Mike Griffiths, HM Inspector of Health and Safety
3 most common causes of Fatal / Life-changing incidents in factories: Falls from Height Workplace Transport Machinery
What issues occur consistently in the incidents that HSE investigates in these 3 categories? What Legislation applies and what does it say? How can these issues be avoided or addressed?
Falls from Height No plan (for the Work at Height) Insufficient competence Incorrect choice of equipment
Falls from Height No Plan Regulation: Work at Height Regulations 2005 (as amended) Regulation 4: Every employer shall ensure that work at height is (a) Properly Planned; (b) Appropriately supervised; and (c) carried out in a manner which is so far as is reasonably practicable safe. Management of Health and Safety at Work Regulations Regulation 3: Every employer shall make a suitable and sufficient assessment of the risks Have a plan! The plan will be informed by the Risk Assessment / Method Statement; and forms part of it. The Plan must be fit for purpose; it must be specific for this piece of work (what about generic risk assessments?).
Falls from Height Insufficient Competence Regulation: Work at Height Regulations 2005 (as amended) Regulation 5: Every employer shall ensure that no person engages in any activity, including organisation, planning and supervision, in relation to work at height or work equipment for use in such work unless he is competent to do so, or if being trained, is being supervised by a competent person. Ensure competence - not just training Supervision
Falls from Height Incorrect choice of equipment Regulation: Work at Height Regulations 2005 (as amended) Regulation 6: Avoidance of Risk - Take account of the Risk Assessment; and Avoid, Prevent, Minimise. Regulation 7: Selection of work equipment - Collective Protection over personal protection; and take account of the actual working conditions and circumstances; Regulation 8: Requirements for particular work equipment - Schedules. Plan iterative process Supervision
Workplace Transport: Many different types of incident
Workplace Transport: Requirements for a collision between a vehicle and a pedestrian: 1. Pedestrian and vehicle in the same place at the same time 2. Pedestrian unsighted 3. Driver of the vehicle unsighted
Workplace Transport Regulations: Workplace (Health, Safety and Welfare) Regulations 1992 Regulation 17: Every workplace shall be organised in such a way that pedestrians and vehicles can circulate in a safe manner. Provision and Use of Work Equipment Regulations 1998 Regulation 4: Every employer shall ensure that work equipment is so constructed or adapted as to be suitable for the purpose for which it is used or intended.
Workplace Transport Pedestrian and vehicles in the same place at the same time How can this be avoided?
Preventing Workplace Injuries Separation
Separation What is wrong? Pedestrian Routes and Pedestrian Crossings are different!
Pedestrians unsighted
Pedestrians sighted What is wrong?
Driver unsighted Driver s vision obscured by the load
Driver unsighted Reversing very narrow field of vision Some vehicles have particularly poor vision for reversing
Machinery Accidents / Safe Interventions Regulations: Provision and Use of Work Equipment Regulations 1998 Regulation 11: Every employer shall ensure that measures are taken, which are effective to: (a) Prevent access to any dangerous part of machinery; or (b) To stop the movement of any dangerous part of machinery before any part of a person enters a danger zone. Normally this means: Fixed or interlocked guards or other protection devices; AND The provision of such information, instruction, training and supervision as is necessary
Machinery Accidents / Safe Interventions The majority of machinery accidents that I see are to maintenance personnel why? Fixed or interlocked guards or other protection devices are removed or defeated in order to gain access for maintenance. Reflex actions How to stay compliant with Regulation 11?
Machinery Accidents / Safe Interventions Regulation 11 says - Prevent access to dangerous parts or stop the movement of dangerous parts before any part of a person enters a danger zone. Where a fixed guard is to be removed for maintenance or access is to be made inside interlocked guards then the machine must be stopped and appropriately isolated; e.g. a Lock-out- Tag-out procedure should be followed and any stored energy released What about fault finding and testing?
Machinery Accidents / Safe Interventions Permit to work / Permit to observe Where a Permit to work/observe is used this is now a software system of work; You should not issue a Permit to Work for yourself (otherwise it is not a Permit to Work ) The requirements for isolation, safety by distance, hold-to-run-control and other safeguards that will be listed on the Permit will be determined by a suitable and sufficient assessment of the risks involved if a Permit-to-Work is needed then this is a significant finding of the Risk Assessment
Machinery Accidents / Safe Interventions Point of Work Risk Assessments (Dynamic Risk Assessments) Who does them? Who is responsible? Should they be recorded? Why? Employer should have a system for ensuring point of work risk assessments are done; that system should include information, instruction, training (in risk assessment) and supervision (of the PoW. risk assessments)
Summary: Working at Height: Plan the WaH Make sure the personnel are competent Carefully consider the choice of equipment Workplace Transport: Keep the vehicles and pedestrians apart Ensure the pedestrians can see the vehicles Ensure the vehicle drivers can see the pedestrians Machinery safety / Safe Interventions: Fixed or interlocked guarding Lock-out-tag-out systems Permit to work/observe
Any Questions?