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

 

HEALTH & SAFETY NEWS UPDATE – 30TH JUNE 2016

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Pallet safety – fish processing firm fined after man killed by falling boxes

A Plymouth company has been fined £500,000 after an employee suffered fatal injuries when a stack of boxes of frozen fish fell on him.

The employee was helping to clear up a fallen stack of frozen fish boxes in one of the cold store areas when there was another fall of stock which struck him. He received multiple and severe injuries which proved fatal.

An investigation by the Health and Safety Executive into the incident, which occurred in 2013, found there was no safe system of work or instruction to staff on how pallets should be stored. There was no written procedure for dealing with falls of stock when they occurred.

HSE inspector Emma O’Hara said after the hearing: “Safe stacking of stock is a cross-industry necessity and can often be overlooked when considering safe systems of work. Duty holders need to ensure that they are stacking safely and that they have a plan for dealing with any unforeseen circumstances such as a fall of stock.”

Pallet safety

Introduction

This guidance covers general-purpose flat pallets, which can be manufactured from a variety of materials. Pallets are used widely throughout industry, and this practical advice is for two audiences:

  • those who have responsibilities for buying and using pallets as a base for assembling, storing, handling and transporting goods and loads;
  • those who have responsibilities for the design and manufacture of pallets.

It tells buyers what they should ask designers and manufacturers to consider when designing a pallet. It also recommends how both new and used pallets should be used and inspected.

Relevant legislation

The use of work equipment such as pallets is covered by the Provision and Use of Work Equipment Regulations 1998 (PUWER).  This includes a requirement for work equipment to be ‘constructed or adapted as to be suitable for the purpose for which it is used or provided’, as well as meeting maintenance and inspection requirements.

Your risk assessment, required by the Management of Health and Safety at Work Regulations 1999, should cover the hazards and risks from using and stacking pallets in the workplace. It should include not only the risks to employees but also any others at risk, for example members of the public or contractors visiting the workplace.

What is the legal definition of a pallet?

A pallet is defined in BS ISO 445 as follows:

‘a horizontal platform of minimum height compatible with handling by pallet trucks, and/or forklift trucks and other appropriate handling equipment, used as a base for assembling, storing, handling and transporting goods and loads in factories, warehouses etc’.

It may be constructed with, or fitted with, a superstructure.

The accident record

Pallets are heavy, so when accidents occur they tend to be serious. Falling pallets have caused a number of fatal accidents but the risks posed by falling pallets are often not fully appreciated. Most accidents could be prevented by developing and following safe working practices.

Accidents directly attributable to pallets are usually caused by:

  • poor design, construction or repair;
  • using inferior materials;
  • using a pallet which is unsuitable for a particular load, handling or storage method, eg pallets taken at random from a ‘mixed bag’ of used pallets for which the original specification is not known;
  • unsafe stacking resulting in falling stacks or pallets;
  • handling problems caused by mixing smaller Europallets (800 mm x 1200 mm) with larger UK pallets (1200 mm x 1000 mm) in racking systems. The smaller pallet may fall from the rack beams or be displaced by the larger pallet;
  • continuing to use a damaged pallet;
  • bad handling techniques;
  • pallets being used in an unsuitable environment.

Suitability

The majority of pallets are designed for moving a certain class or type of goods and are intended to be handled or stored in a particular way. For example:

  • a pallet designed for transporting cartons of cornflakes with a forklift truck and stored singly in racking is unlikely to be suitable for goods such as cans of paint lifted by a bar sling or multiple stacking;
  • a pallet designed specifically to carry evenly distributed loads, such as cartons of cornflakes or sheet paper, will not be strong enough to carry concentrated loads such as an electric motor of the same weight. The design parameters should ensure that a pallet is of adequate strength for the purpose intended, particularly if it is to be used with a variety of loads, handling and storage methods.

Pallet design considerations

Most manufacturers produce basic pallet designs suitable for general duties.

However, user requirements can differ widely and these basic designs may not satisfy some customers’ requirements. Good communications between the pallet manufacturer and user are essential to ensure the pallet construction is suitable for its intended use.

It is recommended that, where possible, the pallet design should satisfy the requirements of the appropriate British Standards (BS ISO 6780: 2003, BS EN ISO 8611-1:2012, BS EN ISO 8611-2:2012 and BS EN ISO 8611-3:2012).

The designer needs to know the following information to make sure the pallet is suitable for its intended use:

Pallet loads

  • The type of loads to be carried, for example if they are solid, liquid, powder, packed in drums, sacks, cartons etc
  • If the loads have any characteristics likely to damage the pallets, such as having corrosive properties
  • The weight of the loads and how they are distributed on the pallet, ie evenly over the whole surface or concentrated at one point
  • If there is a recommended way for the load to be placed on the pallet and the consequences if this is not followed
  • The requirements for the safe transportation of the loads, ie if the surface friction between the pallet and the load is adequate or if additional restraint will be required

Pallet environment 

  • Where the pallet will be used, for example in cold-store, outdoors, indoors, chemical works, or drying rooms
  • If the pallet will be used in an environment which has high or low temperatures or high humidity

Pallet movement

  • If the pallet is to be moved by pallet truck, forklift truck, cranes with fork attachments, bar slings, or automated stacking equipment – also if any conveyors are to be used
  • If two-way or four-way entry is needed
  • If the pallets will be lifted under their baseboards, eg as in storage and retrieval machines

Stacking loaded pallets – height and weight considerations

  • When pallets are stacked, think about the load on the bottom pallet and the capacity of the baseboards of each pallet when it comes to spreading the load. This should ensure that the payload does not distort over time, making the stack unstable. Such distortion is called ‘creep deflection’
  • This sort of distortion can take place with various payloads, such as the deflection of plastics, powder settling in bags and the weakening of cardboard boxes due to moisture

Pallet racking

  • The type of racking to be used, eg shelf, beam, or drive-in-racking and if pallet support bars are fitted
  • Drive-in racking places considerable stress on a pallet if it is stored with the longest dimension across the rack span. The shortest dimension should therefore be used
  • The dimension span between vertical beams of the drive-in-racking, as this must be compatible with the design of the pallet. Pallet support beams must be wide enough to support a pallet positioned off-centre and close to one side of the rack opening.

Pallet reuse

  • If the pallets are to be non-returnable/disposable or if they are intended to be reusable ‘durable’ equipment

Pallet transportation

  • The dimensions of the vehicles or containers that will carry the pallets

Pallet size

  • Where possible, pallet sizes should follow those recommended in BS ISO 6780: 2003

Pallet management planning

Problems can be caused by a user selecting a pallet at random from a pallet store on the premises, without thinking of what it is being used for. Here are some recommendations to help you promote both effective and safe usage in your pallet management plan.

Stability of the load

Pallets should be loaded to an established pattern designed to achieve maximum stability and safety within the rated load of the pallet. Loads should be applied gradually and, unless the pallet has been specifically designed for point loading, should as far as possible be uniformly distributed over the deck area.

Height of the load

As a general guide, the height of the load should not exceed the longest base dimension of the pallet. Shrink- or stretchwrapping the load usually provides greater security, minimising the possibility of movement of the goods being moved. With these techniques you can safely transport loads taller than the longest base dimension of the pallet. This will result in palletised loads that are around the internal height of closed vehicles or freight containers.

Plastic pallets

Plastic pallets have slippery surfaces and extra measures may be needed to secure the goods to them during transportation and to ensure that empty plastic pallet stacks are stable. Special attention is required when transporting plastic pallets by forklift truck as they are extremely slippery and potentially unstable on the forklift’s tines.

If palletised loads are to be stacked directly on top of each other, provide a firm base on the floor and on top of the preceding pallet load.

Deciding on a safe stacking height

When deciding on a safe stacking height, the pallet user should take into account:

  • information from the pallet manufacturer – this is particularly important for plastic pallets. All safe loading information should use the terminology defined in BS EN ISO 445;
  • the support characteristics of the pallets payload – get information from the payload supplier where necessary;
  • local conditions/stacking pattern.

Stacks should be checked periodically, as stability depends on the type and shape of the load and on prevailing humidity and temperature conditions.

Stack height depends on the height, strength and stability of the unit loads, and the ability of the operator to see clearly. Only build taller stacks after detailed consultation with the manufacturer or other competent authority, and the maximum height should be no more than six times the narrowest dimension of the bottom pallet. This is provided that:

  • you have carefully assessed the block stacking pattern and the compression characteristics of the payload;
  • the pallet itself is designed to meet the stacking height required.

For more information, including compression hazards, handling layout, and pallet use/maintenance/inspection, download the HSE guidance note free by clicking on the link: http://www.hse.gov.uk/pubns/pm15.pdf or visit the HSE Warehousing web page: http://www.hse.gov.uk/logistics/warehousing.htm. Alternatively, 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