SIM No. 05/2010/02
This Sector Information Minute provides information on risks associated with baggage handling on the ramp, with particular emphasis on loose-loaded narrow-bodied aircraft. It also contains guidance on enforcement in this area.
The manual loading of baggage, mail sacks and cargo into and out of aircraft holds present a risk of manual handling injuries to ground handlers. The back and shoulders are the areas of the body particularly affected but other areas such as the neck and knees can also be affected. There is a margin of error in HSE accident data due to misallocation of SIC codes and discrepancies in estimates of total employees in the sector. However, best estimates indicate that the rate of manual handling injury for baggage handlers is approximately five times that of the all industry average.
This guidance note deals with loading and unloading aircraft which do not use containerised bins (known as 'Unit Load Devices' (ULDs)). Smaller, narrow-bodied aircraft continue to rely on ground handlers to load and unload the hold by manual transfer between the dolly/truck, mobile conveyor belt (if used) and hold. Whilst this guidance deals specifically with baggage handling on the ramp, manual handling risks in baggage sort halls and at passenger check-in desks may also need to be addressed.
On wide-bodied aircraft the use of ULDs and their associated mechanical handling equipment reduces the need for manual handling. However, some of these aircraft, such as Boeing 747s have small rear holds which do not accommodate ULDs and so must be loaded manually. For these aircraft holds, the guidance in this SIM remains valid.
The economics of air travel, the contracting out of ground handling operations by airlines and the highly competitive nature of the business mean that changes to the design of the aircraft hold, installation of handling equipment and the use of ULDs for narrow-bodied aircraft are long-term goals. Efforts are being made to attain these goals by European and international agreement, and by contacts with aircraft designers and manufacturers. In the short-term, however, baggage handling will continue to be a labour intensive task and action should be taken where necessary to reduce the risk of MSDs.
There are many tasks during the aircraft handling operation that require personnel to manually handle equipment and objects, these typically include:
The two highest risk areas for manual handling injuries have been shown by research to be:
Ergonomics and medical research has helped to clarify the main risks of back disorder associated with manual handling. Physical activities associated with an increase risk of back disorder are: heavy physical work; lifting and handling of loads; and awkward postures (e.g., bending and twisting)
The specific factors that modify the extent of the loading to the lower back are as follows:
These factors can act in combination making the risk greater. For instance, a repetitive lifting task undertaken in an unfavourable posture can represent a high risk.
Detailed description of the manual handling risks presented by baggage handling can be found in Appendix 1.
A current risk assessment should identify what the employer sees as the main risks and what measures have been put in place to minimise the identified risks. Baggage handling companies may wish to base their risk assessment on the findings of the stakeholder project at East Midlands airport which identified a suitable hierarchy of control measures for the control of manual handling risks in baggage handling. The report of this project can be found here . Inspectors may wish to make themselves familiar with the conclusions of this project. A copy of the identified hierarchy of controls is reproduced in Appendix 2.
This is one task parameter that it is difficult for the baggage handling organisation to control. Current industry recommendations in the IATA Airport Handling Manual are that the maximum weight of any single piece of checked baggage should not exceed 23kg (50lbs), without prior arrangement. Although this limit is widely accepted, some airlines will accept baggage up to 32kg, and some foreign carriers have even heavier weight limits.
It is also recommended in the IATA AHM that ”Heavy” tags/labels must be placed on all pieces of baggage which exceed 23kg with the actual weight shown on the tag/label and that baggage belts weigh scales at the passenger check in points should have an audible or visible warning when any individual bag weight exceeds 23kg.
Weight restriction and labelling are in the control of the airline and the check-in staff and weight limits are not always enforced. Where heavy bags which are not labelled are found, the airline should be approached to ensure that systems are put in place to ensure that any existing weight limits are implemented and that heavy bags are tagged.
Training and work procedures should include provision for team lifting or alternative lifting methods and lifting aids for heavy bags.
There are also manual handling risks associated with manual manoeuvring of equipment. All ground support equipment such as passenger steps and baggage carts should be moved by mechanical means wherever possible, ensuring staff have been trained appropriately. For example motorised or solar powered passenger steps. Baggage carts should be moved by a tug rather than pulled manually. This eliminates the push/pull forces required to move equipment.
The highest levels of risk reduction and control for loose bag handling are provided by new extending belt loader (EBL) technology (such as Rampsnake, Powerstow, and Mongoose) or in hold systems using an extended belt loader and sliding hold floor. This significantly reduces the highest risk activity of manually handling bags inside the aircraft. Baggage handling companies have been reluctant to invest in this technology due to perceived high cost and reliability issues.
The next level of risk control will be achieved using a mobile belt conveyor. This will not reduce the need to handle bags inside the aircraft. However, when positioned correctly outside the aircraft it significantly reduces the risk to the external handlers. The vertical lift distances are generally kept within acceptable ranges and if the cart is positioned correctly the handler does not need to twist or sideways bend.
A mobile belt conveyor should be positioned just inside the hold door for onload to allow the bags to fall in front of the handler. The belt should be positioned just outside the hold for an offload to allow the handler to push the bag out of the hold and on to the belt.
The HSE view is that where hold door sill heights are greater than 1 m above ground level, it is expected that lifting/moving equipment such as conveyors (belt loaders) are used, and this should be taken into account when considering enforcement action. Belt loaders should be adequately guarded and suitable safe systems of work should be in place for workers to access the hold. While static belt loaders can be used to access the hold, guard rails must be in place. On no account should workers ride on moving belt loaders. The belt loader should be positioned to reduce the MSD risks both in transferring bags from the ground to the belt, and in transferring from the belt into the hold.
There should be an effective equipment maintenance regime in place. Maintenance of the conveyor belts is important to ensure their availability and to minimise hazards whilst in use.
Direct to hold handling using a flatbed truck/lorry should be avoided whenever possible. The requirement for the vertical lift part of the lift are almost inevitably outside acceptable ranges and it is very difficult to avoid significant amounts of trunk twisting and sideways bending. Postures are likely to be restricted due to the hold doorway. Working from a flat bed vehicle also introduces a new risk of fall from height unless the vehicle has suitable edge protection and means of access and egress. Guidance on this has previously been sent to the handling companies and is available on the AT community website. Inspectors should consider this guidance as appropriate.
In most cases direct to hold handling from ground level should also be avoided unless it is unavoidable due to hold position or sill height. Handling direct from the ground is likely to require handling outside acceptable ranges for vertical lift region. This method of handling will require the handler to lean into the hold to place and then propel the bag into position, this will require the handler to twist and sideways bend while handling.
In certain circumstances, it may be appropriate for an aircraft with a hold sill height of around 1 m above ground level to be loaded or off-loaded onto a properly designed flatbed truck. The baggage handling company must have a robust risk assessment in place justifying the use of a flatbed truck rather than a belt loader.
Handlers should wear appropriate clothing. For manual handling this should include kneepads for working in the hold, protective footwear and gloves. Footwear should provide suitable grip on smooth floors and in wet conditions in addition to toe protection.
Other clothing required when airside includes hi-viz and waterproof clothing and ear protection. All protective clothing should be compatible and should not adversely affect posture and freedom of movement. Protective clothing and equipment should be replaced when it becomes worn or damaged to reduce the risk of snagging on the load.
The effectiveness of back and abdominal support belts remains unproven and HSE does not advocate their use for manual handling tasks. Further guidance can be found on page 39 of the Guidance to the Manual Handling Operations Regulations(L23).
There should be task rotation where possible to even out risk factors and to allow workers a variety of movement, rather than, for instance, loading inside the hold for a full shift. Employers should take effective measures to ensure that there is rotation between jobs - working in the hold, working on the ramp, driving the dolly truck, etc.
Suitable breaks and rest periods need to be provided during the shift. It is not possible to be prescriptive as to when and how long breaks should be, also the nature of the baggage handling work on the ramp means that workers will usually have short breaks between each turnround. However, as a general guide they should not work for more than two hours without a significant rest break of 15-20 minutes.
There should be drinking facilities nearby to combat dehydration and rest area away from the task, as required by the Workplace (Health, Safety and Welfare) Regulations 1992.
Pre-employment health screening: It is good practice to have a system to screen applicants for relevant pre-existing conditions (e.g. by way of a form to be completed by applicants). This could be carried out by Occupational Health advisers if they are employed. If not, the company should have access to a health professional who is able to comment on an applicants suitability. In addition to assisting the company in recruiting suitable workers, the completed questionnaire can be presented as some evidence that the employer took reasonable steps to protect the employee in the event of an employee aggravating an undeclared injury.
The benefits of access to a competent OH service should be stressed, not only for assessing initial fitness for work but for assisting with risk assessments, and early detection of cases of work related musculoskeletal disorders and their subsequent management. Baggage handling companies should be encouraged to have systems in place to effectively manage the return to work of employers who have suffered manual handling injuries in line with the guidance . Inspectors should contact their local Occupational Health Inspector, via the Specialist Group, for further advice on individual cases.
Training on manual handling should be given before staff start manual handling work and supervisors should provide some level of monitoring during the handling operations to ensure that the techniques shown during training are applied.
A system should be in place to feed back investigation findings from any manual handling incidents into the training programme to try to reduce risk of repetition.
It must be noted that the provision of information and training alone will not ensure safe manual handling. The first objective of reducing the risk of injury should always be to design the manual handling operations to be as safe as is reasonably practicable. This will involve improving the task, the working environment and reducing the load weight as appropriate. Where possible the manual handling operations should be designed to suit individuals, relying on training alone to overcome deficiencies in the handling system is unlikely to adequately control the risks of injury. Effective training will complement a safe system of work, and has an important part to play in reducing the risk of manual handling injury. It is not a substitute for a safe system of work.
Suggested good practice in terms of handling techniques for baggage handling is contained in Appendix 3.
Inspectors are requested to:
RIDDOR data for 2007/08 indicates that 55% of the 1508 over 3 day injuries reported at airports result from manual handling incidents. The best estimate is that the rate of manual handling injuries in baggage handling is approximately five times the average rate for all industries.
The legal framework which sets the requirements for the management of risk from manual handling is laid down in the Health and Safety at Work etc Act 1974, the Management of Health and Safety at Work Regulations 1999 and the Manual Handling Operations Regulations 1992 (as amended).
Where there is evidence that there is a significant risk of injury and:
a Prohibition Notice or Deferred Prohibition Notice should be considered if supported by specialist advice, and taking into account the further advice in this SIM on the possible implications of serving PNs. A letter or Improvement Notice for the airline may be necessary to address deficiencies in maintenance of in-hold systems which are creating risks.
The HSE view is that where hold door sill heights are greater than 1 m above ground level, it is expected that lifting/moving equipment such as conveyors ( belt loaders) are used, and this should be taken into account when considering enforcement action as above. Belt loaders should be adequately guarded and suitable safe systems of work should be in place for workers to access the hold. While static belt loaders can be used to access the hold, guard rails must be in place. On no account should workers ride on moving belt loaders. The belt loader should be positioned to reduce the MSD risks both in transferring bags from the ground to the belt, and in transferring from the belt into the hold.
Standard belt loaders are the minimum level of assistance for this task. Use of belt loaders still leaves significant MSD risks in transferring bags from the trailer/ dolly to the belt, and from the belt into and down the hold. There is now new technology including extending belt loaders which can transfer the bags automatically from dollies into and to the far end of the hold. While such equipment requires significant investment, it is becoming more widely available and consideration should be given to establishing longer term plans to introduce such technology.
Where belt loaders are used additional actions may be necessary such as job rotation and improved design of dollies or trailers, plus use of in-hold transfer systems.
It should be noted that in certain circumstances, an aircraft with a door sill height of around 1 m above ground level may be safely loaded/unloaded by use of a properly designed flat-bed lorry. Any such system of work must be thoroughly assessed to consider both MSD risks and risks of falls from the flat bed and while accessing the hold. Guidance on guarding of flat beds has previously been sent to the handling companies and is available on the AT community website. Inspectors should consider this guidance as appropriate.
Inspectors should take into account the overall implications of an immediate PN, which could prevent aircraft turnround and may have serious implications for overall airport and aircraft safety. If the prohibition would, of itself, bring about other risks to health and safety that otherwise would not have existed, a deferred PN will be the preferred option, allowing, for instance, reasonable time for the repair of defective conveyors for use on subsequent aircraft turnround operations, without imposing additional risks in changing the system of work around an aircraft awaiting take-off. Where a longer time scale is required, for instance for the acquisition of additional equipment, an Improvement Notice is likely to be the practical option.
Where inspectors find failings of management systems such as:
And there is evidence that:
an Improvement Notice should be considered to address these issues. Advice or enforcement should be addressed to the party or parties best able to rectify an identified problem, that is airport and/or airline and/or ground handler.
Owing to the forces required to start movement of manually-manoeuvred equipment such a baggage dollies, belt loaders or passenger steps, these present a discrete risk of injury and also contribute to the overall risk of manual handling injury to which baggage handlers are exposed. The manual movement of such equipment also increases the risk of damage to aircraft. Powered equipment is widely available and a reasonably practicable alternative. Where manually-manoeuvred equipment is in use, and the baggage handling company have no plan in place to introduce powered alternatives, an Improvement Notice should be served requiring such a plan to be produced. In the interim, Inspectors should also be requiring evidence that a safe system of work is in place for the manual movement of equipment.
Where there are indications that excessively heavy bags are being handled, or bags weighing in excess of 23kg are not being tagged or labelled with the actual weight of the bag, Inspectors should investigate the systems in place with the airline or airport concerned to control bag weights and label such bags. Where no such system exists, or it is clear that the system is not being effectively managed, an Improvement Notice should be considered to address this issue.
Inspectors should apply local factors based on their knowledge of the specific situation and employer.
Inspectors should consider and target specific manual handling operations and any underlying management failings by the employer and, if relevant, the airline or airport involved.
As always, Inspectors should take action against the company in the best position to remedy the defects. In most cases, the target for action is likely to be the employer of the affected personnel. However, Transportation Section would encourage Inspectors to also pursue relevant issues from HSG209 with the service provider's client (most probably the airline). As mentioned above, matters relating to the assessment, control and monitoring of contractors and the control of risks to non-employees are likely to be the most pertinent in this context. Transportation Section should be consulted before any enforcement action proceeds on such matters.
The risk of musculoskeletal injury among baggage handlers is well known in the industry and is the cause of considerable lost time and absence, and consequent cost to the employer, as well as the cost to the nation of injury and early retirements, and the pain and suffering of individuals.
Inspectors should also consider that enforcement action will have a positive impact on dutyholders in the industry in general.
There is currently a great deal of work being undertaken internationally seeking to control the musculoskeletal risks presented by baggage handling activities. HSE has been involved in these discussions, including the introduction of the 23kg baggage weight limit in the IATA Airport Handling Manual. Further information on current projects and initiatives can be found on the AT community website.
For guidance and advice on specific issues contact Myles Francis, Transportation Section, on tel: 503 4275 or Sarah Tapley, Ergonomist, on tel: 507 6258.
The concerns regarding handling techniques are as follows:
The assessment of the current baggage handling methods identifies a number of manual handling related factors, which expose a significant proportion of the working population to the risk of injury. This includes the vertical height and distance of the lift, the hand reach from the lower back, trunk twisting and sideways bending, postural constraints and the grip on the load.
The potentially high load weights combined with the frequency of handling also contribute to the risk of injury. The evidence presented in this report, and other studies including previous work by the HSE (Tapley & Riley, 2005 and Riley, 2008) provide a strong case for this task to be re-designed to reduce the risk of injury.
A comparison of the risk ratings of five different baggage handling methods indicates the following hierarchy of risk, starting with the lowest:
1. EBL type technology – There is a risk reduction for the external worker in terms of postural improvement for an EBL with a height adjusting and extending belt, however, for other EBLs without this capability the risk is the same as that for a conventional belt loader. There is a considerable risk reduction for the internal worker through the automation of the transfer of the bags down the hold, the reduction in lifting required, and the posture when lifting. There are other approaches that perform similar functions, such as the combination of moving hold floor and advanced beltloader technology (e.g. SCLS and RTT Longreach).
2. Beltloader – The vertical lift region when using a belt loader generally remains above knee and below shoulder level. When poorly set up the there may be an increased tendency for trunk twisting and/or sideways bending. Compared to the EBL, there is an additional need to manually move items along the hold. This function needs to be performed by an extra worker positioned within the hold doorway for on-loads, and by the un-stacking worker during off-loads. For the internal stacking and un-stacking workers, the risks are the same as for the Mallaghan LBT90 and direct to hold methods.
3. Mallaghan LBT90 – The change in risk associated with the Mallaghan LBT90 is only for the external workers on it. The vertical lift region is similar to that observed when using a belt loader, and reach distances to grasp and place items are generally improved compared to using a beltloader. There is a risk that the hand distance from the lower back is increased if the belt mechanism fails or jams temporarily. Also, if workers then have to stand on the belt to move the bags there is a risk of slipping. The external handler will generally have the additional risk associated with transferring the bags down the hold to the in-hold stacker. Due to the relative position of the stack and the hold, there is considered to be an increased tendency for trunk twisting, but in our observations the proportion of time spent in these postures was small. The platform surface has the potential to be slippery. For these reasons the risk is ranked slightly higher than for belt loader use. However, there are no baggage carts required, avoiding the possibility that they might be moved manually.
4. Direct to hold from ground level – The vertical lift region can be between cart and above head height depending on the sill height of the hold door. There is also the additional risk associated with reaching to the opposite side of the cart compared to the Mallaghan LBT90. The external handler will generally transfer the bags down the hold to the in-hold stacker.
5. Direct to hold using a flatbed truck – The vertical lift region occurs between close to floor level and shoulder level. Depending on the headroom, the hold doorway can restrict the external handlers posture. There is also a tendency for both trunk twisting and sideways bending for the external worker at the hold doorway. There is an increased risk of a fall from low height due to working on an open platform that has the potential to be slippery. The need for the external worker to transfer bags down the hold remains. For these reasons the risk is considered to be greater than when loading direct to hold from ground level.
The EBL technology trialled in this project reduces the risk of injury primarily through the mechanisation of the transfer of bags down the hold and the use of height adjustable belts. The outcome of the trial is that this type of technology can significantly reduce the risk of injury, particularly to the internal stacker. The following comments apply to any EBL that has similar operational features to that studied. Further observations relating to the use of the EBL include:
For handlers working on the ramp (regardless of conveyor belt use)
For work in the hold