Updates on new and changing regulations plus best practice in health, safety, quality and environment

Understanding the impact of business to business health and safety ‘rules’

A recent report published by the HSE entitled “Understanding the impact of business to business health and safety rules” makes interesting reading:the impact of business to business health and safety

https://www.hse.gov.uk/regulation/assets/docs/understanding-impact-business-to-business-health-safety-rules.pdf?utm_source=govdelivery&utm_medium=email&utm_campaign=construction-jul-19&utm_term=pdf-download&utm_content=blue-tape

The report raises a number of points, and will give all consultants food for though.  The findings that stand out for me though, were:

  • 39% of SMEs thought that the polices and procedures that they have in place for health and safety are excessive and disproportionate; and
  • 35% think that there is no real link between what they have to do for health and safety and keeping employees safe.

The research also recognises Health and safety consultants play an important role in helping SMEs with the burdens of health and safety rules and regs; and, importantly, that consultants are not a driver of health and safety rules.

But surely there is something wrong here?  Consultants are doing a good job in helping businesses, but a significant minority still say that their health and safety systems are not right.  Perhaps this is something to do with the consultants?  The report notes that large consultancies have dedicated sales teams that are under pressure to get business and that this is the driving factor rather than the needs of the business.

So, I think the conclusion is obvious:  consultants DO help small business, but only if you use the right one!

“Report abstract

This paper explores perceptions of health and safety ‘rules’ and their effects both on businesses (particularly SMEs)and the health and safety system. They persist despite significant Government attention to perceptions of health and safety burden under its better regulation agenda. Health and safety ‘rules’ are obligations imposed not government regulation but by businesses or business intermediary organisations. They are variously described by interested parties as ‘blue tape’, ‘business to business burdens’, ‘privatesector regulation’ and similar terms. This review will refer to them as health and safety ‘rules’”

Posted by Roger Hart

Breakfast Clubs Invite, October and November 2019 dates

Need more advice on Health & Safety and HR Issues?  Join us for breakfast at one of our free clubs and meet our Chartered Safety Practitioners, HR Partners (HR Champions) and like-minded businesses.  Share your ideas and experiences over a coffee and get the answers you need there and then!

We’ll provide a clear and focused 60-minute talk on what you need to be aware of. You can join us for free using the links below to book your place and meet some of the hundreds of businesses already benefiting from our advice and support. Book your place whether your a client, linked ot one of our customers or are just curious to know more.

Thursday 3rd October, Worcester Rugby Club WR3 8ZE
08.00 arrival | 09.30 finish map


Thursday 10th October, Jurys Inn Cheltenham GL51 0TS
08.00 arrival | 09.30 finish map


Thursday 11th October, Berwick Lodge Bristol BS10 7TD
08.00 arrival | 09.30 finish map


Thursday 18th October, Bowman House Swindon SN4 7DB
08.30 arrival | 09.30 finish map

Posted by Roger Hart

HSE Targets Principal Designers 2019/20

Principal-Designers-cdm-2015Are you acting as a Principal Designer? If you are you may be the subject of a visit as HSE Targets Principal Designers in its current year plan (you can find all our posts on Principal Designers and prosecutions by click here to find out more about HSE requirements for Principal Designers under CDM 2015 follow this link: http://www.hse.gov.uk/construction/areyou/principal-designer.htm).

The HSE Business Plan 2019/20 is aimed at reviewing the following categories:

  • Lead and engage with others to improve workplace health & safety
  • Provide an effective regulatory framework
  • Secure effective management and control of risk
  • Reduce the likelihood of low frequency; high-impact catastrophic incident
  • Enable improvement through efficient and effective delivery

Under the section ‘Secure management and control risk’, the HSE actions and focus are as outlined below:

  • Refurbishment Projects – SMEs carrying out refurbishments
  • Principal designers – embedding the requirements of CDM 2015 through targeted inspections of duty holders providing Principal Designer services
  • Lung Disease and MSDs – prevention and control of occupational lung disease

Going forward Principal designers will need to review how they are fulfilling their key responsibilities under CDM 2015.

At Outsource Safety we are able to assist with any CDM queries and can walk you through the process. Please contact us for further details on 01453 800100 contact us or request a call back from one of our safety consultant.

Posted by Roger Hart

HSE update: Mild Steel Welding Fume is Carcinogenic

You may have seen the recent HSE update announcing mild steel welding fume is carcinogenic and IARCs new classification of it as a carcinogen (cancer-causing agent).  This has caused a huge amount of questions for both our helpline for existing client supported under Safety~net and also from our work monitoring welding fume exposure, you can also watch our 3 minute video below

 

We have completed many sampling exercises over the last 25 years and often work to submit our reports back to the Health and Safety Executive on behalf of the client and also represent their interests when HSE have concerns. If you have any concerns please do contact us or request a call back from one of our safety consultants or an occupational hygienist.

from IARC: “The International Agency for Research on Cancer (IARC) highlighted environmental factors that could cause cancer in humans, including the fumes generated during welding operations. Welding fumes could produce several negative health effects, including respiratory problems and lung cancer due to prolonged exposure. Recently, the IARC, the cancer research arm of the World Health Organization, classified welding fumes as possibly carcinogenic to humans after there have been studies indicating welding fumes and gases may increase cancer risks.”

What is the impact of the reclassification of mild steel welding fume?Mild Steel Welding Fume Carcinogenic

Firstly, don’t panic. Mild Steel Welding Fume is Carcinogenic but welding fumes have always been harmful and you will have some protection already in place through local exhaust ventilation, disposable masks or perhaps air fed helmets for your welders.  Now you need to review these controls to ensure that they are adequate and also make allowance for the higher known level of risk, so what you might choose to do may change in light of this.  For example, if you decided previously that you could not justify the expense of air fed helmets you might wish to review that decision.

Secondly, take advice on HSE’s comments on LEV being the key requirement.  Whilst its true that a well designed LEV system is most likely the best way forward you cannot always have this in place when work positions and work types change and vary.  We’ve seen some great systems for serial production of the same items but we’ve also seen systems which rely on the welder using them and moving them sat unused for month after month. What works best can vary and sometimes we do need to rely on personal protection through an air fed helmet.

How do I monitor for exposure to mild steel welding fume?

Its quite straightforward but you do need to be competent.  Its typically carried out through air monitoring by an Occupational Hygienist and its something which we have offered for many years. A volume of air is drawn through a filter and the mass measured, 90% of fume is made up of the consumable and so the permissible amount of exposure does vary between suppliers and also is affected by other factors, for example;

  1. Welding position:
    1. does the welding plume rise into the welder’s face?
    2. Is the weld below the worker (down hand position)?
    3. Is the weld completed within a workshop?
    4. Is the weld completed within a confined space?
  2. Current controls:
    1. Are disposable masks in use?
    2. Is an air fed welding helmet available?
    3. Is LEV provided?
    4. Is LEV used consistently?
    5. Is the LEV effective in capturing the fume?
  3. Exposure considerations:
    1. Is the parent metal coated?
      1. Galvanised or painted surfaces are much higher risk exposures
    2. Is the weld completed within the structure?
      1. Fumes could build up to very high levels
    3. Are their others nearby who will be affected?
      1. For smaller work zones this could be significant
  4. Other factors:
    1. Process variables such as amps and feed speed can increase fume exposure
    2. Changes in process from TIG to MIG or MMA welding can also adversely affect fume generation

See how on gun extraction could help: https://youtu.be/-JywnVZJLNk

What can I do to reduce exposure to welding fume?

You can look to outsource or automate the process if possible.  LEV is a great solution when it is practicable but often it needs to be moved constantly to remain effective (LEV only works effectively within 1 diameter, i.e. if the end of the extract arm is 100mm it MUST remain within 100mm of the weld points at ALL TIMES.  If you have weld seams which are longer than a few centimetres this often proves difficult as a welder does not have a free arm with which to move the LEV point whilst welding.

You then need to consider another method of control, these could be:

  1. Updating you LEV to extract over a wider area through use of a booth, a downdraft bench or other extracted enclosure;
    1. Please review the welding fume RPE selector from BOHS: http://www.breathefreely.org.uk/wst/
  2. Using air fed welding helmets, these give protection to your workers wherever they are but may be overwhelmed in confined spaces;
  3. using on gun extraction to capture fume at source (see our video for a demonstration: https://youtu.be/-JywnVZJLNk);
  4. Swapping welding methods, TIG usually generates less fume than MIG;
  5. Adjusting settings, you might be able to reduce the weld current to reduce fume;
  6. reducing concurrent exposures, you may be able to remove paint, oil or other coatings before the area is welded.
Posted by Roger Hart

Dust Extraction Classes on Vacuums – What class do I need?

Firstly, good for you for even stopping to ask yourself about Dust Extraction Classes.  A lot of people are still using extraction equipment which is designed for domestic vacuuming – something not designed or capable of protecting you from hazardous dust.  Think about it, would you take something you know to be harmful and then suck it up only to spray the very finest (and most hazardous) parts of it into the air around you and your workmates?  Not a good idea but if you would like some good ideas on protecting yourself and others from hazardous dust please do contact us or request a call back from one of our safety consultants or an occupational hygienist.

What do I need?respirable crystalline silica, RCS welding fume

Something which can extract it and keep it inside a bag until you dispose of it.  Don’t use a vacuum without bags – unless you like inhaling dangerous dust and are hoping to get a lung disease! On the same subject be wary of small on tool extractors which collect dust efficiently only to leave you with having to ‘knock them out’ giving you dust exposure which a well-designed vacuum extractor would deal with.  For the smallest of these systems that can mean quite a few times a day, and when you’re dealing with RCS (respirable crystalline silica) that’s a bad idea for you and those around you.

Added benefits: time and money

If you, or your boss, still aren’t convinced how about considering time and money saved?  If you’re not cleaning up afterwards you’re saving money.  If you’re on domestic work creating dust and spreading it throughout a nice house good extraction can mean no cleanup and that equals happy lungs and happy clients.  Believe it or not, good extraction will also prolong the life of your tools and equipment, by up to 3 times!  When you’ve got expensive professional tools that’s a significant payback.

More reasons to choose good dust extraction

Don’t forget there are also some harsher reasons why not using good extraction could cost you money.

  1. Main contractors don’t want you exposing other trades to dangerous dust and value those with good dust practices;
  2. They also have to factor in for your clean up if you create a lot of dust or delaying other trades;
  3. The HSE would very happily fine you under FFI or issue a notice to you if you’re not taking good precautions to control dust generation;
  4. No win no fee cases are rising massively for health-related issues with payouts in the tens of thousands happening regularly (see our sentencing guidelines blog).

Types of vacuum: (MAC = maximum allowable concentration)

  1. L Class ≤ 1.0% Dust with maximum allowable concentrations (MAC) > 1 mg/m³ (soft wood dust, other lower hazard dust such as Corian)
  2. M Class < 0.1% Dusts with maximum allowable concentrations (MAC) ≥ 0.1 mg/m³ (hard wood dust, concrete and brick dust)
  3. H Class < 0.005% Dusts with maximum allowable concentrations (MAC) < 0.1 mg/m³ (asbestos, mould spores, carcinogenic dusts)

Notes on vacuum types

In practice, you may see very little to distinguish a type L from a type M vacuum but there are differences. Although their extraction rates and filtration levels are often similar features will vary, for example, a true type M vacuum will have an audible alarm to warn when the suction rates drop due to a full dust bag or a hose blockage. For the majority of construction sites, M class will be a minimum requirement and we would suggest this is also the case within any factory environment.  Interestingly, HSE set a minimum requirement of M class, a strong reason why you should make the step up to a better level of extraction.

Other factors to consider relate to use in practice which means in practice;

  1. A bag size adequate for the amount of use / level /volume of dust being extracted;
  2. A power take-off which helps to ensure that the extractor is running all the time the tool is active (and then switches off when not needed);
  3. A delayed shut off is preferable which ensures some over-run to extract remaining dust after the tool itself shuts down (typically 5 seconds and clears the tool and hose of dust);
  4. A filter cleaner which can be manual or automatic, this dislodges dust from the filter and maintains good flow.  Improving capture efficiency and reducing the likelihood of a motor overheat or burnout;
  5. Attachments which make your vacuum far more effective, see below (whale tail for extracting mixing containers, impact breaker attachment, grinder guard / extractor, drilling shroud).

HSE guidance

Posted by Roger Hart

HSE to target all businesses in dust exposure inspections

Please find below an update from HSE regarding their focus on dust exposure across all sectors of industry – if you need support or advice on dust exposures including air monitoring please contact us or request a call back from one of our safety consultants or an occupational hygienist.  We have many years of experience in monitoring for construction health including air sampling for wood and other process dust plus fume including respirable crystalline silica and also welding fume.

British businesses targeted in new dust inspectionsdust exposure

Firms across Great Britain are to be targeted in a new series of inspections focusing on dust control by the Health and Safety Executive (HSE).Over the next few weeks, HSE is concentrating on industries such as construction, woodworking and food manufacturing where occupational lung diseases, including in some cases occupational cancers, are more common.

Inspectors are visiting businesses across the country to see what measures have been put in place to protect workers’ lungs from the likes of asbestos, silica, wood and flour dust. They will be looking for evidence of businesses and their workers knowing the risks, planning their work and using the right controls. Where necessary, HSE will use enforcement to make sure people are protected.

HSE’s chief medical officer, Professor David Fishwick said:

“Exposure to asbestos, silica, wood, flour and other dust can have life-changing consequences.

“Each year work-related lung diseases linked to past exposures are estimated to kill 12,000 workers across Great Britain. In many cases these diseases take a long time to develop after exposure, so the damage done may not be immediately obvious. Others, such as occupational asthma and acute silicosis, can occur more quickly.

“These conditions can and do have a significant impact on both the individuals affected and those closest to them, so it is imperative that workers take the necessary precautions to protect their lungs.”

Sarah Jardine, HSE’s chief inspector of construction said:

“We are carrying out this series of inspections to ensure businesses are fulfilling their legal duties to protect workers from harm. This includes controlling the levels of dust in workplaces.

“We want to ensure employers and their workers are aware of the risks associated with any task that produces dust. Such work needs to be properly planned and use the right controls, such as water suppression, extraction and masks.

“The bottom line is we want everyone, workers and their employers, to be protected from harm and ill health so they can go home healthy to their families.”

For more information on the inspections and to download our free #DustBuster selfie cards visit the #Dustbuster resource page and follow the campaign on Twitter, Facebook and LinkedIn.

You can also join the conversation at #WorkRight

Posted by Roger Hart

HSE to focus on construction health in June

respirable crystalline silica, RCS welding fumePlease find below an update from HSE regarding their focus on construction health – if you need support or advice on dust exposures including air monitoring please contact us or request a call back from one of our safety consultants or an occupational hygienist.  We have many years of experience in monitoring for construction health including air sampling for dust and fume including respirable crystalline silica and also welding fume (mild steel).

HSE to focus on the Construction Industry

During mid-June to mid-July, HSE’s campaign activity will once more include a focus on health in the construction industry, with an emphasis on lung disease – in particular where lung disease has been caused by exposure to asbestos and dust.

What Needs to be Done?

Naturally, health and safety, in general, should be a priority on all construction projects, and everyone has a duty to play a leading part in this and achieve the required standards – whether they be a manager, supervisor, employee, or contractor. The key messages for action are straightforward:

  • Know the risks
  • Plan your work
  • Use the right controls

By understanding the main risks to health and the measures required to control these, workers can be better protected – and ultimately this will help achieve the aim to eradicate ill health and disease from the construction industry. Progress can also be made by sharing best practice examples – such as case studies: please visit HCLG’s website which features a number of construction industry case studies, as do some of the campaigns below.

Free Resources and Advice
Recent years have seen a number of campaigns launched, focusing on worker health and protecting workers from lung disease.  These have resulted in a vast range of valuable, free advice and resources being made widely available and easily accessible to everyone:

  • HSE’s Go Home Healthy campaign: one of the main areas of focus for this initiative is lung disease, and in-depth information and a number of resources are available on HSE’s website
  • IOSH’s No Time to Lose (NTTL) campaign: ‘A wake-up call to cancer caused by work’ highlights the need for a wider understanding of carcinogen exposure issues and how businesses can take action. Free resources include those related to asbestos, silica dust and diesel fumes i.e. known risks to lung health
  • BOHS’s Breathe Freely campaign: ‘Controlling exposures to prevent occupational lung disease in construction’ is the primary aim of this campaign, and the Breathe Freely website contains a vast and wide range of resources – all specifically developed for the construction industry

What Next?

HSE’s initiative will continue to shine a spotlight on health, and demonstrate where progress is being made and where room for improvement remains. Supporting the above campaigns on social media will help achieve wider awareness of the issues; what action needs to happen; and the wide range of available resources.
By working together as leaders in the industry, and by sharing best practice, everyone can make a difference and play their part in raising standards to improve worker health protection in the construction industry.

Posted by Roger Hart

Managing the Transition from OHSAS18001 to ISO45001

Designing, implementing and maintaining management systems such as ISO45001 can seem daunting and time consuming.  Outsource Safety can help you and ensure that your systems are effective, efficient and focussed on your business risks and needs.

With an integrated management system, all the elements work together, with each function aligned behind a single goal; improving the performance of the entire organisation.  An IMS can benefit your organisation through increased efficiency and effectiveness and cost reductions, while minimising the disruption caused by numerous external audits.

We have proven expertise in:

  • ISO9001
  • ISO14001
  • ISO45001
  • ISO50001

Whether you are in construction/contracting; manufacturing/industrial; or administrative we can help with:

  • Design and implementation of integrated management systems
  • Internal audit
  • Management Review
  • Training and awareness
  • Transition to new standards

Transition from OHSAS18001 to ISO45001 – when do I have to do it?

OHSAS18001 will cease to exist in March 2021….so you will have to go through the transition process well before then to ensure continuity of certification.  The date sounds a long way off, but don’t forget you will have to plan and implement the transition, ensure that you have sufficient documented evidence in place, then get your certification body in to audit the system.  It is wise to allow some contingency time too, in case there are any issues to be put right at the final audit.  Each certification body will have its own process for transition, so it’s worth talking to them to ensure the process runs smoothly.  Also, it is likely that the certification auditors will be very busy in the immediate run up to the deadline, so get the dates booked in as soon as you can.

So, even though you have nearly 2 years to complete the transition process, it will need to be carefully planned.

Transition from OHSAS18001 to ISO45001 – what are the differences?

The new ISO45001 standard is in the Annex-SL format – that is consistent with ISO9001, ISO14001, ISO50001 and many other international standards.  If you are familiar with the Annex -SL format through working with other Standards, you will already have a good idea about the structure and this will make the task easier.  However, it is often easier to concentrate on the differences, rather that recognise the similarities between the Standards, you can view more information on th standard here: https://www.iso.org/iso-45001-occupational-health-and-safety.htmlhttps://www.iso.org/iso-45001-occupational-health-and-safety.html

The key areas of difference are

  • Leadership: It needs to be demonstrated that top management are fully committed to and understand the management system.  This goes well beyond attendance at an annual management review meeting!
  • Context: It has to be established what the strategic risks and opportunities are for the organisation and understand the entire environment in which the organisation operates, including the needs and expectations of workers
  • Worker participation and consultation
  • Identification and resolution of root causes following failures (not just accidents)
  • Integration of safety and health into business processes and systems.

Transition from OHSAS18001 to ISO45001 – how can I maximise the benefits (and minimise the work!)?

Consider the transition process as an opportunity to improve what you do and how you do it, rather than a problem to be solved.  Everything that you do should be based around the risks and needs of your business.  The new format of the Standards is less prescriptive with regards to documentation, so there should be no need to generate loads more paperwork.

But the biggest opportunity comes with the potential to integrate your management systems.  In fact this is a requirement of the Standard, but allows you to make it more effective and more efficient.  Do away with duplicated processes, systems and paperwork.  This will allow you to focus on what is really important for your business and drive improvement.  Do not look at health and safety management in isolation.

Posted by Roger Hart

3M faces court case over ear defence

How Effective are your Ear Protectors?

A recent lawsuit against 3M and Aearo Technologies, who were found compliant in providing defective Combat Arms Earplugs, falsifying test results and misrepresenting the Earplugs performance to obtain a multi-million dollar contract with the US military, has resulted in 3M agreeing to pay out $9.1 million to resolve allegations that it knowingly sold the Dual-Ended Combat Arms Earplugs to the US Military without disclosing defects that hampered the effectiveness of the hearing protection device. The Earplugs were designed to block out and to reduce battlefield explosions and artillery fire, whilst still allowing the user to hear quieter noises such as communication by fellow soldiers or enemy combatants. The design, however, was not fit for purpose and failed to seal the ear canal correctly, when in a certain position, thereby opening up the user’s ears to potential hearing damage. US Army veteran, George Dooley filed the lawsuit, when diagnosed with hearing loss and tinnitus, having never before suffered from any hearing loss.

Mr Dooley was diagnosed with tinnitus and hearing loss when he retired from the military in 2008. He regularly used 3M’s defective Combat Arms earplugs at gun ranges and in military vehicles, including while deployed in Iraq. This has had a dramatic impact on his day to day life; the constant ringing in his ears interferes with everyday conversations and affects his sleep.

Whilst this is an American case, hearing loss through ineffective ear protection needs to be considered carefully. At Outsource-safety we are able to carry out noise exposure surveys, capture accurate exposure data and recommend appropriate noise management plans and possible ear protection. Please contact us for further discussions and to arrange a consultation.  If you have a requirement for noise monitoring you can speak directly to one of our experienced consultants on 01453 800100 or request a personal call back from one of them.

Posted by Roger Hart

Children and Construction Site Dangers: Stay Safe, Stay Away – Free Video

With the Summer holidays looming and many constructions sites situated near to where children play and have access to, extra care needs to be adhered to, to ensure all safety measures are in place. Children are often attracted to the noise, trucks and materials on a building site but are unaware of the dangers that await them. Correct signage and following the relevant health & safety procedures are prevalent and would prevent unfortunate incidents involving children occurring.

Our work supporting the Working Well Together Campaign is something we’re very committed to.  Our MD serves as Treasurer for the Southwest Region and attends meetings with HSE representatives and key members of the Health and Safety Executive and we help drive the safety message out to many small builders who would otherwise miss key safety messages like those around RCS and dust control.  Check out their new safety video aimed at primary aged school children here and feel free to distribute and use it as much as you can.

Take for example the case of Westdale Services Ltd; the failure to provide an adequate ladder guard, resulted in a young boy gaining access and climbing to the top platform of the scaffold, then climbing to the uppermost ladder to a height of approximately 10 metres. Regrettably, the boy fell causing life-changing injuries; he now has no bowel or bladder control and is unable to walk any distance.

An investigation by the Health and Safety Executive (HSE) found the security arrangements for preventing access to the scaffolding, especially by children from a nearby school, were inadequate.

Westdale Services Limited of Doncaster Road, Askern, Doncaster pleaded guilty to breaching Section 3(1) of the Health and Safety at Work Act 1974 and has been fined £160,000 and ordered to pay £22,310 in costs.

Speaking after the hearing, HSE inspector Michael Batt commented: “The death or injury of a child is particularly tragic and a lot of thought must go into securing construction sites. Children do not perceive danger as adults do. The potential for unauthorized access to construction sites must be carefully risk assessed and effective controls put in place.

“This incident could have been prevented by removal of the ladder completely or installing an appropriately sized ladder guard to cover the full width of the rungs.”

At Outsource Safety we work with construction and industry across the UK. We provide outsourced and interim support for every sector with our experienced professionals always on hand for expert advice.  If you’d like to support Working Well Together or would like to know about future events please contact us or email directly: wwtswg@gmail.com

Posted by Roger Hart