Third party accreditation schemes, such as: CHAS, Safecontractor, etc

There are many third party accreditation schemes that are used by a wide range of organisations.  There is no legal requirement for the third party accreditation of health and safety performance of a company as part of the procurement process. Many suppliers and their (potential) clients choose to use the services of a third party accreditation scheme for health and safety, with the purpose of helping them to manage their tendering or procurement needs.  Generally, such schemes are used as some form of pre-selection criteria, particularly in the construction industry and in the facilities management sector, although such schemes are potentially useful across a wide range of industries.  Some organisations, for example, insist that all of their contractors have registered with, and have been accredited by, a third-party organisation such as: Buying Force, Construction Line, EXOR, Achilles, SafeContractor or CHAS (although there are many more third part accreditation schemes around). Obtaining third party accreditation is not a given – it often requires several submissions to address all of the issues satisfactorily (some third party accreditation organisations have suggested that in the order of 80% of contractors fail to get through the accreditation process on the first attempt).

Why put yourself through a third party accreditation scheme?
Many organisations that put themselves through the rigours of a third party accreditation scheme do so in order to meet a requirement of at least one of their current (or prospective) clients. Being accredited will not necessarily lead to more work, but for companies, failure to achieve accreditation may result in work being lost.

How do third-party accreditation schemes work?
The principle behind all of these third-party accreditation schemes is fairly simple and straightforward.  A provider of services (a contractor), must first register their company details with the accreditation company.  As well as doing this, they must also provide information relating to their health and safety policy and associated supporting documentation.  This associated supporting documentation may include:

• copies of up-to-date insurance documents,
• a signed copy of the health and safety policy statement,
• training records for employees, including evidence of induction training,
• arrangements for the vetting or accreditation of any subcontractors and may be used,
• copies of appropriate risk assessment documentation relating to operations or undertakings consistent with the services to be provided,
• copies of method statements relating to the operations or undertakings consistent with services to be provided,
• information relating to sources of competent health and safety advice and guidance,
• evidence that a statutory examinations are carried out (such as LOLER certificates),
• evidence of active monitoring of the health and safety performance of the company (such as safety walk round or site audit documents),
• evidence of on-going health and safety training, including asbestos awareness training,
• etc.

Be prepared to provide information relating to areas other than health and safety. Some schemes require information relating to financial aspects of the company (turnover, etc) and the environmental management of the company, or even information on equal opportunities policies, etc.

Advantages of third-party accreditation schemes
These third-party accreditation schemes have the potential to take some of the worry away from the client in appointing a contractor as they can select them from a database of approved contractors. Successfully completing the accreditation puts your organisation on the database and may open up new areas for trade.  Another theoretical advantage of the third-party accreditation scheme is that subscription to such a scheme should mean that the subscribing organisation only has to go through this process once.  However, this theoretical advantage does not always translate into reality as organisations often find themselves subscribing to many third-party accreditation schemes to meet the demands of various client organisations.  The relatively new Safety Schemes in Procurement (SSIP) Competence Forum was set up in response to concerns from the construction industry with regard to the plethora of pre-qualification assessments and forms they had to fill out, many of which duplicated previous efforts and added significantly to costs and paperwork. One potential advantage of the use of the third-party accreditation scheme is that it provides documentary evidence that the client organisation has undertaken at least some rudimentary evaluation of health and safety performance of prospective contractors.  A significant advantage to organisations that have successfully been accredited by one of these schemes is that it is slightly more secure from competition from organisations that have not been accredited.

Disadvantages of third-party accreditation schemes
As mentioned above there are many third party accreditation schemes currently in operation in United Kingdom and different schemes are favoured by different clients.  In many cases, there is little opportunity for accreditation by one scheme to lead on to accreditation under another scheme. This means that some contracting organisations need to undertake several third-party accreditations, which is both costly and time-consuming.
Another disadvantage of third-party accreditation schemes is that they are principally paper or desktop exercises, has few of these schemes involve any site visitor or direct communication with the client or the contracting organisation.
Third party accreditation schemes are based around written records and documentation.  This creates a natural barrier for the very small organisations that do not necessarily require a written health and safety policy (if they have fewer than five employees). If such organisations wish to partake of a third-party accreditation scheme, then they will have to reduce all of their policies and procedures to writing. Naturally, there are costs in both time and money in pursuing this.

How to complete (the health and safety part of) a third-party accreditation scheme
In order to be effective in gaining third party accreditation, it is important for the company to have a good grasp of health and safety within the company – based on management commitment to health and safety as part of the business as well as good written procedures.  Any organisation that has a suitable and up-to-date health and safety policy that reflects it undertakings and which has completed suitable and sufficient assessments of the risks arising from it undertakings should be able to satisfactorily complete a third-party accreditation scheme. In order to be successful, it is recommended that the company does not leave the process to the last minute, as there may be a need to write new policies and procedures and to collect and collate records, etc. The following list covers most of the key points that will need to be covered when sending in the application:

• signed copy of the health and safety policy statement (most third-party accreditation schemes require evidence that this has been signed and dated recently)
• Sample policies from within the health and safety policy document covering key issues, such as:
• accident and incident investigation
• asbestos safety policy (including the discovery of asbestos on site)
• control of the contract is policy (including details on the selection appointment and monitoring of all subcontractors)
• electrical safety policy (including a policy for testing maintenance and inspection portable electrical equipment)
• fire safety policy
• first aid policy (including training records and certificates for first aiders)
• hazard spotting and corrective actions
• loan working policy
• machinery and equipment safety policy (including maintenance servicing and statutory examination of equipment)
• manual handling policy
• occupational health policy (including, where appropriate, arrangements for occupational health monitoring) 
• training policy
• work at height policy
• examples of relevant to the risk assessments (the should relate to the services provided and activities undertaken on behalf of clients) and should cover at least the following areas:
• fire safety (in many cases, a fire safety risk assessment based on office-based activities is satisfactory) 
• manual handling
• mechanical handling (including the use of cranes, forklift trucks etc)
• noise and vibration
• use of tools (including hand tools and power tools)
• work at height (including arrangements for rescue of suspended casualties)
• other risk assessments, that may be required relating to the nature of the work to be undertaken
• examples of relevant method statements (this should relate to the services provided and activities undertaken on behalf of clients)
• evidence of training, including training records and, ideally, copies of CSCS Cards and other similar schemes (including information on how training needs are identified and managed). It is not necessary for all training to be externally accredited (such as by IOSH or the CIEH) and so most of the records will be of internally provided training (such as on the job training and tool-box talks).
• information on the source of competent health and safety advice used by the organisation and details as to whether the source of this advice is from within the company or from an external provider of such services (such as health and safety consultant) - such information will usually include the CV of the source of such competent advice
• accident statistics (with break down into categories) for the last three years
• examples of accident investigation, including identified a remedial actions, for at least two accidents or near misses that have occurred in the last one or two years
• details of any prosecutions or enforcement actions resulting in the issuing of either prohibition notices or improvement notices
• consideration of the needs for occupational health checks and monitoring 
• evidence of the testing and maintenance of items of portable electrical equipment
• For some applications (such as CHAS) you need to provide a D-U-N-S number, which is a registration number issued by Dun & Bradstreet. This can be obtained, free of charge, by applying on line at http://dbuk.dnb.com/Forms/Customer_Service.asp 

One of the most common ways that organisations fail to overcome the various hurdles associated with third party accreditation schemes is that the information, although provided, is not clear and transparent. When completing application form for a third party accreditation scheme, do give consideration as to easy it is for the third party accreditor to read and to understand. If issues lack clarity, then they are likely to be returned to you for clarification, resulting in further work and costs (in time and effort). Attention to detail on the initial application can save time later on.

Summary
Gaining third party accreditation can be rewarding as it can help to secure work, but the process must not be undertaken lightly. Many of these schemes are largely paperwork exercises and successful completion will depend on the quality and completeness of your documentation. Although few of these accreditation schemes currently recognise each other, the discipline of completing one accreditation will make others easier and will make the process of tender submission easier as the necessary documentation is likely to be available to the company.

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Working with oils and greases - Health and Safety implications

It is an inevitable consequence of many aspects of production and maintenance work that workers will come into contact with lubricants, including greases and oils.  Prolonged contact with oils and greases can cause a range of skin problems, such as: rashes (e.g. oil acne), dermatitis and even skin cancer and testicular cancer.  Contact with hot lubricants, during servicing or maintenance, may also cause burns. 

The chemically hazardous nature of oils means that consideration needs to be given to the provisions of the Control of Substances Hazardous to Health Regulations 2002 (COSHH).  Under these regulations, the employer has various duties for preventing exposure to hazardous substances or for controlling such exposure to prevent harm to employees.  The employer must: 

·       assess the health risk arising from the work done and decide what precautions are needed,

·       introduce appropriate measures to prevent or control the risk,

·       ensure that control measures are used and the equipment is properly maintained and procedures observed,

·       where necessary, monitor exposure to hazardous substances and carry out appropriate health surveillance,

·       inform, instruct and train employees as to the risks and of the precautions to be taken,

·       make appropriate arrangements for dealing with accidents, incidents and emergencies. 

Oils can be damaged (or denatured) in normal use and the used oils are usually more hazardous than the clean, new oils. It is generally the used oils that are more strongly associated with skin cancers, etc.

Some of the hazards associated with oils and greases

Skin rashes and dermatitis

‘Oil acne’ may be identified by the presence of blackheads, pimples and pustules on the skin.   The arms are the area most commonly affected (as these are the area most likely to come into contact with oils and greases), but any other part of the body may be effected if it comes into contact with oils or oil soaked clothing.  Oils may also remove the skin’s own naturally protective oils, leaving it dry.  This dry skin is liable to crack and is more susceptible to damage caused by cuts and abrasions.

Skin cancer and testicular cancer

It has been established that contact with certain mineral oils may cause cancer in humans. The carcinogenic potential of oil products is usually, but not always, associated with the presence of polycyclic aromatic hydrocarbons.  Used oils (especially used engine oil) have been shown to have elevated polycyclic aromatic hydrocarbons levels.  Prolonged exposure to certain mineral oils, and especially to used engine oil, can lead to the development of warty swellings or sores on the skin, especially where contact is on the scrotum.  These warty swellings are slow to heal and may be cancerous.  It is recognised that prolonged skin contact with used engine oil can lead to skin cancer and testicular cancer (from putting oily rags into overall pockets).  Consequently, used engine oil is listed as a carcinogenic substance in Schedule 1 of the Control of Substances Hazardous to Health Regulations 2002 (COSHH). 

Slipping hazard

Slips often take place when there is not effective contact between a shoe sole and the floor surface. This can be due to: faults with the floor surface, an inappropriate floor surface, inappropriate footwear or contamination between the shoe sole and the floor surface such as oils, greases and water. All of these factors, either individually or in combination, affect slip resistance.

Burns

In common with all hot substances and surfaces, skin contact with hot oils, or pipe work carrying hot oils, may cause burns.

Some of the methods that can be used to control the hazards from oils and greases

The best control measures are those that avoid contact with oils (such as fully enclosed pumping systems in place of pouring systems for draining and filling operations), while others limit the amount of contact (such as hand washing after exposure). 

Risk Assessment
The use, storage and disposal of oils should be subject to suitable and sufficient risk assessments. The risk assessments should consider all of the processes involved and should specify the measures that will be used to control these hazards and risks. The risk assessmetn process should consider COSHH; Slips, trips and falls; hot oils; burns; fire risk; etc.

Overalls and Aprons

Workers potentially exposed to oils should be provided with a sufficient number of protective overalls.  It is usual for them to have at least three sets of overalls (one set to wear, one set being cleaned and at least one spare set), although some tasks may require more sets of overalls.  Suitable arrangements need to be made for the overalls to be cleaned.  It is recommended that overalls are dry cleaned in order to remove oils and greases.  Ideally, overalls should be supplied without (trouser) pockets, so that oily rags cannot be stuffed into the pockets - reducing the potential for prolonged skin (scrotal) contact.  Lack of pockets also reduces the risk of other injuries from the tools, etc. that may also otherwise be put into them.

The use of (disposable) plastic aprons should be considered for certain operations where there is a risk of oil contamination of the overalls.

Gloves

Appropriate gloves should be worn as a barrier to protect the hands from contact with oils and greases.  In many cases, disposable gloves are used, while in others, more robust longer use nitrile gloves are provided.  The type of gloves provided will be dictated by the level of protection required and the type of work being undertaken.  The thin, disposable gloves reduce skin contact with oil while allowing fine work to continue. The potential helath risks (to some people) from powdered latex gloves should be considered as part of the overall risk assessment. 

Suitable washing facilities

Decent washing facilities are necessary to remove oil from the skin.  These should include both hot and cold running water as well as suitable skin cleansers.  Suitable hand drying facilities should also be provided, such as paper towels.  The use of suitable conditioning creams after washing can help to counter the degreasing effects of the oil on the skin.  Skin must never be cleaned with solvents, etc.  So called “barrier creams” must not be relied on to protect the skin from exposure to oils.  They can, however, be a useful extra protection and can make it easier to wash oils off of the skin after exposure.

Tissue roll in place of rags

It is recommended that, where appropriate, the use of rags for cleaning up is replaced by the use of suitable tissue wipes (usually supplied in a roll form).  Dispensers for these rolls may be wall mounted at suitable locations in the workshop.  This means that clean tissue is readily available for addressing small spills, cleaning tools, etc. and also that there is no temptation to keep rags (potentially oil contaminated) in overall pockets.

Draining and filling of lubrication systems, including those associated with vehicles

The drainage of used oil from lubrication systems offers significant risk of contact with the used oil.  These contact risks exist during the draining process, but also in subsequent handling of the drained oil, such as during transfer to a waste disposal holding vessel such as an oil drum or tank.  The risks may be reduced substantially by the use of a suitable oil collection vessel that later allows the waste oil to be pumped from the collection vessel to the waste oil storage vessel.  The collection vessel should be fitted with a wide funnel (for catching the oil) which should in turn be fitted with mesh to catch sump keys, bolts, oil filters, etc.

Storage arrangements

Oil, including waste oil, should be stored in suitable, robust vessels inside a bunded storage area (with a bund capacity of at least 110% of the size of the largest storage vessel). Waste oils should be disposed of by a licensed collector of such special waste. 

Information, instruction and training 

Employees who are potentially exposed to oils and greases must be made aware of the hazards associated with these materials and of the control measures to be used to protect their health.  Awareness can also be raised with suitable notices and leaflets that are available from the HSE. 

Spillage procedure

As oils and greases cause slippery surfaces and so, consequently, any spillages must be cleaned up immediately, using suitable absorbent granules.  Appropriate steps should be taken to stop leaks, including general maintenance, gasket replacement, etc.

Potential for oil in air-lines

Where compressed air is used to provide breathing air to air-fed masks, etc., care must be taken to ensure that the workers are not exposed to oil mists from the compressed air.  Suitable filters should be fitted and maintained and the quality of the air should be checked regularly.

Health surveillance

As it is recognised that prolonged skin contact with mineral oils can lead to occupational dermatitis and, in some cases skin cancer, the employer should carry out routine skin inspections as a precautionary measure. Employees should be encouraged to report sore, red or itching skin, whilst the responsible person should carry out regular, documented and recorded skin inspections of hands and forearms at monthly intervals. Cases of suspected dermatitis should be referred to a doctor or occupational hygiene nurse for further investigation. The results of health surveillance must be recorded and records must be retained for 40 years.

Summary

 

As well as being excellent lubricants, oils and greases are hazardous substances.  Prolonged exposure may result in skin problems, including skin (and scrotal) cancer.  Avoiding exposure to oils is the best control measure available and is often achieved by the use of suitable barrier techniques, such as gloves, overalls, etc.  Where exposure does occur, good personal hygiene and health surveillance are essential.  Oil spillages causing slippery surfaces must be cleaned up immediately and oils (including waste) must be stored and disposed of appropriately.

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A sad headline: Asbestos kills a retired painter and decorator

A RETIRED painter and decorator died due to contact with asbestos, an inquest heard on Thursday.

Mr Peter Taylor, of St Peter's Place, Canterbury, was a retired Painter and Decorator. He died in July 2012 at the Pilgrims Hospice aged 63. The pathologist (Dr George Vittay) told the inquest that Mr Taylor died of pneumonia, caused by mesothelioma.

Verdict: Industrial disease.

There are many deaths each year from exposure to asbestos. People working in the refurbishment industry are most at risk as they may disturb asbestos present in the buildings in which they ply their trade.

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The management of Health and safety of communal areas

In buildings with multiple occupancy, the landlord (or building manager or facilities manager) is responsible for the premises as a whole, but also has special responsibility for the common areas of the premises.  These can be thought of the parts of the premises not demised to (or directly under the control of) individual tenants.  Typically, these may include: car parking areas, external areas (roads, paths, lighting, refuse storage areas, etc), entrance doors, reception areas, corridors, staircases and lifts. In addition, the landlord will usually be responsible for the various plant rooms (boiler room, lift motor room, pump rooms, etc), roof areas, fixed electrical installation, water supply, etc as well as for the safe management of contractors working in these areas. There are also some special areas of safety management that fall under the control of the landlord or facilities manager, such as: fire safety for the common areas, the fixed electrical installation, cooling towers, asbestos, etc.

Asbestos

It is recommended that the landlord has a Managment Survey (previously refered to as a Type 2 survey) or a Refurbishment / demolition survey (previously referred to as a Type 3 asbestos survey) carried out on the premises. The key findings of this assessment must be made available to tenants and to contractors and should include the location and type of any asbestos containing materials.

Where asbestos (or asbestos containing material) is known to be present in a building, there should be some form of asbestos management plan in place. This may involve simply monitoring the condition of the asbestos at regular intervals to ensure that it has not been damaged. At the other extreme, it may involve a planned removal of the asbestos by a competent organisation.

Control of contractors

Control of contractors working on site on behalf of the landlord can be a difficult area to manage. Many landlords (and facilities managers) introduce some form of contractor approval system to ensure that certain minimum standards are met. These systems usually ensure that the contractors have adequate insurance, that they have a health and safety policy and that they have appropriate risk assessments and method statements in place.  They do not ensure that the contractors are carrying out the work in accordance with the risk assessments and method statements. It is recommended that at least some of the works carried out by contractors are observed and monitored by the landlord (or their representative) to ensure that they are working in accordance with their agreed standards.  Higher risk activities should be monitored more often and more closely.  Certain contractor tasks will require a higher level of control, such as the use of a permit to work system.

Contractors will need to be given appropriate information and instruction relating to hazards associated with the premises. These may include the presence and location of asbestos, the location of underground services (such as gas, water and electrical services), etc.

COSHH and chemicals

Copies of safety data sheets and of the COSHH assessments should be available on site for any substances used or stored in the common areas, even if stored and used by contractors. These may include water treatment chemicals, cleaning materials and maintenance sprays and lubricants, etc.

Electricity

In most premises, the tenants will be responsible for their own portable electrical equipment. The fixed electrical installation may be responsibility of the landlord or the tenant, depending on the tenancy contract. In many cases, the fixed electrical installation (in part or in total) will be the responsibility of the landlord. In this case, it is recommended that the landlord arranges for the fixed electrical installation to be tested and inspected by a competent person (such as an NICEIC approved contractor) at regular intervals (usually five yearly inspections for commercial premises and three yearly inspections for industrial premises).

External areas and building façade

The external areas of the premises should be inspected regularly, including checks on the condition of the building façade and all structure attached to the building, such as lights, aerials, CCTV cameras, flagpoles, etc. Similarly, checks should be carried out for all external areas, including car parking areas, roads and footpaths, fencing, lighting, etc. Any defects should be addressed and made safe.

Fire Safety

Fire safety is likely to be a shared responsibility, with the landlord being responsible for the common areas and the tenants being responsible for their demised area. It is recommended that the landlord carries out a fire risk assessment for the common parts of the premises and make suitable arrangements for the provision, maintenance, servicing and testing of:

·         A fire alarm, including automatic fire detection

·         Emergency lighting (in the common parts)

·         Fire fighting equipment (in the common parts)

·         Doors, fire doors and automatic door release systems

·         Emergency evacuation routes

·         (Wet or Dry) risers and sprinkler systems

·         Housekeeping in common areas

Tenant responsibilities

The landlord should make it clear to the tenant what their responsibilities are. While the landlord may, reasonably, be responsible for the provision, servicing and maintenance of collective fire safety measures (such as building wide fire alarm and fire/smoke detection) the tenant is responsible for the safe evacuation of their own workers and visitors from the premises. The tenant may be responsible for the provision of fire fighting equipment in their demised area, etc. The responsibilities need to be considered, identified and ascribed.

Tenants’ fire risk assessments

Tenants are generally responsible for their own fire safety arrangements, although some aspects (such as a building-wide fire alarm) may be shared facilities managed by the Landlord. It is recommended that the landlord request copies of the tenants’ fire safety risk assessments and that copies of these are filed and, if requested, made available to the fire authority during the course of an inspection visit.  A tenant should provide the landlord (and other tenants) with information relating to special fire risks, such as the storage of LPGs, etc.

Gas supply and services

The landlord should ensure that the gas supply and services are safe and are maintained in a safe and serviceable condition.  All gas pipe work should be clearly identified (with suitable labels stating “Gas” or by colour coding the pipe work (yellow ochre). All gas equipment under the control of the landlord should be regularly maintained and serviced (by a Gas Safe registered contractor) and a Landlord’s Gas Safety Certificate should be obtained for all gas equipment.

Lifts and lift motor rooms

Lift motor rooms should be clearly identified and should be kept locked and should only be accessed by competent persons (such as lift engineers). Hydraulic lifts should be bunded to contain any leakages of hydraulic oil and all lift motor equipment must be suitably guarded.

Passenger lifts should be tested and inspected by a competent person at least once every six months although this frequency may be reduced to once in every twelve months for goods lifts that are not used to transport people (i.e. if their use is restricted to goods only), as required under the Lifting Operations Lifting Equipment Regulations 1998 (LOLER).

Suitable arrangements should be made for the servicing and maintenance of lifts and for the rescue of people trapped due to lift failure.

Pressure systems

Any pressurised systems within the premises should be tested and inspected by a competent person at the intervals described in the written scheme of examination for the system.  As with other equipment, the landlord will be responsible for ensuring that it is serviced and maintained in a safe condition.

Roof areas

Access to roof areas should be secured to prevent unauthorised access. Consideration must be given to the protection of workers from falls from height. This will require a risk assessment to determine the appropriate control measures for the premises. Typical collective control measures include having suitable edge protection (such as a balustrade wall or fenced edge protection of at least 1100 mm height). In certain cases it may be appropriate to consider individual or personal protective measures such as anchor points for use with harnesses and lanyards.  

Consideration should be given to the need for roof access. It is common for various pieces of plant and equipment to be located on flat roof sections, especially air conditioning units, water storage tanks, lift motor rooms, etc. In such cases, regular roof access may be required by a range of contractors. If contractors are required to make use of individual protective measures, then the use of such equipment must be made clear to the contractor and the landlord should satisfy themselves that the use of such equipment is covered in the contractors risk assessments and method statements, etc. In cases where the roof area is accessed by tenants’ contractors (such as to service tenants’ air-con units or to fit aerials) then the landlord should ensure that the tenant and the tenant appointed contractor have considered to the safety issues associated with roof access.

Other aspects of roof access safety to be considered include fragile roof sections, glazed sections and skylights, etc.

Staircases, landings and corridors

Staircases should be in good condition, ideally with handrails on both sides of the staircase. The staircases, landings and corridors should be well lit, free from obstructions and slipping and tripping hazards. These areas should be checked regularly to ensure that they remain in good condition.

Water supply and cooling towers, etc

The landlord will usually be responsible for the water supply to the premises, including cold water storage tanks, water heating arrangements and hot water storage. The landlord is also likely to be responsible for ensuring that the risks from poor water hygiene are avoided or controlled. This will usually require a Legionella risk assessment in line with the requirements of the HSC Approved Code of Practice & Guidance (L8) "Legionnaires' disease: The control of legionella bacteria in water systems". Control measures required may include: regular water temperature monitoring, maintenance of cooling towers, provision and maintenance of water dosing chemicals and equipment, dip-slide sampling of cooling tower water, etc. Such work is often contracted out to a water hygiene specialist.

In premises that have cooling towers or evaporative condensers, the landlord will be responsible for ensuring that these have been notified to the local authority (as required under the Notification of Cooling Towers and Evaporative Condensers Regulations 1992). Further to this, the landlord must maintain and service the cooling tower to ensure that the risks from Legionella are controlled properly. This will involve a detailed cooling tower (legionella) risk assessment and regular checking and testing of the water in the tower. Such work is often contracted out to a specialist water hygiene company.

Window and canopy cleaning

Suitable arrangements much be made for the cleaning of the building and its windows and canopies, etc. This may well involve working at height using ladders, scaffolds, cherry pickers, scissor lifts, window cleaning cradles, abseiling systems, etc. Although such work is generally carried out in external areas, consideration needs to be given to the cleaning of high level internal structures, such as atrium glazing, etc. Any access equipment associated with the premises must be tested and inspected by a competent person at appropriate intervals. This includes the testing and inspection of eye-bolt anchor points, access cradles and associated runways, etc.
 
Michael Ellerby
Director
LRB Consulting Limited
www.LRBconsulting.co.uk

Advice on COSHH Training for small engineering workshops

There are a host of different hazards present in most engineering workshops, including: noise, hot surfaces, moving vehicles, moving parts of machinery, vibration, electricity, hazardous substances, etc.  When considering the risks from exposure to substances hazardous to health associated with engineering workshops, the range of substances may be daunting.  This article focuses on two hazardous substances commonly used in engineering workshops and demonstrates how the general management principles of COSHH may be applied. 

Elements to consider even before the training session

The training environment

COSHH training in the small engineering workshop may be carried out in a traditional training room environment.  Alternatively, if the numbers are relatively small, the training may be carried out in the workshop, using the existing workplace and the equipment therein as props for the training.  One of the problems with a workshop environment is that there tends to be a lot of background noise and so it may be necessary to: turn off equipment, turn off the air compressor and release the stored pressure in the air lines, turn off the local exhaust ventilation system(s), etc. 
 
Arrangements should be made for dealing with other distractions, such as deliveries, etc.

Consider the aim of the training course

When carrying out COSHH training for the smaller engineering workshop, the aim of the training is unlikely to be training in the COSHH regulation themselves, but is much more likely to be focussed on making workers aware of the health risks associated with the substances that they may be exposed to and on the control measures to be used to prevent (or control) that exposure. 

Consideration of the range of substances present

Before embarking on a COSHH risk assessment or on COSHH related training, it is important to determine what substances hazardous to health are present in the workshop.  Typical substances hazardous to health that may be found in an engineering workshop include:

•             Oils and greases

•             Spray lubricants (such as WD40)
•             Metal working fluids
•             Solvents (cleaning materials, thinners, etc.)
•             Paints (containing solvents, pigments, lead, etc.)
•             Isocyanates (in 2-pack polyurethane paints, etc.)
•             Epoxy materials (adhesives)
•             Welding and cutting fume (arc, gas and plasma)
•             Soldering fumes
•             Vapour phase degreasing materials
•             Kerosene based degreasing materials
•             Dusts (such as from processes like grinding, linishing and polishing)

A list (or inventory) should be made of all of the substances used, stored or generated in the workshop.

Information

Manufacturers’ (or suppliers’) safety data sheets are particularly useful for determining if a substance is hazardous to health. In fact, Regulation 12 of the COSHH Regulations states that relevant safety data sheets are amongst the pieces of information that must be made available to employees who are exposed to substances hazardous to health.  In order to carry out a suitable training session, the trainer must understand the hazards associated with the substances and this information may be found on the safety data sheet will provide this information. 

The HSE produces a wide range of informational literature that may be of direct benefit to small engineering companies and their COSHH issues.  These include a range of free leaflets (such as the INDG series) and priced publications (such as the HSG series).  Much of this information may also be downloaded (free of charge) from the internet.

It is recommended that useful information is made available to workers.  This may be contained in the COSHH risk assessment file or, more usefully, made available at the point of use (such as in local files on the shop floor or on notice boards).  Workers should be encouraged to access this information.

The application of the basic principles of COSHH to the management of health risks from exposure to hazardous substances

The Control of Substances Hazardous to Health Regulations 2002, as amended (COSHH) require that the health risks arising from exposure to substances hazardous to health are avoided where this is reasonably practicable or that they are controlled where it is not reasonably practicable to avoid them.  In order to comply with the principles of COSHH, the employer should:

•      Assess the risks to health and decide what precautions are needed.

•      Inform workers of the risks associated with exposure to substances hazardous to health and of the control measures to be used to ensure their health and safety.

•      Prevent workers being exposed to substances hazardous to health or, where this is not reasonably practicable, ensure that such exposure is controlled adequately.

•      Ensure that exposure control measures are followed at all times, and regularly checked and maintained, and that safety procedures are observed.

•      Monitor workers exposure to substances hazardous to health and carry out appropriate health surveillance, where the COSHH assessment has shown this is necessary.

•      Train workers in the use of control measures and the use of any personal protective equipment that may be required.

•      Provide suitable welfare facilities, such as washing and areas to consume food away from the work place.

COSHH issues associated with exposure to metal working fluids

Introduction

The main health effects arising from exposure to metal working fluids (MWF) are to the skin and to the respiratory system.  These include: irritation of the skin, dermatitis oil acne and folliculitis; as well as: occupational asthma, bronchitis, irritation of the upper respiratory tract, breathing difficulties or, rarely, a serious lung disease called extrinsic allergic alveolitis.   Water based MWF support microbial growth and, hence, can lead to biological contamination of the MWF, increasing the risks of ill health arising from exposure.  Ill health effects may also be increased by chemical contamination of the MWF from: tramp oils, hydraulic fluids, polycyclic aromatic compounds (in neat oils) and nitrosamines (in water based oils). The (COSHH) risk assessment for the use of MWF should identify a range of simple control measures that can significantly reduce the risks of ill health developing. 

Health effects of exposure to metal working fluids

Respiratory ill health

Workers exposed to MWF mist and vapour are at risk of developing work-related asthma, bronchitis, irritation of the respiratory tract and breathing difficulties, as well as extrinsic allergic alveolitis (which can cause increasingly severe breathing difficulties in recurrent episodes, following repeated exposure). Exposure may also cause irritation to the eyes, nose and throat.

Inhalation of these biological contaminants (such as bacteria or toxins) can lead to irritation of the respiratory tract and flu-like symptoms, as well as aggravating existing asthma.

Skin problems

Dermatitis can be caused:

•      by bacteria (or their toxic by-products) when they are present in the MWF in the sump;

•      through contact with sensitising metal (such as chromium, nickel and cobalt), which can leach out from cutting tools, grinding wheels and substrates into MWF; and

•      by contact with chemical additives, such as biocides and corrosion inhibitors.

The use of unrefined mineral oils may lead to skin cancer on affected skin, such as hands and the lower arms.  Prolonged exposure through wearing contaminated clothing and the habit of putting oily rags into overall pockets increases the risks of skin cancer and of scrotal cancer.  These risks are lessened by the use of highly refined oils, etc.

Routes for exposure to metal working fluids

MWF fluids are usually applied by continuous jet, by a spray or by a hand dispenser.  They can only cause health effects if they come into contact with the body.  The common routes for exposure are: 

•      Inhalation of the mist generated during the machining operation.

•      Direct contact (such as from splashes) with unprotected skin, particularly hands, forearms and heads.

•      Entry into the body through direct contact with cuts, abrasions or other broken skin.

•      Ingestion (arising from eating, drinking or smoking in work areas, or from poor personal hygiene). 

Control measures for working with metal working fluids

In general, the introduction and maintenance of simple control measures will significantly reduce the risks of ill health developing from exposure to MWF.

General control measures

•      Ensure that the most appropriate MWF has been selected.

•      Devise a safe system of work for working with metalworking fluids and instruct workers in this safe system of work.

•      Ensure that suitable splash guards are provided, fitted and used appropriately.

•      Minimise the production of MWF mist and vapour, such as by controlling the volume and rate of delivery of the MWF to the tool.

•      Avoid the use of compressed air to remove excess metalworking fluids from machined parts, plant or equipment.

Extraction and ventilation

•      Provide suitable extraction systems (such as local exhaust ventilation), where the need is identified in the (COSHH) risk assessment.

•      Ensure that any enclosures or extraction systems provided to remove or control mist or vapour are used properly.

•      Ensure that there is a time delay before opening the doors on (CNC) machine enclosures to ensure that all mist and vapour have been removed by the ventilation.

•      Introduce regular monitoring (checks) of the equipment and arrange for any damaged or defective splash guards, extraction systems, etc. to be repaired.

•      Ensure that the extraction system is checked and serviced regularly and that it is subject to statutory examination (by a competent person) at least once in every fourteen month period.

•      Ensure that there is adequate general ventilation in the work area - open workroom doors and windows to improve natural ventilation, where appropriate.

 Avoiding skin contact and skin protection

•      Introduce suitable measures to reduce the potential for contact with MWF .

•      Reduce contact with wet work pieces and surfaces.

•      Instruct workers not to put bare hands into fluid sumps and not to use oily rags to wipe them clean.

•      Provide suitable personal protective equipment and ensure that it is worn as appropriate.  Suitable PPE may consist of gloves (or gauntlets), overalls, aprons, goggles or face shields.

•      Instruct workers in the risks of contamination of the inside of gloves (with MWF) when putting them on or taking them off.

Sump fluid control

•      Ensure that waste materials (especially unwanted food, drink, cigarette stubs) are not disposed of into the sump.

•      Instruct workers to inform a supervisor if they observe any layers of scum or large amounts of tramp oil on top of the sump fluid, or if the sump fluid becomes dirty or smelly.

•      Introduce and follow good working practices when mixing fluids, cleaning and topping up sumps etc.

•      Monitor the levels of bacterial contamination using dip slides, or other means of measuring the level of bacterial activity.

•      Consider a contract management service for the MWF (offered by some suppliers). 

Personal Hygiene

•      Provide suitable hand washing facilities, including running hot and cold water, soap and towels.

•      Provide, and encourage the use of, suitable pre-work barrier creams and after-work conditioning creams.  This barrier cream should be designed to provide a protective layer between the skin and the MWF, while the after-work conditioning cream is intended to replace the natural skin oils removed by washing and by contact with the MWF.

•      Ensure that any cuts and abrasions are covered with a suitable waterproof dressing.

•      Instruct workers in the need for high standards of personal hygiene.

•      Instruct workers to wash regularly with soap and water to remove MWF from skin. Instruct workers to avoid using abrasive or solvent cleaners.

•      Instruct workers to wash their hands thoroughly before eating, drinking or smoking.

•      Store personal protective equipment in the changing facilities provided or another clean storage area.

•      Ensure that a sufficient number of suitable overalls are provided and that they are changed regularly.

•      Instruct workers not to put oily rags into their pockets.

•      Provide a laundry service for dirty overalls and instruct workers not to take hem home for washing.

•      Prohibit eating, drinking and smoking in areas where metalworking fluids are used.

 

Health Surveillance

•      Appoint a responsible person to carry out health surveillance, as identified by the risk assessment.

•      Carry out asthma health checks.

•      Refer anyone affected by exposure to MWF to an occupational health professional.

•      In the event of any ill health being identified, ensure that prompt action is taken to identify the likely cause and ensure it is prevented or adequately controlled.

•      Keep workers informed of the collective findings of health surveillance.

COSHH issues associated with exposure to oils and greases

Introduction 

It is an inevitable consequence of many aspects of production and maintenance work that workers will come into contact with greases, oils and general lubricants.  Prolonged contact with these oils and greases can cause a range of skin problems, such as: rashes (e.g. oil acne), dermatitis and even skin cancer and testicular cancer.  Contact with hot lubricants, during servicing or maintenance, may also cause burns. 

Routes for exposure to oils and greases

Oils and greases may be used widely in the workshop.  They may be associated with the lubrication of the moving parts of machinery in the workshop, they may be associated with work being undertaken or may be contamination on surfaces (such as work benches, inspection pits, work pieces, etc.).  The common routes for exposure are:

•      Inhalation of the mist generated during the machining operation or from the use of spray lubricants (such as WD40).

•      Direct contact with unprotected skin, particularly the hands or indirect (but often prolonged contact) from oil contaminated clothing, such as overalls.  This may occur when fill or draining a lubrication system or reservoir.

•      Entry into the body through direct contact with cuts, abrasions or other broken skin.

•      Ingestion (arising from eating, drinking or smoking in work areas, or from poor personal hygiene). 

Hazards associated with oils and greases 

Skin rashes and dermatitis

‘Oil acne’ may be identified by the presence of blackheads, pimples and pustules on the skin.   The arms are the area most commonly affected (as these are the area most likely to come into contact with oils and greases), but any other part of the body may be effected if it comes into contact with oils or oil soaked clothing.  Oils may also remove the skin’s own naturally protective oils, leaving it dry.  This dry skin is liable to crack and is more susceptible to damage caused by cuts and abrasions.

Skin and testicular cancer

It has been established that contact with certain mineral oils may cause cancer in humans. The carcinogenic potential of oil products is usually, but not always, associated with the presence of polycyclic aromatic hydrocarbons.  Used oils (especially used engine oil) have been shown to have elevated polycyclic aromatic hydrocarbons levels.  Prolonged exposure to certain mineral oils, and especially to used engine oil, can lead to the development of warty swellings or sores on the skin, especially where contact is on the scrotum.  These warty swellings are slow to heal and may be cancerous.  It is recognised that prolonged skin contact with used engine oil can lead to skin cancer and testicular cancer (from putting oily rags into overall pockets).  Consequently, used engine oil is listed as a carcinogenic substance in Schedule 1 of the Control of Substances Hazardous to Health Regulations 2002 (COSHH).   

Other hazards

Hazards associated with slipping due to oil on the floor or with burns from hot oils are not considered in this article.

Control measures for working with oils and greases

The best control measures are those that avoid contact with oils (such as fully enclosed pumping systems in place of pouring systems for draining and filling operations), while others limit the amount of contact (such as hand washing after exposure).

Overalls

Workers potentially exposed to oils should be provided with a sufficient number of protective overalls.  It is usual for them to have at least three sets of overalls (one set to wear, one set being cleaned and at least one spare set), although some tasks may require more sets of overalls.  Suitable arrangements need to be made for the overalls to be cleaned.  It is recommended that overalls are dry cleaned in order to remove oils and greases.

Ideally, overalls should be supplied without (trouser) pockets, so that oily rags cannot be stuffed into the pockets - reducing the potential for prolonged skin (scrotal) contact.  Lack of pockets also reduces the risk of other injuries from the tools, etc. that may also otherwise be put into them.

Aprons

The use of (disposable) plastic aprons should be considered for certain operations where there is a risk of oil contamination of the overalls. 

Gloves

Appropriate gloves should be worn as a barrier to protect the hands from contact with oils and greases.  In many cases, disposable gloves are used, while in others, more robust longer use nitrile gloves are provided.  The type of gloves provided will be dictated by the level of protection required and the type of work being undertaken.  The thin, disposable gloves reduce skin contact with oil while allowing fine work to continue.

Suitable washing facilities

Decent washing facilities are necessary to remove oil from the skin.  These should include both hot and cold running water as well as suitable skin cleansers.  Suitable hand drying facilities should also be provided, such as paper towels.  The use of suitable conditioning creams after washing can help to counter the degreasing effects of the oil on the skin.  Skin must never be cleaned with solvents, etc.  So called “barrier creams” must not be relied on to protect the skin from exposure to oils.  They can, however, be a useful extra protection and can make it easier to wash oils off of the skin after exposure.

Use of tissue rolls in place of rags

It is recommended that, where appropriate, the use of rags for cleaning up is replaced by the use of suitable tissue wipes (usually supplied in a roll form).  Dispensers for these rolls may be wall mounted at suitable locations in the workshop.  This means that clean tissue is readily available for addressing small spills, cleaning tools, etc. and also that there is no temptation to keep rags (potentially oil contaminated) in overall pockets.

Draining and filling of lubrication systems, including those associated with vehicles

The drainage of used oil from lubrication systems offers significant risk of contact with the used oil.  These contact risks exist during the draining process, but also in subsequent handling of the drained oil, such as during transfer to a waste disposal holding vessel such as an oil drum or tank.  The risks may be reduced substantially by the use of a suitable oil collection vessel that later allows the waste oil to be pumped from the collection vessel to the waste oil storage vessel.  The collection vessel should be fitted with a wide funnel (for catching the oil) which should in turn be fitted with mesh to catch sump keys, bolts, oil filters, etc.

Storage and disposal of (waste) oil

Oil, including waste oil, should be stored in suitable, robust vessels inside a bunded storage area (with a bund capacity of at least 110% of the size of the largest storage vessel) pending collection for disposal by a licensed collector of such special waste. 

Health surveillance

As it is recognised that prolonged skin contact with mineral oils can lead to occupational dermatitis and, in some cases skin cancer, the employer should carry out routine skin inspections as a precautionary measure.  Employees should be encouraged to report sore, red or itching skin, whilst the responsible person should carry out regular, documented and recorded skin inspections of hands and forearms at monthly intervals.  Cases of suspected dermatitis should be referred to a doctor or occupational hygiene nurse for further investigation.  The results of health surveillance must be recorded and records must be retained for 40 years.

Information, instruction and training 

Employees who are potentially exposed to oils and greases must be made aware of the hazards associated with these materials and of the control measures to be used to protect their health.  Awareness can also be raised with suitable notices and leaflets that are available from the HSE.

Care with air-lines

Where compressed air is used to provide breathing air to air-fed masks, etc., care must be taken to ensure that the workers are not exposed to oil mists from the compressed air.  Suitable filters should be fitted and maintained and the quality of the air should be checked regularly.

Summary

Consideration needs to be given to the aims of the training course.  In many cases, the training needs to be focus on the nature of the hazard to which people will (or may) be exposed and on the measures that need to be used to avoid or control that hazard.  In the case of COSHH and its relevance to a small engineering workshop, it may be prudent to focus the training on examples that affect the workshop rather than on the intricacies and technicalities of the COSHH Regulations.  This may be achieved by training using examples that are directly relevant to the workshop.

 

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