The HSE’s silica campaign is one of many that have been underway since the start of their 2021/22 operational year. This new campaign is targeting all businesses that are users of silica with UK sand casting foundries being visited.
The silica campaign is not only considering foundries but mineral products businesses across a range of sectors (stone, brick, sand, concrete) are also under scrutiny, with inspections being undertaken to review the control of silica (and especially the respirable crystalline fraction that is so harmful to health that in 2016 it was deemed to be carcinogenic).
However, it is not just silica that is being reviewed in foundries – already campaigns addressing welding fume, metal working fluids and woodworking are underway.
Other investigations and what to expect during a visit
The foundry visits commenced on 3rd October and will continue for the remainder of the HSE’s operational year (to April 2023). Seven key areas will be scrutinised – moulding, metal melting, tapping and pouring, knockout and/or shakeout, fettling, shotblasting, plus sand reclamation and the operation of the sand plant.
In addition to silica, the inspection visits will be looking at the control of a range of dusts, fumes, vapours, and particles from these production areas. The reasons for these visits are many but include increased knowledge of the importance of good lung health (something the world has learned more about through the Covid-19 pandemic), outputs from the HSE research project (long latency health risks project) RR1115, and known health risks from exposure to some substances in foundries.
- Metals found in fume and dust can include nickel, chromium, manganese and lead, all of which are known to have long-term health effects if exposure is not controlled.
- Ferrous foundry fume, if inhaled, can cause cancer and other foundry fume can cause asthma.
- Some metals such as nickel and cobalt can cause dermatitis and skin allergies.
- Substances found in binder systems can include furfuryl alcohol, phenol-formaldehyde, benzene and isocyanates. Some of these substances or their decomposition products can cause asthma dermatitis and skin allergies, and some can cause cancer. Much work has already been undertaken by the supply chain to reduce/remove benzene-based products supplied to the UK industry but it is the foundry as the duty holder which needs to ensure its employees are protected from hazardous substances.
- Toxic gases, such as carbon monoxide, can be formed from furnace combustion processes and the pyrolysis of organic binder systems.
As part of any visit to a site, foundry management teams can be expected to be questioned on the use of LEV systems and their maintenance/use. A part of this will be whether routine ‘thorough examination and testing’ has taken place at the prescribed frequencies cited in both the main body of the COSHH regulations and in schedule 4, where further specific details of requirements are included.
COSHH risk assessments, proof of face-fit testing (a legal requirement), training records with regards to hazards and chemical hazard training as part of induction training, are among the minimum documentation that foundries can be expected to evidence to demonstrate management control of all the hazardous substances mentioned above.
Inspectors are also likely to question from where help and guidance on managing substances in the workplace is sought. This could include the in-house capability through to external consultants and/or dedicated providers of software and management systems. Overall competency of the on-site management with regards to health and safety may be questioned.
Visits are expected to take place via planned meetings to ensure that the right personnel will be present and that access to all records and documents required will be available during the inspection, but this cannot be guaranteed.
To help foundries better understand what is required to keep people safe in the workplace when undertaking foundry activities, the HSE recently published updated COSHH essentials sheets, which are free to download and offer some guidance at: www.hse.gov.uk/coshh/essentials/direct-advice/foundry.htm
Potential consequences for the industry
The CHASAC Committee, SHIFT and Cast Metals Federation members have been made aware, by the HSE Molten Metals team, that if there are weaknesses in the controls being implemented by the industry through this campaign, then it is highly likely that a much larger and more in-depth campaign focussed on foundries will be possible during the next operational year. Considering the number of sand foundries operating in the UK, it is possible that every such foundry could be visited.
While it is clear the HSE has been tasked with undertaking a much more proactive approach to looking at occupational safety, it is also vital that foundries remember that inspectors still have a duty to ensure the safety of the UK workforce. So, if an activity witnessed by an inspector on site is deemed dangerous in their opinion, or if, for instance, guarding is missing from machinery where people could sustain injuries, then enforcement should still be expected by the foundry.
When enforcement is issued, it has been known for some in the industry to comment that: “Inspectors don’t understand foundries and how they work”. The fact is, they don’t need to. Inspectors need to know the law and it remains the responsibility of the duty holder to prove compliance with it. All employers need to ensure that they adapt accordingly to any changes in legislation or as new knowledge about health risks comes to light.
The phrase “but we’ve always done it this way” will not work.
Contact: Richard Heath at the Cast Metals Federation, Tel: +44 (0) 121 809 3502, email: [email protected]