a. Is a risk assessment made for any new or modified activity, process, plant, equipment, substance, premises etc.?
b. Have all existing activities, processes, plant, equipment, substances and premises etc. been assessed for risks?
c. Where relevant, do risk assessments take account of young persons and expectant mothers?
d. Is the responsibility for carrying out the risk assessment clearly allocated?
e. Is there provision for the co-ordination of risk assessments?
f. Is the assessment recorded?
g. Are the results of the assessment evaluated to decide whether controls are effective, or if more can be done to reduce risks?
h. Is the result of the assessment communicated to those affected by it (employees and contractors)?
i. Are there instructions to indicate when an assessment should be reviewed?
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)
• 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.
a. Have special occupational health hazards (e.g. upper limb disorders, asthma, deafness) been identified and consideration given to health surveillance where appropriate?
b. Have you identified any jobs for which a health assessment is necessary before recruitment?
c. Have you made arrangements for obtaining medical advice if required on occupational health questions?
d: Do you have arrangements for reviewing sickness absence and helping employees to return to work after serious illness?
1. Health Surveillance at Work, HSG61, HSE 1999, ISBN 0 7176
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.
• 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.
a. Has an exercise to identify all hazardous substances been completed?
b. Have you recorded an assessment of the risks created by all hazardous substances used in, or arising from, work activities?
c. Does your assessment include information on the :-
(ii) methods of use?
(iii) risks to health?
(iv) control measures?
(v) actions, if any, required to prevent or control exposure?
d. Have you communicated your assessment to those who need to know - operators and supervisors?
e. Are the control measures in place, properly used, examined, and maintained?
f. Are there routine examinations of engineering controls (LEV) and personal protective equipment?
g. Have you identified any processes for which work place monitoring may be appropriate (e.g. airborne dusts and fumes)
h. Have you identified any employees for whom health surveillance may be appropriate?
i. Are records of equipment examinations, work place monitoring and health surveillance maintained?
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)
• 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.
a. Has an action plan been drawn up with objectives for improving
and maintaining the way health and safety is managed?
b. Does the action plan identify priorities: what needs doing straight away and medium/ longer-term objectives?
c. Is there a link between the health and safety action plan and workplans of individuals in the company?
a. Are the requirements of the Construction (Design and Management) Regulations 1994 adhered to for all relevant building construction and demolition work?
b. Is the company/organisation aware of its duties as the
client under the Construction (Design and Management) Regulations
1994 including the appointment of a Planning Supervisor and
Principle Contractor and ensuring that a project health and
safety file is available upon project completion?
c. Is competent advice sought so that health and safety aspects are taken into account when designing, selecting and purchasing buildings, structures, extensions or modifications that are new to the company?
d. Is the competent adviser kept fully informed as to the use to which buildings etc. are to be put?
e. Do any new premises, extensions or comply with the requirements of the Workplace (Health, Safety and Welfare) Regulations?
• 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.
a. Are the requirements of the Construction (Design and Management) Regulations 1994 adhered to for all relevant engineering construction and demolition work?
b. Do those responsible for specification or purchase of work equipment cross check to ensure that adequate information and design features are provided to fulfil health and safety standards?
c. Is past health and safety performance considered when selecting suppliers equipment?
d. Is a check made to ensure that the manufacturer or importer of new equipment complies with machinery safety regulations and that the equipment carries the CE mark?
e. Is a check made to ensure that adequate design features and information are provided so that the equipment can be installed, set, used, maintained, dismantled or disposed of safely?
• 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).
a. Is health and safety considered in all potential substance purchase decisions?
b. Is health and safety data, exposure limits, outcome of tests etc. sought before a purchase decision made?
c. If found to be hazardous, are ways of avoiding use of the substance considered before purchase?
d. Is action taken to ensure that hazardous substances delivered are accompanied by warnings and material safety data sheets to help ensure that they are safe when handled, stored, used or disposed of?
• 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.
1. Managing Construction for Health and Safety: The
Construction (Design and management) Regulations 1994 and
Approved Code of Practice, L54, HSE 1995, ISBN 0 7176 0792
2. The Provision and Use of Work Equipment Regulations (PUWER) 1998, Approved Code of Practice and Guidance, L22, HSE 1999, ISBN 0 7176 1626 6.
3. General COSHH ACoP, Carcinogens ACoP and Biological Agents ACoP: Control of Substances Hazardous to Health Regulations (COSHH) 1999 and Approved Codes of Practice, L5, HSE 1999, ISBN 0 7176 1670 3.
4. Workplace (Health, Safety and Welfare) Regulations 1992, Approved Code of Practice and Guidance, L24, HSE 1992, ISBN 0 7176 0413 6.
5. Safety Requirements for Textile Machinery, BS EN ISO 11111:1995, British Standards Institution 1995.
6. The Supply of Machinery (Safety) Regulations 1992, HMSO 1992.
7. Supplying New Machinery: Advice to suppliers, INDG270, HSE 1998, ISBN 0 7176 1560 X.
8. Buying New Machinery: A short guide to the law, INDG271, HSE 1998, ISBN 0 7176 1559 6.
• Implementation of any preventative and protective
measures must be on the basis of the Principles of Prevention
specified in Schedule 1 of the MHSW Regs.
• The health and safety programme, which defines the scope of the health and safety arrangements (SMS), identifies all areas relevant to the control of health and safety (and environment). An employer must have such arrangements and if employing five or more persons must document them ( MHSW Regs.).
• A safety management standard and supporting documentation will exist for each area. The programme should include risk assessment, safe operations, training, management of change, emergency preparedness, SMS monitoring (pro-active and reactive) and management review of the SMS. The number of areas will depend on the nature of the organisation and its operations but should cover the above as a minimum. Look for a schedule of SMS standards.
• Every employer must have procedures for responding to serious or imminent danger (MHSW Regs.). These will cover all hazards identified in the risk assessments for the site and include evacuation of employees from the premises. These procedures may be documented in an emergency plan.
• Every employer must establish the necessary contacts with external emergency services to ensure adequate rescue, first aid, and medical care resources are available in an emergency (MHSW Regs.).
• When two or more employers share a workplace, each must co-operate with the other(s), and take reasonable steps to co-ordinate safety including the sharing of risk information (MHSW Regs.).
• Employers have a duty of care to the temporary employee, and to the employee of an employment agency. This requires the provision of information on special occupational qualifications or skills and health surveillance prior to the commencement of duties (MHSW Regs.)
• Every employer must carry out a suitable and sufficient risk assessment in respect of the risks to which his own employees or others may be exposed (MHSW Regs.). A risk assessment means identifying the hazards and evaluating the risks from them. Additionally, there must be a process for applying risk controls to eliminate or reduce them. The policy should summarise this.
• The requirement for, and content of, rules for contractors is detailed in part 9.10. The location of such rules should be given in the Policy Statement.
• The requirement for, and content of, rules for visitors is detailed in 9.10. The location of such rules should be given in the Policy Statement.
• Employers have a duty of care not only to their own workpeople, contractors and visitors, but also to members of the public (HASWA). The duty extends to risks to the public, for example, from fire, explosion, or from falling objects or harmful emissions. Reference may be made to any separate environmental policy the company may have. Environmental matters are covered in part 8 the Audit.