As a consequence of the Health and Safety Executive’s (HSE) ‘silica campaigns’ last year, a number of UK foundries were visited. The outcome – a high number of enforcement notices were issued to foundries, both for health concerns and for safety breaches of legislation.
The levels of enforcement issued has not done the industry in the UK any favours.
As a direct result of the high level of enforcement, CHASAC (Castings Health and Safety Advisory Committee), which is the HSE’s strategic oversight committee, has written to all UK foundry managing directors to inform them of the issues and to remind them of their responsibilities for keeping their employees safe. The only foundries excluded from receiving this letter were those who had been visited as part of the initial silica campaign.
This high level of enforcement has not only had an impact on those foundries visited last year, but is impacting all other UK foundries in the current operational year. Once the initial visits had been completed in 2022 an internal review by the HSE has resulted in them concluding that a much larger campaign was needed for this operational year (2023/2024). Therefore, as of Monday 3rd July visits to foundries started once again. The HSE’s intention is that all foundries will have been visited by the end of December 2023, and certainly before the end of March 2024.
Given that their inspectors will not only be looking at the same issues as in last year’s campaign, but also now fumes and emissions at melting operations and from fettling and finishing operations, any foundry, not just sand foundries, will be on their list for a possible visit. Therefore, all foundries can anticipate a visit before the end of March 2024.
When inspectors are on site there is also the normal ‘matters of evident concern’ aspects that foundries need to be aware of. For clarity, ‘matters of evident concern’ is anything that the inspector witnesses or is informed of, whether that is an issue of an immediate safety concern or another occupational health issue on site, such as noise or vibration for instance. If any such concern is seen by the inspector or they are advised about such an issue, they are obligated to address them. This would then either result in a Notification of Contravention (not seen on HSE public webpages, but £166.00 per hour fee for intervention (FFI) cost still applies), through to an Improvement Notice or a Prohibition Notice being issued to the foundry. Improvement and prohibition notices not only are subject to the FFI cost, but also go ‘live’ on the HSE’s public website, where they can be seen by anyone in the world for five years, including, of course, potential recruits and competitors.
There will, of course, be foundries where no such issues are found, and the Cast Metals Federation (CMF) knows of many such cases, where visits result in no actions being needed by the HSE – and this is good news for all of course, not least the employees.
AREAS FOR PARTICULAR FOCUS BY FOUNDRIES
As a result of analysis of the findings of the HSE visits last year, CHASAC identified twelve points where changes and improvements need to be made by the industry:
- Provision of adequate LEV on furnaces to extract fume at source.
- Provision and use of RPE when pouring molten metal.
- Ensuring adequate RPE programmes and correct use across the foundry.
- Provision of adequate COSHH sampling and monitoring.
- Provision of adequate health surveillance.
- Improving training of supervisors on their health and safety roles and responsibilities.
- Provision of LEV in mould making.
- Minimisation of release of RCS when filling mould boxes.
- Provision of LEV and RPE for fettling operations.
- Provision and use of LEV and RPE in mould making and use of compressed air for finishing moulds.
- Eliminating the use of dry sweeping for cleaning inside foundries.
- Eliminating the use of compressed air for cleaning inside foundries.
Many of these are not easy to solve. (The last point around the use of airlines, for instance, is covered in the COSHH essential document for moulding operations – a document that also offers additional measures to go alongside the use of airlines).
All the above topics are not new and have been known to the industry for some considerable time. Yet, as has been proven by the results of the HSE visits over the past twelve months, they are issues that are still not being consistently controlled in our foundries.
Basic safety concerns, such as a lack of guarding on machinery, or guards incorrectly set and used, failure to provide molten metal PPE and pedestrian/vehicle segregation were also found on several sites visited. These too are not new issues for the industry, so it is particularly disappointing that these risks to employee health and wellbeing are still being seen.
It is clear these issues will not help with the retention of existing personnel, something that has been a challenge for all industries in recent years. Nor will it help change the perception of the industry that many outside it have, therefore hindering and harming the recruitment and retention of new people.
Like all businesses, foundries will confidently tell stakeholders that they always work safely and do whatever is necessary to keep employees safe, but the high levels of enforcement actions being seen provide clear evidence that this is still not the case in all foundries.
To be sustainable businesses, here for the future and supplying the cast metal components needed for our modern world, changes are needed now in our foundries, involving investment in our people, plant and equipment. After all, it is in the interest of everyone.
Contact: Richard Heath at the Cast Metals Federation, Tel: +44 (0) 121 809 3502, email: [email protected]