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Manufacturing Sector Workplan 2016-17: Occupational asthmagens and carcinogens in manufacturing industries

Summary

This outlines the 2016/17 FOD proactive inspection programme to manufacturing industries where workers can be exposed to materials containing asthmagens and/or carcinogens from use or generated during the production or processes.  The focus is on reducing serious ill health by ensuring the appropriate controls are in place.

Introduction

Ill health effects from exposure to respiratory sensitisers and/or carcinogens can be chronic and life-changing. Every year many workers develop occupational asthma or occupational cancer as a result of exposures to substances in their workplace.

The purpose of this inspection programme is to target sectors where carcinogens and/or asthmagens are regularly used, produced or process generated to ensure the risks are properly managed and to reduce the incidence of serious health effects from exposure.

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:

When setting up the COIN service order 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 food manufacturing premises for risks from flour dust and enzyme risks from musculoskeletal disorders should also be assessed. (see Workplan OG for MSD in food manufacturing premises inspection [web team to add link]).

When inspecting foundries and other cast metal sites risks from respirable crystalline silica (RCS) should also be assessed (see Workplan OG for RCS 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 health risks

Guidance is available on the application of the EMM to health risks and hazardous substances including where asthmagens and carcinogens are used, 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 common 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

Inspection focus

Included SIC codes

Food manufacturing

Asthmagens
- flour dust
- enzymes in improvers

10710 Manufacture of bread; manufacture of fresh pastry goods and cakes
10720 Manufacture of rusks and biscuits; manufacture of preserved pastry goods and cakes
52240 Retail Bakeries that are HSE-enforced
10610 – 11 Grain Milling

Woodworking

Asthmagens and carcinogens
- wood dust

16100 Sawmill, plane, impregnation wood
16210 Manufacture of veneer sheets, plywood, etc.
16220 Manufacture of assembled parquet floors
16230 Manufacture builders' carpentry & joinery
16240 Manufacture of wooden containers
16290 Manufacture of other products of wood
31010 Manufacture of office and shop furniture
31020 Manufacture of kitchen furniture
31090 Manufacture of other furniture

Fabricated Metal
(including shipbuilding, boatbuilding and repair)

Asthmagens and carcinogens
- welding fume
- metal working fluids

25110 Manufacture of metal structures and parts of structures
25210 Manufacture of central heating radiators and boilers
25290 Manufacture of other tanks, reservoirs and containers of metal
25300 Manufacture of steam generators, except central heating hot water boilers
25620 Machining
28150 Manufacture of bearings, gears, gearing and driving elements
25910 Manufacture of steel drums and similar containers
25920 Manufacture of light metal packaging
29320 Manufacture of other parts and accessories for motor vehicles
25990 Manufacture of other fabricated metal products
30110 Building of ships and floating structures
30120 Building of pleasure and sporting boats
33150 Repair and maintenance of ships and boats

Molten metals

Asthmagens and carcinogens
- dust
- fume
- chemicals

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

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

Timing

Resources

Inspect sites nationally in line with targeting.

Recording & 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 asthmagens and carcinogens
  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 sector specific health and safety information.

Diversity

Be aware there may 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 COSHH references

General asthmagen references

General carcinogen references

See Appendices for references relevant to each industry.

Contacts

ESID Manufacturing, Transportation and Safety Unit (MTSU), General Manufacturing for food and wood.

ESID Manufacturing, Transportation and Safety Unit (MTSU), Metals, Minerals and Engineering for molten metals, fabricated metals, welding, shipbuilding and boat building.

Appendices

Updated 2016-08-18