Health and Safety
Executive / Commission
Freedom of information
SIM 03/2008/04
This SIM gives advice to inspectors regarding interventions to examine the management of quarry process hazards and risks as part of the FOD workplan 2008/09. It may also be relevant to accident and dangerous occurrence investigations arising from the process risks. It also includes guidance on those parts of the Fit3 Strategic Programme which are relevant to quarries.
1 The Quarries Regulations 1999 (QR) require the Quarry Operator to ensure that quarry excavations, stockpiles and tips are designed, constructed, operated and maintained so as to ensure that instability or movement which is likely to give rise to a risk to the health and safety of any person is avoided. The Regulations also require the Operator to:
2 The design, Excavation & Tips Rules (E&TR), geotechnical appraisals and assessments, and operator site inspections should all contribute to the safe operation of the quarry and are inherently linked.
3 To develop and maintain the technical knowledge, skills and experience of Quarry Inspectors and contribute to their Continuing Professional Development (CPD).
4 Safety: To ensure that operators have identified the relevant hazards and implemented the necessary risk control measures to ensure safe operation of the quarry in accordance with the health and safety document, that the quarry design is based upon an adequate geotechnical assessment, and that the quarry is worked in accordance with the design (see Appendices 1, 2 and 3).
5 Health: To incorporate the third phase of a three-year initiative on exposure to silica that aims to assess and enforce compliance with COSHH 2002 (as amended), particularly focusing on compliance with the revised WEL. The initiative also aims to promote awareness of the Silica Essentials guidance. It is envisaged that this part of the workplan will be lead by Occupational Hygiene (OH) Specialists as part of joint visits with Quarry Inspector’s (QI). The silica project is part of the Specialist Group OH workplan for 08/09. QI’s should liaise with relevant OH Specialists to coordinate visits to sites. This is in addition to quarry process work (see Appendix 4).
6 Fit 3 Strategic Programme: To address relevant Fit 3 projects as a contribution to the Injuries Reduction, Disease Reduction and Health at Work Programmes (see Appendix 5).
7 The FOD inspection programme for 2008-09 allocates 2.25 work years to inspection of quarry process safety, namely the identification of hazards and management of risks arising from excavations, tips and lagoons and use of explosives. Each QI should be allocated 14.5 contact days to this work programme. Resource allocation by Division is:
| Division | Staff resource (staff years) |
|---|---|
| Wales & South West | 0.5 |
| ESE | 0 |
| London | 0 |
| Midlands | 0.5 |
| NW | 0.25 |
| YNE | 0.5 |
| Scotland | 0.5 |
8 Although Divisions are expected to assist their neighbours with reactive work in quarries where timeliness is an issue, for example due to the local QI being unavailable through leave, there is no requirement for a Division to make up a shortfall in planned quarries programme work arising from long term staff shortages.
9 Other proactive and reactive work not included in the resource allocation above but which may be carried on by inspectors in quarries, includes:
10 Relevant SIC codes for premises to be included in this programme are:
11 There will be a number of visits to quarries where there is the potential for exposure to silica with the objective of ensuring that 50% of quarry operators have procedures in place to secure compliance with the revised silica WEL. QIs and OH Specialists should liaise locally to arrange visits.
12 The inspection intervention should start in April 2008 and visits completed and recorded by the end of the 2008-2009 work year.
13 Inspectors should focus on the following 5 areas during visits:
14 When planning quarry visits, inspectors should allow sufficient time to examine the management of process risks, including physical inspection of excavations and associated tips (including lagoons and stockpiles), and examination of records and reports necessary to identify whether the operator’s systems for managing process risks are adequate.
15 Where blasting is taking place, it may be appropriate to arrange to visit during loading of the shot to observe and discuss blasting practices with those involved. So as to assess compliance with the requirements of QR Part V, e.g. management and transport of explosives on site, liaison with contractors, safe disposal of unused explosives, adequacy of record keeping, etc.
16 Process safety inspections may be “bundled” with other work such as Fit3 Programme visits and investigations involving the same site or operator in order to make the best use of inspector time.
17 To cover all the programmed work at a large quarry, several visits over a period of time may be necessary.
18 For the silica intervention the content of the inspection and compliance issues are given in Appendix 4.
19 For Fit 3 Programme work inspection topics for quarries are given in Appendix 5.
20 Poor compliance should result in enforcement action in accordance with the HSC Enforcement Policy Statement and the Enforcement Management Model.
21 The Appendices identify relevant guidance and benchmark standards for enforcement action.
22 FOD HQ will advise on COIN work recording requirements.
23 QIs may wish to maintain a written record of interventions as part of CPD records maintained for professional purposes.
24 Please note the Health and Safety Supplements relating to site visits, which are available in 'Your Health and Safety'.
25 Inspector resource will be locally managed using the contents of this SIM to assist in the development of Group/Personal Workplans.
26 To enable the Sector to monitor progress against this plan, QIs should link the contact Case to a centrally generated Master Case. The number for this Case will be notified to QIs. Time recording will be by clocking through from the visit Case in the normal way.
27 Sector will produce a half-year and end-year report for FOD MB. This report will include quantitative and qualitative information to enable evaluation of the intervention strategy.
28 Additional information for QIs will be disseminated as necessary via the Quarries Community website.
29 Further information for the relevant topic can be found below:
Quarry Industry/technical queries:
Silica Intervention queries:
1 At all rock quarries, it is important to ensure that the blast design reflects geological and geotechnical conditions. Experience and research have shown that faces lower than 15m reduce the risk of flyrock 1,2,3.The blast hole diameter, hole pattern, explosives coupling, quarry design, other aspects of blast design, face loading equipment and face maintenance systems need to be appropriate to the geological conditions.
2 Flyrock should be minimised through choosing a suitable ratio of burden to face height (or stiffness ratio4). Ratios of less than 1:1 give increased risk of fly-rock and increased ground vibration, and ratios above 1:4 give an increased risk of fly-rock. For example, using these criteria, a 3m burden would give a maximum face height of 12m. Wyllie and Mah4 indicates that, for best results, stiffness ratios should be between 3 and 4.
3 Good excavation design, coupled with good blast design, should minimise the likelihood of flyrock, of over-sized or under-sized material in the blast pile, and the potential for developing overhangs in the stemmed zone or loose rocks in the face. If significant loose material remains after blasting, the blast design should be reviewed by the explosives supervisor in consultation with the quarry operator with a view to improving the outcome of the next blast. Such discussions may also need to involve the geotechnical specialist e.g. if significant changes to the quarry design are being considered.
4 If dominant geo-structural discontinuities (jointing, bedding, cleavage, etc.) result in very clean faces after blasting, the rock mass may still be subject to failure along planes parallel to the face. Such planes may act to increase blast damage such as back break, due to the reflection of blast energy within the face4.
5 Arrangements for the competence assurance of shot firers and explosives supervisors are discussed in SIM 03/2007/10.
6 Depending on the circumstances, enforcement may be relevant against the operator, and /or the blasting contractor as an employer, or against individuals appointed under Part V of the Quarries Regulations 1999. Where an improvement or prohibition notice is served relating to physical conditions in the quarry, gathering evidence for immediate prosecution should also be considered.
7 Enforcement is likely to be appropriate when:
1 Causes of face failures and instability include:
2 QR Regulation 30 places an absolute duty on the operator, which includes the requirement to maintain the excavation or tip to ensure that instability or movement likely to give rise to a health and safety risk is avoided. Regulation 31 requires the E&TR to include precautions to be taken to ensure the health and safety of any person and the stability and safety of the excavation or tip.
3 Scaling will be necessary when blasting, erosion or other processes lead to loose material or overhangs on the face, which would create danger if it fell. In such circumstances it may be necessary to demarcate a danger area (QR Regulation 22) whereby access must be temporarily restricted only to authorised persons operating under a Safe System or Permit to Work. The choice of scaling method chosen must reflect the balance of risks involved.
4 The Work at Height Regulations 2005 require that, where it is reasonably practicable, work should be carried out other than at height. Mechanical scaling from below should therefore be the preferred method. Additional information on falls and falling objects in quarries is provided in SIM 03/2005/11.
5 The Work at Height Regulations 2005 and Provision and Use of Work Equipment Regulations 1998 require work equipment to be suitable for the work it is expected to do. The aim is that geology, face geometry, loading methodology and equipment should be matched to suit the variety of conditions pertaining in an individual quarry. The selection of work equipment should be formally assessed against the duties that the equipment would be required to carry out. The selection of face machines needs to take into account the geological/geotechnical considerations and output requirements of the site, in addition to the required reach of the machine. If suitable equipment is not readily available it may be necessary to reduce face heights in order to operate the quarry safely.
6 The manufacturers of earth moving machinery provide handbooks of charts, diagrams and specifications to explain in detail the reach and capture distances and optimum working geometries for loading efficiency of different machines, e.g. the maximum height of an excavator pad above the loading level into dump truck or crusher. These sources should be used by operators to inform their choice of machinery and working methods.
7 Care must be taken to ensure that design criteria are not compromised in the event that equipment is brought to site to either supplement or replace original equipment, particularly in the event of short-term hire situations. If equivalent equipment is not available, then the design must be reviewed and amendments implemented on the ground as necessary.
8 The blast pile is unconsolidated loose material, and in placing mobile plant on the blast pile to work, the geotechnical appraisal should carefully consider if the rockpile is a significant hazard (Quarries ACOP paras 293-295). There should be a record of the decision, and the reasons for it, if it is decided is not a significant hazard.
9 Face or tip crests should always be assumed to be unstable due to the nature of the rock or engineering soil, water content, jointing, weathering, sub-drill and blast damage etc. Where the face condition is poor, a factor of safety cannot be determined and assumptions made must always err in favour of safety.
10 A safe standoff distance from the crest should be determined based on the stability and potential for failure of the rock mass. Additional edge protection or fall prevention for personnel will also be required. Drivers of fuel trucks, emulsion explosives mixer-trucks, etc., also need to be appraised of risks from rock-fall, face edges, etc as an integral part of their site inductions. The operator must ensure that any such equipment is suitable for use on the site with access routes and roadways designed accordingly. Such arrangements will form part of the vehicles rules.
11. If hydraulic breakers are used on the quarry floor, there should be consideration given in the geotechnical assessment as to what standoff from any face is appropriate.
12. Stockpiles may be significant hazards. A stockpile being loaded out must be treated as an excavation, and different criteria apply (ACOP para 301 (b)).
13 The whole stockground should be included as part of the quarry design, addressing not only the construction and working of stockpiles but also vehicle and pedestrian routing and segregation. This will form part of the Vehicles Rules as well as E&TR.
14 Simultaneous loading and stockpiling / tipping in the same area of a stockpile are to be avoided. When loading from stockpiles takes place, vehicle access to tip on the same stockpile should be prevented e.g. by removing the ramp, or tipping loads across the ramp.
15 Quarry design should be “cradle-to-grave”. Older faces that are not being worked must not be ignored. These faces, e.g. behind buildings or plant, may be high and/or prone to degradation.
16 In addition to ensuring that safe faces are maintained throughout the life of a quarry, the Operator has to plan for the closure of the quarry at which point faces must be left in a safe condition. This necessarily entails significant planning well in advance of final blasting. It is vital that provision is made for adequate lead-in times. Particularly in hard rock quarries, the progressive establishment of safe final faces actively contributes to the minimisation of hazards and risks for personnel and plant working below them.
17 Depending on the circumstances, enforcement should be considered against the operator and/ or those employers or individuals with influence over how the quarry is worked, such as drilling and blasting or loading and hauling contractors, geotechnical specialists etc., if they have not complied with their duties under QR99. Where an improvement or prohibition notice is served relating to physical conditions in the quarry, gathering evidence for immediate prosecution should also be considered.
18 Advice on enforcement regarding falls and falling objects is given in SIM 03/2005/11.
19 Enforcement is also likely to be appropriate when:
1 It is particularly important that there is an effective relationship between the Quarry Operator, Geotechnical Specialist and Explosives Supervisor, to the extent that hazards, resultant risks and associated mitigation measures are identified and routinely reassessed in the event of any design changes. They must understand and appreciate each other’s roles.
2 The basis of and requirement for, adherence to the geotechnical design should be included in the excavations and tips rules and the relevant parts given, and explained, to all those working at the quarry who need them for their day to day work.
3 Co-ordination and communication with contractors is particularly important given the increasing role of contractors in the industry in areas such as drilling, blasting, face excavation/load & haul contracts. The operator has a duty to set out in the Health and Safety Document how their activities are to be co-coordinated, together with their roles and responsibilities within the overall management structure of the site.
4 Information on assessing and enforcing competence requirements is available in SIM 03/2005/15.
5 The competent person appointed under QR R8(1)(c) should be ‘readily available’ at the quarry, in that they should normally be expected to be present on site at all times when work is being carried on at the quarry. If they are not present on site, a substitute possessing the relevant competences must be nominated to be in charge. In order to fulfill the requirement of being ‘readily available’ it is expected that the competent person appointed under Reg 8(1)(c) is based at the site where they are appointed.
1 The Disease Reduction Programme's (DRP) Respiratory Project includes an intervention to reduce the incidence of respiratory ill health (silicosis and Chronic Obstructive Pulmonary Disease - COPD) amongst quarry workers. This intervention is included in the Fit3 Strategic Programme - Prioritised Portfolio of Projects for 2008/09.
2 There are two main drivers behind the current focus on respiratory ill health associated with exposure to silica:
3 This SIM outlines the third phase of a three-year initiative that aims to assess and enforce compliance with COSHH 2002 (as amended), particularly focusing on compliance with the new WEL, in quarries. The initiative also aims to promote awareness of the Silica Essentials guidance. The first two phases targeted stonemasons and brickmakers.
4 There is guidance on dust control measures for the quarrying industry such as:
5 Occupational Hygiene Specialist Inspectors should focus on the following 4 areas:
6 Poor compliance should result in enforcement action in accordance with the HSC Enforcement Policy Statement and the Enforcement Management Model. Enforcement action taken should reflect the emphasis in Regulation 7 of COSHH 2002 (as amended) to apply the principles of good control practice when controlling exposure to substances hazardous to health. Schedule 2A provides details on what is required.
7 Large employers are Aggregate Industries, Cemex, Hanson, Lafarge and Tarmac. Following interventions at one or more quarries operated by these companies, based on feedback from QIs and Occupational Hygiene Specialists Sector staff will approach senior management who will be asked to submit, where necessary, an improvement plan intended to secure compliance with the silica WEL. This plan will be copied to both Quarry Inspectors and Occupational Hygiene Specialist Inspectors. These arrangements are not intended to override any decisions made locally about enforcement action which may be appropriate.
8 A list of target areas in which this intervention should be carried out will be provided by the Sector.
9 Occupational Hygiene Specialist Inspector time has been allocated to this work.
1 Inspectors may wish to take the opportunity to address relevant Fit 3 projects. Those considered to be relevant to the quarry environment are given below. Recording of this component of the visit should be in accordance with the instructions for recording Fit 3 work.
| Programme | Proposed Project | Deliverables |
|---|---|---|
| Injury Reduction Programme | ||
Slips, Trip and Falls from Height |
Reduce slips, trips and FFH in
|
Where Slips trips and FFH identified as Matters of Evident Concern (MEC)
|
Workplace Transport |
Moving Goods Safely III (MGS)
Routemap
|
Target bagged products and moving dimension stone by road, both for direct employees and haulage contractors, consider
Promote Routemap as tool with particular emphasis on:
|
| Noise and Vibration | Promote good practice in the provision and use of health surveillance | Consider application to use of vibrating hand tools in stone masons based in quarries. |
Manufacturing |
Safe interventions on specific machinery and plant in quarries, targeting maintenance contractors Targeted commitments |
Promote good practice amongst production, maintenance and contracting staff involved in machinery and plant maintenance (MEC and Reactive only) Draw attention to Target Zero initiative, particularly with SME’s that are not part of a trade association |
| Non – Fit3 | Migrant workers | Investigation of complaints and reported incidents involving migrant workers |
| Disease Reduction Programme | ||
| Cancer | Asbestos | Continuation of 2006/07 DTM enforcement. Consider exposure of high risk groups such as maintenance workers. |
| Cancer and Respiratory | Silica | See Appendix 4 |
| Health at Work | ||
| Health and Work | MSD focussing on back pain | MEC only |