As the Health and Safety Executive (HSE) comes towards the end of the third year of its current silica campaign, which is also looking at other fumes, dusts and vapours in foundries, where should UK foundries be looking when it comes to ongoing scrutiny from the regulator?
Firstly, the scale of enforcement issued to foundries during this current campaign has been far higher than would have been expected to occur, given the promotion of the campaign by the HSE itself, the trade association (Cast Metals Federation) and by the SHIFT safety initiative, as well as the likes of Foundry Trade Journal publishing columns on health and safety in each issue. Best estimates at present put the level of enforcement at circa seventy per cent, ranging from notifications of contravention (NoC) through improvement notices and onto prohibition notices. The exact figures will not be known until the middle of 2025 at the earliest.
Issues have been found from moulding and metal melting through to finishing operations and all stages in between. Enforcement has not been limited to only those small foundries who keep themselves very much under the radar, but to some of the largest also, and every casting process (die, sand and investment) has been found wanting, although the focus has been on sand casting.
So, what does this mean for management teams within foundries and what should they be looking to do, to have less or no issues when the regulator visits?
Where breaches have been found during visits, they are against long standing regulations and will be again when it comes to noise and asbestos, which started this year and in the case of noise will run for four years. Regulations with breaches against them from the silica campaign have been in place for over twenty years and we should have done better.
Given that in many cases, multiple regulations are cited in breaches, with the Health and Safety at Work Act 1974 being quoted in most cases, alongside specific legislation such as COSHH, PUWER etc. the statement is being made that business is failing in its general duty of care towards its employees.
This means that today and going forward the industry is still in a position where a focus must be placed on the knowledge and understanding of health and safety by the leaders within each operating foundry. From there, this needs to cascade down the management chain, so that every person in management, regardless of their level, knows what their own responsibilities for themselves and their teams are when it comes to keeping people safe. Greater emphasis and time need to be spent with management teams ensuring they understand they are the people who should be proactively leading the protocols and measures necessary to keep their teams safe and able to turn up for work every shift.
Without better informed management and supervisory teams, and without those teams being better skilled at understanding the risks to health from hazardous substances, physical agents, and machinery etc. the gap between what should be being done (safety as perceived) and what is actually occurring (safety as is) will continue to remain. The gap between ‘as perceived’ versus ‘as is’ will remain ongoing unless more people with a responsibility for those working in their teams become more proactive in their area, to ensure their teams are following protocols, using control measures and safe systems of work, and as necessary, using any required PPE and/or RPE correctly each working day.
To knowingly expose someone to hazards and not take measures to keep people safe, not only threatens the ongoing ability of people to work each day without risk of harm, but in the worst case scenario, risks someone (or more than one person) at board level losing their liberty for a period of time. This means management must protect both the employees and their directors. Directors must ensure the management can make that happen.
Of course, all businesses have a finite amount of money to operate with, regardless of their size, and it is far easier for them to see a return on investment (ROI) if they purchase a new state-of-the-art machine to replace ageing assets, as opposed to the ROI on training of the workforce and leadership and supervision.
However, the industry faces many challenges moving forward including from AI, and an ageing workforce who will want to retire at some point etc. The threshold for anyone to win a civil claim against a business is much lower than that which must be met by the HSE for a criminal prosecution. So, the management and leadership of employees must be right if we are to tempt people into foundries as opposed to any other career, in probably much cleaner and less physically demanding conditions.
After all it’s in everyone’s interests, as the modern world does not work without foundries and foundries do not work without employees who can be kept safe and well.
Contact: Richard Heath at the Cast Metals Federation, Tel: +44 (0) 121 809 3502, email: [email protected]