HSE SAFETY ALERT: CHANGE IN ENFORCEMENT EXPECTATIONS FOR MILD STEEL WELDING FUME

The Health & Safety Executive have issued the following safety alert last month (February 2019), aimed at all workers, employers, self-employed, contractors’ and any others who undertake welding activities, including mild steel, in any industry:

KEY ISSUES

  • There is new scientific evidence that exposure to all welding fume, including mild steel welding fume, can cause lung cancer.
  • There is also limited evidence linked to kidney cancer.
  • There is a change in HSE enforcement expectations in relation to the control of exposure of welding fume, including that from mild steel welding.
  • All businesses undertaking welding activities should ensure effective engineering controls are provided and correctly used to control fume arising from those welding activities.
  • Where engineering controls are not adequate to control all fume exposure, adequate and suitable respiratory protective equipment (RPE) is also required to control risk from the residual fume.

INTRODUCTION

There is new scientific evidence from the International Agency for Research on Cancer that exposure to mild steel welding fume can cause lung cancer and possibly kidney cancer in humans. The Workplace Health Expert Committee has endorsed the reclassification of mild steel welding fume as a human carcinogen.

CONSEQUENCES

With immediate effect, there is a strengthening of HSE’s enforcement expectation for all welding fume, including mild steel welding; because general ventilation does not achieve the necessary control.

OUTCOME

Control of the cancer risk will require suitable engineering controls for all welding activities indoors e.g. Local Exhaust Ventilation (LEV). Extraction will also control exposure to manganese, which is present in mild steel welding fume, which can cause neurological effects similar to Parkinson’s disease.

Where LEV alone does not adequately control exposure, it should be supplemented by adequate and suitable respiratory protective equipment (RPE) to protect against the residual fume.

Appropriate RPE should be provided for welding outdoors. You should ensure welders are suitably instructed and trained in the use of these controls.

Regardless of duration, HSE will no longer accept any welding undertaken without any suitable exposure control measures in place, as there is no known level of safe exposure.

Risk assessments should reflect the change in the expected control measures.

ACTION REQUIRED

  • Make sure exposure to any welding fume released is adequately controlled using engineering controls (typically LEV).
  • Make sure suitable controls are provided for all welding activities, irrelevant of duration. This includes welding outdoors.
  • Where engineering controls alone cannot control exposure, then adequate and suitable RPE should be provided to control risk from any residual fume.
  • Make sure all engineering controls are correctly used, suitably maintained and are subject to thorough examination and test where required.
  • Make sure any RPE is subject to an RPE programme. An RPE programme encapsulates all the elements of RPE use you need to ensure that your RPE is effective in protecting the wearer.

RELEVANT LEGAL DOCUMENTS

  • Health and Safety at Work etc. Act 1974
  • Control of Substances Hazardous to Health Regulations 2002

REFERENCES

WELDING FUME – REDUCING THE RISK

The above HSE guidance can be viewed by clicking on the link: http://www.hse.gov.uk/welding/fume-welding.htm or contact us on 07896 016380 or at fiona@eljay.co.uk, and we’ll be happy to help

Contains public sector information published by the Health and Safety Executive and licensed under the Open Government Licence

 

Cancer and construction: Diesel engine exhaust emissions

We hope you find our news updates useful. If you know of anyone who may benefit from reading them, please encourage them to register at the bottom-left of our news page (http://www.eljay.co.uk/news/) and we’ll email them a link each time an update is published. If in the unlikely event any difficulties are experienced whilst registering we’ll be more than happy to help and can be contacted on 07896 016380 or at Fiona@eljay.co.uk

The subject of air pollution has been very much in the headlines recently, particularly in London, where it was described in January as being worse than that in Beijing. And the London Atmospheric Emissions Inventory (LAEI) shows that the construction industry’s contribution to this is disproportionate compared to that of the usual road transport related suspects, with site-based plant and machinery being mostly to blame. This is due to the fact that emissions from these “non-road mobile machines” or NRMMs, are regulated under a different and (until now) more relaxed system to road transport. Even whilst complying with recent regulatory standards, emissions from a modern excavator, for example, are still apparently 15 times greater than those from a modern double decker bus. And whilst attempts are being made by London mayor Sadiq Khan to address these issues and their effects on the health of Londoners, the health of construction workers themselves is also thrown into doubt by the absence of legal diesel fume exposure limits.

According to the HSE, as of 2005, cancers relating to exposure to diesel exhaust emissions accounted for 6.5% of construction-related cancer deaths – that’s an estimated 230 construction workers each year. At the very least, short-term exposure to diesel engine exhaust emissions or DEEEs, can cause eye or respiratory irritation. And longer periods of exposure, in particular to any blue or black smoke, can lead to coughing, chestiness and breathlessness.

The law requires that a suitable and sufficient assessment of the risks to health which arise from exposure to hazardous substances is made, eg DEEEs. This is covered by the Health and Safety at Work etc Act 1974 and several other regulations, in particular the Control of Substances Hazardous to Health Regulations 2002 (as amended) (COSHH) and the Management of Health and Safety at Work Regulations 1999. Having completed the assessment, there is a further duty to take the necessary steps to prevent or adequately control exposure to the hazard, and to use and maintain the relevant controls.

The HSE provides the following guidance on managing the risks to construction workers from DEEEs.

Cancer and construction: Diesel engine exhaust emissions

What is it?

Exhaust emissions from diesel engines are made up of a complex mixture of gases, vapours, liquid aerosols and soot particles. It contains many known carcinogenic substances such as Polycyclic Aromatic Hydrocarbons (known as PAHs). These PAHs are adsorbed onto the soot which makes them easy to inhale.

The quantity and make-up of DEEEs depends mainly on the engine type and setting, how it is maintained, fuel quality, the demands placed on the engine and temperature that it is working at. Three different types of visible smoke may be produced:

  • blue smoke (mainly oil and unburnt fuel) which indicates a poorly serviced / tuned engine
  • black smoke (soot, oil and unburnt fuel) which indicates a mechanical fault with the engine
  • white smoke (water droplets and unburnt fuel) which is produced when the engine is started from cold and disappears when the engine warms up

What is the risk to construction workers?

The major source of DEEEs on a construction site is likely to be from generators and heavy vehicles like lorries, excavators or telehandlers. The more significant risks are linked to longer periods of work with this equipment in enclosed spaces and / or situations where there is blue or black smoke.

Breathing DEEEs can cause a number of ill-health effects. Short-term exposure may cause eye or respiratory irritation. This should stop when you are in fresh air. Longer periods of exposure, in particular to any blue or black smoke, can lead to coughing, chestiness and breathlessness.

There is also evidence that repeated exposure to DEEEs over many years can increase the risk of lung cancer. HSE commissioned research highlighted it as a significant risk to construction workers from DEEEs, estimating that over 200 died prematurely in 2005. It is important to note that this estimate is based on past exposures up to 50 years ago. Engine and fuel technology has changed significantly since then. However, risks remain that you need to control.

Can you prevent this risk?

Yes. There are a number of steps you can take: http://www.hse.gov.uk/pubns/books/hsg187.htm (click on the link to download a free copy of HSE publication “Control of diesel engine exhaust emissions in the workplace”)

For more information, visit the HSE web page http://www.hse.gov.uk/construction/healthrisks/cancer-and-construction/diesel-engine-exhaust.htm or contact us on 07896 016380 or at fiona@eljay.co.uk, and we’ll be happy to help.

Contains public sector information published by the Health and Safety Executive and licensed under the Open Government Licence

 

 

HEALTH & SAFETY NEWS UPDATE – 3RD MARCH 2016

REGISTER BELOW-LEFT TO RECEIVE OUR UPDATES BY EMAIL

IN THIS UPDATE

Introduction

Fairgrounds and amusement parks – HSE to prosecute Alton Towers’ owners after ‘Smiler’ incident

Temporary demountable structures – firm fined after circus tent collapse

Control of Substances Hazardous to Health (COSHH) – insulation company fined for health and safety failings

Introduction

The Health and Safety Executive has again been in the news over the last week, after informing Merlin Operations Ltd that it will be prosecuted over an incident in which five people were seriously injured on a rollercoaster ride at Alton Towers in Staffordshire. Two female passengers on the ‘Smiler’ ride suffered leg amputations and three others were also seriously injured when their carriage collided with a stationary carriage on the same track. The incident happened on 2 June 2015. We open this week’s update with HSE guidance on safe practice for fairgrounds and amusement parks.

Staying with the leisure industry, we also share HSE guidance this week on ‘temporary demountable structures’, following news of a marquee and tent supplier being fined after guy ropes securing a circus tent snapped causing it to collapse injuring three adults and five children at Burley Park, New Forest.

And finally, we close with HSE guidance on the Control of Substances Hazardous to Health (COSHH), following news of a Welsh insulation company that produced natural insulation products being fined £30,000 plus £59,000 costs for health and safety failings.

We hope you find our news updates useful. If you know of anyone who may benefit from reading them, please encourage them to register at the bottom-left of our news page (http://www.eljay.co.uk/news/) and we’ll email them a link each time an update is published. If in the unlikely event any difficulties are experienced whilst registering we’ll be more than happy to help and can be contacted on 07896 016380 or at Fiona@eljay.co.uk

Fairgrounds and amusement parks – HSE to prosecute Alton Towers’ owners after ‘Smiler’ incident

HSE media statement – 25th February 2016

The Health and Safety Executive (HSE) has today informed Merlin Attractions Operations Ltd that it will be prosecuted over an incident in which five people were seriously injured on a rollercoaster ride at Alton Towers in Staffordshire.

Two female passengers on the ‘Smiler’ ride suffered leg amputations and three others were also seriously injured when their carriage collided with a stationary carriage on the same track. The incident happened on 2 June 2015.

Merlin Attractions Operation Ltd based in Poole, Dorset, will appear at North Staffordshire Justice Centre, Newcastle-under-Lyme on 22 April 2016 to face a charge under the Health and Safety at Work Act etc, 1974.

Neil Craig, head of operations for HSE in the Midlands said:

“We have today informed Merlin Attractions Operations Ltd that it will be prosecuted for breaching health and safety law.

“This was a serious incident with life-changing consequences for five people.

“We have conducted a very thorough investigation and consider that there is sufficient evidence and that it is in the public interest to bring a prosecution.”

Merlin Attractions Operations Ltd is the company responsible for Alton Towers and under health and safety law is responsible for managing the risks created by the operation of the theme park’s rides.

Guidance on safe practice

Free to download by clicking on the following link: http://www.hse.gov.uk/pubns/books/hsg175.htm – revised guidance on what the Fairgrounds and Amusement Parks Joint Advisory Committee on Fairgrounds and Amusement Parks (FJAC) considers appropriate safe measures for the industry to adopt in order to comply with the law.

Although fairgrounds and amusement parks are relatively safe compared to activities such as driving a car or riding a bicycle, as we are all too aware, there have been a small number of serious incidents involving employees and members of the public. The Health and Safety Executive has worked with the members of the Fairgrounds and Amusement Parks Joint Advisory Committee to improve standards and to produce this revised guide.

Acknowledging the inherent nature of fairgrounds and describing how risks can be managed effectively, it also promotes a sensible, over-arching approach recognising that while users expect high safety levels from risks beyond their control, incidental elements, eg a dodgem bump, are considered ‘part of the fun’.

The guide, however, concentrates on the safety of employers and employees, as well as the public, and begins with the industry-specific ‘system for safety of attractions’ presented in easy table-form, which then steers the reader smoothly through the publication.

For more information, contact us on 07896 016380 or at Fiona@eljay.co.uk, and we’ll be happy to help.

Temporary demountable structures – firm fined after circus tent collapse

The owner of a company who supplies marquees and tents has been fined after guy ropes securing a circus tent snapped causing it to collapse injuring three adults and five children at Burley Park, New Forest.

Southampton Magistrates’ Court heard that on 10 August 2014 a sudden gust of wind went through the circus tent and eighteen of the guy ropes which secured the tent failed and snapped.

An investigation by the Health and Safety Executive (HSE) into the incident found that Happy Promotions Limited had in December 2013 taken their tent for inspection and repair to the marquee and tent supplier, who was asked to replace the guy ropes.

However, the court heard the guy ropes supplied were in fact made up of unrated webbing and had no safe working load. This led to the incident at Burley Park 8 months later.

HSE inspector Andrew Johnson said after the hearing: “The fact the guy ropes snapped (rather than the pegs being pulled from the ground) is a clear indication that the fault lies with the strength of the guy ropes, rather than the method of erection. Fortunately, the tent was empty at the time of the incident. Had a performance been underway there would have been performers and around 30 people were due to attend the afternoon performance. Were the tent occupied the collapse would likely have resulted in multiple serious injuries.”

Temporary demountable structures (TDS) – Stages, seating, marquees etc

Your duties as an event organiser

You are responsible for ensuring that as far as reasonably practicable, employees and others at a venue who could be affected by the construction and use of a TDS (such as scaffolders, riggers and members of the public) are not exposed to risks to their health and are kept safe from harm.

What you should know

Most fatal and serious injuries arise when workers fall during construction work or as a result of the collapse of the structure, lifting operations or mobile plant.

Checklist – TDS dos and don’ts

Do

Planning

  • Consider what the structure will be used for, what it needs to be able to do, who will use it and how?
  • Prepare a clear specification for the structure’s required use. This should include the technical details required to enable a design to be undertaken by your appointed TDS contractor(s) / designer (s).
  • TDS contractors / designers hired to design, supply, build, manage and take down a structure for you, should be competent and adequately resourced.
  • Provide TDS contractors / designers with relevant site information and/or allow them site access to carry out their own site assessments.
  • Your TDS contractor should ensure that the proposed structure has a design prepared by a competent person, which takes account of the use and conditions in which it is to be installed.
  • Where a structure is to carry advertising / scrim, include this requirement in any design concept, specification and structural assessment.
  • Novel or unusual structures may require additional testing by a TDS designer to demonstrate the integrity of the design.
  • Whoever builds the structure should undertake an assessment of the likely construction hazards and risks. To help with an assessment and to find out more about construction hazards and risks see:
  • Falls from height
  • Construction safety topics (including lifting operations and vehicle safety)
  • Health risks in construction
  • Plan and work with your contractors to develop safe systems of working and make sure all significant risks on the site are properly controlled, eg use of cranes and lift trucks.
  • Plan to minimise confusion and conflict, particularly between those contractors carrying out concurrent or consecutive activities on the same structure.
  • Consider the extent of control that you and your contractors have over the work activity and workplace during each phase of the build, use and deconstruction cycle of a structure. Organisers and TDS contractors should agree the extent of their control at the planning stage, so that responsibility for structural safety is understood and maintained throughout the event.

Building and dismantling the TDS

  • The assessments done under Planning (above) should serve as a guide on how to build and dismantle the structure safely.
  • Make sure there is sufficient time and resources available to build and dismantle the structure safely.
  • Use competent staff and have a suitable onsite operational management system in place to supervise and monitor safety compliance.
  • A programme of works, including key safety checkpoints, can be helpful to communicate critical erection / dismantling stages to the site manager / crew bosses and operatives.
  • Build the structure to the agreed design in accordance with a safe system of work.
  • Arrange for the structure to be checked to make sure that it has been built according to the design.

While TDS is in use

  • Have arrangements in place to inspect the structure for deterioration during the time it is installed in line with a documented management plan and, if needed, arrange for remedial works.
  • Any change in the proposed use of the structure or site conditions which may affect the structure’s suitability should trigger a design check for the new conditions. An example of this may be the requirement to add additional banners to a structure such as a PA tower. The organiser is responsible for ensuring this is done.
  • Have arrangements in place to ensure that any measures required to keep the structure safe during use are implemented. For example, if the structure is susceptible to the weather, monitor and measure the local weather conditions. In adverse weather conditions, know what to do with the structure to protect its stability, eg when to open wind relief panels and when to evacuate.

Don’t

  • Take forward incomplete design concepts, as this could result in last-minute modifications, leading to safety problems.
  • Build a structure on unstable ground.
  • Put advertising / scrim on a structure if a competent person has not approved it as being safe – it can affect wind loading and increase the risk of collapse / overturn.
  • Use flammable fabrics.

For more information, visit the HSE web page http://www.hse.gov.uk/event-safety/temporary-demountable-structures.htm, or contact us on 07896 016380 or at Fiona@eljay.co.uk, and we’ll be happy to help.

Control of Substances Hazardous to Health (COSHH) – insulation company fined for health and safety failings

A Welsh insulation company that produced natural insulation products have been fined £30,000 plus £59,000 costs for health and safety failings.

Wrexham Magistrates’ Court heard that the company failed to conduct an adequate risk assessment for the processing of hemp. They also failed to adequately guard machinery.

An investigation by the Health and Safety Executive (HSE) into the concerns raised anonymously found that the COSHH assessment was not suitable and sufficient.

Control of Substances Hazardous to Health (COSHH)

What is a ‘substance hazardous to health’?

COSHH covers substances that are hazardous to health. Substances can take many forms and include:

  • chemicals
  • products containing chemicals
  • fumes
  • dusts
  • vapours
  • mists
  • nanotechnology
  • gases and asphyxiating gases and
  • biological agents (germs). If the packaging has any of the hazard symbols then it is classed as a hazardous substance.
  • germs that cause diseases such as leptospirosis or legionnaires disease and germs used in laboratories.

COSHH does not cover

  • lead,
  • asbestos or
  • radioactive substances

because these have their own specific regulations.

What you need to do

Before you start your COSHH assessment, you need to:

Think about

  • What do you do that involves hazardous substances?
  • How can these cause harm?
  • How can you reduce the risk of harm occurring?

Always try to prevent exposure at source. For example:

  • Can you avoid using a hazardous substance or use a safer process – preventing exposure, eg using water-based rather than solvent-based products, applying by brush rather than spraying?
  • Can you substitute it for something safer – eg swap an irritant cleaning product for something milder, or using a vacuum cleaner rather than a brush?
  • Can you use a safer form, eg can you use a solid rather than liquid to avoid splashes or a waxy solid instead of a dry powder to avoid dust?

Check your trade press and talk to employees. At trade meetings, ask others in your industry for ideas.

If you can’t prevent exposure, you need to control it adequately by applying the principles of good control practice (http://www.hse.gov.uk/coshh/detail/goodpractice.htm)

Control is adequate when the risk of harm is ‘as low as is reasonably practicable’.

This means:

  • All control measures are in good working order.
  • Exposures are below the Workplace Exposure Limit, where one exists.
  • Exposure to substances that cause cancer, asthma or genetic damage is reduced to as low a level as possible.

COSHH Essentials

COSHH Essentials sets out basic advice on what to do to control exposure to hazardous substances in the workplace. It takes the form of straightforward advice in ‘factsheets’ called ‘control guidance sheets’. There are two types of sheets, industry-specific ‘direct advice sheets’ and ‘generic control guidance sheets’.

Direct advice sheets (click on the link: http://www.hse.gov.uk/coshh/essentials/direct-advice/index.htm)

First check the direct advice sheets listed by industry to see if there are any direct advice sheets for tasks or processes in your industry. If your industry is not listed don’t worry, you can use our e-tool to identify which generic control guidance sheets are appropriate.

COSHH e-tool (click on the link: http://www.hse.gov.uk/coshh/essentials/coshh-tool.htm)

When using the tool you will be prompted by questions to enter some basic information about the substance you are using, before being directed to the most appropriate generic control guidance sheet for you.

Frequently asked questions (click on the link: http://www.hse.gov.uk/coshh/essentials/faq.htm)

  • Why does COSHH essentials not list all of the R phrases/H statements that are on my Safety Data Sheet (SDS)
  • I can’t find my safety data sheet. What should I do?
  • I have just completed COSHH essentials, is this sufficient to use as my COSHH assessment?
  • Some of the information I need is missing from my safety data sheet. What should I do?
  • There isn’t a boiling point in the safety data sheet?
  • Why can’t I mix a liquid with a solid?

For more information, visit the HSE web page http://www.hse.gov.uk/coshh/, or contact us on 07896 016380 or at Fiona@eljay.co.uk

Contains public sector information published by the Health and Safety Executive and licensed under the Open Government Licence