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Workplan 2016-17: Inspection of Metal Recycling Sites (including End of Life Vehicles (ELVs))

Summary

This OG outlines the waste and recycling inspection initiative for 2016–17 targeting metal recycling sites, including those involved with the processing and recycling of end of life vehicles (ELV’s).

Introduction

Metal recycling sites (often previously referred to as scrapyards) recycle, process and/or stores waste metal. Sites usually obtain unwanted or unrepairable items (often referred to as “end of life”) such as vehicles, electronic equipment, appliances and general waste metal in order to remove valuable components for reuse or selling to other traders or the public. Operators utilise a range of processes and equipment to strip, cut or even burn waste in order to extract the key metals or components.  

 The processes actually performed at a metal recycling site are essentially controlled by an environmental permit system operated by the relevant environmental regulator (i.e. the Environment Agency (EA) in England, the Scottish Environment Protection Agency (SEPA) in Scotland and Natural Resources Wales (NRW) in Wales). This usually reflects the level of environmental risk associated with the work activity being performed, with sites being referred to as “permitted” or “non-permitted”. From a health and safety perspective this classification is immaterial, as all metal recycling sites will utilise a range of machinery and equipment to undertake whatever work activities and/or processes they are performing. HSE inspectors can therefore expect to encounter a wide range of both safety and health risks at any metal recycling site they may visit.

Certain sites will be authorised to process and recycle end of life vehicles (ELV). An ELV is any motor vehicle that has been designated as waste – usually due to its age and/or condition. The introduction of the End of Life Vehicle Regulations in 2003 has resulted in a significant change to the waste metal recycling industry as every ELV now has to be appropriately “de-polluted”. De-pollution involves the safe and controlled removal of harmful components and substances such as car batteries, engine oil and fuel. During 2016-17 Environment Agency (EA) officers in England are scheduled to undertake an inspection campaign targeting “ELV de-pollution”. HSE inspectors are encouraged to visit jointly with EA colleagues where practical.

Action

HSE Waste & Recycling Team

HSE’s Waste and Recycling Team will:

DIOs

DIOs should:

FOD Inspectors

Inspectors should:

Background

The focus of this initiative will be on metal (scrap) recycling sites including those who recycle ELVs - a traditionally a poorly performing sub-sector of the waste and recycling industry. This sub-sector of the industry only employs approximately 10-15% of the entire workforce but between 2001/02 and 2014/15 it accounted for around 25% of all injuries (50% of fatal injuries, and 35% of major injuries).

 There has not been a targeted or co-ordinated HSE inspection of the metal recycling sector since 2008. In this time the industry has changed significantly, with developments in technology, processes, and the impact of the ELV Regulations. The industry also has a high proportion of small to medium sized enterprises (SMEs).

HSE’s Waste and Recycling team have actively engaged with industry stakeholders including key trade associations such as British Metals Recycling Association (BMRA), Motor Vehicle Dismantlers’ Association (MVDA) and British Vehicle Salvage Federation (BVSF). These associations have expressed support for an inspection campaign and will publicise the initiative to their members. NB These trade associations only represent a small percentage of those employed in the industry; therefore inspectors are still likely to encounter sites that will be unaware of this inspection initiative.

Machinery

Inspectors could potentially discover a wide range of plant and machinery during an inspection of a metal recycling site, including:

Recycling of catalytic converters

During 2016-17 the EA are undertaking a targeted “de-pollution” inspection campaign, including the recycling of catalytic convertors. Catalytic converters contain precious metals that can be extracted by “de-canning” i.e. cutting open the catalytic converter and removing the content. However certain catalytic converters also contain refractory ceramic fibre (RCF) matting which should to be removed as part of the process. Currently EH40/2005 lists RCF as having a Workplace Exposure Limit (WEL) of 5mg.m-3 (1 fibre/millilitre). It is classified as a Category 1B carcinogen with properties very similar to asbestos. It should therefore be treated in exactly the same manner as asbestos and the key principles of the Control of Substances Hazardous to Health Regulations 2002 (COSHH) applied i.e. exposure to RCF should be reduced as low as reasonably practicable. Measures to control exposure to RCF should include:

It should be noted that not all catalytic converters contain RCF. Unfortunately there is currently no simple way for operators to determine whether a catalytic converter contains RCF until it is cut open. Operators should therefore treat all catalytic converters as containing RCF until they are able to identify that they do not.

 As part of their inspection campaign, the EA have produced an internal guide for their officers entitled “Catalytic Converters containing Refractory Ceramic Fibre (RCF)”, which they have agreed to make available to HSE Inspectors. A copy of this guide can be obtained from HSE’s Waste & Recycling team.Please note that this document is a closed internal EA document and therefore should not be made available to anyone outside of HSE (without the permission of the EA).

The EA has supplied HSE with details of those companies that are known to recycle catalytic converters. These are highlighted within the lists that have been issued to DIOs. However it is still possible that other sites may also perform this work. Where an inspector is made aware that a site is recycling catalytic converters containing RCF they should consider obtaining OH/SG advice prior to visiting site. Inspectors who encounter catalytic converter recycling should also notify HSE’s Waste and Recycling Sector team of the details of their visit via email (wasteandrecycling@hse.gov.uk).

Inspectors may also encounter RCF at sites recycling “empty” catalytic converter casings (those that have already been processed to remove their precious metals). These casings are normally recycled as general waste metal, but potential exists that some could still contain RCF if it is not been fully removed during the precious metal extraction process. Inspectors should also satisfy themselves that potential RCF exposure is being adequately controlled at sites undertaking this work.

Targeting

Following liaison with the EA, SEPA and NRW, HSE’s Waste and Recycling team have obtained databases of permitted sites. These have been analysed in order to identify those sites that undertake work activities that fall within the scope of this inspection initiative. These sites have been sorted into each FOD geographical region, and their details supplied to the relevant DIO’s. Many of these sites will be unknown to HSE. All sites contained within the listings were operational at the time of permit issue. Sites known to recycle catalytic converters will also be highlighted for information.

 NOTE: DIO’s (and operational colleagues) retain the discretion to contact a site should concerns be identified over the suitability of that site for inclusion in this inspection initiative e.g. if they believe the site to be a Head Office (with no work on site) or no longer trading from that address.

As previously mentioned, the EA in England are also scheduled to undertake an ELV “de-pollution” inspection campaign in 2016-17. This will target approximately 70 of their worst performing sites. The EA are keen to adopt a co-ordinated inspection approach with HSE for this work. HSE Inspectors are encouraged to make contact with their colleagues in the EA locally to explore the practicality of joint visiting.

Timing

There are no restrictions with regard to the timing of inspections. They may be undertaken at any time throughout the 2016/17 work-year.

Resources

FOD should aim to undertake 100 inspections of metal recycling sites per geographical region (300 visits in total).

Recording & Reporting

Inspections should be recorded in accordance with current work recording instructions. If necessary, refer to the DO-IT Inspection Tool Quick Guide’s for advice on how to create, and then record a DO-IT Inspection Case/Service Order. Please remember to include the keyword #SCRAP1617 in the inspection note summary field for any record that is created. This is essential in enabling HSE’s Waste and Recycling team to monitor progress and outcomes of this initiative.

 The record should also include findings/comments about:

  1. Processes carried out and equipment used
  2. Are appropriate 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

Inspectors who encounter catalytic converter recycling to should also inform HSE’s Waste and Recycling team with details of their visit via email (wasteandrecycling@hse.gov.uk).

Health & Safety

The inspection of a metal recycling site does not automatically necessitate the need for additional health and safety precautions e.g. two person inspections. However when planning any visit inspectors (and their line managers) should ensure they are familiar with the mandatory precautions which all visiting staff must consider when undertaking HSE business outside of HSE premises or their official office – details of which can be found on the intranet. Inspectors are particularly reminded of the need to wear appropriate standard safety footwear and either a high visibility tabard or jacket, and to check upon arrival at each site of any additional safety precautions that may be required e.g. eye protection, hearing protection and hard hat.

 It is the responsibility of each FOD operational team to ensure that an appropriate assessment is made of a site prior to any proposed inspection.

Diversity

Inspectors should be aware of the potential diversity needs of workers they may encounter at a metal recycling site. Consideration should be given to issues such as literacy and English as a second language. Further guidance can be found on the intranet.

Further References

Contacts

Vulnerable Workers, Agriculture and Waste and Recycling Sector; Waste and Recycling team.

Email: wasteandrecycling@hse.gov.uk

Updated 2017-02-10