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

Hand Arm Vibration: Competency for HAVS Health Surveillance

Competency for HAVS Health SurveillanceOur recent support work across our client based and in particular two Improvement Notices issued by HSE on which we have assisted have highlighted the issue of competency when it comes to Competency for HAVS Health Surveillance.  It’s easy to get lost amongst the science and application of the regulations, which can certainly be a challenge for non-techical specialists.  What is sometimes missed is making sure that the support which you have is appropriate and fully qualified.

When you are engaging the services of a professional, often a practising GP, it can be daunting to ask the right questions but this is something which you should do.  Read on to find out what you should expect from your health surveillance.  Further information can also be downloaded from the HSE Website at this link: HAVS Competency

Hand Arm Vibration: Competency for HAVS Health Surveillance

To undertake HAVS health surveillance at Tier 3, the occupational health professional should:

  • (a) understand the health effects of workplace vibration exposure and how it may present clinically;
  • (b) have the clinical skills to adequately assess the worker, provide advice and recommend Tier 4 assessment where appropriate.

Occupational health staff undertaking HAV health surveillance assessments should:

(a) be registered/licensed to undertake clinical practice as defined by their appropriate professional body (eg GMC for doctors, NMC for nurses);

(b) have a higher qualification in occupational health. Doctors should hold a diploma in occupational medicine as a minimum. Other occupational health staff should have a higher qualification in occupational health, eg diploma or degree;

(c) have successfully completed a Faculty of Occupational Medicine (FOM) approved HAV training course.

Where tests (eg Purdue peg board) are delegated to occupational health technicians (or equivalent), the supervising clinician must ensure they are competent to undertake the task and are sufficiently supervised. The supervising clinician retains overall responsibility for the assessment undertaken of the worker. This responsibility cannot be delegated to the technician.

Guidance specifically aimed at Clinicians and specialists can be found here; Health surveillance – Guidance for Occupational Health Profession-als

Posted by Roger Hart

3D printing, managing the risks

Many companies and educational establishments are now incorporating 3D printing into their activities.  Whilst 3D printing brings great new possibilities it also brings some specific risks which must be managed.

There are various 3D printing technologies but this post refers to Fused Filament fabrication (FFF) and uses the CLEAPSSS Design and Technology guidance as its basis; CLEAPSS Guidance  If you have specific questions or would like to look at exposure for your own printer please contact us using the call back request or the chat link at the bottom right of this page.3D printing

FFF technology is the most common form of 3D printing used in SME’s and educational premises, laying down melted plastic filament in a series of layers. The adjacent layers cool and bond together before the next layer is deposited.

In common with most substances which are exposed to high temperatures (over 200oC is not uncommon), the filament printing process can give rise to substances which present a risk to health when inhaled in sufficient quantity or when someone with pre-existing asthma or other breathing issues is exposed.  Thought, therefore, needs to be given to how we might prevent these risks through control of exposure and this requires some knowledge of the process itself.

In general, the higher the temperature the greater the generation of fume and the greater the potential for more noxious fume to be generated. In simple terms, you should try to ensure that the printer head is at a temperature which is hot enough for the work to be completed well but not over the temperature (this will vary with print speed and filament thickness).  If fume is generated the next risk relates to how exposure occurs, generally you do not need to be close to the print whilst it is in progress and so personal exposure can often be very limited, particularly over an extended print time.  A useful control is ventilation, both at the print point and within the room itself.  For most situations, a larger room with good ventilation as required under the Work Place Regulations will serve the purpose adequately.  For multiple machines operating frequently a more advanced Local Exhaust Ventilation system might be required.

Other safety considerations

In addition to the fume advice above also consider the following points of best practice;

  • Some print runs can take many hours, so the ability to pause the print or to split the print job into smaller components may be necessary.
  • In a school workshop, the power supplies to equipment should be controlled via a key-controlled electrical shut off. This switch should be lockable, accessible and checked regularly to establish that it is working at all times. This is an essential requirement for workshops, and other rooms, where machines are used; such as graphics rooms; rooms used for systems and control work and preparation rooms where machines are located.
  • A 3D printer and any associated LEV may need to be on the same circuit as PCs and other equipment that does not get switched off if the emergency stop button is activated.
  • The electrical supply to the machine will need to be fed via a conduit from a fused, labelled switch, which allows the machine to be isolated from the supply when maintenance or servicing is to be carried out. This should not be a standard stand-alone 13A plug which could be accidentally plugged in restoring power to the machine during maintenance.
  • Additional stop switches which provide ‘no voltage release ’capacity may need to be provided.
  • Third limb switches, such as foot stops, may need to be added.
  • Appropriate and effective guards should be provided, which could be interlocked to the machine start system.
  • Access to moving parts such as gearbox or belt covers should be secured so that a specialist tool must be used to open the cover(s).
  • Subject to a local risk assessment, the machine may require LEV to be installed e.g. an exposure control cabinet.
Posted by Roger Hart

HSE to visit any site carrying out welding activities in January to March period

Fabricated metal inspections

HSE will be inspecting sites that carry out metal fabrication in January to March 2020 to check compliance with the law.

The focus will be on control of exposure to welding fume and metalworking fluids.  All welding fumes (including mild steel) are now classed as carcinogens. Metalworking fluids can cause occupational asthma, occupational hypersensitivity pneumonitis and dermatitis.  There is revised guidance available so you can protect your workers from these serious health hazards. Please see the below links to obtain further information.

If you have questions please contact us or request a call back or use the chat button at the bottom right of the screen. See below for some useful guidance on expected controls.

Welding

Metalworking fluids

Posted by Roger Hart

£600,000 Fine for Property Developer over HAVS risk assessment

A property management and development organisation has been fined after five employees developed Hand Arm Vibration Syndrome (HAVS).  Between 2009 and 2014 five employees of Places for People Homes Limited used vibrating powered tools to carry out grounds’ maintenance tasks.  The company has been fined £600,000 and ordered to pay costs of £13,995.06 following an investigation by the Health and Safety Executive (HSE) which found the company failed to assess or manage the risks associated with vibrating tools through completing an adequate HAVS risk assessment. It also failed to provide suitable training or health surveillance for its maintenance workers and failed to maintain and replace tools which increased vibration levels.HAVS risk assessment

HAVS is preventable, but once the damage is done it is permanent. Damage from HAVS can include the inability to do fine work and cold can trigger painful finger blanching attacks. A suitable HAVS risk assessment must be completed by a competent person to satisfy your legal duty.

The potential of a risk related to vibration affects a wide range of industries, including construction, manufacturing, agriculture and horticulture – in fact anywhere that powered hand tools are used.

The law requires you to undertake a risk assessment of exposure and health surveillance is vital to detect and respond to early signs of damage.

Like other specialist areas of health and safety, it is likely that you will need to get help if this is an issue for you.  We’ll happily call you back or you can contact us on 01453 800100 to speak directly to a Chartered Safety Professional.  Alternatively use the online chat on the bottom right hand side of this page.

In order to undertake a thorough assessment of exposure, you will need information on both the vibration magnitude of the tools involved and the length of time the tools are in use.  Neither of these are easy to measure (or estimate with sufficient accuracy).

The HSE has recently published guidance on sources of vibration magnitude (see https://www.hse.gov.uk/vibration/hav/source-vibration-magnitude-app3.pdf), but this does not always provide the answers.  So, should you use manufacturers’ data?  Again, there is no simple answer.  What about exposure time? How do I measure this? It is tempting to invest in expensive and complicated technical solutions to address these issues, but these may not actually achieve what you are looking for.

This is a complex area and it is important to get it right to ensure the wellbeing of your staff and that you are compliant with the law.  Don’t wait until you have a problem – don’t forget that HAVS is incurable and permanent.  If you think that your workers are potentially at risk from vibration, act now and undertake an assessment of the risk and identify any additional measures that you need to take.

Posted by Roger Hart

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 you’re a client, linked to 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 17th October, Berwick Lodge Bristol BS10 7TD
08.00 arrival | 09.30 finish map


Thursday 6th November, Bowman House Swindon SN4 7DB
08.30 arrival | 10.00 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?

It’s 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 the process from TIG to MIG or MMA welding can also adversely affect fume generation

See how on gun extraction could help: Binzel on torch extraction, welding fume to the right is what our client found in its waste tray after around 2 months of use;

What can I do to reduce exposure to welding fume?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.

View the revised HSE Guidance on fume control here; http://www.hse.gov.uk/pubns/guidance/wl3.pdf

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