PART 3- HOW YOU PLAN FOR AND CONTROL HEALTH AND SAFETY

References

1. Successful Health and Safety Management, HS(G)65, 1997, ISBN 0 7176 1276 7.
2. Five Steps to Risk Assessment, INDG163, HSE 1998, ISBN 0 7176 1565 0.
3. A Guide to Risk Assessment Requirements: Common provisions in health and safety law, INDG218, HSE 1996, ISBN 0 7176 1211 2
4. Health and Safety Organisation, KDL11, available from KDLI Publications (Tel: 0161 624 9749) or from the Knitting Industries Federation Ltd. (Tel: 0116 254 1608).
5. Briefing Paper No.5: Assessments, November 1992, Briefing Paper available from BCIA Ltd. (Tel: 0171 636 7788) or from GMB Clothing and Textile Section (Tel: 0181 947 3131)

Help

• Specific duties to carry out assessments arise in most modern safety legislation including the Noise at Work Regulations (see Part 9.1), the Control of Substances Hazardous to Health Regulations (COSHH) see Part 3,1.3) and the Fire Precautions (Workplace) Regulations (see part 6.9). Assessments carried out for the purposes of other Regulations do not normally need to be repeated, provided they remain valid and cover all significant risks. Basically what is required is an identification of the hazards which a particular activity may present (i.e. its potential for causing human injury, damage to property, damage to the environment or some combination of these), and estimations of the consequence and likelihood of that hazard being realised. The association/combination of the consequence and likelihood is the risk. Qualitatively the consequence may be categorised as slightly harmful, harmful and extremely harmful. Similarly the likelihood may be expressed as likely, unlikely and highly unlikely. There should be a risk assessment procedure covering the above.

The purpose of the assessment is to establish what risk control measures need to be taken to comply with health and safety law.

Risk assessment is necessary for the management of changes to operations.

• To manage safety effectively, existing activities must be assessed for risks. There should be a schedule of risk assessments for all current operations.
• Employers must take account of the capabilities and vulnerabilities of young persons and new or expectant mothers when assessing the risks to which they will be exposed (MHSW Regs.). This should be included in the risk assessment procedure.
• Who carries out the assessment will depend on the activity. For most activities in the textile industry it will probably be sufficient for assessment to be carried out in-house, although there may be a need for some specialised health and safety training. For more complex and specialist situations (e.g. noise, some hazardous substances, radiation) specific expertise may be necessary and it is important to recognise when outside help should be called in. The risk assessment procedure should include these provisions and identify the posts.
• It is important that consistent standards are applied throughout the company, and if more than one person is responsible for carrying out assessments then some central oversight is necessary.
The risk assessment procedure should identify the provision for this.
• The "significant findings" of assessments need to be recorded by employers who employ more than 5 persons. The record should comprise an effective statement of hazards and risks, which leads to the actions necessary to protect employees. The findings should be used to develop risk controls e.g. safe working procedures and workplaces, within the health and safety arrangements (SMS).
• The results of a risk assessment must be considered in line with the General Principles of Prevention (Schedule 1, MHSW Regs.). This is the application of risk management that seeks to avoid risks if possible or reduce by engineered means to acceptable levels prior to the application of procedural controls and protective equipment.
• Managers, supervisors and workers should have the assessment brought to their attention. It should part of any training.
• Employers must review an assessment when the situation changes or new experience shows the assessment to be inadequate. The review process and its frequency should be given in the risk assessment and the management of change procedures.

References

1. Health Surveillance at Work, HSG61, HSE 1999, ISBN 0 7176 1705 X
2. Management of Health and Safety at Work Regulations, Approved Code of Practice and Guidance, L21, HSE 1999, ISBN 0 7176 2488 9.
3. Occupational Health, KDL12, available from KDLI Publications (Tel: 0161 624 9749) or from the Knitting Industries Federation Ltd. (Tel: 0116 254 1608)
4. Health surveillance in noisy industries, INDG193, HSE 1993.

Help

• Health Surveillance is a requirement of Regulation 6 of the Management of Health and Safety at Work Regulations (REF 2). Health surveillance is required in relation to certain hazardous substances (see questions on COSHH). Consider also whether other potential problems may justify health surveillance e.g. repetitive strain injuries or noise above 95db(A). Early detection can prevent health problems from becoming serious and enable people to remain at work instead of requiring sick leave.
• Capacities for heavy physical work and good colour vision are examples of obvious health pre-requisites for certain jobs. Expert medical opinion may be necessary, however for certain jobs and certain people - e.g. the desirability of employing someone with chest problems in a dusty process.
• The Employment Medical Advisory Service is able to provide names of medical practitioners who are experienced in occupational health matters and able to give advice.
• An early return to work after absence is in everybody's interests. Depending on the circumstances this may or may not require expert advice.

References

1. COSHH - a brief guide to the regulations, INDG 136, HSE 2003
2.General COSHH ACoP,: Control of Substances Hazardous to Health Regulations (COSHH) 2002 and Approved Codes of Practice, L5, HSE 2002, ISBN 0 7176 2534-6.
3. A Step by Step Guide to COSHH Assessment, HS(G)97, HSE 1992, ISBN 0 7176 1446 8.
4. Health Surveillance under COSHH, guidance for employers. HSE, 1990, ISBN 0 7176 0491 8.
5. COSHH Essentials - Easy steps to control chemicals, HS(G)193, HSE 1999, ISBN 0 7176 2421 8.6. Ventilation, Confederation of British Wool Textiles, WSHS1 Rev.3/98
7. Dyeing and Finishing Information Sheets, HSE:
1: Dyes and chemicals in textiles finishing, an introduction
2: Non-dyestuff chemicals, safe handling in textile finishing
3: Dyestuff, safe handling in textile finishing
4: Hazards form dyes and chemicals in textile finishing, a brief guide for employees
5: Reactive dyes, safe handling in textile finishing
6: Dust control in dyestuffs handling
7: Selection and safe use of spotting solvents in textile and clothing industries
8. Anthrax: Safe working and the prevention of infection, HS(G)174, HSE 1997, ISBN 0 7176 1415 8.
9. Chemical Safety Summary Poster, HSE, ISBN 0 7176 1521 9
10. Control of Cotton and Wool Process Dusts, HSE742/2, information sheet which is not on general publication but is accessible from HSE
11. Anthrax (pocket card), MS(B)3, HSE
12. Briefing Paper No.1: COSHH Control of substances hazardous to health, June 1998, Briefing Paper available from BCIA Ltd. (Tel: 0171 636 7788) or from GMB Clothing and Textile Section(Tel: 0181 947 3131)
13. Briefing Paper No.7: Formaldehyde in Fabrics, July 1997, Briefing Paper available from BCIA Ltd. (Tel: 0171 636 7788) or from GMB Clothing and Textile Section(Tel: 0181 947 3131)
14. Chemical Safety, KDL7, available from KDLI Publications (Tel: 0161 624 9749) or from the Knitting Industries Federation Ltd. (Tel: 0116 254 1608)

Help

• See Regulation 6, REF 2. No hazardous substance should be used unless an assessment has been prepared. Hazardous substance is defined in the Regulations and includes any substance labelled very toxic, toxic, harmful, corrosive or irritant, substances for which occupational exposure limits have been set by the Health and Safety Commission, pathogenic micro-organisms and dust of any kind which is present in substantial concentrations in air.
• Safety Data Sheets containing the following information must be provided :
• Identification of substance or preparation, and company or undertaking, composition of, and information on, the ingredients identification of hazards first-aid measures fire fighting measures accidental release measures handling and storage exposure controls and personal protection physical and chemical properties stability and reactivity toxicological information ecological information disposal considerations transport information regulatory and other information.
• An Approved Code of Practice "Safety Data Sheets for Substances and Preparations Dangerous for Supply" will be consulted by suppliers when drawing up data sheets. Data sheets must be provided free of charge on, or before, initial substance supply. Suppliers must ensure data sheets are kept up-to-date and when revised the revision is provided to all those who have been supplied with the substance in the previous year.
• Check not only the approved method of use but also the actual working practices adopted by employees - they often bear little resemblance. Look for likely exposure during storage, transport, handling, use/processing and in disposal (e.g. of containers).
• "Risk" is defined as the likelihood that a hazard will be realised and cause actual harm - it depends on the nature of the hazard and the way in which people may be exposed.
question d requires an objective examination of existing control measures and this may include measurement (e.g. of airborne contaminants).
• The first duty is to prevent exposure altogether (e.g. by ceasing to use the hazardous substance) but this is not often a realistic option and the duty then becomes one of controlling the exposure. Regulation 7 (REF 2) and the Approved Code of Practice give extensive guidance on control.
• The assessment should be written down unless it is so simple that it can be easily repeated (Reg. 6 and ACOP). Communication to employees is required by Regulation 12 which requires that they be provided with information, instruction and training. Supervisors need the information in order to ensure that control measures are properly followed and maintained.
• It is nonsense to agree on control measures and then fail to ensure that they are correctly implemented. Regulation 9 and the ACOP have specific requirements on maintenance of control measures. Note in particular the requirement that local exhaust ventilation is examined and tested at least every 14 months, and that respiratory protective equipment should be examined at least every month (ACOP para. 66).
• Monitoring may be appropriate for dustier processes. Guidance on when to monitor for textile dust can be obtained from REF 10. See Regulation 10 and the Approved Code of Practice.
• For question g, see Regulation 11 and the Approved Code of Practice. Health surveillance may range from simple record keeping, through regular checks by a responsible person, to full-scale medical surveillance. In practice health surveillance is only likely to be necessary in the textile industry where there is exposure to textile dust or to reactive dyes. Guidance on reactive dyes can be found in Ref. 7. Guidance on health surveillance for wool, cotton and flax dusts is due out in 2001.

Help

• An action plan is needed to decide what should be done to make the necessary improvements. Your results from this audit will guide you in identifying areas for improvement and setting out what is to be achieved and when. Priority should be attached to the higher risk activities.
• If the initial diagnosis suggests a poorly developed system for managing health and safety, one early priority will probably be training people to raise awareness and give people the knowledge to implement the plan. As improved control becomes established, the plan may shift towards improving management and risk control systems. Health and safety plans can operate at several levels in a company: larger companies may have plans for different parts of the company and link into workplans for individuals.

Help

• Those authorised to place contracts or project manage building construction and demolition work should be fully conversant with the requirements of the Construction (Design and Management) Regulations.
• Competent advice should be sought from an architect, surveyor, consulting engineer etc. who would ensure that plans and premises comply with the minimum standards under building and fire regulations.
• This would normally be achieved by the competent person referred to in Part 1.2 being made fully aware by the company (the purchaser) of the uses to which the building etc. will be put prior to a purchase decision being made.
• The Workplace (Health, Safety and Welfare) Regulations place detailed requirements on premises, extensions and modifications. These include requirements for handrails, rest rooms for pregnant women and emergency lighting.

Help

• Question a. Those authorised to place contracts for, or project manage engineering, construction and demolition work should be fully conversant with the requirements of the Construction (Design and Management) Regulations.

• Question b. Purchase/procurement procedures should incorporate regulatory requirements. There are considerable responsibilities laid on the designer, manufacturer, importer or supplier to ensure that articles for use at work are tested and safe (HSW Act and Supply of Machinery Regs.). Nevertheless it is good practice for the prospective purchaser to make enquiries of the supplier and/or importer of the product safety record of the designer and/or manufacturer. References may be obtainable from other users.

• Question d. The Supply of Machinery (Safety) Regulations 1992 govern the supply of machinery. Machinery supplied in the UK, including imports must:

(i) Satisfy wide ranging health and safety requirements, for example, on construction, moving parts and stability;

(ii) In some cases, have been subjected to type examination by an approved body;

(iii) Address the recommendations made in standards such as BS EN ISO 11111 Safety Requirements for Textile Machinery;

(iv) Carry CE marking and other information; and

(v) The manufacturer or the importer will generally have to be able to assemble a file containing technical information relating to the scheme

The principal consideration is whether the machinery meets the Essential Health and Safety Requirements. These cover guarding, control systems, noise, vibration, lighting, electrical hazards and other items.

The responsibility for compliance rests with the manufacturer or importer who supplies the machinery into the EC. Remember that if you buy new machinery outside the EC for use inside the EC, you may effectively be the importer and hence carry the above responsibilities. If in doubt, further advice should be sought.

• Question e. All articles supplied for use at work must be safe when being set, used, cleaned or maintained (HSWA). They must also be suitable for the purpose for which they are used or provided (PUWER).

Help

• Purchase/procurement procedures should incorporate regulatory requirements.

• All substances (solid, liquid, gas, vapours or dust) which have potential to cause harm must be assessed for risk (COSHH Regs.). The process of assessment is best started prior to purchase.

• Question c: If found to be hazardous, consideration should be given, prior to purchase, to a change in processing that avoids the need for use of the substance, or alternatively the use of a safer substitute.

• Question d: the purchase order should specify this requirement.