HSE national priorities for delivery in 2010/11 include a combined workstream to promote the new guidance for motor vehicle repair (MVR) HSG 261 ‘Health and safety in motor vehicle repair and associated industries’ and implement the SLIC campaign on risks from hazardous substances in SMEs by application in MVR. There are 2 phases - a promotional phase in the first half of the workyear and an enforcement phase between October and December. These activities contribute towards the Health and Safety Strategy goals to support SMEs, creating healthier safer workplaces and building competence.
HSG 261 ‘Health and safety in motor vehicle repair and associated industries’ was published in October 2009. It updated, combined and replaced advice contained in HSG 62 (Health and safety in tyre and exhaust premises) and HSG 67 (Health and safety in MVR). Significant revisions included guidance on the use of isocyanate paints. This reflected developments agreed with industry stakeholders on the appropriate controls during paint spraying and which were promoted at a series of 30 Safety and Health Awareness Days (SHADs). The SHADs were held throughout the UK between 2004 and 2008 and were successful in engaging the key industry stakeholders and many MVR bodyshops. A revised version of INDG 388 ‘Safety in Motor Vehicle Repair - working with isocyanate paints’ was published in December 2009.
Coincidentally SLIC agreed a cross-European campaign on risks from hazardous substances in small and medium sized enterprises (SMEs) for 2010. This provided an option for member states to select one or more industries/sectors (from MVR, bakeries, woodworking/furniture production, cleaning) for activity. The campaign calls for promotional activity between April and September, followed by an enforcement phase between October and December. The opportunity has been taken in GB to combine the work to promote the MVR guidance with the SLIC campaign. The prime target will be control of isocyanate based paints during vehicle spraying, but could also include control of exposure to other hazardous substances such as exhaust fumes, used engine oils, solvents and glues.
The HSE guidance on MVR, in particular control of isocyanates during MVR paint spraying, will be promoted as the standard to be achieved throughout Europe, so it is important that the UK is seen to be fully participating in the campaign. While MVR SHADs have recently been conducted the combination of the SLIC Campaign, the recently published HSG 261 and INDG 388, the revised HSE MVR website and the now broad acceptance of the MVR bodyshop industry for the control measures provide an opportunity to tackle bodyshops that were previously unreached, unwilling or unconvinced, and to consolidate the appropriate controls in those who have acted.
Under the Health &Safety (Enforcing Authority) Regs 1998 MVR was allocated to HSE, while tyre and exhaust premises were enforced by LAs. However, over the past 10 years or so, many tyre and exhaust outlets have diversified to include vehicle servicing and parts replacement, and there is now little distinction between the different types of premises involved in mechanical repair/servicing. Additionally, local arrangements between HSE and LAs (including premises transfer and joint warranting) have resulted in some LAs visiting the full range of MVR premises, including bodyshops. Consequently, LAs are encouraged to participate in this activity. This could be through joint activity with HSE, where appropriate.
To meet the SLIC campaign requirement for activity in two phases, those electing to carry out this activity should:
a) Phase 1 - Arrange local promotional activity, particularly but not exclusively based on HSG 261 and INDG 388 (rev 1), during the period April - September 2010. The extent and type of activity is for local determination but could be HSAO/EHO led, targeted mailshots and/or SHADs, etc.
b) Phase 2 - Carry out visits to a range of MVR premises during the period September - December, to both those who have received the promotional information (or attended the SHAD), and to some premises that have not. For the purposes of SLIC ‘enforcement activity’ should be interpreted as any visit to an MVR premises which involves inspection activity to determine the extent of penetration of the guidance material, and the degree of implementation of the recommendations. Phase 2 could provide formal enforcement opportunities.
The SLIC campaign is aimed at SMEs with 10 - 50 employees but for the purposes of this workstream can be interpreted as including MVR micro-businesses (<10 workers). This size range is likely to include most MVR premises.
Greatest benefit from the campaign could probably be achieved by targeting MVR bodyshops that did not attend the previous Isocyanate SHADs. Lists of those invited to (and those who attended) local SHADs may still be available within Divisions.
a) Promotional activity
The European campaign will be launched centrally, probably at the MVR H&S Forum meeting in late March. Launch plans include a scroll banner on the HSE website, an additional page on the MVR website, press notice for the trade press.
A SLIC campaign logo, mascot, flyer, posters and other stationary will be available as downloadable items for local promotional purposes.
Materials such as video clips for SHADs, or other local promotional events, are available on the HSE MVR website. There is extensive guidance on running an MVR bodyshop SHAD (Organisational protocol for MVR bodyshop Safety Health and Awareness Days (SHADs) 2006 - 07), which may be useful for organisers. Support for SHADs/promotional events may be available through the occupational hygiene and/or occupational health sections of the local Specialist Groups. The Sector may also be able to identify industry speakers, if required, for SHADs/promotional events.
b) Enforcement
The key messages, risks, controls, etc and enforcement guidance in the October 2007 (version 7) of the Topic pack ‘Control of isocyanate exposure in motor vehicle repair (MVR) bodyshops Disease Reduction Programme’ remain current.
Additional guidance is available in the following HSE Sector Information Minutes (SIMs):
Information in HSG 261 and supporting INDGs sets out good industry practice, and local HSE or Sector advice should be sought if it is intended to use it as a standard for formal enforcement action.
It will be necessary to feedback to SLIC information on the type, extent and effectiveness of the promotional and inspection/enforcement activity (including detail of any formal enforcement action) by the end of December 2010.
A short report should be sent to Manufacturing Sector detailing the Phase 1 promotional activity before end of October 2010. A template is attached to assist, but the relevant information could be provided in another format, if appropriate.
For LA inspectors involved in the Phase 2 enforcement phase, a report should be sent to HSE Manufacturing Sector as soon as possible, preferably before the end of December 2010, which should include the information shown in the attached template. If using the nationally agreed Case Study Form please include the information shown in the attached template.
1. Type of promotional activity eg mailshot, SHAD, other
2. Numbers of MVR premises contacted/attended SHAD etc
3. Approximate percentage (of those in 2 above) involved in spraying isocyanate paints
1. Numbers of premises visited
2. Numbers that had received information on HSG261 through the promotional activity
3. Numbers that had received information on HSG261 through other route(s).
4. Comments on the suitability for control of hazardous substances
5. Details of any formal enforcement action taken
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Making a difference - Judith Hackitt