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Workplan 2016-17: Respirable Crystalline Silica in the manufacturing industries

Summary

This outlines the 2016/17 FOD proactive inspection programme to manufacturing industries using materials containing Respirable Crystalline Silica (RCS). The focus is on reducing serious ill health by ensuring the appropriate controls are in place.

Introduction

The purpose of the programme is to improve health outcomes by reducing the incidence of serious ill health from exposure to RCS.

RCS is found in stone, rocks, sands and clays.

Inhaling RCS can lead to serious health effects:

Silicosis is a serious and irreversible lung disease that causes permanent disablement and early death. It makes breathing more difficult and increases the risk of lung infections. It is made worse by smoking. Silicosis usually follows exposure to RCS over many years. Workers with silicosis are at an increased risk of tuberculosis, kidney disease and arthritis.

Acute silicosis is a rare complication of short-term exposure to very large amounts of silica. This condition is life-threatening and associated with very significant clinical consequences.

COPD is a group of lung diseases, including bronchitis and emphysema, resulting in severe breathlessness, prolonged coughing and chronic disability. It may be caused by breathing in any fine dusts, including RCS. It can be very disabling and lead to death. Cigarette smoking can make it worse (as with any lung disease).

Heavy and prolonged exposure to RCS can cause lung cancer.

RCS has a Workplace Exposure Limit (WEL) of 0.1 mg/m3 (respirable dust, averaged over 8 hours). It does not have a short term exposure limit (STEL).

Action

DIOs

Premises should be selected using the SIC codes and other targeting information in the Organisation section of this OG, with sufficient visits planned for Quarter 1 and carried out before the end of June.

When setting up the COIN case include keyword #healthcampaign1617 in the notes summary line.

FOD inspectors

The management of occupational health must be assessed in line with this OG when inspecting any premises within scope of the SIC codes targeted (see ‘Organisation’ section). When inspectors prioritise action in relation to Matters of Evident Concern (MEC) or Matters of Potential Major Concern (see OC18/12), further visits should be made to complete the actions below, as necessary. 

The SIC code recorded for the premises must be checked and, if necessary, amended to ensure the visit and findings are correctly analysed for sector insight and future targeting.

Inspectors should:

Obtain occupational hygiene specialist support if required, especially where exposure is not suitably controlled or if uncertain about the level of control required.

Send to Manufacturing Sector information on good or poor practices found.

When inspecting foundries and other cast metal sites risks from both RCS and other dusts and fumes must be assessed (see Workplan OG for asthmagens and carcinogens inspection information).

See further references section and appendices for guidance material.

Occupational hygiene inspectors

Provide support to FOD inspectors on assessment, monitoring and control issues.

Occupational health inspectors

Provide support to FOD inspectors on cases of ill-health and health surveillance issues.

Sector staff

Provide support to FOD inspectors on benchmarking, risk gap and industry standards. See end of each Appendix for contact details.

Background

The Control of Substances Hazardous to Health 2002 (COSHH) is the primary legislation used to assess and secure compliance.

EMM application to RCS

Guidance is available on the application of the EMM to health risks and hazardous substances including RCS to determine the risk gap and Initial Enforcement Expectation (IEE).

Inspectors should give priority to minimising the risk (i.e. control) over arrangements for managing the symptoms (i.e. health surveillance) and focus particularly on those tasks where inadequate controls can result in an extreme or substantial risk gap under the EMM.

Further details on the application of the EMM and indicative IEE are contained in Appendix 7.

Organisation

Targeting

Industry

Included SIC code

Molten metals

24100 Manufacture of Basic Iron and Steel and Ferro-Alloys
24410 Precious metals production
24420 Aluminium production
24430 Lead, zinc and tin production
24440 Copper production
24450 Other non-ferrous metal production
24510 Casting of Iron
24520 Casting of Steel
24530 Casting of light metals
24540 Casting of other non-ferrous metals

Stone working

23700 Cutting, shaping and finishing of stone

Brick and tile making

23300 Manufacture of clay building materials

Potteries and ceramics

23200 Manufacture of refractory products
23310 Manufacture of ceramic tiles and flags
23410 Manufacture of ceramic household and ornamental articles
23420 Manufacture of ceramic sanitary fixtures
23430 Manufacture of ceramic insulators and insulating fittings
23440 Manufacture of other technical ceramic products
23490 Manufacture of other ceramic products

Concrete products

23610 Manufacture of concrete products for construction purposes

The appendices for specific industry sectors contains guidance on the areas to target during inspection.

Timing

Majority of visits to be carried out in Q1.

Recording and Reporting

Inspections should be recorded in accordance with current work recording instructions (COIN/DOIT) and should include findings/comments about:

  1. Processes carried out and material involving RCS
  2. Are the control measures used, checked and maintained
  3. Specific control failings
  4. Any management failings such as training, instruction etc
  5. Any SG involvement
  6. Any Material Breach or Enforcement action taken

If comment on the matters cannot be provided, please give a brief explanation of the reasons why not.

Health and Safety

See Appendices for industry specific health and safety information.

Diversity

Be aware there might be workers employed whose first language is not English.

Further References

Presentations giving a refresher briefing on a number of industries have been prepared (see FISH page).

General references

See Appendices for references relevant to each industry.

Contacts

ESID Manufacturing, Transportation and Safety Unit (MTSU), Metals, Minerals and Engineering for all industries above.

Appendices

Updated 2016-07-15