Health and Safety Executive

Inspection in the waste/recycling industry 2010/11: Workplace transport risks in skip-hire activities

SIM No. 03/2010/05

Open Government Status
Fully Open
Author Unit/Section
OPSTD - Manufacturing Sector - Waste Management and Recycling
Target Audience
HSE Inspectors covering Manufacturing and Services industries.
Contact
Wayne Williams, Cardiff Office, VPN: 511 3116

Summary

This Sector Information Minute (SIM) alerts inspectors to a planned inspection campaign within the waste and recycling industry during 20010/11. Inspections should be targeted at skip-hire operations and associated recycling activities, particularly those where hand sorting of recyclables (‘totting’) takes place, and has specific emphasis on management of workplace transport risks. This initiative follows on from a wider initiative in this target area in 2009/10 (SIM 03/2009/03). Feedback from that initiative indicated that poor standards in site layout and traffic management were one of the most significant hazards identified.

Purpose

The purpose of the initiative is to build on the work undertaken in 2009/10 and deliver a program of FOD inspections in 2010/11 to cover the issues specific to management of workplace transport risks in skip-hire, and in particular those where hand sorting of recyclables (‘totting’) takes place, and in doing so:

  • raise the level of awareness of the serious hazards and risks associated with workplace transport issues in the operation of skip-hire sites, particularly those where totting takes place with vehicular assistance;
  • secure a significant reduction in the risk of serious and fatal accidents associated with workplace transport through a targeted inspection and enforcement initiative; and
  • undertake inspections to ensure compliance with generic and industry specific guidance covering management of workplace transport issues and in particular the hand sorting of recyclables where vehicular assistance is involved.

Justification

The waste and recycling industry has an overall accident rate around 4 times greater than the UK average and a fatal accident rate around 9 times the average for all industries. It is not possible to identify a specific accident rate for skip-hire activity alone, but workplace transport (i.e. ‘hit by moving vehicle’) in waste and recycling sector as a whole accounted for 51% (26) of fatalities in the 3 years 2006/07 to 2008/09.

Feedback from inspections undertaken during 2009/10, which did not solely focus on workplace transport, indicates that a large proportion of the inspector visits identified poor standards of poor traffic management that included poor site layout, the reversing of vehicles and the failure to properly segregate vehicles and pedestrians. This initiative will provides inspectors with the opportunity to build on this recently acquired knowledge and experience as well as focus on a single highest risk activity; namely workplace transport.

The 2010/11 initiative will provide the opportunity to visit a wider range of predominantly locally based companies, some of whom were not previously targeted in 2009/2010, and where appropriate, revisit those companies previously identified as poor performers.

Audience/ industry

HSE inspectors covering Manufacturing and Service Industries.Skip-hire operations, in particular those where hand sorting of recyclables (‘totting’) takes place, site operators, managers and drivers.

Activities required

Band 3/4 FOD inspector to carry out site visits to assess the management and operation of risk control measures. 

This will be one of three inspection initiatives taking place in the waste and recycling industry in the 2010/11 work year. The others will invlove the safe use of balers and compactors and interventions with local authorities; individual SIMs will be available for these activities.

For local planning purposes we would not expect the skip-hire visits to take more than 0.5 contact days to conduct. There is no specific target set for the number of visits.

Timing

Visits can be made anytime within the work year 2010/11.

Further Information

An inspection proforma is provided at Appendix 1 and further information is given in Appendix 2.

Please return completed proformas to Lisa Weston, HSE, Phase 1, Government Buildings, Ty Glas, Llanishen, Cardiff, CF14 5SH.

Initial Enforcement Expectations (IEE) and Enforcement Management Model (EMM) guidance

Workplace transport is a mature topic and it is expected that formal enforcement (notices and prosecution) will play an active part in the delivery of this initiative, securing dutyholders' compliance and effecting the necessary reduction in workplace injuries.

The inspection proforma at Appendix 1 should be used to judge conditions across the site, identify problems and inform enforcement action in accordance with the EMM.

Workplace transport poses a significant risk of substantial harm if not properly controlled and the standards of control are well known in industry. These factors should inform decisions on the EMM, the 'risk gap' and the initial enforcement expectation. It is therefore expected that the outcome of the EMM will be formal enforcement, at least in the form of a notice, where, for example:

  • Any item is scored as '4' on the proforma;
  • Pedestrian/vehicle segregation is clearly inadequate (Appendix 3 of the inspection pack gives useful guidance on the specific ‘struck by’ risks that arise from the ‘struck by’ project SIM 3/2006/08
  • The employer has no system for maintaining vehicles in a safe condition; and
  • Drivers have not been suitably trained to operate the vehicles they are using.

Improvement Notice templates 1, 3 and 4 in part 6 of the inspection topic pack are relevant - template 4 will need modifying if the vehicle is not subject to the fork lift truck (e.g. telehandler) ACoP (L117).

Also, Appendix 3 provides some specific Improvement Notice (IN) templates relating to use of vehicles in the vicinity of pedestrians who are hand sorting.

Health and safety

Inspection of skip-hire companies has potential to expose HSE staff to risks to their safety.

There is a significant risk on site due to vehicle movements. Inspectors should ensure that they are accompanied on their visit by site management and that drivers are aware of their presence. Inspectors must wear high visibility clothing at all times. When observing ‘totting’ of vehicle movements inspectors should be in a safe position away from the vehicle’s operating area, the driver should be aware of your presence at all times and you do not place yourself in blindspots or other areas where vehicles may collide with you.

Inspectors should also be aware of and comply with HSE’s policy on lone working.

Diversity

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 & Delivery pages give more information on these areas and others, including the Communications and EIA toolkits.

Contact

For further information please contact Wayne Williams, Manufacturing Sector – Waste Management and Recycling, Government Buildings, Ty Glas, Cardiff, CF14 5SH. VPN 511 3116 tel 02920 263116.

SIM 03/2010/05: Appendix 1 Inspection proforma for skip-hire inspections.

Inspector name and location:

Date of visit:

COIN Reference (eg. ID, Case or SVC number):

Company/Organisation visited:

Address:

Assessment scale

1

2

3

4

Full compliance in areas that matter

Broad compliance in areas that matter

Some compliance in areas that matter

Limited compliance in areas that matter

 

 

1

2

3

4

NA
Reducing the risk of being struck by vehicles.

Management of the workplace transport risk at yard/transfer stations (excludes the point of collection).

A suitable and sufficient of site specific transport risk.
(Identifies vehicle type, task suitability. Identification of groups of employees and non-employees at risk. Identification of all reversing situations and other high risk operations)

 

 

 

 

 

Allocation of responsibilities for workplace transport and knowledge of site specific standards.
(clearly understood at all levels)

 

 

 

 

 

Site rules and supervision to ensure compliance.
(site rules are brought to the attention of drivers and pedestrians. Site management aware of site rules and their responsibility to ensure compliance)

 

 

 

 

 

Site layout and internal traffic routes – safe site.

Sufficient space for vehicle and pedestrian movements.
(pedestrians/vehicles separated by physical barriers where reasonably practicable or by means of marked routes. Traffic routes wide enough for the largest vehicle using them and wide enough to allow vehicles to pass oncoming traffic. Clear sight lines without blind areas or corners. Open areas for manoeuvring).

 

 

 

 

 

Suitable and sufficient lighting.
(all roads, manoeuvring areas etc adequately lit, lights working and clean with an absence of glare).

 

 

 

 

 

Good road, yard and walkway surfaces.
(firm, even surfaces free from significant potholes and ruts)

 

 

 

 

 
Vehicle selection and suitability

Vehicle is appropriate for the site.
(Vehicles of a size and type which can carry out all tasks without encroaching on pedestrian walkways or other pedestrian areas).

 

 

 

 

 

Vehicles are suitable for the terrain.

 

 

 

 

 

Skip loader vehicles fitted with all wheel braking or equivalent to prevent “runaway” when lifting/ lowering skips. 

 

 

 

 

 

Drivers have appropriate visibility for the range of duties they perform.
(Drivers should have adequate direct vision supplemented by visibility aids where direct vision is not possible and there is a risk of ‘struck by’ accidents. Consider the benefits of fitting additional mirrors or CCTV or other sensing devices).

 

 

 

 

 
Vehicle maintenance.

There should be adequate maintenance systems in place including driver’s prestart checks, defect reporting procedures in addition to planned maintenance in accordance with manufacturer’s specifications (Vehicles should be well maintained with effective brakes, steering, clear windscreens and mirrors and effective wipers, horn and lights).

 

 

 

 

 
Vehicle movements

As far as practicable the need to reverse, particularly in pedestrian areas should be minimised.

 

 

 

 

 
Driver competence

All vehicles operated by trained, competent drivers.

 

 

 

 

 

No unauthorised use of vehicles.
(System detailing categories of vehicles drivers authorised to operate. Control of keys).

 

 

 

 

 

Drivers have knowledge of site rules and instructions.

 

 

 

 

 

 
Sorting waste with mechanical assistance (“totting”)
1. Safe site

Mechanical sorting is used so far as is reasonably practicable to eliminate the need for handpicking in association with vehicles.

 

 

 

 

 

Sorting areas are well lit.

 

 

 

 

 

Non essential personnel excluded for areas in which mechanical loading machinery operates.

 

 

 

 

 

Non essential vehicles excluded from areas in which mechanical loading machinery and pickers operate.

 

 

 

 

 

Effective segregation of pedestrians and tipping vehicles.

 

 

 

 

 

Safe/segregated/protected zones established for totters to withdraw to before mechanical loading machine approaches stockpile.

 

 

 

 

 
2. Safe Vehicle/Driver

Machine operator able to see that pickers are in a safe position before approaching the stockpile.

 

 

 

 

 

Machine operator has clear understanding of the safe system of work

 

 

 

 

 

Clear communication between the pickers and the machine operator.

 

 

 

 

 
3. Safe system of work

Adherence to a safe system of work during hand picking and ‘turning’ of the waste stockpile.

 

 

 

 

 

Pickers have a clear understanding of the safe system of work

 

 

 

 

 

Pickers wear high visibility clothing at all times.

 

 

 

 

 

 

 

 

 

 

 

Plant and machinery guarding

The dangerous parts of fixed plant used for processing materials are adequately guarded with fixed/ interlocked guards to prevent access to the dangerous parts.

 

 

 

 

 

 

Access and egress

Suitable means provided to allow safe access and safe work at height when operating and maintaining fixed plant.

 

 

 

 

 

Action taken:

 

 

Comments:

 

 
Return to Lisa Weston, HSE, Phase 1, Government Buildings, Ty Glas, Llanishen, Cardiff, CF14 5SH.

SIM 03/2010/05:  Appendix 2 Inspection of skip-hire activities

Targetting

The waste management licences and waste carriers registers held on the Environment Agency’s (EA) website will list many skip-hire operators by town and postcode.  Alternatively, local trade directories can be used. Inspectors should concentrate on activities at the yard or transfer station as opposed to the point of collection of the waste. Experience has shown that the majority of accidents occur in these situations.

Feedback from the previous initiative in 2009/10 has shown that it was not always possible for Inspectors to identify a suitable number (or type) of waste operation from the above source.  To address this in 2010/11 the Sector has made arrangements to  obtain relevant company details (name, address and telephone number) from the EA’s National Waste Carriers database.  the licence will only allow that information to be made available to inspectors from a central source, and therefore requests for such information should be made to Lisa Weston in the Cardiff office.

Primary Inspection Issues

Workplace transport - The majority of the serious accidents in this industry are related to workplace transport.  Site layout, control of the site, organisation of vehicle movements, vehicles and competence of drivers are key issues that have featured in fatalities.  A range of guidance material is available:

Hand sorting using vehicle assistance aka ‘totting’:  There have been several fatalities resulting from inadequate control of mechanical shovel movements during hand picking of waste/ recyclables from heaps.  Guidance for hand sorting of recyclables (totting) with vehicle assistance is available.

A new WISH guidance sheet (Waste 24) which will provide further practical guidance for hand sorting of recyclables, aka ‘totting’ is due to be published during the early part of the 2010/11 work year.

Other inspection issues

The main focus of this inspection initiative is on workplace transport issues, however, other site issues e.g. machinery guarding, welfare provision, processing and handling of Waste Electrical and Electronic Equipment (WEEE), orphaned compressed gas cylinders , handling of asbestos etc., identified should be dealt as a matter of evident concern and according to first principles. Where necessary, advice should be sought from Specialist Inspectors in the FOD Specialist Groups (on detailed technical or occupational hygiene and health issues) and from the relevant Sector Inspectors (on specific industry standards).

With regard to Machinery Safety a variety of static machinery can be found within skip-hire operations as the materials are treated. These can include trommels, other screening units with troughed conveyors and crushers, balers and compactors.  Failure to provide, use or maintain guarding is a significant risk to workers safety.  Inspectors should be aware that a range of new guidance on this topic is under preparation and should be available early in the 2010/11 work year, for example:

  • SIM 03/2010/03 - Safe maintenance activity.
  • SIM 03/2010/06 - Balers and Compactors: safe interventions in the waste and recycling industry
  • WISH guidance sheet (Waste 14) - Safe interventions with machinery in the waste and recycling industry.
  • Baler and Compactor Guidance: Recommended minimum mechanical safeguarding requirements for the design, construction and use of waste baling and compacting machines.

Inspectors should also make regular reference to the web pages for the waste management and recycling industry

Recording visits

The inspection proforma at Appendix 1 should be completed and returned to the manufacturing sector (Lisa Weston, Cardiff Office). Contacts should be recorded on COIN as normal, no keywords are required.

Other noteworthy information such as copies of letter, enforcement notices, examples of best practice and photographs should also be forwarded to the Sector with the proforma.

Inspector competence

No specific additional training or competence is required to undertake these visits as  the initiative will rely on inspectors’ existing competencies in workplace transport gained from working in this and other sectors: consequently it will require little or no training resource for those involved. The inspection proforma at Appendix 1, and the listed guidance material covers the relevant areas.

SIM 05/2010/03 Appendix 3: Initial Enforcement Expectation - IEE (hand sorting with a mechanical loading shovel)

Activity

Issue

Benchmark

Risk Gap

IEE

Mechanical loading shovels used to sort waste/ recyclables.

Non essential personnel have access to the vehicle operating area during vehicle operations.

Serious personal injury/ nil- negligible

Extreme

IN
(notice 1)

Mechanical loading shovels used to sort waste/ recyclables with pedestrian workers picking (totting) out fractions from the stockpile.

Loading shovels operating in close proximity to pedestrian workers without adequate controls in place to ensure effective segregation.

Serious personal injury/ nil- negligible

Extreme

IN
(notice 2)

Mechanical loading shovels operating in areas which it is foreseeable they may share with pedestrians.

Effective all round vision is not provided, e.g. mirrors, clear windscreen and CCTV coverage of blind spots.

Serious personal injury/ nil-negligible

Extreme

IN
(notice 2)

Notice 1: Sorting operations, segregation of mechanical shovels and pedestrians

….you are contravening …the following statutory provisions:

The Health and Safety at Work etc Act 1974 sections 2(1) and/or 3(1), The Management of Health and Safety at Work Regulations 1999, regulation 5(1) and the Workplace (Health, Safety and Welfare) Regulations 1992, regulation 4(1).

…the reasons for my said opinion are:

that you as an employer, subject to a duty by virtue of Regulation 4(1) of the Workplace (Health, safety and welfare) Regulations 1992 (as amended) have failed to comply with the provision of Regulation 17(1) of the said regulations in that adequate arrangements are not in place to allow pedestrians and vehicles to circulate in a safe manner and to effectively segregate moving vehicles and pedestrians during the process of sorting (totting) materials.

Schedule:

To comply with this Notice:

  1. You should provide a system in the picking area which, so far as reasonably practicable:-
    1. prevents the operation of mechanical shovels and other vehicles in areas where sorting of materials by pedestrian workers is taking place; and
    2. prevents pedestrian access to areas where mechanical shovels and other vehicles are in operation. So far as is reasonably practicable segregation should be provided by physical means such as barriers or protected zones (refuge) or are safe by distance.
  2. So far as is reasonably practicable, separate traffic routes to and from the picking area should be provided for pedestrians and vehicles. Where separate routes are not reasonably practicable, and vehicles and pedestrians use the same route, it should be wide enough to enable any vehicle likely to use it to pass pedestrians safely.
  3. Where pedestrian and vehicle routes have to cross, appropriate crossing places should be provided. Where necessary, barriers or rails should be provided to prevent pedestrians crossing at any particularly dangerous points, and to guide them to designated crossing points. At designated crossing places there should be adequate visibility for pedestrians and vehicle drivers.
  4. You should draw up and implement a system for informing and instructing employees and other people who come onto the site, including visitors (both pedestrians and people in vehicles) about the site rules concerning pedestrian/ vehicle separation.
  5. You should set up a system for checking compliance with your site rules for operating vehicles within the picking area and pedestrian/ vehicle separation. The system should include reference to:
    1. Which named individual(s) is/are responsible for monitoring compliance;
    2. How (including how often) they should monitor compliance
    3. What they should do if non-compliance is found (including investigating any reasons for non-compliance; any need for further precautions including further information, instruction, training and supervision, reference to any disciplinary procedures); and
    4. What records should be kept of non compliance.
  6. OR

    Any other equally effective means of complying with the Notice may be used.

    Available HSE Guidance – this does not form part of the Notice
    Waste 18: Hand sorting of recyclables (totting) with vehicle assistance

    Waste 24: Practical guidance for hand sorting of recyclables ‘totting’
    This will soon be available on the WISH Forum on HSE’s Waste and Recycling website.

Notice 2: Sorting operations, adequate field of vision for drivers of mechanical shovels

….you are contravening …the following statutory provisions:

The Health and Safety at Work etc Act 1974 sections 2(1) and/or 3(1) and The Provision and Use of Work Equipment Regulations 1998, regulation 28(e).

…the reasons for my said opinion are:

the direct field of vision for the driver of the loading shovel is inadequate to ensure the safety of pedestrians.

No schedule to be included. Make reference in accompanying letter to the need to carry out risk assessment to identify the appropriate devices needed to provide the driver with means to improve his vision so far as is reasonably practicable. A loading shovel driver’s direct field of vision is often inadequate both moving forward and reversing. Vision aids may include external front, side and rear mirrors, closed circuit television (CCTV) and sensing devices.

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