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Hygiene facilities on waste and recycling collection vehicles

Summary

This replaces the interim enforcement position outlined in SIM 03/2012/11 and provides up-to-date guidance about providing hygiene facilities on waste and recycling collection vehicles.

Introduction

Previous HSE guidance (agreed with the industry) indicated that hand wash basins should be provided on collection vehicles. The use of hand wipes and gels without additional hand wash facilities was accepted only where exposure to a minimal health risk could be demonstrated.

Rather than conventional hand washing facilities, reliance in waste and recycling activities has grown on protecting hands first by wearing suitable gloves, etc and then, after removal, cleaning hands with wipes and/or hand gels.

Hand wipes and/or hand gels are widely used in the healthcare sector. However their suitability in other industry sectors (such as agriculture, entertainments and waste and recycling) is less clear because the type, range and degree of contamination may be significantly different.

HSL reviewed the available data on the efficacy of conventional hand washing (with soap and running water) and alternatives (such as hand gels/rubs/wipes) in removing the contamination typical for a range of outdoor activities, workplaces and related environments (including waste and recycling).

HSL’s conclusions suggested a hierarchical approach should be applied when choosing what hygiene facilities to provide:

However, the research was unable to conclude that adequate control of exposure to secure legal compliance could not be achieved by adopting any or a mix of the various approaches outlined.

In light of these findings a revised enforcement position has been agreed as set out below. Other relevant guidance (eg Waste 04 and Waste 27) has been revised and updated to reflect the contents of this revised approach.

Appendix 1 outlines the relevant legal requirements and Appendix 2 summarises the research findings.

Action

Inspectors should:

Background

HSE commissioned HSL to undertake this research because of the uncertainty about relative suitability of the different approaches to hand cleansing. It was funded by HSE with a contribution from the waste and recycling industry.

HSL reviewed available data on the efficacy of currently available alternatives to soap and water for hand washing in removing contamination typical of that experienced in a range of outdoor activities, workplaces and related environments.

Organisation

No specific organisational requirements.

Further References

Approved code of practice and guidance L5: The Control of Substances Hazardous to Health Regulations 2002 (as amended) at:

Contacts

Agriculture, Waste and Recycling Sector, Waste Management and Recycling Team

Appendix 1: Relevant Legislation

Regulation 21 of the Workplace (Health, Safety and Welfare) Regulations 1992 requires the provision of adequate welfare facilities, including washing facilities in workplaces. However, this does not apply to waste and recycling collection vehicles because regulation 3 specifically excludes means of transport/vehicles.

The following legal provisions do apply:

Appendix 2: Summary of research main findings and conclusions

The research report summarises HSL’s findings in evidence-based statements about different methods of hand cleaning. These findings include:

The report concludes that the direct and indirect data which exist suggests the following hierarchy of choice of hand hygiene methods should be applied:

Footnote

1. Washing with specialist medicated soaps has repeatedly demonstrated ‘multi-log reductions’ in hand contaminants. ‘Multi-log reductions’ refers to the effectiveness of a disinfectant or a biocide,ie how much it reduces the number of live organisms (usually measured in tenfold or ‘log’ reductions). In health care, a benchmark for hand hygiene product efficacy is at reduction of least 4 log (104), ie a 99.99% kill (100 left from a million bacteria). A multi-log reduction usually refers to a highly effective product that is achieving at least a 99.99% kill.

Updated 2014-08-02