As the Health & Safety Manager for the CSS UK team, I am in charge of the safety of Express Reinforcement Ltd (ERL) site in Neath, South Wales. One of my responsibilities is maintaining the Safety Management Systems (SMS) for ERL. On September 9, 2011, the HSE Inspector (SJB 426776) issued an Improvement notice to the ERL Neath site. This notice requested a suitable and sufficient risk assessment for the operation of a Manual Power Bending Machine at the site.
Following an investigation by the Health and Safety Executive (HSE) inspector, it was found that the current risk assessment and safe systems of work for Neath’s manual power bending machine, provided by the previous H&S manager, did not adequately identify significant hazards and suitable control measures, including appropriate training. Despite the existence of control measures, the inspector found issues during the accident investigation.
An Improvement notice was issued by the (HSE) Inspector to review the safe systems of work with regard to the manual power bending machine operations and to provide a suitable risk assessment and safe systems of work. The new safe systems of work for the manual power bending machine are a significant improvement; they use a more step-by-step structured approach. The previous risk assessment and safe systems of work were inadequate and did not meet the legal requirements stated in the Management of Health & Safety at Work Regulations 1999 Regulation 3.
Under the Heath & Safety at Work Act 1974 Section 2, there is an obligation to ensure the provision of safe plant and equipment as well as safe systems of work. Additionally, there is a requirement to provide information, instruction, training, and supervision. Another specific requirement can be found under the Management of Health & Safety at Work Regulations 1999 Regulation 3. This mandates carrying out a suitable and sufficient risk assessment for all significant activities performed under our control. Within this process, an additional risk associated with the Manual Handling Operations regulations has been identified, necessitating a specific assessment for this particular activity.
I had confidence in my ability to perform the review and complete the risk assessment following the INDG 163 HSE Five Steps to Risk Assessments document. To aid in the assessment process, I obtained a copy of the document as a reference and also acquired the ERL risk assessment form, which includes a list of hazards related to the task for identification.
I conducted a risk assessment review for the manual power bending machine in bay 2 at Neath. This involved observing the process, identifying individuals affected by the task, and recognizing associated hazards. Additionally, I inspected the surrounding area for any other potential dangers.
During the risk assessment process, I asked Bob Wellington, the supervisor of the power bending machine, and Richard Collier, the site manager, to help me review the risk assessment and the safe systems of work document. This was done to ensure that we had included all important hazards related to operating the power bending machine.
Before visiting the site to conduct the risk assessment and safe system of work for the HSE Improvement notice, I verified the dates with Richard Collier, the site manager, over the phone. We had previously arranged a date with the HSE Inspector for when the new risk assessment and safe systems of work should be finished and all related documents ought to be received by the inspector.
I had planned to meet with Richard Collier and Bob Wellington at the beginning of the shift. Together, we walked over to the bending machine area. I inquired about Bob’s previous training and any information or instructions he had been given regarding operating the bending machine. Bob informed me that he had been employed by Express Ltd for about twenty years and that his training had primarily involved on-the-job learning from a previous supervisor. However, formal consultations of risk assessments had been infrequent.
I witnessed the bending process and documented the associated hazards, such as the manual handling risks involved in lifting and handling re-bar products. I made a note of the individuals present during the bending operations so that their training records can be later checked to ensure they have received sufficient training.
Upon observing the bending process, I prioritized the associated hazards based on the highest risk first. Additionally, I used the weighing scales that were available to determine the average weight of the heavier re-bar being handled. This information was gathered for use in the manual handling assessment.
After completing the activity, Bob and I returned to my office where we discussed the details of the activity to make sure that I did not overlook any steps or identify any major risks.
In our safety management system PPH04, we evaluated the hazards’ priority by assessing their severity of consequences and likelihood of occurrence. This assessment was done using high, medium, and low criteria in accordance with the risk assessment procedure.
I documented the concerns raised by the HSE inspector regarding the high risk involved. Bob and Richard Collier took into consideration my suggestions, which included implementing a safety limit switch to prevent crushing and trapping of fingers, as well as an additional control switch to avoid accidental activation of the foot pedal. These measures would reduce the risks to an acceptable level. It was observed that there were no significant risks associated with manual handling activities, and mechanical means like overhead cranes were also available.
After implementing additional control measures to decrease the initial high risk to a lower level, several remaining risks remained that could be reduced but not completely eliminated with further controls. The risk assessment was completed after the installation of the new system, which was intended to reduce the danger of trapping and crushing of digits. This completion has been duly documented.
From a health & Safety perspective, it is comforting to know that the added control measures are effective in minimizing the risks of trapping and crushing injuries.
The previous H&S manager identified the high risk hazard of trapping / crushing of digits in a previous risk assessment. However, they did not recommend any suitable control measures other than (keep hands clear). This does not comply with the risk assessment process, including the hierarchy of control.
After conducting the risk assessment, we found that this high risk should be minimized and managed. To address it, we followed the hierarchy of control (ERICPD). Could we eliminate the risk by not performing the process? No, since bending reinforcement bar is an intrinsic part of the process, the risk is inherent.
Is it possible to mitigate the risk by finding an alternative method? Although not simple due to the same aforementioned reason, it is feasible. One possibility is to install a magnetic safety limit switch near the bending pin back stop. During the bending process, the operator may need to hold the re-bar depending on its shape code. If the operator’s hands or fingers touch the limit switch, the machine would immediately shut down for safety purposes.
In order to mitigate the risk of accidentally activating the bending process, we have implemented a separate isolation switch. This switch must be physically turned on by the operator before they can press the bending pedal to start the process. This precautionary measure aims to isolate people from potential harm and reduce any associated risks.
We have established a safe working procedure for operating this equipment. It was developed through a risk assessment that includes an operator assessment process and monitoring. The PPE assessment noted the requirement for PERSONAL PROTECTIVE EQUIPMENT, and failure to wear the appropriate gear would lead to an Incident Non-conformity Report (INCR) being issued against the employee, potentially resulting in disciplinary action.
In order to decrease the risk of trapping and crushing injuries, I suggest implementing safety limit switches and pedal isolation switches on all bending machines. Additionally, it is important to strengthen training requirements, such as recording training sessions and consulting risk assessments.
After finishing a draft copy of the revised risk assessments and safe working procedures for the manual bending machine, I asked Bob Wellington and the operators to review them. The goal was to ensure that they agreed with the identified hazards and the training approach.
As a qualified instructor with RTITB & ITSSAR, I am able to design and deliver our in-house training requirements as well as provide our safe systems of work procedures. Additionally, my qualifications in H&S and Environmental contribute to the efficiency and effectiveness of our training and risk control measures. To address our funding needs, I organized a meeting with Richard Collier and proposed utilizing a contractor widely used in the reinforcement industry for the manufacturing and installation of the new safety controls that were identified. The quotation provided by this contractor, Marsh Engineering, was highly competitive, leading to the decision to engage their services.
After receiving feedback from Bob Wellington, I finalized the revised risk assessment and safe working procedure in preparation for the consultation process. During this process, I conducted a safety consultation with all bending machine operators, including supervision. We discussed the hazards and risks identified in the risk assessments and reviewed the control measures in place. Additionally, we reviewed the safe working procedure.
After I finished revising the risk assessment and safe systems of work as per the improvement notice, I sent all the necessary documents to the HSE Inspector for approval. Several days later, I received an email notification stating that the risk assessment, safe systems of work, and related consultation documents were satisfactory and met the improvement notice’s requirements.
Following the completion of the HSE improvement notice, I informed the Health and Safety Committee. It is their responsibility to communicate this information to the workforce. Additionally, the site manager briefed supervisors during the weekly team briefs led by management. These briefs were also used as a means to convey the health and safety message.
