Tuesday, 31 July 2012

Ten things to remember for a safety audit

Here is a list of ten thing to remember for a safety audit:

1. Why you are doing it
If you don't focus on the needs of the client, then the report is unlikely to keep the client satisfied and is unlikely to address their issues.

2. Note book
However you choose to record your findings, some form of notebook is necessary. Something with a hard back is very useful.

3. Pen
Take at least one pen (or pencil) and one spare. 

4. Camera
If a picture paints a thousand words ...
Very useful for reminding you of the details of a site - take more photos thatn you intend to use.

5. Tape measure
Not glamourous: to check door widths, rail heights, etc. 

6. Address
I know it sounds obvious, but without an accurate address (and maybe some access details) a lot of time can be lost in finding a site. This may mean that you keep the client waiting or even that they leave without meeting you.

7. Access to site records
Without organising and getting access to the site records, it is not possible to give the cleint an accurate reflection of their level of compliance.

8. To talk to people
Unless it is a vacant site, it is likely that the people on site will have some useful information, story, or other information that should form part of the audit visit. Do not neglect to talk to them and solicit their views.

9. To provide a summary of key finding before leaving the site
Even though you will not have fully formulated what is going to be in the report, it is important to give the cleint an insight as to the main points. Discuss the good as well as the bad. If there are any serious concerns, discuss these with the client before leaving the site. This may help to prevent an incident from occurring, which is part of the reason why you are there at all!

10. To make a positive contribution to Health and Safety 
In most cases, the reason that you are at the site is because you have been invited by the client. Repay this invitation by helping the client with a positive contribution to health and safety on their site.

Wednesday, 18 July 2012

Manual Handling - Reducing the load

Summary

Manual handling relates to the movements of loads by human effort, as opposed to the use of mechanical handling equipment such as lift trucks, etc. It is estimated that over a third of all reported workplace accidents arise from manual handling activities. The risks include musculoskeletal injuries, such as back strain, injuries caused by the load falling onto or trapping part of the handler, or injuries caused by the handler falling. The exact proportion varies across different industry sectors and is highest in nursing care, where is accounts for about 50% of all reported accidents.

Employers’ Duties
Under the Manual Handling Operations Regulations 1992 (as amended) a clear hierarchy is established: avoid, assess and reduce. The employer has a duty to avoid the risk of injury to employees arising from manual handling operations, where this is reasonably practicable. Where this is not reasonably practicable, the employer must assess the risks arising from the manual handling operation and reduce this risk down to as low a level as is reasonably practicable. Consideration must also be given to the information, instruction and training given to employees and to the provision of appropriate personal protective equipment.
Assuming that it is not reasonably practicable to avoid manual handling and that a suitable and sufficient assessment has been made of the risk, it is necessary to reduce the risks from manual handling down to as low a level as is reasonably practicable.
Reducing the risk
Avoiding (the need for) manual handling
Consideration should be given to automation or mechanisation of the handling operation. This may involve the use of: lift trucks; cranes; hoists; conveyor systems; powered pallet trucks; pneumatic transfer systems; pumped pipe work systems; gravity feed systems (such as debris chutes) and goods lifts, etc. The effectiveness of automation is greater if it is incorporated into the original design for the process. Potential solutions include:
Caveat: although avoiding manual handling is important, it is of little benefit if the resultant risks (such as from fork lift truck operation) are greater than the original risks from manual handling.
Mechanical assistance
With the use of appropriate mechanical assistance, some manual handling is retained, but that the bodily forces are applied more efficiently, hence reducing the risk of injury. Examples include (but are not limited to):
· simple handling aids, such as grab hooks or suction pads (to reduce the problem of handling a load that is difficult to grasp);
· a simple lever can decrease the amount of bodily force needed (reducing the risk of injury);
· specialist fabric or paper roll lifters (to reduce the amount of handling involved in routine operations such as roll changing in a production environment);
· a hoist can be used to support the weight of a load, leaving the handler free to control its position
· a trolley, pallet truck, sack truck, cylinder trolley, wheel barrow or roller conveyor (to reduce the effort required to move a load horizontally);
· specialist drum hoists, trolleys and dollies (for the handling of barrels, etc);
· pneumatic and rollered tables (to reduce the amount of bodily force needed in the fine positioning of items for machining, etc);
· star-wheeled sack trucks (for use on stairs);.
· specialist devices, such as Arjo lifts (in the health care industry)
· Etc.

 
Changing the task and/or premises layout
Improvements in the flow and storage of products and materials as well as the design of the premises can reduce the risks to employees and may also lead to improvements in efficiency and productivity. With certain heavy loads, the risks associated with the task can be reduced by splitting the load up into smaller, lighter loads (e.g. boxed components may be packed in 10 Kg load rather than 20 Kg loads, etc.). Where heavy items must be moved in and out of storage, the optimum position for storage of such loads is around waist height. Storage much above or below this height should be reserved for loads that are lighter, more easily handled, or are handled in frequently. Designing the working area such that the distances that materials need to be carried are reduced will improve productivity as well as reducing the risks of injury.Similarly, reducing or eliminating the need to open doors, etc. while carrying loads will make similar improvements.
Where the task requires poor handling techniques and posture
Where the task requires poor handling techniques or poor posture to be adopted, efforts must be made to reduce the negative effects of these. The effects of the distance and position of the load from the body, twisting of the trunk and poor posture can be mitigated through changing the task, altering the lay out of the task and effective use of the body. Tasks that are designed to permit the load to be held closer to the body reduce risks of injury. The approach, grasping and placing of the load should be carefully controlled by:
· designing the lay out so that the handler can get close to the load without twisting
· designing the lay out so that the handler’s feet can get as close as possible to the centre of gravity of the load
· storing objects so they can be picked up and carried without an immediate change of direction or twisting
Where the task involves greater distances of lifting, lowering and travel
The stresses on the (lower) back during lifting, lowering and stooping, as well as those from having to travel long distances with a load, can be reduced through changes to the task and to the use of the body. The following measures could be considered:
· giving emphasis to storing, or otherwise providing, loads at waist height (this being the optimum height for lifting);
· providing a suitable platform to assist employees to reach items safely (but must be balanced against the increased risks of trips or stumbles);
· avoiding storing heavy loads such that they require the employee to reach above head height;
· fitting, where appropriate, shelves with rollers or with rollered shelves;
· providing suitable handling aids (such as levers) for lifting objects off the ground to remove the need for stooping and lifting;
· giving consideration to changing the task, such as by replacing carrying with controlled pushing or pulling;
· diving loads could to enable lifting half with each hand (allowing the weight to be distributed evenly;
· using conveyor or rollered table systems to get the load as close to the handler as possible;
· providing suitable resting points (such as tables) where loads must be carried over long distances.
Where the task involves excessive effort, fixed posture and insufficient rest and recovery
Building in variation of the work routine is beneficial in reducing the stresses and strains on backs of those involved in manual handling. Consideration should be given to:
· arranging for the weight to be borne by other means, such as a sling or hoist, when the same posture is maintained for a long period;
· conducting handling activities at the pace of the individual (not of a machine);
· adopting a system that allows for flexible work breaks, to reduce fatigue;
· encouraging the handler o take breaks and move around at convenient times (when the task involves heavy static loads);
· introducing job rotation to avoid fatigue, especially if the different operations use different muscle groups.
Summary
A recent survey of self-reported work-related illness estimated that for the period 2001 - 2002, 1.1 million people in Great Britain suffered from musculoskeletal disorders that were caused, or made worse, by their current or past work. An estimated 12.3 million working days were lost due to these work-related musculoskeletal disorders, with each sufferer taking an average of 20 days off work in the 12-month period. Much of this pain and suffering is avoidable through a simple risk assessment process and from the introduction of appropriate control measures.

Saturday, 14 July 2012

Latex Allergy - Health & Safety and Stuff


What is Latex?

Approximately a quarter of the world's demand for elastic products is supplied by the natural rubber that is derived from the Hevea brasiliensis tree, which is widely grown in South East Asia, and other countries. Natural rubber latex (NRL) from this tree is used in the production of numerous rubber products found at home and at work.
What is Latex Allergy?

Latex allergy is an allergic reaction to latex proteins. The symptoms occur when allergic individuals are in contact with latex or the powder from latex gloves, and may include itchy red skin rash, itching eyes and nose, sneezing, coughing, or difficulty breathing and asthma. In rare cases, if an allergic person is exposed to latex it can lead to a severe allergic reaction and death.

Some individuals may have other reactions to natural rubber latex gloves that are due to irritation or to allergic reactions to other chemicals that are present in the rubber in the gloves. Such reactions often occur several hours after exposure to the natural rubber products are not included in this definition of latex allergy.

Natural rubber latex allergens attach to the cornstarch that is used in powdered gloves. This powder acts as a vehicle making the natural rubber latex proteins airborne when these gloves are used, enabling the allergens to be inhaled. This means that natural rubber latex allergic individuals may experience symptoms of an allergic reaction, by being in a room where powdered NRL gloves are used even though they are not in contact with these gloves directly.

What are the costs of ignoring the potential latex allergies in workers?
As well as the costs in terms of human suffering, there are also potentially large costs in terms of fines, business disruption and court appearances. A trainee nurse was awarded more than £300,000 compensation in an out of court settlement with Scarborough General Hospital NHS Trust after developing an allergy to natural rubber latex gloves.

In a recent case, damages were awarded to a nurse after developing a latex allergy by Leeds County. In this case, the nurse suffered facial swelling, anaphylactic shock and breathing difficulties. She who was moved to office work but was also unable to carry out this work due to latex present in equipment located in the office. Her situation was so bad that she also suffered reactions in shops, gyms, and swimming pools and she had to have her house modified to remove all latex containing items. The nurse was awarded just under £270,000 in compensation including payments for pain and suffering as well as loss of future earnings.

In another case, a nurse was awarded £354,000 compensation after she was forced to abandon her nursing career due to an allergy to latex.

How prevalent is latex allergy?

It is documented that allergy to certain latex proteins emerged as an occupational disease in the 1980s and that it continues to be an important occupational health problem because natural rubber products are being used increasingly all around the world, especially in healthcare.

Although there is a large body of research on latex allergy, few studies have examined occupational health interventions. This systematic review summarises current evidence and is intended to assist occupational health professionals, managers and other interested parties in providing advice on occupational health interventions to address the problem of latex allergy from both individual and institutional perspectives. The review is concerned particularly with issues relating to gloves, as these represent by far the main occupational use of latex. Latex allergy of the immediate type is distinguished in this review from contact dermatitis caused by delaying hypersensitivity (type IV allergy) to chemicals that are added to latex during processing. The main focus of this review is on type I or immediate-type allergy to latex proteins, which has a reported prevalence of up to 17% in certain occupational groups.

Latex allergy is an allergy to natural rubber latex (NRL), which is a milky fluid that is obtained from the Hevea brasiliensis tree, which is widely grown in South East Asia, and other countries. Natural rubber latex is an integral component in thousands of everyday consumer and healthcare items, such as gloves. In common with many other natural products, natural rubber latex contains proteins and it is these proteins to which some individuals may develop an allergy.

Which workers are at the greatest risk?

Several categories of workers are at risk of developing latex allergy. Some studies have shown that about 17% of healthcare workers are at risk of reactions to natural rubber latex. People with a history of certain food allergies, such as banana, avocado, kiwi and chestnut are thought to be more likely to develop a latex allergy as are people with atopic allergic disease (which is estimated to be about 30 - 40% of the UK population). Workers who are exposed to natural rubber latex on a regular basis are more likely to develop latex allergy. Typical worker in this category include: car mechanics, caters and workers in the electronics trades.

Is there more than one type of latex allergy?

There are two important types of allergy related to natural rubber latex. One allergy is caused by exposure to the natural proteins (this is referred to as Type I allergy) and the other exposure to the chemicals that are used to convert the natural rubber latex into a usable item (this is referred to as Type IV allergy). Also, some workers may experience an irritant reaction when using products made from natural rubber latex (known as irritant contact dermatitis) which is not a true allergy.

Type I Allergy
Type I natural rubber latex allergy is an immediate allergic reaction to natural rubber latex proteins and is potentially life threatening. There are a few reports of deaths due to latex allergy. The typical symptoms of Type I latex allergy include: urticaria (often called hives) and hay fever type symptoms, asthma. In some rare cases more severe symptoms, such as anaphylaxis (a condition where there is a severe drop in blood pressure leading to possible loss of consciousness or severe breathing difficulty), have been reported. The onset of the Type I allergy may occur after months, or even years, of the initial exposure. In many reported cases, the symptoms become progressively more severe on repeated exposure to the natural rubber latex and so it is essential that work is organised so that sensitised individuals can avoid further contact with natural rubber latex proteins.

Type IV Allergy
Type IV allergy occurs in some people who react to the chemicals used in the manufacturing process, mostly the accelerators. The chemicals most likely to cause this reaction are thiurams, dithiocarbamates and mercaptobenzothiazoles (MBT). This is a delayed hypersensitivity reaction which occurs 6 - 48 hours post-exposure. The symptoms of Type IV allergy include: red itchy scaly rash which is often localised to the area of use (such as the wrists and forearms) but which may spread to other areas.

What products containing natural rubber latex are workers likely to be exposed to?

Natural latex rubber is used widely in several industry sectors. There are, for example, many medical and consumer products that contain natural rubber latex.

Examination and surgical gloves
Erasers
Hand grips and gym mats
Oral and Nasal airways
Rubber bands
Swimming cap
Endotracheal tubes
Balloons
Goggles
Intravenous tubing
Adhesives
Tyres
Surgical masks
Washing up gloves
Rubber aprons
Baby teats
Catheters
Hot water bottles
Stethoscopes
Rubber buttons on calculator, remote controls, etc
Etc

What steps can I take to avoid my employees developing latex allergy?

Natural latex rubber is a substance hazardous to health and, as such, it falls under the Control of Substances Hazardous to Health Regulations 2002 (COSHH). Under COSHH, employers must assess all the circumstances in which employees may be exposed substances hazardous to health, including natural latex rubber. Employers must consider how to either prevent exposure or otherwise implement precautions that will adequately control any risks. In terms of practical guidance in the matter of reducing the risk of natural latex rubber allergy, the employer should consider the following precautions:
• Where possible, powdered latex gloves should not be used in the workplace as the risk of developing latex allergy is highest with the use of powdered latex gloves.
• Using either powder-free latex or non-latex gloves for the whole workforce.
• Employees with latex allergy, latex sensitivity or latex-induced asthma should use non-latex gloves and co-workers should use powder-free low protein gloves or non-latex gloves.

Risk Assessment

As with all aspects of the management of health and safety at work, the risk assessment is the most useful tool in identifying areas where staff are at risk of developing latex allergy. It is not possible to know who will develop allergic reactions to latex, and so all workers must be protected through a risk assessment. The risk assessment should look at the work carried out and the need to protect workers from, for example, infection. Where there is a risk of infection, latex gloves may be provided to protect the workers. Employers, however, can also use the risk assessment to look at ways of eliminating the risk from unnecessary exposure to latex, substituting other materials where feasible, such as vinyl or nitrile gloves, and generally limiting exposure to latex. It is essential for the risk assessment to question the need to use natural rubber latex products to complete this work and the use of an alternative should be considered. It should be recorded and staff given appropriate training and health information based on its findings to enable them to protect themselves.

What action should I carry out if a worker develops latex allergy?

If a worker develops suspected latex allergy, you should refer them to your occupational health department or to their own Doctor (GP) if you do not have one. Also, under the duties imposed under the Reporting of Injuries, Disease and Dangerous Occurrences Regulations 1995 (RIDDOR), you have to report incidents of occupational dermatitis and asthma attributable to latex to the appropriate enforcing authority (i.e. the Health and Safety Executive or your local authority) and keep a record of such incidents.

Are there suitable alternatives to natural latex rubber gloves?

Gloves made from a range of different materials (such as: polyvinyl chloride (PVC), neoprene and vinyl) are now available. These should be considered as a useful option for eliminating or reducing exposure to natural rubber latex in the workplace. However, alternatives to latex gloves have other associated problems, particularly with user satisfaction and barrier effectiveness.

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Welding Operations and its Associated Hazards

Introduction

Welding and cutting operations are widely used in manufacturing and engineering environments. 
Fire is the principle hazard and can arise from the leakage of gases from the hoses catching fire or from the ignition of nearby flammable materials by the heat associated with welding (hot surfaces and sparks, etc).

Typical hazards associated with welding operations

There are several typical hazards associated with welding operations, including: Fire; molten metal and sparks; exposure to UV light; hot surfaces; exposure to substances hazardous to health; pressurised systems; electricity and slips, trips and falls

Fire: Welding creates hot surfaces, sparks and emissions of molten metals so there is always a risk of fire. Gas welding operations involve the use of a fuel (acetylene, propane, etc.) and so increase the risks of fire further. Leaking valves or failure to isolate the system correctly may lead to fuel in air build up. Leakage of oxygen can be dangerous as this may lead to an oxygen enriched atmosphere. In oxygen enriched atmosphere, materials are more readily combustible than under normal conditions. Accidents may occur when drums or tanks that have previously contained flammable substances are welded or cut as even with empty tanks, the heat can vaporise residues that will be ignited by the cutting or welding flame. The resulting explosion blows the drum apart, potentially causing serious or even fatal injury.

Molten metal and sparks: Welding operations generate sparks and emissions of molten metals, which may cause fires or can cause injury to the skin and eyes.

Exposure to UV light: Exposure to UV light from welding operations can cause damage to the eyes including a condition known as “arc eye”.

Hazardous substances: Welding fume comprises of metal oxides (mainly iron oxide) and of irritating gases, such as oxides of nitrogen and ozone. Welding fume can cause irritation and “metal fume fever'”. Long term exposure may lead to lung diseases and increase the risk of occupational asthma and cancer. Welding involving stainless steel increases the cancer risks as the welding fume will contain other metal oxides, such as chromium oxide. Surface coatings on the substrate (material being welded) may also give risk to additional hazardous substances, such as lead, etc.

Pressurised systems: In gas welding there is also the potential danger of the huge amount of energy stored in the cylinder by virtue of the compression of the gas, and fuel gases, which by definition, contain stored chemical energy. Pressurised containers (such as gas bottles for propane, oxygen or for inert gases for arc welding) may explode or give rise to a rapid venting of pressurised gases if damaged.

Electricity: There are risks of electric shock and of electrocution associated with arc welding operations.

Slips, trips and falls: There are risks of injury from slips, trips and falls arising from welding operations, generally as a result of poor housekeeping or of poor cable and hose management.

Risk assessment and control measures

Welding operations must be subject to suitable and sufficient assessment of the risks that they create. As well as the general requirement for risk assessment (created by Regulation 3 of the Management of Health and Safety at Work Regulations 1999) there may be a requirement for risk assessment under other regulations, in particular:
• Control of Substances Hazardous to Health Regulations 2002 for hazardous substances (welding fume and other substances that may be inhaled, ingested, etc.
• Dangerous Substances and Explosive Atmospheres Regulations 2002 for flammable and explosive substances (such as welding gases) that may cause fires and explosions.
• Regulatory Reform (Fire Safety) Order 2005 for the general fire risks associated with welding operations.

Fire: General fire safety precautions should be taken. Care should be taken to prevent to accumulation of combustible materials in areas where welding operations are carried out.
By the nature of the process, it is impossible to eliminate sources of ignition from cutting and welding operations. Precautions must be taken to prevent the build up of dangerous concentrations of flammable and explosive gases (such as acetylene). The condition of regulators, hoses and connections should be checked regularly, including checking for leaks (such as by the use of soap solution). Any damaged, worn or otherwise defective hoses or equipment must be replaced.

Flashbacks may be prevented by proper cleaning of the torch and adequate purging of the equipment before lighting up. There are also proprietary anti-flashback devices that should be fitted.

Prohibit the welding of vessels that may have contained flammable substances. If such vessels need to the welded (or cut) then the work should be controlled carefully (such as through a permit to work system) and the vessels must be fully cleaned and purged before welding.

Give consideration to the safe storage of gas cylinders. Fuel gases (such as LPG and acetylene) should be stored away from the oxygen cylinders in a suitable, secure compound with appropriate warning signs displayed. Gas cylinders should be stored outside of the building and should be separated from the building by a suitable fire wall or separation.

Molten metal and sparks and exposure to UV light: The eyes of welders, and of those working close to them, must be protected from molten metal, sparks and intense light. Welders will normally wear welding goggles (in the case of gas cutting and welding) or welding masks (in the case of arc welding). If other working nearby are at risk from the "flash", then suitable fire proof welding screens should be provided. Exposed skin (such as the hands) must be protected from splashes, sparks and from contact with hot surfaces.

Hazardous substances: Exposure to welding fume can be achieved in several ways. The most appropriate method or methods will be determined by the risk assessment. Control measures include:
• General ventilation – this is appropriate if the amount of welding to be carried out is small and there is sufficient general ventilation available to control, the risks from exposure to welding fume. In some cases, welding operations can be carried out outside.
• Extraction – there are several forms of extraction that can be used. Generally, the welding fume is extracted by a system comprising of a captor hood and a hose leading to a fan. The captor hood needs to be positioned close to the area being welded and the velocity of the air through the system needs to be fast enough to capture the fume and carry it through the extraction system. Welding torches can be fitted with their own high velocity low volume extraction systems that are designed to remove the welding fume as soon as it is generated and before it reaches the welder.
• Respiratory protective equipment – although the use of PPE is considered to be the last resort, it may be necessary to protect welders from exposure to fumes (such as one off welding involving stainless steel) and in cases where the use of extraction equipment may not provide adequate protection. The use of disposable masks (to EN 149 FFP2S) or the use of proprietary welding masks involving filtered air can be considered as part of the risk assessment.
• Restrictions on smoking, eating and drinking - smoking is now prohibited in all workplaces. It is recommended that restrictions are placed on the consumption of food and drink in the welding areas as this may lead to the ingestion of hazardous substances (especially chromium oxides) from the hands.
• General welfare facilities – provide suitable hand washing facilities, including soap and water.
• Health surveillance – this will not protect employees from exposure to hazardous substance. However, appropriate health surveillance will often allow for early identification of symptoms so that additional preventive measures can be taken at an early stage. Where workers are exposed to welding fume, especially welding fume that may contain chromium oxides, the employer should carry out lung function testing. The results of health surveillance must be recorded and records must be retained for 40 years.

Pressurised systems: The dangers associated with pressurise systems in welding operations may be controlled by the proper storage, handling and maintenance of cylinders and their fittings. Particular care must be taken not to damage the gas regulator on the gas bottles. Care should be taken to ensure that cylinders do not become involved in fires; if the metal shell is exposed to intense heat, the internal pressure will increase and the yield strength of the metal will be reduced, with possible splitting of the shell and explosive release and combustion of the contents.

Electricity: Like any other electrical equipment, arc welding sets need proper use, inspection and maintenance. It is important to ensure a proper earth-return from the work piece to the set. Electrical flexes, associated fittings and electrode holders must be properly insulated for outdoor use and there should be a suitable procedure for isolating the electrical power supply near to the welder. All electrical circuits should be fitted with an over-current device, for example, a miniature circuit breaker (MCB). Workpieces should be earthed unless a double insulated transformer is being used, in which case the transformer casing should be earthed and not the workpiece.

Slips, trips and falls: General housekeeping in the work area needs to be managed. In particular, cables and hoses need to be routed such that they do no create tripping hazards. In the case of portable welding equipment, this is largely the responsibility of the welder, but with fixed welding systems, consideration needs to be given to the routing of cables and hoses at the design stage.

Summary
Simple control measures are all that is required to control many of the risks associated with welding operations, although more elaborate control measures are required for more intensive welding operations or for those with special hazardous, such as stainless steel welding.


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Sunday, 8 July 2012

Slips, trips and falls


Slip, trip and fall accidents can happen almost anywhere and are the most common cause of injuries in the workplace.  According to the HSE, such injuries cost employers well over £500 million each year in lost production and other costs.  They also cost owners and occupiers of premises substantial amounts of money each year when the injured party is a visitor, contractor or tenant moving through a common area of the premises.  Legal action can be taken under existing workplace health and safety legislation as well s under the Occupiers’ Liability Act 1956 and under the tort of Negligence.  When legal actions are brought as a result of an injury, they can be extremely damaging to the business involved, particularly in injuries involving members of the public.  Although businesses are insured, it should be noted that insurance only covers a small proportion of the costs.  Insurance does not cover, for example: time (spent in accident investigation, treating the injuries, attending court, etc.), fines, legal fees, etc. 

Slips, trips and falls warning notice
There are many reasons why people slip, trip or fall.  The most common reasons are associated with: the floor, contamination on the floor (or footwear), obstacles on the floor, cleaning of the floors, damaged flooring, missing handrails, environmental factors, poor lighting, inappropriate footwear, etc.

Many of these reasons are avoidable by taking simple steps, such as: ensuring that housekeeping arrangements are satisfactory; ensuring that the maintenance regime is operating effectively; checking the premises regularly by walking around; etc.


Preventative actions
There are many actions employers and occupiers of premises can take to try to prevent injuries to employees, visitors, contractors, etc. arising from slips trips and falls.  The actions relevant to a particular property should be determined by risk assessment.  

Floors
Design
The floor should be suitable for its intended use and environment and for the type of work activity that may take place on it. Walkways should be wide enough to allow safe passage of the type and volume of foot (and other) traffic that is expected.  If a floor is situated in places where it cannot be kept dry, then people should still be able to walk on it without fear of a slip.  This is an important design feature in place such as leisure centres, swimming pools, cold storage areas, kitchens, etc.  The floor must be fitted correctly to ensure that there are no trip hazards.
Cleaning 
Floor cleaning can make the floor slippery during cleaning and as a result of the materials used in cleaning.  The floor must be cleaned correctly to ensure that it does not become slippery or keeps its slip resistance properties (if a non slip floor).  Although it is often not possible, normal cleaning activities should be carried out when the premises are unoccupied (or last thing at night).  Appropriate barriers (such as Yellow “A” Frames) should be provided to warn people that the floor is still wet.  Appropriate cleaning techniques should be introduced, such as: using a dry mop/squeegee to reduce floor drying time.  In some cases, it would be appropriate to arrange alternative bypass routes. Consideration should be given to the tripping risks created by trailing vacuum cleaner cables, etc.
Maintenance
The floors and floor coverings (carpets, tiles, etc.) must be maintained in good condition in order to ensure that trip hazards are not present and that they do not develop.  Holes in the floor should be filled in and carpets and other floor coverings should be secured into place.  It should be ensured that mats do not slip and slide on the floor surface.  It may be appropriate to use a lay of materials to adhere the mat to the floor in normal use.  It should be ensured that mats and carpets do not turn up and the edges to create tripping hazards.
Changes in elevation
Where reasonably practicable, ramps, raised platforms and other changes of level should be avoided.  Where they cannot be avoided, they should be highlighted, such as by suitable warning notices, signs, use of colour or other highlighting techniques. 
General
It is useful to provide a sufficient number of suitable bins to prevent litter, etc.

Steps and Stairs
Design
Steps and stairs should be designed so as to be suitable for their intended use and environment.  They should be well lit and provided with robust handrails, ideally on each side.  Consideration should be given to the height and width steps.  The risers should be consistent and the nosings on the steps and stairs should be clearly marked in colours that contrast with the rest of the steps.

Housekeeping and Active Monitoring
Even if walkways are suitable and satisfactory, they need to be maintained in this condition.  Further to this, good standards of housekeeping need to be maintained.  Regular, active monitoring of walkways is essential to prevent issues from developing.  Regular walk rounds of the premises can identify issues such as:
  • inappropriately routed or protected trailing wires (such as may be associated with short term building maintenance activities)
  • water or other fluids from leaking roofs or pipework
  • spillages
  • general accumulation of detritus and other obstructions
Lighting
Ensure that lighting levels are suitable for the area and should avoid casting shadows across the walkway or staircase.  Ensure that defective lighting is addressed as soon as it is reported.

Spillages
Suitable arrangements should be in place to deal with (wet and dry) spillages.  These should be reported and dealt with as soon as they happen or as soon as they are noticed.  The nature of any spillage response provision or spillage cleaning kit will depend on the nature of any expected spillages.  

Trailing cables 
Trailing cables should be avoided whenever possible.  Equipment should be positioned to avoid cables crossing pedestrian routes and proprietary cable covers should be securely fixed into place if cables need to be trailed.  Consideration should be given to the use of cordless portable tools. 

Known slippery surfaces or conditions
Where certain floors are known to be slippery or are known to be slippery when wet, then these areas should be assessed and the cause of the slipperiness should be treated accordingly.  By way of example:
  • it may be appropriate to weather mats at the entrances to premises to prevent water from being brought in on peoples shoes and making a polished marble floor extremely slippery
  • it may be necessary to have a floor chemically treated  and to introduce the use of appropriate cleaning methods and materials
  • gritting materials may need to be provided to make external paths and walkways safe in cold weather
Drinks machines and dispensers
The floors around drinks machines and dispensers may become slippery due to spillages of water, tea, coffee, etc.  It may be appropriate to:
  • resite such machines to be away from main walkways and through routes
  • to fit absorbent carpets around the machines
Footwear
Instruct workers to wear suitable footwear, particularly with the correct type of sole. If the type of work requires protective footwear to be provided, then the employer is required by law to provide it free of charge.  Occupiers of premises have virtually no control on the type of footwear worn by visitors.

Contractors
Contractors need to be made aware of your site rules and working conditions and they need to be managed.

Summary
Although slips, trips and falls may be the most common cause of accidents, they can be controlled and managed by appropriate work practices and (generally) with very little expenditure.  If an organisation is to be effective in defending legal accidents for injuries arising from slips, trips and falls then they will need to be able to demonstrate that they are taking all reasonable actions to prevent such injuries.  This involves creating and maintaining the right environment and monitoring the workplace and the control measures.


Michael Ellerby
LLB BSc CMIOSH MIIRSM CChem MRSC CSci
Director
LRB Consulting Limited

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The Storage of Substances Hazardous to Health - Second Part


Many organisations need to store substances that are classified as hazardous to health, sometimes in substantial quantities.  As discussed previously, several sets of Regulations may apply, depending on the exact nature of the substance being store, but in nearly every case, the Control of Substances Hazardous to Health Regulations 2002 (or COSHH Regulations) will apply.  However, consideration needs to be given to the full range of hazards that may be present, including issues such as compatibility with other materials, reaction with air or water, etc.  Many aspects of the safe storage of substances hazardous to health rely on common sense and part of the purpose of the COSHH risk assessment is to formalise the application of this common sense.
Storage of gases
Gases are usually stored under pressure inside metal gas bottles.  These bottles can vary in size from a few millilitres up to several tonnes.   The gas bottles, and associated pipe work, must be colour coded and/or labelled for identification purposes as required by either various pieces of specific legislation (which are outlined in Schedule 7 of the COSHH Regulations) or by Regulation 12(5) of the COSHH Regulations (a requirement that was new in the 2002 Regulations).  Similar rules apply to pipe work systems used for the storage and transfer of liquids and even solids.
Where incompatible gases are being used on a site, there must be a safe system of work in operation that negates the possibility of the accidental mixing of these gases.  In the case of hydrogen and oxygen, these gases have different screw threads on their fittings to prevent accidental connection of the wrong gas to the wrong part of the system (this system is also seen on oxy-acetylene welding/cutting equipment).
Gas cylinders, and the associated supply pipe work, need to be adequately protected from accidental damage (such as from vehicle movements).  They may also need to be protected from heat, including heat build up from sunlight.
Storage of liquids
Bulk storage
Bulk storage of liquids generally takes place is designated bulk storage tanks.  These tanks are usually bunded, to contain accidental releases of materials.  The tanks are usually filled from a delivery tanker.  It is essential that the right material is unloaded into the right tank.  There have been a number of serious industrial accidents when tanks have been charged with the wrong chemical.  Once such incident is described later in the section dealing with acids/hypochlorite solutions and is described in more detail below.
Small/medium scale storage
Small and medium scale storage of solid hazardous substances generally involves intermediate bulk containers (IBCs), drums or bottles.  The size may vary from a few grams up to about 1200 Kg.
Storage of oil
It is not uncommon for water to be polluted by oil.  The requirements for the storage of oil in containers which carry more than 200 litres are set out in the Control of Pollution (Oil Storage) (England) Regulations 2001. These regulations, which do not apply to waste oil or oil stored in a building or wholly underground, require:
  • secondary containment (such as a bund):
    • with a capacity of not less than 110 per cent of the container’s storage capacity
    • positioned to minimise any risk of damage by impact, e.g. by fork-lift trucks
    • with its base and walls impermeable to water and oil
    • without its base and walls penetrated by any valve, pipe or other opening used for draining the system
    • with the base or walls, where they are penetrated by any fill pipe, or draw off pipe, adequately sealed to prevent oil escaping from the system
  • any valve, filter, sight gauge, vent pipe, etc to be situated within the secondary containment system
  • fill pipes, not within the secondary containment system, to have a drip tray to catch any oil spilled when the container is being filled with oil.
The regulations also include requirements for the storage of oil in fixed tanks, both above ground and underground, which include particular requirements for ensuring that fill, draw-off and overflow pipes are not damaged, and that the tanks are fitted with automatic overfill protection devices.
Storage of solid materials
Bulk storage
Bulk storage of solid materials may take place in several ways:
  • Loose, but in defined locations in a yard (e.g. granite or asphalt blocks)
  • In large open access bins (sand, etc.)
  • In silos (e.g. flour, various process chemicals)
  • In “big bags” which generally hold between one and three tonnes (a range of process chemicals)
If powdery or friable materials are stored loosely, the effect of dispersal by wind, leading to airborne contamination, must be considered.
Small/medium scale storage
Small and medium scale storage of solid hazardous substances generally involves bags, sack, drums or bottles.  The size may vary from a few grams up to about 250 Kg.  Materials may also be stored in roll form, such as in the case of glass fibre, or rolls of various fabrics impregnated with resins, etc.
Storage of incompatible or reactive materials
Where there is a risk of accidentally mixing materials that are incompatible, there is a duty to ensure that all reasonably practicable measures are taken to prevent this from occurring.  This will include, amongst other things, the introduction and maintenance of a safe system of work designed to prevent mixing.  Deliveries, including accompanying paperwork, should be checked carefully and all deliveries and transfers should be supervised adequately.
Acids/bases
Acids and bases must be stored separately as significant heat (of neutralisation) may be generated when these materials are mixed.  The storage arrangements for these materials should ensure that they cannot be mixed accidentally, even in the event of spillage.  Ideally, these materials should be stored in separate, bunded locations.
Acids/hypochlorite
Acids and hypochlorite mixtures should be stored separately as toxic chlorine gas is generated when these materials are mixed.  The storage arrangements for these materials should ensure that they cannot be mixed accidentally, even in the event of spillage.  Unfortunately, in premises with swimming pools (where hypochlorite solutions are often used as part of the water treatment) these materials are often stored close to each other.  It is recommended that containers of these two substances are bunded separately to prevent mixing after a spillage has occurred.
Case study: - The danger from the accidental mixing of acids and hypochlorites was shown in the following case study:
In September 2002, a lorry driver from AE Costins Limited delivered an IBC of hypochlorite solution to site on behalf of the supplier and distributor (Tennants Distribution Limited).  The lorry driver then accidentally connected the IBC to a hydrochloric acid bulk storage tank instead of the hypochlorite bulk storage tank.  When the hypochlorite was pumped into the wrong tank the two chemicals reacted, generating a cloud of chlorine gas.  26 employees were taken to hospital for examination, though only one was detained overnight.  This accident was blamed onto the inadequate training of the lorry driver and the failure of Tennants Distribution Limited to ensure that driver of vehicle contracted to the Company to and transfer sodium hypochlorite solution were competent to do so.  Tennants were fined £12,000, with costs of about £5,500.
Acids/(poly)sulphides
Acids and sulphides (including polysulphides) must be stored separately as toxic hydrogen sulphide gas is generated when these materials are mixed.  In July 2001, a load of waste alkali that was contaminated with polysulphides reacted with some waste acids at Park Environmental Services Limited, liberating hydrogen sulphide gas.  One employee was overcome by the gas and was further injured by falling down steps.  Although often underrated as a toxic gas, hydrogen sulphide is more toxic than hydrogen cyanide.  The Company was fined a quarter of a million pounds under S2 (1) of the Health and Safety at Work Etc Act 1974, with costs of about £20,000.
Fortunately, its smell is unpleasantly noticeable well below its toxic level.  The storage arrangements for these materials should ensure that they cannot be mixed accidentally, even in the event of spillage.  
Acids/cyanides
Acids and cyanides must be stored separately as toxic hydrogen cyanide (cyanide gas) is generated when these materials are mixed.  The storage arrangements for these materials should ensure that they cannot be mixed accidentally, even in the event of spillage.  More is said on the storage of cyanides in the section on highly toxic substances (below). 
Oxidising agents/organic materials
Oxidising agents include a wide range of commonly used substances, including peroxides (such as methyl ethyl ketone peroxide, or MEKP, used in the manufacture of glass reinforced plastics, or GRPs, and chromic acid (used in the certain electroplating processes).  Fires may be initiated by the action of oxidising agents on organic materials.  This may include the organic materials often associated with packaging and storage, such as paper, cardboard and wooden pallets.  Naturally, consideration needs to be given to the safe storage of oxidising agents.  The area should be clearly identified and organic materials (including packaging and process chemicals) must be excluded from this area.
Materials that react with water 
Many substances react violently with water.  Some produce explosive gases, such as the release of acetylene from the reaction of calcium carbide with water, or the release of hydrogen from the reaction of alkali metals (such as potassium or sodium) with water.  Sodium also generated enough heat to ignite the released hydrogen).  Other materials react violently with water to generate heat, known as the heat of dilution (such as in cases of pearl caustic soda, concentrated sulphuric acid, oleum, etc.).  The dilution of these materials needs to done correctly, usually with stirring and cooling as well as consideration to the order of addition, etc.  
Materials that react with air 
Some materials (such as Raney nickel catalysts) react violently (or even pyrophorically) with air.  Typically, these materials are stored under water, such as in the form of a slurry.
Storage of highly toxic substances
With highly toxic substances, it is recommended that these are stored in a secure location, such as a locked storage area.  It is also recommended that an inventory of stored materials is maintained, including records of usage.
As with all substances hazardous to health, consideration must be given to reducing the amount of these substances used and/or stored as well as giving consideration to the use of these materials at all.  Regulation 7(2) of COSHH 2002 creates a duty to consider safer alternatives.
Storage of waste materials
Consideration needs to be given to the hazardous nature of stored waste materials.  Consideration needs to be given to the toxic, corrosive or otherwise harmful nature of the substance, as well as any incompatibilities. 
Application of COSHH to storage
As stated at the start of the first article, COSHH applies as much to the storage of substances hazardous to health as it does to their use.  The COSHH Regulations require employers to prevent exposure to hazardous substances to both employees and non-employees where it is reasonably practicable to do so.  Where it is not reasonably practicable to avoid exposure, then exposure must be adequately controlled.  COSHH assessments must consider the storage of substances as well as their use.
Michael Ellerby
LLB BSc CMIOSH MIIRSM MIFSM CChem MRSC CSci
Director
LRB Consulting Limited

Please visit our website