Control of legionella (and other) bacteria in metal working fluids (MWFs)

Legionella bacteria are commonly found in water supplies at low concentrations and if conditions (eg temperature and nutrients) are right, these microorganisms will grow. Water mix metal working fluids (MWFs) are mostly water and their industrial use may produce aerosols. Inhaling an aerosol contaminated with Legionella bacteria can cause Legionnaires’ disease. HSE guidance L8 “Legionnaires’ disease. The control of legionella bacteria in water systems” recommends that the MWF storage and distribution system of lathe and machine tool coolant systems should be cleaned and disinfected every six months or more frequently if recommended by machine tool or fluid suppliers.

However, the Health and Safety Laboratory has carried out research, Survival of Legionella pneumophila in metalworking fluids, which shows there is a minimal risk of Legionella bacteria contaminating such a system, if the system is properly managed.

HSE’s guidance on managing bacterial contamination of metalworking fluids suggests a risk-based approach, based on monitoring fluid condition and bacterial contamination:

If you can demonstrate that metalworking fluids are managed in accordance with the COSHH essentials sheet Managing sumps and bacterial contamination ( and HSE’s guidance on managing bacterial contamination in metalworking fluids an additional assessment of the risk of Legionnaires’ disease is normally unnecessary. However, further assessment and precautions will be necessary to cover any special circumstances, such as deep cleaning of sumps and machinery with jet washers, where the potential for exposure to airborne hazardous bacteria is much greater. This is due to the disturbance of microbial slime known as biofilm – where Legionella may survive. Avoid water jetting where possible, as it tends to create fine water droplets or mists.

If water jetting is necessary carry out a risk assessment, to include respiratory and other risks such as those arising from the use of high pressure and electricity, see,

More guidance on metalworking fluids can be found on the HSE web page:

For more information on controlling the risk of Legionnaires’ disease, see Legionella and Legionnaires’ disease:, or contact us on 07896 016380 or at, ad we’ll be happy to help

Contains public sector information licensed under the Open Government Licence v3.0.


Safety in the storage and handling of steel and other metal stock (revised guidance)

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Safety in the storage and handling of steel and other metal stock (revised guidance) – metal company fined after worker loses foot

A Bedfordshire metal company has been fined for safety breaches after a worker suffered severe leg injuries and lost most of his foot.

Luton Magistrates’ Court heard how the 24 year-old, who was an agency worker for the company, was injured when a trolley carrying metal stock fell on his legs causing severe injuries.

A bundle of 18 stainless steel bars weighing about 900kg was on a four wheeled trolley. The trolley was manually moved by the worker and another staff member but it tipped over and the bundle of bars fell off the top of the trolley trapping his leg and foot. He was rushed to hospital by the emergency services.

His right leg was broken and his right foot was badly crushed. Despite a number of operations to save his foot, most of it was amputated and he now has a prosthetic foot. It was many months before he was able to return to work. He is currently only able to work on a part-time basis.

HSE found that the metal trolleys had been used on site for some 20 years without incident. The metal company purchased the trolleys to be used as ‘workstations’, but employees had chosen to also use them to move metal stock around the site. There was no risk assessment or written system of work for these trolleys at the time of the accident. The trolley also had faulty wheels and there was no record of any maintenance.  After the accident, the trolley was given a safe working load of 500kg; half the weight placed on the trolley at the time of the accident.

The metal company pleaded guilty to Section 3(1) of the Health and Safety at Work etc Act 1974 and was fined £130,000 with costs of £2,456.40 and a victim surcharge of £120.

Speaking after the hearing, HSE Inspector Emma Page said: “[The worker’s] life has been drastically altered by what happened and this incident could have been very easily avoided with some very simple measures. The right equipment and a correct maintenance system would have prevented this from happening.”

Safety in the storage and handling of steel and other metal stock

Many accidents, some resulting in death and serious injury, continue to occur during the storage and handling of steel and other metal stock. They cause enormous social and economic cost over and above the human tragedy involved. It is in everyone’s interest that they are reduced. Accident investigations often show that these injuries could have been avoided.

This revised guidance ( is aimed at directors, owners, managers and supervisors and pays particular attention to the most common hazards, including (un)loading of delivery vehicles, storage systems, workplace transport, mechanical lifting and injuries from sharp edges.

New sections compare the use of single- versus double-hoist cranes and give additional information on the safe use of pendant and remote controllers, suitable lifting accessories, working at height and providing better access arrangements with stock products. There are now specific requirements which effectively prohibit the stacking of ‘U’ frame racking and ‘barring-off’.

This revised guidance was produced in consultation with the National Association of Steel Services Centres (also known as NASS) and the City of Wolverhampton Council working as partners with HSE in the Steel Stockholders Lead Authority Partnership (SSLAP).

For more information, visit the HSE web page or contact us on 07896 016380 or at, 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



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 ( 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

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


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.


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: or visit the HSE Warehousing web page: Alternatively, contact us on 07896 016380 or at, 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