SIM 03/2010/03
This SIM provides information on the planned workstream for 2010/11 on safety during maintenance activities in manufacturing premises. The FOD Planning Guidelines categorise this as core work in manufacturing. This topic should, where relevant, be used during proactive inspections to test the dutyholder's safety management arrangements, and may lead to enforcement action. The SIM suggests work activities which are specifically in scope and are high risk (plant and basic building maintenance activities in manufacturing premises), and explains that the same principles can also be applied to analogous work (eg certain types of cleaning operations) and to other employment sectors undertaking similar activities. The scope is not intended to extend to issues related to the need for/frequency of maintenance activities (eg the principles of planned preventative maintenance or condition-based maintenance). This work will contribute towards the Health and Safety Strategy goals of creating healthier, safer workplaces and building competence.
This workstream is being introduced now for two main reasons: a) there is a European 'safe maintenance' campaign running for the two years 2010/11 and 2011/12, and all the activity described in this SIM will contribute towards that initiative, and b) analysis of fatalities in the manufacturing industries over the past few years suggests that 25 to 30% of these are related to maintenance activities, so it is timely to direct dutyholders' attentions to these issues.
Related promotional activity will include: the creation of dedicated pages on the HSE website following the GB launch of the European campaign in the summer of 2010; provision of cascade materials to trade associations by Sectors, for onward transmission to member companies; contact with relevant professional bodies by Specialist Group portfolio holders, and complementary activities by various other GB social partner organisations such as the TUC, EEF, IOSH, RoSPA and the CBI
The activities described below are intended to be the core of FOD's contribution to the Safe Maintenance workstream in the manufacturing industries, but this should not constrain inspectors from applying the same principles to related activities (such as some types of cleaning or machinery interventions) and to other sectors of employment, where appropriate.
FOD Divisions may also wish to include 'safe maintenance' as a scenario in industry-based SHADs, promote these issues with local safety groups, or undertake other local initiatives. Promotional material from the European Agency for Safety and Health (EU-OSHA) will be available on the HSE website and also in limited quantities of hard copy that can be ordered from Prolog (see the 'European campaign resources' section later in this SIM). The 'Safe Interventions' proforma used until now for internal reporting purposes could also be used as self assessment handouts at SHADs and other events.
When undertaking proactive inspections in manufacturing premises, inspectors should include the safety of maintenance operations as an indicator of how well the dutyholder is managing safety overall. For the purposes of this planned workstream, the intention is to focus on the safety of the maintenance activities themselves, not the adequacy of the dutyholder's maintenance arrangements for keeping the plant safe for production purposes.
The scope of this workstream is plant and basic building maintenance. The latter is intended to include work that would normally be inspected by inspectors in manufacturing groups, not work that would normally be passed to inspectors in Construction Division. Whilst not wishing to be overly prescriptive, the following issues are recommended as being suitable: isolation, permits to work and entry into confined spaces; falls from height (including roofs); falls of heavy items, and asbestos/duty to manage issues related to the building's fabric. For companies employing contractors for maintenance work, selection of contractors may also be an issue.
Isolation, permits to work and confined spaces: These issues are considered jointly here, because of the degree of overlap. Isolation tends to refer to more individual machines or items of plant, and involves prevention of inadvertent powered movement by securely isolating the plant from power sources – usually the electricity supply, but can involve hydraulic and pneumatic power for instance, and may include the dissipation of stored energy. Security ("lock off") can be provided by padlocks on electrical isolator switches, for instance, and multi-user padlocks can be provided if more than a single maintenance worker is involved. Permits to work tend to refer to more extensive plant, more complex management systems, and entry into confined spaces. It might include delineating safe areas of work (eg by restricting overhead crane use), temporarily overriding fire protection systems and more actively managing a wider range of parameters. Permits to work may be used when external contractors are brought in to conduct maintenance work.
A number of references may be helpful for EMM benchmarks. These include: PD5304:2005 Guidance on safe use of machinery (Section 12 'Maintenance and safe working practices'); IND(G)98(rev3) on permits to work (but more related to HID industries) and the Confined Spaces Regulations and ACOP. Two appendices to the 'Safe Interventions' SIM used in previous years also provide a useful aide memoire for structuring inspection questions related to isolation and confined spaces inspections (although the Manufacturing Sector is no longer collecting returns on these proforma).
Falls from height: Falls can occur both when gaining access to places of work, and from the place of work itself (which may not have been designed for this purpose). Activities within scope will be gaining access to items of plant for maintenance purposes, and small scale building maintenance tasks that might be being done in-house, such as changing light bulbs, clearing gutters, cleaning roof lights, and painting.
Guidance on such issues and on the application of the EMM is already contained in the falls from height inspection topic pack. It may also be helpful to bring dutyholders' attention to the ongoing shattered lives campaign which includes resources and materials to help assess and manage falls from height risks, and the recently published WAIT tool which helps those not particularly familiar with the range of access equipment now available to select the most appropriate items. During September - December 2010 dutyholders can also be encouraged to exchange any unfit ladders as part of HSE's annual ladder exchange initiative.
Falls of heavy items: Analysis of fatalities in the manufacturing industries shows that deaths from such causes are more prevalent than is commonly appreciated. In the maintenance setting causes can include: the failure of lifting equipment; unsuitable lifting/slinging/moving practices; inadequate temporary support or securing for heavy items against gravity fall, supports not on level or firm ground, under-estimation of the weight of the item or over-estimation of an individual's capability to support an item.
It is not uncommon for heavy items to be moved, temporarily supported or inadvertently disturbed during maintenance activities. Inspectors should consider whether suitable risk assessments and systems of work are in place for maintenance activity where heavy items may be moved, temporarily supported or disturbed. Checks could include the suitability of the lifting plan, the competence of slingers to undertake such one-off activities, and the suitability, maintenance and inspection of lifting equipment. (NB For the purposes of this SIM the word "heavy" is intended to cover items with the potential to cause fatal or major injuries – usually by virtue of the combination of weight and momentum caused by gravity).
The issues covered under 'falls of heavy items' are too broad to covered by a limited number of EMM benchmark references. FOD Specialist Group Specialist Inspector advice should be sought on technical lifting issues, Services, Transportation and Safety Unit have the policy lead on PUWER/LOLER issues, and the Manufacturing Sector may be able to assist with access to incident analysis.
Asbestos/duty to manage: Besides creating the potential for falls from height, minor building maintenance tasks may well involve disturbing the building fabric and exposing the maintenance and other workers to asbestos fibres. The 'duty to manage' requirements are intended to cater for precisely such situations, and consideration of the dutyholder's building maintenance activities provides a suitable opportunity to test their arrangements in practice. Guidance on such issues is already contained in the asbestos inspection topic pack.
Selection of contractors: This is not a primary focus of the maintenance workstream, but it may well be raised during discussions with dutyholders. A suitable reference document to which dutyholders can be directed is 'Control of Contractors' - Use of contractors - a joint responsibility (a 19 page document which is clear, concise and contains topic headings with key messages).
This SIM makes reference to the main benchmark standards that should be used to advise dutyholders and inform enforcement decisions. A 'first principles' approach should be sufficient to deal with most of the situations which will be encountered.
The topics covered in this SIM are too broad to allow detailed IEE/EMM guidance to be contained within it, but other internal guidance such as the topic packs can be used for this purpose.
Additional support is available from Specialist Inspectors in the FOD Specialist Groups on detailed technical issues, from the Product Safety teams if safe maintenance problems arise from the machine's design, and from the relevant Sector inspectors on specific industry standards. The Specialist Group portfolio holders and/or Services, Transportation and Safety Unit will be best placed to deal with any deep seated problems related to generic maintenance equipment, working practices or guidance, but such issues should be routed through Specialist Group team leaders and via ELO for LAs taking part
Promotional activity and publicity related to HSE's enforcement actions will be publicised through the HSE website during the two year campaign period.
No specific reporting is required. Patterns of enforcement activity and any particularly relevant prosecutions will be picked up and publicised through COIN reports and press notices. However, particularly interesting or novel examples of fieldwork/enforcement activity should be sent to Geoff Cox (geoff.cox@hse.gsi.gov.uk) in the Manufacturing Sector by e.mail.
Limited quantities of hard copy resources can be ordered from Prolog by e.mailing Jane Benton (jane.benton@prolog.uk.com) with the order code, quantity and delivery address. Overall quantities likely to be available to HSE staff are indicated in brackets, so please bear this in mind when ordering:
Head of Manufacturing Sector, Sheffield VPN 514 2398 - on the overall FOD and Sector work described in this SIM, including receipt of reports on fieldwork and/or enforcement.
International Unit , Sanctuary Buildings, London VPN 529 3824 - on the European campaign and contributions from other GB social partners.
Manufacturing Sector, Leeds VPN 515 4310 - on fatality and enforcement statistics.
Services, Transportation and Safety Unit , Basingstoke VPN 502 4056; and
STSU, Bootle VPN 523 4778 - on the falls from height inspection topic pack.
C-CID, Bootle VPN 523 4330 - on Shattered Lives and the Ladder Exchange.
Manufacturing Sector, Birmingham VPN 510 6254 - on fatal accident data related to falls of heavy items in manufacturing, and the development of policy lines.
Services, Transportation and Safety Unit , Sheffield VPN 514 2363 - on the LOLER aspects of falls of heavy items.
C-CID, Bootle VPN 523 4560 - on asbestos/duty to manage issues.
