SIM 03/2009/10
This SIM replaces SIM 03/2003/62 but there are no other changes apart from the serial number. It provides inspectors with advice on how to apply the EMM to situations in which people employed in the plastics processing industry are required to use hand-held trimming knives for removing flash from plastic components or for similar operations.
1 HSE statistics and company surveys suggest that hand-knife injuries typically account for 25-50% of all lost time accidents in the plastics processing industry. Hand-knife injuries usually happen when the knife slips during cutting or trimming. In most cases the blade comes into contact with the worker's other hand causing laceration to the hand and/or fingers. More details are given in the free HSE publication Plastics Processing Sheet No 12: How to reduce your hand knife injuries
2 Plastics Processing Sheet No 12 also contains a series of case studies showing how some employers have dramatically reduced their overall accident rates by implementing risk-reduction strategies focusing on the risk of hand-knife injuries. In each case the keys to success have included securing the commitment of senior managers to reducing the number of hand-knife injuries, making this commitment highly visible, communicating it effectively to the workforce and gaining the active involvement of line managers, supervisors and front line workers in implementing the strategy.
3 Poor practice usually exists through ignorance of what can be done or because senior managers have not been persuaded to make the necessary level of commitment to an improvement strategy. By using typical scenarios this SIM aims to help inspectors to apply the EMM to circumstances in which conventional trimming knives (of the type commonly available from DIY stores), craft knives, scalpels or other similar sharp-edged or pointed tools that are not of an inherently safe design (deburring tools, knives with shrouded blades, etc) are being used for trimming or similar operations.
Operators are required to use knives of the type mentioned in paragraph 3 in circumstances in which there is a risk of injury but they are not provided with suitable personal protective equipment (ppe) designed to protect the part of the body at risk (see plastics processing sheet no 12 - Table 2).
3. The worst outcome would be a deep laceration or stab wound leading to arterial bleeding and/or tendons being severed. The consequences would therefore be a serious personal injury.
4 In most cases the likelihood of such consequences would be remote. (However, it is recognised that, depending on the particular circumstances and method of work, there may be occasions on which the likelihood of such consequences would be regarded as possible or, in extreme circumstances, even probable . Inspectors need to apply their judgement in each case).
5 The benchmark (ie where the dutyholder should be in terms of residual risk) should be a negligible risk of such serious personal injury.
6 In most cases applying paras 3-5 above to the EMM risk gap table 2.1 for single casualties will give a substantial risk gap.
7 The Sector's view is that the required standards for this situation are established. Provision/use of suitable protective gloves, gauntlets, arm guards or aprons as appropriate to protect against knife injury is established good practice and well known within the industry.
8 Applying the above to the EMM table 5.1 leads to an Improvement Notice as the initial enforcement expectation. The Improvement Notice would be used to require the selection and provision of suitable PPE to a recognised standard (see Plastics Processing Sheet No 12 - table 2) and/ or provision of trimming tools of an inherently safe design.
Operators are provided with, and make use of, suitable ppe but the trimming knives they are required to use are still conventional trimming knives, craft knives or scalpels as opposed to knives of an inherently safe design.
9 Assuming that suitable PPE to a recognised standard is being used correctly, the worst outcome is likely to be a significant injury such as a laceration that could cause the IP to be disabled from performing his/her normal duties for more than three days.
10 The likelihood of such consequences, given the correct use of PPE, would most likely be possible
11 The benchmark in these circumstances would be a remote likelihood of significant injury .
12 Applying paras 9-11 above to the EMM table 2.1 for single casualties gives a moderate risk gap.
10. The Sector view is that the standards expected in these circumstances are established . Minimising the occurrence of flash through good design, maintenance and operation of mould tools, reducing the risk of hand-knife injuries by applying sound ergonomic principles to the design of workstations and by selecting and using inherently safe hand tools, such as deburring tools or safety knives, are widely known and accepted good practices in the industry.
11 Applying the above to the EMM table 5.1 leads to a letter/Inspection form as the initial enforcement expectation. A letter referring the dutyholder to Plastics Processing Sheet No 12 and pressing them to implement a strategy of the type described in the processing sheet would be appropriate in many circumstances.
15 SIM 03/2003/62 - cancel and destroy
