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PART 13 - HOW YOU CONTROL PROCESS RISKS WHICH APPLY LARGELY TO THE FOOTWEAR INDUSTRY

QUESTION SET


1. Clicking Presses

a. Are all two handed controls on clicking presses working correctly?
b. Do you check that two-handed controls are working correctly?
c. Are knives stored and carried safely?
d. Are working areas/Pedestrian walkways clearly marked?
e. Are pedestrian walkways kept clear?
f. Do employees use pedestrian walkways where required?
g. Do you ensure employees do not distract operators when they are working at the clicking presses?
h. Have working blocks recently been checked, turned and are they kept in good order?

Help

  • Footwear Industry Health and Safety Committee Guidance Note 'Slips Trips and Falls' (8-2001), and Audit 9.6 and help set.
  • Footwear Industry Health and Safety Committee Guidance Note 'The Provision and Use of Work Equipment Regulations' (3-2000).

Two handed control devices should meet the following standard:

  • The hand controls should be placed, separated and protected as to prevent spanning with one hand only; being operated with one hand and another part of the body, or being readily bridged.
  • It should not be possible to set the dangerous parts in motion unless the controls are operated within approximately 0.5 seconds of each other. Having set the dangerous part in motion, it should not be possible to do so again until both controls have been returned to their off position. This effectively discourages two people operating the machine together by coordinating their actions, and also prevents the operator from locking one control in the start position which would allow him to operate the machine by means of the other control leaving one hand free.
  • Movement of the dangerous parts should be arrested immediately or, where appropriate, arrested and reversed if one or both controls are released whilst there is still danger from the movements of these parts.
  • The hand controls should be situated at such a distance from the danger point that, on releasing the controls, it is not possible for the operator to reach the danger point before motion of the dangerous parts has been arrested, or where appropriate, arrested and reversed.

Detailed design specifications can be found in British Standard BS EN 574:1997 'Safety of machinery-Two-handed control devices-Functional aspects-Principles for design'.

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2 Travelling Head Presses

a. Is the correct operation of the guarding (photo-electric, interlocking, fixed, and two handed controls) checked daily?
b. Have working blocks recently been checked, turned and are they kept in good order?

Help

  • Footwear Industry Health and Safety Committee Guidance Note 'The Provision and Use of Work Equipment Regulations' (3-2000).
  • Audit 3.1.3 and help set (COSHH).

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3 Bottom Stock

a. Is hearing protection and eye protection worn whilst working at shanking machines?
b. Are guards in place on shanking machines?
c. Is hearing protection worn whilst working at channelling, bevelling and grooving machines?
d. Are guards in place for channelling, bevelling and grooving machines?
e. Is adequate exhaust ventilation provided at channelling, bevelling and grooving machines?

Help

  • Footwear Industry Health and Safety Committee Guidance Note 'The Provision and Use of Work Equipment Regulations' (3-2000).
  • Footwear Industry Health and Safety Committee Guidance Note 'Turn it Down' (guidance on noise control) (1-1999), and Audit 9.1 and help set.
  • Audit 3.1.3 and help set (COSHH).

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4 Closing Preparation

a. On skiving machines is the knife correctly adjusted to minimise the gap to prevent injury?
b. On skiving machines is the bottom plate frequently checked for wear to ensure safe operation?
c. Where lubricants are used are the risks to health (dermatitis, fume inhalation etc) prevented or adequately controlled?
d. On splitting machines is the knife correctly adjusted to prevent injury?
e. Is adequate eye protection worn when sharpening blades on splitting machines, where appropriate?
f. Have you prevented or adequately controlled the risk from exposure to dust in splitting and skiving operations?
g. Where local exhaust ventilation is provided, is it adequately maintained?
h. Are measures in place to prevent the ignition of leather dust in local exhaust ventilation systems following the sharpening of knives and/or blades?

Help

  • Footwear Industry Health and Safety Committee Guidance Note 'The Provision and Use of Work Equipment Regulations' (3-2000).
  • Footwear Industry Health and Safety Committee Guidance Note 'Fire' (9-2002), and Audit 9.3 and help set.
  • Audit 3.1.3 and help set (COSHH).

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5 Closing

a. If there is a risk of eye injury from needle breakage, are guards fitted?
b. On punching machines, is the gap between punch and component set sufficiently low to prevent finger access?
c. Where hot melt adhesives are used are procedures in place to prevent exposure to fumes from burn-ups?
d. Where hot melt adhesives are used are adequate control measures in place to eliminate the risk of injury from burns?
e. On eyeletting machines are finger guards in place at all times and for all operations?
f. Has the risk from the exposure to noise whilst using eyeletting machines been prevented or adequately controlled?

Help

  • Footwear Industry Health and Safety Committee Guidance Note 'The Provision and Use of Work Equipment Regulations' (3-2000).
  • Footwear Industry Health and Safety Committee Guidance Note 'Fire' (9-2002), and Audit 9.3 and help set.
  • Footwear Industry Health and Safety Committee Guidance Note 'Turn it Down' (guidance on noise control) (1-1999), and Audit 9.1 and help set.
  • Audit 3.1.3 and help set (COSHH).
  • See information on hot melt adhesives under 6.



6 Lasting

a. Where solvents are used, are measures in place to prevent or adequately control exposure (inhalation and skin contact)?
b. Where hot melt adhesives are used are procedures in place to prevent exposure to fumes from burn-ups?
c. Where hot melt adhesives are used are adequate control measures in place to eliminate the risk of injury from burns?
d. Has the risk of ill health (including respiratory sensitisation) from the use of isocyanates been prevented or adequately controlled?
e. Is spacing between workstations sufficient to avoid collision and to allow operatives to work safely?
f. Is hearing protection and eye protection required and if so, is it worn?

Help

Footwear Industry Health and Safety Committee Guidance Note 'Solvents' (1-99), and Audit 3.1.3 and help set.

Footwear Industry Health and Safety Committee Guidance Note 'Isocyanates' (5-1998).

All hot melt adhesives, once melted, will tend to carbonise/burn-up and the higher the temperature the faster this will happen.

  • Follow manufacturer's temperature specifications.
  • Ensure that all operatives, including maintenance staff, receive adequate training.
  • Carbonisation on thermostats will reduce their accuracy and they should be cleaned and maintained on a regular basis.
  • Do not rely on machine indicated temperatures. Use an accurate thermocouple device to actually measure the hot melt temperature rather than rely on the dial indicated temperature.
  • Inaccuracies in temperature can be caused by a deteriorated heating element, which can be monitored by ampage checks.
  • Run the machine at the speed recommended by the manufacturer rather than attempt to run faster by turning up the hot melt temperature.
  • Do not leave the machines at full working temperature for extended periods.
  • Cement in hot melt reservoirs must be regularly checked to maintain the correct level.
    Reservoirs must be regularly checked and cleaned to prevent build up of carbonised material.

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7 Roughing

a. Are measures in place to prevent the ignition of dust from roughing operations (roughing and brush sharpening)?
b. Are employees adequately trained in roughing to control the high risk of injury?
c. Is hearing protection and eye protection required, and if so is it worn?

Help

  • Footwear Industry Health and Safety Committee Guidance Note 'The Provision and Use of Work Equipment Regulations' (3-2000).
  • British Standard BS EN 930:1997 'Footwear, leather and imitation leather goods manufacturing machines. Roughing, scouring, polishing and trimming machines. Safety requirements'.

Training for working at roughing machines should include consideration of the following.

  • To avoid entanglement, loose fitting clothing and jewellery should not be worn and long hair should be protected.
  • Correct plate selection is important, as plates that are too small will allow the wire brush to mushroom increasing the risk of finger injury. Plates that are too large will stop the brush from reaching the upper and cause the shoe to be snatched out of the operative's hand.
  • Plates should be securely fitted to prevent them from becoming loose and increasing the risk of injury.
    Machines should be properly isolated before changing brushes and bands.



8 Sole and Heel Attaching

a. Are employees adequately trained in sole and heel attaching to control the high risk of injury?
b. On the sole laying press, are the employees trained to position the machine arms correctly to prevent the risk of injury from the lasted upper being ejected?

Help

  • Footwear Industry Health and Safety Committee Guidance Note 'The Provision and Use of Work Equipment Regulations' (3-2000).).



9 Moulding

a. Has the risk of ill health (including respiratory sensitisation) from the use of isocyanates been prevented or adequately controlled?
b. Have all practicable steps been taken to prevent burn ups?
c. In the event of a burn up are adequate procedures in place for evacuation, ventilation and correction?
d. Due to the high weight of moulds, have all practicable steps been taken to prevent injury during mould changing?
e. Have adequate steps been taken to prevent handling injuries during raw material transfer?

Help

  • Footwear Industry Health and Safety Committee Guidance Note 'Isocyanates' (5-1998).
  • Footwear Industry Health and Safety Committee Guidance Note 'The Provision and Use of Work Equipment Regulations' (3-2000).
  • Footwear Industry Health and Safety Committee Guidance Note 'Fire' (9-2002), and Audit 9.3 and help set.
  • Footwear Industry Health and Safety Committee Guidance Note 'A Weight Off Your Mind' (5-98), and Audit 9.7 and help set.
  • British Standard BS EN 1845:1999 'Footwear manufacturing machines. Footwear moulding machines. Safety requirements'

All injection moulding compounds will burn-up/carbonise and give off toxic fumes if overheated.

  • Material left in the barrel for longer than the manufacturers recommended times may lead to burn-ups. This can be prevented by regular checks to ensure that element, barrel and nozzle temperatures are set and working correctly and that production screw speeds are set according to manufacturers specifications.
  • Contamination of material in the barrel can lead to nozzle blockage resulting in burn-ups. This can be prevented by regular purges of the system.
  • Manufacturers recommendations on the use of reground materials should be strictly followed
  • Ensure that the machine barrel is emptied when the machine is not in use.



10 Finishing/Cleaning

a. Where solvents and solvent-based substances are used are measures in place to prevent or adequately control exposure by inhalation and/or skin contact?
b. Are employees adequately trained in trimming and scouring to control the high risk of injury?
c. Is hearing protection and eye protection required and if so, is it worn?
d. Is adequate exhaust ventilation provided at all trimming and scouring machines?
e. Is local exhaust ventilation adequately maintained?

Help

  • Footwear Industry Health and Safety Committee Guidance Note 'Solvents' (1-99), and Audit 3.1.3 and help set.

Where solvents are used the following should be considered:

  • Adequate assessments should be carried out. All assessments should be reviewed with sufficient frequency to ensure they are valid.
  • A competent management team should plan assessments, and assessment reviews.
  • The assessment should consider substitution and any health risks associated with the use of substitutes, and should also cover high exposure maintenance work.
  • Local exhaust ventilations should be provided at all appropriate processes and this should be adequately maintained to ensure it is working correctly.
  • Personal protective equipment such as gloves should be properly selected, its correct use and maintenance must be ensured by supervisory staff.
  • There needs to be recognition within the industry that absorption through the skin is a real risk, fingering-in should not take place or washing of hands in solvents.
  • Benches should not be cleaned by wiping with solvents.
  • Plunger cans should be used to prevent evaporation.