Author Unit/Section:

Manufacturing Sector

Target Audience:

FOD Inspectors

Background

1 The aim is to achieve a major reduction in risk of serious or fatal injuries to people involved in clearing blockages or performing running repairs inside dangerous machines due to unexpected start-up and in confined space work. This will be achieved by:

• raising awareness about the risks and standards required for safe isolation and lock off and safe entry to confined spaces;
• ensuring, through formal enforcement, that robust isolation and lock off procedures for machinery and robust safe systems of work forentry to confined spaces are implemented; and
• ensuring that employers have, or put in place, sound risk control systems for managing these procedures.

Action required

2 Questionnaires with guidance notes have been produced for use during machinery and confined space inspections. These can be found at Appendix 1: "Safe Interventions – Enforcement Initiative Machinery Safety " and Appendix 2: "Safe Interventions – Enforcement Initiative Entry Into Confined Spaces " . Completed questionnaires should be sent to the national project manager as outlined in para 8. Examples of issues to consider include:

• Is the hardware right?
• Are the procedures right?
• Does the employer have an adequate risk control system for managing those procedures and maintaining the hardware?

3 It isn’t necessary to witness directly the isolation and lock-off procedures for a particular machine or entry into a confined space (this will often not be practical) evidence around this can be obtained from documentation and through discussions with management and, importantly, the employees or contractors who carry out the interventions.

4 This is an enforcement initiative and where standards are found to be below minimum legal requirements, inspectors are expected to take formal enforcement action.

5 Where conditions found at the first inspection fall short of minimum legal requirements in any significant respect a return visit should be made after an appropriate period to check that the required improvements have been implemented. A further questionnaire should be completed in respect of the follow up visit. In this way the national project team will be able to measure the improvement in standards achieved by the initiative. In most cases the follow up inspection is likely to be the visit at which an Improvement Notice or Prohibition Notice served at the first visit is subsequently checked/discharged. In the case of a prosecution the return visit will be after the court case has been heard. Return visits are not required where standards encountered at the first visit are at or above minimum legal requirements.

Targeting

6 The project has run successfully within FOD for the last 5 years. As in 2008/09 inspectors are requested to undertake a safe interventions visit and complete the relevant machinery or confined space questionnaire at any manufacturing site where the issues are particularly relevant. This includes at RIDDOR investigations where an unsafe intervention was a causative factor. In the period that this project has been running inspectors have found that safe intervention issues are particularly relevant in the following manufacturing industries.  However this should not inhibit inspectors from paying visits to other industries for the purposes of this initiative.

• Quarries
• Waste recycling
• Concrete and building products
• Food

Start and completion dates

7 Safe interventions inspections should be carried out between April 2009 and the end of March 2010.

Reporting procedures

8 Completed questionnaires should be returned to the national project manager, Graham King at HSE, Edgar Allen House, 241 Glossop Road, Sheffield S10 2GW (graham.king@hse.gsi.gov.uk) Telephone 0114 291 2353 (VPN 514 2353).

9 At each visit counting towards the Safe Interventions project a questionnaire should be completed along with an IRF1 for the inspection where relevant (FOD work recording instructions require that an IRF1 is completed at all inspections, with only very limited exceptions). Time spent on the project at a visit will not itself be recorded as category time in COIN.

Diversity

10 Inspectors should be aware of who (in terms of diversity e.g. men, women, disabled etc) is the target group in the sector they are dealing with. Give consideration to, and factor into the approach, any issues that may surround this audience such as literacy issues, English as a second language and disability (access needs).

The Diversity pages give more information on these areas.

Publicity

11 Manufacturing Sector will organise publicity for this project via the manufacturing industry trade press.

Cancellation of instructions

12 SIM 3/2006/05 and SIM 03/2008/01