With the three-year long campaign with regards silica and foundries ending at the end of March this year, it is timely to consider the findings, and what the industry needs to do in response?
Over the last three operational years, as part of its silica campaign, the Health and Safety Executive (HSE) has visited a large number of sand foundries in the UK. They primarily visited sand foundries but did also get on site at foundries running other processes, as the visits for foundries also included dusts, fumes and vapours beyond silica.
HOW DID WE DO?
The HSE informed the industry via CHASAC and the CMF that the levels of enforcement issued out was upwards of three quarters of foundries (more than 75 per cent) visited receiving enforcement, ranging from Notifications of Contravention (NoCs), through improvement notices and on to prohibition notices.
Considering that communication from the Cast Metals Federation, the HSE, SHIFT and media outlets such as Foundry Trade Journalwere produced and readily available prior to the campaign getting underway, and the fact that industry has been kept updated on findings as the campaign went along – including three letters from CHASAC itself to all UK foundry MDs – the outcome is appalling.
The key areas being highlighted as found to be wanting, have again been highlighted to directors in the third letter to them. They remained the same twelve points as identified and shared in the second letter. They are:
- Provision of adequate local exhaust ventilation (LEV) on furnaces to extract fume at source.
- Wearing the correct PPE for working with molten metal.
- Provision and use of respiratory protective equipment (RPE) when pouring molten metal.
- Provision and use of LEV and RPE in mould making and use of compressed air to finish moulds.
- Minimisation of release of RCS when filling mould boxes.
- Provision of LEV and RPE for fettling operations.
- Ensuring adequate RPE programmes to select the correct RPE, maintain and store it properly and ensure its correct use – including, for tightfitting masks, face fitting, workers being clean shaven and filters changed.
- Provision of adequate COSHH sampling and monitoring to show that harmful substances are being adequately controlled.
- Provision of adequate health surveillance for workers exposed to RCS and asthmagens to pick up problems early and prevent them getting worse.
- Elimination of dry sweeping and use of compressed air for cleaning surfaces and machinery.
- Provision of adequate welfare facilities.
- Training for supervisors to ensure that they are competent to supervise hazardous tasks.
None of the legislation against which breaches were identified is new, as I have commented on before in this column. The legislation has been around for decades. This legislation, along with guidance produced by the HSE over time via ACoPs etc. and shared, along with technical presentations on individual aspects at SHIFT meetings, CMF members meetings etc. should be more than capable of informing duty holders what they need to do. Foundries, like any other business, are required to have competent health and safety advice, either in-house (the preferred option), or via external consultants, to help directors comply with their legal and vicarious responsibilities to keep their employees safe and well by being aware of what is required.
So, with well established and known (and hopefully understood) legislation in place and competent advice provided to duty holders, as well as the HSE informing them directly, why has the industry faired so badly?
There is no one easy answer to this question. If there was, it might be easier to resolve the issue. There will always be debates about the costs of doing the right thing, especially when to date no-one at a site has suffered an accident or ill-health related to work. However, under UK legislation, we must look for risks to the physical safety and the health of employees and act on those, to prevent actual harm occurring in the first place.
There will be debates about the cost of producing in the UK versus other locations throughout the world and needing to stay competitive against those providers of castings. There will be debates too about what we have to do in the UK in the name of health and safety as opposed to what other countries do. There will be many other debates and reasons offered up too.
However, ultimately, we operate in the UK under long standing UK legislation, which is produced by parliament, and parliament creates the regulators that oversee what we do, and who inspects our industry to ensure that compliance is being met against the requirements mandated, so we must find ways to be able to meet the challenges and demands put before us.
The HSE is now actively looking at the results of the inspections and the enforcement issued with a view to the next steps. The recommendations from the sector should be with the main body of the HSE before the end of summer this year. Historically, campaigns with such high levels of enforcement result in subsequent follow-up campaigns, and there are ongoing actions for the HSE in the coming year across wide swathes of UK industries looking into musculoskeletal disorders, noise, the duty to manage asbestos and health surveillance.
All the above means that one way or another we will be under the microscope for some time to come. The only way to reduce the amount of interest in what foundries are doing is for the industry to improve itself. When foundries are struggling to recruit and get new staff to replace those leaving for retirement or any other reason, doing the right thing, is as ever a must, rather than a nicety.
Contact: Richard Heath at the Cast Metals Federation, Tel: +44 (0) 121 809 3502, email: [email protected]