the individual may have to go down the NVQ route as well.

We should stress that this is the current best knowledge position and things could change but its well worth being aware of this change.  If your site staff are currently using green cards you could find that this will cause you an issue.  Some good news is that since 30 September, CSCS will also recognise these additional construction-related qualifications: HNC, HND, degrees, NEBOSH construction certificates and national diplomas, CIOB certificates.

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800100

Contact form

Please complete the form below and we promise to respond within 24 hrs. If you need more urgent help just call 01453 800109 and ask for Andrea.

Posted by Roger Hart

Standard of electrical qualification for renewables and micro generation

As our renewables team continues to grow we’re working with a number of of business on wind, and other renewables projects providing CDM Coordiantor and safety support.  We work closely with major UK providers and also clients from Europe and America entering the UK market for the first time; Renewables team (PV / Solar / Wind / Biomass).

A question which we recently assisted in answering regarded the electrical safety standards required and level of competence for these types of installations.  It is also worth noting that the CITB (Construction Industry Training Board) are also launching their own scheme for renewables including solar PV and wind energy – we’ll have an update on that soon as it will of course benefit from a grant approved status.

Information reproduced here has been taken from the Microgeneration Certification Scheme website: www.microgenerationcertification.org, if you have any questions please contact us on 01453 800100

3.1 Capability

Certificated contractors shall have the capability and capacity to undertake the supply, design, installation, set to work, commissioning and handover of micro and small wind turbine systems.

Where contractors do not engage in the design or supply of micro and small wind turbine systems, but work solely as an installer for a client who has already commissioned a system design; then the contractor must be competent to review and verify that the design would meet the design requirements set out in this standard and this should be recorded.

5 COMPETENCE OF STAFF

All personnel employed by, or sub-contracted to, the contractor must be able to demonstrate that they are trained and competent in the disciplines and skills, appropriate to the activities required for their role, in accordance with this standard.

Complete records of training and competence skills of personnel must be maintained by the certificated contractor, in particular:

  • Design staff, carrying out full conceptual design, must be able to demonstrate a thorough knowledge of the technologies involved and the interaction of associated technologies.
  • All personnel engaged in the actual installation are expected to have technical knowledge and installation skills, to install components and equipment within the designed system, in accordance with all appropriate codes of practice, manufacturer’s specifications and regulations.
  • All personnel engaged in the final inspection, commissioning, maintenance or repair, must have a comprehensive technical knowledge of the products, interfacing services and structures to complete the specified processes.

Examples of the underpinning knowledge areas required to show competence are given in Appendix C.

APPENDIX C:  Competence of Staff

Assessments of competence will cover the following underpinning knowledge areas:

  • C. 1. Mechanical Engineering (understanding of static and dynamic stresses and loads involved with wind turbines)
  • C. 2. Environmental impacts of wind turbines (e.g. noise, flicker)
  • C. 3. Concrete structures and processes
  • C. 4. Resource assessment and performance calculation (inc understanding of limitations of NOABL and impact of turbulence)
  • C. 5. Non-conventional AC output (variable voltage, variable current, variable frequencies) of wind turbine
  • C. 6. DC Electrical systems
  • C. 7. Conventional AC Electrical Systems (BS 7671)
  • C. 8. Grid connection requirements (G83 and/or G59)
  • C. 9. Battery systems for off-grid applications (sizing, depth of discharge, ventilation, dump loads etc.)

MCS Standard 001 specifies a very general requirement on training as follows:

17. Training and competence

All staff employed in installation, set to work and/or commissioning activities must have received adequate training in each of the areas/operations in which they are involved.

The Company must have a training record for each employee which details training received, and any qualifications or certificates held by the individual. The record should be signed or verified by the employee.

The Company must have a record detailing the MCS related activities for which each individual is approved on the basis of their competence. The competencies required for installers are detailed in the relevant installation standards.

18. Health and Safety

The company must have health and safety policies and procedures, including risk assessment, to ensure all installations are conducted safely.

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800100

Contact form

Please complete the form below and we promise to respond within 24 hrs. If you need more urgent help just call 01453 800109 and ask for Andrea.

Posted by Roger Hart

Dielectric gloves and their storage use and in service testing: Electrical Insulating Gloves (EN 60903)

We work with a number of businesses who make use of the following equipment and so thought it wise to issues a reminder that this protective equipment does need periodic testing. Our clients in the water and utility sectors as well as contractors in the electrical sector should find the following information useful.

If you have a need and are involved in utility works, moleing, water or power contracting please call 01453 800100 and ask to speak to Derek or Jeremy (our people).

Electrical Insulating Gloves (EN 60903): In-Service Recommendations

Storage

Gloves should ideally be stored in their container or package in which they were provided. Care should be taken to ensure that the gloves are not compressed or folded, or stored in proximity to steam pipes, radiators or other sources of artificial heat or exposed to direct sunlight, artificial light or other sources of ozone.  It is recommended that the ambient temperature remains between 10ºC and 21ºC where possible.

Examination before use

Before each use, inflate your gloves by blowing into them to check for air leaks – also carry out a brief visual inspection for nicks and tears. For gloves of Classes 2, 3 and 4, an inspection of the inside of the gloves is recommended. If either of a pair of gloves is thought to be unsafe, the pair shall not be used and should be returned for testing.

Precautions in use

Glove should not be exposed unnecessarily to heat or light or allowed to come into contact with oil, grease, solvents in general, white spirit or strong acid. If protective gloves are used at the same time as rubber gloves for electrical purposes, they should be worn over the rubber gloves. If the protective gloves become damp, oily or greasy, they should be removed and replaced.

When gloves become soiled they should be washed with soap and water at a temperature not exceeding 55ºC, thoroughly dried and then dusted with talc. If insulating compounds such as tar and paint continue to stick to the glove, the affected parts should be wiped immediately with a suitable solvent (this will depend on the materia the gloves are manufactured from and avoiding excessive use of that solvent) and then immediately washed in clean warm water and treated as prescribed. Note: Petrol, paraffin or white spirit should not be used to remove such compounds.

Gloves which become wet in use or by washing must be dried thoroughly, but not in a manner that will cause the temperature of the gloves to exceed 55ºC.

Periodic inspection and electrical retesting

No gloves of Classes 1, 2, 3 and 4, even those held in storage, should be used unless they have been tested – the maximum period is 6 months. The tests consist of air inflation to check for air leaks, visual inspection while inflated, and then a routine dielectric test. However, for gloves of Classes 00 and 0 a check for air leaks and visual inspection only is generally considered adequate.

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800100

Contact form

Please complete the form below and we promise to respond within 24 hrs. If you need more urgent help just call 01453 800109 and ask for Andrea.

 

Posted by Roger Hart

Renewables continues to soar, offshore wind power grows by almost 100%

As our renewables team continues to grow we’re working with a number of business on wind, ground mounted PV Solar and bio mass projects providing CDM coordinator and other support.  We work closely with major UK providers and also clients from Europe and America entering the UK market for the first time.

The offshore wind industry has experienced a record-breaking year in terms of new deployment, according to a new report.  A study by RenewableUK, which assesses the state of the wind industry from July 2012 to June 2013, revealed a “step change in the offshore wind sector”.

Installed capacity stood at 3,321 megawatts (MW) at the end of June 2013, up from 1,858 MW 12 months earlier – an increase of 79 per cent – while four large scale offshore projects went operational during the 12-month period covered by the report.

They included Greater Gabbard, Gunfleet Sands III, Sheringham Shoal, and London Array which is currently the biggest offshore wind farm in the world.

The 1,463MW installed offshore marks the first year in which offshore deployment has outstripped onshore wind. Onshore, 1,258MW of new capacity came into operation, bringing the total installed onshore to 6,389MW – an increase of 25 per cent.

RenewableUK said the UK’s total wind capacity had increased from 6,856 to 9,710MW – a 40 per cent increase – enough to power more than five and a half million UK homes. The new capacity brought £2bn of activity to the UK economy.

RenewableUK’s chief executive Maria McCaffery said: “We’ve smashed another record in the past year with more offshore wind installed than ever before – the 79 per cent increase in capacity within 12 months is a terrific achievement. With onshore expanding by 25 per cent, the wind industry as a whole has proved that it has the tenacity to achieve substantial growth.

“It’s tangible proof of the dedication of thousands of Britons who are working tirelessly to generate electricity from a clean, home-grown source at a cost that we can control, increasing the UK’s energy security.”

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800100

Contact form

Please complete the form below and we promise to respond within 24 hrs. If you need more urgent help just call 01453 800109 and ask for Andrea.

Posted by Roger Hart
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