Construction Hand Arm Vibration: Inspection and Enforcement Guidance
This OG provides guidance applying the EMM for construction hand-arm vibration (HAV) risks. It focuses on common issues and high-risk activities, prioritising those with the potential for significant exposure/risk of ill-health.
HAV is a commonly encountered health topic for Inspectors involving the use of hand held power tools (such as grinders or hammer drills), hand guided machinery (such as plate compacters) or hand fed machines (such as pedestal grinders). The Control of Vibration at Work Regulations (CVAWR) 2005 is the primary legislation governing this subject. This guidance assists Inspectors in reaching proportionate enforcement decisions to control and manage construction hand HAV risks. Prolonged and regular exposure to vibration can cause permanent, painful and disabling disorders of the nerves, blood supply, joints and muscles of the hands and arms. These disorders are collectively known as Hand Arm Vibration Syndrome (HAVS). Construction workers are about six times more likely to be prescribed with a vibration related diseases under the Industrial Injuries Disablement Benefit than in any other sector.
Inspectors should assess on-site HAV control and management measures for high-risk activities against the control standards set out in HSE guidance (on the web and in the general HAV OG) and common issues identified in this OG against the ‘duty holder standards’ set out in HSE guidance. Inspectors should give priority to preventing the risk (i.e. elimination and control), managing exposure and arrangements for managing the symptoms (i.e. health surveillance). Focus particularly on those high-risk activities and common issues where inadequate controls can result in an extreme risk gap under the EMM. This guidance sets out the steps Inspectors should take to assess the risks and apply the EMM. It also advises on the initial enforcement expectation (IEE) according to the level of control found relative to the expected control standard.
Step 1: Determine risk
Inspectors should consider the work activities to establish the nature of the hazard and the level of the risk present on site. The information to consider is set out in Appendix 1. Gathering and recording this information is important for supporting any subsequent action taken.
Step 2: Dealing with urgent matters: the risk of serious ill-health
Some activities can expose workers to HAV levels that are sufficient to create a risk of a serious health effect. These activities are set out in Appendix 3. Inspectors should deal with these situations as a priority to ensure the extreme risk is prevented / effectively controlled (e.g. by issuing a PN).
Step 3: Dealing with other matters through the EMM
Where inadequate control is found in less urgent/serious situations, Inspectors should determine the risk gap and IEE using the Enforcement Management Model (EMM). The basis for applying the EMM to Construction HAV is explained in Appendix 2.
Inspectors should focus on the high-risk activities set out in Appendix 3. The HAV control described in the Tables in Appendix 3 have been established as good practice and will often be reasonably practicable, depending on local circumstances.
The EMM has been used to determine the IEE for deficiencies in control for high-risk activities (Appendix 3). The IEE has also been determined for management arrangements (Appendix 4). Dutyholder and strategic factors should be applied as normal.
Step 4: Enforcement action
The emphasis for enforcement of the Control of Vibration at Work Regulations should be to secure elimination of risk from HAV, or reduction of exposure and risk to as low as reasonably practicable (ALARP), by organisational and technical measures, where exposures are likely to exceed the exposure action value. Enforcement of regulation 6(2) will usually be appropriate, together with enforcement of Reg 7 and 8 as required.
Notices should be in accordance with the EMM, Enforcement Policy Statement and the information in this document. In some cases, both a PN and IN may be served to deal with the same set of circumstances – the former to stop an extreme risk of serious personal injury and the latter to secure longer-term compliance.
Proactive prosecutions should be considered where:
- Well established control strategies are completely inadequate (e.g. no or wholly ineffective) AND
- There has been a sustained and very significant risk to workers health (e.g. regularly doing higher risk tasks without any or wholly ineffective controls)
It is advisable that a Noise and Vibration Specialist Inspector is consulted if prosecution is proposed.
Note: Always discuss any enforcement on quality of health surveillance provision with an Occupational Health Inspector before taking action. If it is absent and exposure above the action value then consultation is not necessary.
The construction industry has high levels of ill-health. Exposure to HAV in construction can come from known high risk processes, use of power tools or other vibrating equipment.
Duties of employers under the CVAWR are dependent upon the daily personal exposure of employees. The employee’s daily exposure to vibration depends on the levels of the vibration generated by processes or power tools used and the corresponding exposure times (i.e. total ‘finger on trigger time’). There is an Exposure Action Value of 2.5 m/s2 (or 100 exposure points) and an Exposure Limit Value of 5m/s2 (or 400 exposure points).
Prolonged and regular exposure to high HAV levels can affect the workers’ health, resulting in painful and disabling disorders of the nerves, blood supply, joints and muscles of the hands and arms. These disorders are collectively known as hand arm vibration syndrome (HAVS). The symptoms affecting the blood supply to the fingers are commonly known as vibration-induced white finger (VWF). The risk of onset or worsening of HAVS increases with daily exposure and varies widely between individuals.
This OG assists Inspectors in reaching proportionate enforcement decisions. It focuses on high risk tasks, prioritising those with the potential for significant exposure.
There are no special organisational requirements.
Inspectors should pay particular attention to:
- Information on vibration contained within the health section of the construction web site
- CVAWR guidance
- FAQs on construction HAV
Staff should also be aware of and familiar with other relevant Operational Guidance. In particular:
- Enforcement Management Model – General guidance on application to health
- The vibration section of the HSE website
Construction Sector - Health Risk Management Unit