The UK’s Health & Safety Regulator, the Health and Safety Executive (HSE), started its latest health campaign, which directly affects foundries, last October. This campaign is not only looking at silica control, but also for controls of dusts, fumes and vapours from all stages of the sand casting process, including during sand reclamation.
As all enforcement notices published up to the end of 2022 are available online https://resources.hse.gov.uk/notices/#, the SHIFT safety initiative can provide an update on what has been found for the period between October 2022 and the end of December 2022 – this is the period during which silica campaign visits were generally the primary reason for the HSE being on site. Note: there is a delay of five weeks before notices are published on the HSE website to allow for appeals to the notices by duty holders.
In total, 43 improvement notices and three prohibition notices were issued to ten foundries, and one also received two prohibition notices. These encompassed 92 individual breaches of UK health and safety legislation.
The breaches were mainly of:
- Health and Safety at Work Act 1974 (HSWA) – 44 occurrences.
- Control of Substances Hazardous to Health 2002 (COSHH) – 21 occurrences.
- Provision and User of Work Equipment (PUWER) – 13 occurrences.
- Management of Health and Safety at Work 1999 (MHSWR) – 4 occurrences.
The remaining ten breaches collectively were for VAWR (Vibration), NAWR (Noise), EAW (Electricity), PPEWR (PPE Regs), DSEAR (Explosive atmospheres) and W(HSW)R (Welfare).
Of the notices, 26 related directly to health issues. All but three of these were concerning issues with exposure to either RCS, vibration, noise, molten metal fume. The remaining three were for ‘not undertaking thorough examination and testing of LEV’, ‘not undertaking health surveillance’ and, very disappointingly, ‘having inadequate welfare provision for washing for shopfloor employees’. Of the 20 notices for safety, just over half of them were for guarding issues, with either inadequate protection in place or guarding not present at all. Also highlighted was ‘not maintaining safe gas and electricity networks on site’ (one foundry for both), ‘untrained forklift truck operators’, ‘poor housekeeping’, ‘not wearing PPE while pouring molten metal’ and ‘not having a competent person to help the directors with their obligations to health and safety’.
The levels of enforcement were discussed in the recent CHASAC (Castings Health and Safety Advisory Committee) meeting, where it was agreed that this was a far higher level of enforcement than would have been expected considering the amount of work that has been untaken over more than 15 years to highlight the need to have measures in place to protect people from silica exposure in UK foundries. Direct legislation for iron and steel foundries has been in place since 1953. While measures have been taken by foundries over time, it is clear there are still significant failings that need to be addressed.
All foundry directors and senior managers should be aware the silica campaign continues to the end of this current operational year (end of March 2023). It remains incumbent on directors and managers to ensure that measures are in place to protect employees from exposure to substances that are hazardous to their health, even more so for ones that are known to be carcinogenic, which respirable crystalline silica is. The SHIFT Initiative will be continuing to undertake work to help communicate the necessary information for directors and senior managers when it comes to dealing with workplace exposures and what is expected of this level of management. In addition, the HSE has updated its information available online in the COSHH essentials documents, which can be found at https://www.hse.gov.uk/coshh/essentials/direct-advice/foundry.htm
The COSHH Regulations approved Code of Practice details a lot of useful information and companies offering occupational health monitoring and surveillance can provide a lot of assistance and signposting for foundries. The British Occupational Hygiene Society (BOHS) is also a good place to find information, as indeed is the NEPSI (European Network for Silica) website https://nepsi.eu/
While many sectors, including metal casting, continue to struggle to recruit and retain new employees, the existing workforce is getting older. As the body ages it is more prone to injury and to health deterioration. It is therefore in the interests of not only the individual at work, who wants to protect their own health, but also of the business that is seeking to retain its workforce for as long as possible into the future so as to be sustainable, that actions are taken. As with any large-scale improvement programme, there are likely to be financial costs – this is undeniable. But the costs of failing to act are also significant. There will be challenges too in getting individuals to adapt, but the need to protect the workforce is in everyone’s interests.
Contact: Richard Heath at the Cast Metals Federation, Tel: +44 (0) 121 809 3502, email: [email protected]