1 This initiative targets an industry that has a fatal accident rate amongst the poorest of any industry. The initiative concentrates on the main causes of those fatalities.
2 The initiative seeks compliance with accepted minimum standards, which are supported by HSE and industry good practice guidance. To help achieve compliance examples of enforcement notices have been drafted (see Appendix 2 – to be provided at a later date).
3 The main trade body representing the scrap metal industry, the British Metal Recycling Association has taken steps to improve the performance of the industry by producing a Health and Safety Manual for its members and promoting the Metskills Health and Safety Passport and Passport Plus schemes.
4 Safe site: apply the principles outlined in the Workplace Transport Topic pack and guidance. Scrapyards are often found in urban areas and can be short of space, consider the implications of a small site with movements of large vehicles, lifting operations and drivers who may not be familiar with the premises.
5 Some metal recycling premises may also be open to the public, examine the control of pedestrian movements.
6 Safe vehicles: mechanical shovels lift trucks and other lifting equipment can have “blind spots” behind masts, cabs and in front of buckets. Drivers should have adequate vision of the front, sides and rear of the vehicle by the provision of mirrors and/or CCTV.
7 Inspectors should ensure that the vehicles used are suitable for the conditions, such as sloping or pot-holed areas. Lift trucks are particularly sensitive to uneven and sloping surfaces.
8 Safe working systems: the delivery or removal of materials for scrap yards and metal recycling premises involves large goods vehicles, driven by employees, clients or contractors. All drivers (including visiting drivers) should have clear instructions about how they should operate on the site and their actions may need to be supervised. Instructions should include (but not be limited to); use of PPE, staying with the lorry/ egressing the vehicle, movement around the site, one way systems, areas to avoid, unloading, sheeting, lifting etc.
9 When tipping loads vehicles should be at least one and a half vehicle widths apart (see Safe transport in waste management and recycling facilities).
10 Safe workers: Evidence should be sought to confirm that lift truck operators and drivers of other site-based vehicles are competent to operate it.
11 Falls from vehicles during sheeting, unloading and trimming of loads are a significant risk in these premises if not properly controlled.
12 There are safe sheeting solutions available for all types of vehicle, container and trailer eliminating the need to sheet at height. Site operators should ensure that visiting vehicles can sheet/ trim and load safely and may need to provide facilities to enable this or set minimum standards for all vehicles. The web guidance on sheeting and unsheeting of lorries should be applied (www.hse.gov.uk/workplacetransport/information/sheeting.htm).
13 Where work at height is required safe access should be provided. Large equipment such as balers, compactors and fragmentisers will often require access to servicing points.
14 Waste materials received at scrapyards and metal recycling facitilities have often been found to contain potentially flammable and explosive canisters and containers. LPG cyclinders and canisters are often secreted in waste streams such as vehicles received for scrapping. There is a significant risk of fire and explosion if these containers are not identified and removed as they can enter crushing, shearing and fragmentising processes.
15 Scrapyards and metal recycling facilities should have systems in place to verify that flammable and explosive materials are not entering the processing line.
16 Flammable and explosive materials should be stored in accordance with the standards set out in “The storage of flammable liquids in containers” HSG51 (Second edition) HSE Books 1998 ISBN 0 7176 1471 9 and the LP Gas Association Code of Practice 7 - Storage of Full and Empty LPG Cylinders and Cartridges.
17 LPG cylinders and containers of flammable materials should not be cut, crushed, baled or subject to heat treatment unless under very controlled conditions (not normally found in most scrap yards and metal recycling facilities). If facilities are found that, claim to safely destruct cylinders and containers it is recommended that verification is sought with the assistance of HSE Process Safety inspectors.
18 LPG cylinders are normally the property of the supplier companies who will only send cylinders for refurbishment and destruction to nominated sites.
19 Repatriation and retrieval schemes exist to collect and return “orphaned” containers to their owners. HSE / WISH guidance document “Orphaned compressed gas cylinders in the waste and recycling industries” provides further guidance on this.
20 Mechanical lifting of materials occurs at all scrapyards and metal recycling facilities and can involve large numbers of routine lifts through to small numbers of complex lifts. The dangers are evident but there are a steady number of accidents every year relating to this process.
21 OC 234/11 “The Lifting Operations and Lifting Equipment Regulations 1998” gives inspector guidance on this topic.
22 Lifting equipment: Inspectors should confirm that the lifting equipment and lifting tackle is suitable for the tasks. Operators should be able to assess the weight of loads and ensure that the lift is within the capability of the equipment. Additionally, lifting equipment should be suitable for the environment in which it is working, e.g. yards may be sloping and have a soft surface.
23 Evidence of thorough examination and maintenance should be provided. Typically, thorough examination should be carried out by a competent person at least every 12 months.
24 Safe workers: Operators should be competent to perform all foreseeable lifts. They should be able to ensure the load is within the capabilities of the lifting equipment and tackle, be able to attach it and perform the lifting operation safely.
25 Safe lift: The competent person/ operator should plan all lifts before undertaking them. For complex lifts this may require a written plan. Most scrapyards and metal recycling facilities will normally undertake simple lifts, in these cases the competent person should consider issues such as the load, its attachment, the path of the lift and how it is safely lowered to a resting position.
26 Loads falling during a lift have caused fatalities in this industry. Personnel should be excluded from the path of the lifting operation and any areas into which materials may fall (e.g. stacks falling as a consequence of the lifting operation). Where possible lifts should be from designated areas from which non-essential personnel are excluded. This can reduce the risk injury and the chance of lifting vehicles and other materials not intended for processing.
