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Health Check 2020 - Are You Prepared?
Richard Denton (Senior H&S Consultant)Caroline Lee (Senior H&S Consultant/Legionella Expert)
www.southalls.com
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● COSHH Target Areas● Completion of COSHH assessments● Metal Working Fluids● Wood Dust● Fume and dust exposure● Welding Fume● LEV/PPE● Health Surveillance● Legionella and COVID-19
WHAT WILL WE BE LOOKING AT?
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WHO WE ARE?• Family business, established 2003
• Backed mainly by ex enforcement officers, 20 consultants
• No nonsense realistic approach
• Designers and owners of Safety Cloud
• Safety Cloud and Safety Plus
Why today - health - HSE and LA focus - confidence in management
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Flow
• Richard Denton - COSHH - HSE/LA Target areas
• Caroline Lee - Legionella - how to comply.
• Summary
COSHH - HSE/LA TARGET AREAS
Richard DentonSenior Consultant
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GO HOME HEALTHY CAMPAIGN❏ HSE/LA inspection target❏ Covers dusts, mists, fumes in addition
to other areas such as mental health ❏ Focus shift from safety to health❏ Are we managing what we need to
under COSHH effectively?
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LEGAL DUTIES UNDER COSHH❏ Control of Substances Hazardous to Health Regulation 2002 (as amended) ❏ Substances with the potential to cause harm that could be ingested, inhaled, absorbed and
injected and can include dusts, liquids and gases. ❏ Identify any substances employees use.❏ Assess methods of exposure.❏ Assess the risk to health (refer to MSDS) ❏ Implement controls.❏ Monitor control measures are working.❏ Provide training and instruction.
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TYPES OF HEALTH HAZARDS
Today we are looking at…..❏ Metal Working Fluids (Coolants) - dip slide testing and mist
exposure❏ Wood dust - saws and LEV systems❏ Welding fume - ALL types inc. brief spot welding
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CASE STUDY …… METAL WORKING FLUIDS
● Engineering company visited by the HSE● HSE served Improvement Notice under COSHH Regulation 6 & 7 requiring extraction on all
enclosed CNC Millers and Lathes● Regulation 6 - Duty to risk assess● Regulation 7 - Duty to prevent ● Schedule 2(A) - As Low As Reasonably Practicable (ALARP)● State that if machines operating over 2000rpm creates a mist which is hazardous to health
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CASE STUDY ……METAL WORKING FLUIDS
● Company could demonstrate suitable and sufficient risk assessment● Undertaken air monitoring from external specialists noted no exposure on any machine apart
from one CNC.● Extraction fitted to single CNC machine with negligible exposure● HSE still insist on extraction to all machines● Company continued to challenge the HSE ● HSE visited a second time with a HSL (Laboratory) specialist● Company were successful in demonstrating compliance with the Improvement Notice following
second air monitoring and additional controls such as dwell times on CNC enclosures, dust lamp usage, tool speed monitoring etc.
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WOOD DUST - WHAT DO WE KNOW?
❏ Hardwood dusts known carcinogen❏ Flammable/ Explosive❏ Asthmagen❏ Dermatitis sensitiser❏ MDF can contain formaldehyde
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WOOD DUST - WHAT DO WE KNOW?
❏ NEVER dry sweep❏ Use a M Class Vacuum if possible❏ Fit extraction to machinery (tested every 14
months)❏ Never fill extraction dust bags over ⅔ full❏ Provide PPE (Usually FFP3 dust masks as a
minimum) to change bags❏ Hardwood dust Workplace exposure limit
(WEL) reduced from 5mg/m3 to 3mg/m3 ❏ Softwood WEL remains at 5mg/m3
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WELDING FUME - NEW HSE/LA FOCUS❏ All forms of welding fume can cause cancer.
❏ Control is required where:
❏ Indoor welding tasks require the use of LEV.
If LEV is unable to control fume capture then
Respiratory Protective Equipment (RPE) is
also required.
❏ Outdoor welding requires use of RPE.
❏ Enforcement of the raised control standards is with
immediate effect under Control of Substances
Hazardous to Health (COSHH) Regulation 7.
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WORKPLACE EXPOSURE LIMITS (WEL)❏ HSE Guidance EH40/2005❏ British WEL reflects European WEL❏ No WEL for Metal Working Fluids❏ No WEL for any Welding Fume❏ Hardwood dust WEL 3 mg/m3
❏ Softwood dust WEL 5 mg/m3
❏ Formaldehyde WEL 5 mg/m3
❏ Cutting wood referenced ❏ Hardwood referenced as carcinogen❏ Welding fume referenced as a carcinogen❏ Softwood and hardwood asthmagen❏ Sampling by competent person❏ Health monitoring required
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WHAT ARE THE COMMON CONTROLS?
❏ COSHH Assessments completed by employer
❏ Utilise the MSDS❏ Can we substitute substance?❏ What is our employee exposure?❏ How do we control exposure?❏ PPE?❏ Local Exhaust Ventilation (LEV)?❏ Are we monitoring employee health?
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LEV or PPE - Points to consider?❏ COSHH assessment❏ Exposure assessment❏ Type of substance - e.g. hardwood always
LEV❏ Consider hierarchy of control❏ PPE is considered last resort❏ Cost of installation❏ Occupational health advisors
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TYPES OF LEV
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LEV REQUIREMENTS
❏ Power isolation for maintenance❏ Thorough examination 14 monthly (6
monthly if abrading or polishing)❏ Competent person❏ Records retained for at least 5 years❏ Must be commissioned❏ COSHH - PPE required❏ DSEAR -
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TYPES OF RPE
Disposable half mask
Reusable half mask
Full face mask
Air Fed RPE
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RPE REQUIREMENTS❏ Powered and non-powered❏ Correct type ❏ Must be adequate and suitable❏ Must be CE marked❏ Training required❏ Storage ❏ Monitoring use❏ Facial hair inhibits a full seal❏ Masks vary dependant on hazard:
❏ Solid particles❏ Liquid particles❏ Vapour❏ Gas
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RPE PROTECTION FACTORS
❏ Filtering Facepiece (FFP) 1-3❏ FFP1 dusts (low)❏ FFP2 dust, smoke and aerosols (medium)❏ FFP3 dust, smoke aerosols, radioactive
substances and viruses (high)
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SUMMARY❏ Metal Working Fluids, Wood dust and Welding
Fume are priorities❏ Do not dry sweep wood dust, or metal fines❏ ALWAYS use extraction ❏ COSHH assessments are a legal requirement❏ LEV must be thoroughly examined❏ Review your LEV examination reports❏ PPE use should be the last option❏ Check you are using the right PPE❏ Provide face fit testing for RPE
HEALTH SURVEILLANCE
What is it?Simply a system of ongoing health checks
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Why do health surveillance?
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LEGAL REQUIREMENTS
Ionising radiation
Solvents Fumes Dusts
Biological agents
Hazardous substances
Asbestos Lead
Working in compressed
airNoise
Hand arm vibration
Night shift workers
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WHEN SHOULD HEALTH SURVEILLANCE BE DONE?
● On starting job – “day zero”● On an annual basis● If there has been a
diagnosis
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WHAT’S THE PROCESS?
Self assessment Manager review Discuss
Refer?Adjustments?Monitor and
review
“But I’m not a doctor. How do I discuss these issues with my staff member?”
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EXAMPLE - HIGH BLOOD PRESSURE
● Just ask basic questions● “Are you taking your tablets?”● “Are there any side effects that mean you shouldn’t be
driving, using a table saw, etc.?”● Any concerns - refer to GP/HR/Occupational Health● Keep a record of the discussion
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Are there LEGIONELLA risks in your workplace?If you have one of the following within your workplace or premises then you have to consider Legionella in your risk assessments:
● A cooling tower or evaporative condenser● Dry or wet cooling systems (“hybrid” or “adiabatic coolers”)● Hot and cold water systems ● Spa pools
There are other potential risk systems.
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Potentially foreseeable Legionella risk The 4 factors that encourage legionella multiplication and dispersal: ● Where the water temperature in all or some of the system may be
between 20-45°C● It is possible for water droplets (aerosols) to be created and
spread● Water is stored and/or recirculated● There are deposits that can support bacterial growth such as rust,
sludge, scale, biofilm, or organic matter
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Duty Holder - Employer or person in control of the premises
Should appoint a:
Competent or Responsible Person - person who takes responsibility for controlling any identified risk from exposure to legionella bacteria.
You may call on help or advice from outside sources (e.g. consultancies) to carry out the
RISK ASSESSMENT
What do you need to do to comply?
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● Prevent multiplication of the bacteria by avoiding water temperatures that favour its growth.
● Keep the system and the water in it clean.● Ensure that water cannot stagnate in the system.● Treat the water to control the growth of legionella.● Ensure that the release of water spray is properly controlled.
Preventing or Controlling the Risk: Practical Overview
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Common Sights
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● Susceptible population & mothballed buildings may lead to an increased risk from Legionella.
● Temporarily Closed Buildings○ Have you considered safe practices around decommissioning? ○ Does your risk assessment cover mothballing of the business?○ Have you looked at what water systems are essential to your business
at re-opening? ○ Have you a safe re-commissioning procedure in place?
Legionella & COVID-19
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Make sure you have a legionella risk assessment
Ensure that you are following the outlined controls
Keep a record of any monitoring that you undertake
Review the risk assessment regularly, including during unusual site operating conditions
Key Checks to do in Your Business
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Do you need help?● Gap Analysis● Safety Cloud Software● Consultancy Support● Specialist support - asbestos surveys, DSEAR
assessments, legionella risk assessments & written schemes,
● Bespoke IOSH courses tailored to industry
Questions or need more help?
Webinar series offer: New Safety Cloud and Safety Plus customers receive 2 months free software use for contracts that start in May and June 2020!
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Southalls ServicesSouthalls do:
❖ Act as competent person❖ Gap Analysis❖ H&S Consultancy❖ Food Safety Consultancy❖ Safety Software❖ Fire Safety❖ Noise Assessments❖ DSEAR Assessments❖ Acting as RPO❖ Asbestos Surveys and Management Plans❖ Legionella Risk Assessment and Written Schemes❖ www.southalls.com
