As one of the Health & Safety Manager for the CSS UK team I have responsibilities for Express Reinforcement Ltd (ERL) site at Neath (South Wales). I have responsibility for the maintenance of the (ERL) Safety Management Systems. (SMS) On the 9th September 2011 the ERL Neath site was issued with an Improvement notice by the Health & Safety Executive Inspector (HSE) (SJB 426776) to provide a suitable and sufficient risk assessment for the operation of a Manual power Bending Machine at (ERL) Neath site.
As a result of a reportable accident investigation by the (HSE) inspector, although existing control measures were in place, it was identified that the current risk assessment and safe systems of work for the manual power bending machine provided by the previous H&S manager at Neath did not identify the significant hazards and suitable control measures within the safe systems of work including suitable training.
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 is a significant improvement, they are a more step by step structured approach. The previous risk assessment and safe systems of work were of a poor standard and did not cover the legal requirements under the Management of Health & Safety at Work Regulations 1999 Regulation 3.
Under the Heath & Safety at Work Act 1974 Section 2 there is a requirement to provide safe plant and equipment and safe systems of work, and a requirement to provide information, instruction, training and supervision. There is a more specific requirement Under the Management of Health & Safety at Work Regulations 1999 Regulation 3. We are required to carry out a suitable and sufficient risk assessment of all the significant activities carried out under our control. Included in this operation has been identified an additional risk regarding the Manual Handling Operations regulations require a specific assessment for this activity.
I was confidant that I could undertake the review and complete the risk assessment in accordance with the INDG 163 HSE Five Steps to Risk Assessments document; as part of the risk assessment process I downloaded this document as reference material together with a copy of the ERL risk assessment form which has a list of associated hazards to identify from the task.
I would arrange and proceeded to carry out the risk assessment review by observing the process carried out on the manual power bending machine in bay 2 at Neath and identifying the persons it may affect and hazards associated with the task, I also checked the surrounding area for other hazards.
During the risk assessment process I requested the assistance of the power bending machine supervisor Bob Wellington and site manager Richard Collier in revving the risk assessment and associated safe systems of work document to ensure we had covered all significant hazards from the task of power bending machine operation.
I had previously contacted Richard Collier site manager by telephone to confirm the dates that I would be attending site to carry out the risk assessment and safe system of work for the HSE Improvement notice. We had already agreed a date with the HSE Inspector at the time of the visit by which date the new risk assessment and safe systems of work would need to be completed and all relevant documents received by the HSE Inspector.
I had arranged with Richard Collier to meet with Bob Wellington at the start of the shift, we then proceeded to walk onto the shop floor to the bending machine area. I asked Bob what information, instruction and training had he previously been given with regards to the bending machine operation. Bob explained that he had worked for Express Ltd for approx twenty years and that his training had consisted of on-the-job training by a previous supervisor for approximately two-to-three week’s consultation of risk assessments was very sporadic.
I watched the bending process take place and observed and recorded the hazards associated with the tasks including the manual handling hazards of lifting & handling re-bar products. I recorded in my note book persons present during the bending operations to check at a later date their training records to ensure they have received adequate training.
After observing the bending process I looked at prioritising the associated hazards in order of the highest risk first, I also took an opportunity to utilise weighing scales present to check and determine the average weight of the heavier re-bar being handled, for use in the manual handling assessment.
When the activity had been completed Bob and I went back to my office and talked through what activity had taken place to ensure I hadn’t missed any parts of the process or any significant hazards.
We agreed on the priority of the hazards by evaluating high, medium and low criteria according to the severity of consequences and the likelihood of the hazard actually occurring. This was in accordance with the risk assessment procedure in our safety management system PPH04
I had recorded the concerns with regards to high risk with which the HSE inspector had made comments to, and Bob and Richard Collier listened to my suggestions for introducing a safety limit switch and to prevent crushing and trapping of digits and an extra control switch to prevent inadvertent activation of the foot pedal thus reducing these risk to a lower acceptable level. As noted there was no significant high risk from the manual handling activities and there was also the use of mechanical means available such as overhead cranes.
After introducing further control measures to reduce the high risk to a lower risk, I was left with several lower risks that could be minimised, but not eliminated, by further control measures. In effect when the new system have been installed, the risk assessment has been completed (the new system was installed to reduce the hazard of trapping and crushing of digits) and this has been recorded.
It is re-assuring from a health & Safety perspective that the additional controls measures introduced are affective in reducing the potential hazards from trapping and crushing injuries.
This high risk hazard of trapping / crushing of digits was identified on a previous risk assessment carried out by the previous H&S manager, but unfortunately no suitable control measures were recommended other than (keep hands clear) and this did not comply with the risk assessment process including the hierarchy of control.
As a result of carrying out this reviewed risk assessment, we identified that this high risk needed to be reduced and controlled, to combat it we went through the hierarchy of control (ERICPD). Could we ELIMINATE the risk by not doing the process? No it is the nature of the process of bending reinforcement bar the risk was inherent within the process.
Could we REDUCE the risk by doing it some other way? Again not easy for the same reason above, but possible, as we looked at providing a magnetic safety limit switch that would be positioned close to the bending pin back stop, the operator sometimes dependant upon shape code of the re-bar has to hold the re-bar whilst the re-bar goes through the bending process, if the operators hands or fingers comes into contact with the limit switch the machine would fail to safety immediately.
Could we ISOLATE people from the risk, again possible, we have introduced a separate isolation switch the requires the operator to physically turn the switch from the off position to the on position to activate the bending pedal which the operator is required to press to start the bending process, this process was highlighted as a potential high risk because the operator could inadvertently press the foot pedal which would activate the bending process.
We can CONTROL persons who operate this equipment by use of a safe working procedure that has been produced through the use of the risk assessment, including an operator assessment process and monitoring. PERSONAL PROTECTIVE EQUIPMENT was already mandatory and required as identified in the PPE assessment and failure to wear the correct PPE would result in an Incident Non-conformity Report (INCR) being issued against the employee which could result in DISIPLINERY Action being taken.
I recommended that safety limit switches and pedal isolation switches be introduced on all bending machine to reduce the hazard and risk of trapping and crushing injuries, re-enforce training requirements including the recording of training and consultation of risk assessments.
Once I had completed a draft copy of the revised risk assessments and safe working procedures for the manual bending machine I requested that Bob Wellington and operators view the risk assessment and safe working procedures to ensure they agreed with the hazards identified and the method of training required.
Because I am a qualified instructor with RTITB & ITSSAR I am capable of designing and delivery of our in-house training requirements and delivery of our safe systems of work procedures together with my qualifications in H&S and Environmental. This helps with the cost effectiveness of training and risk control measures. I arranged a meting with Richard Collier to agree funding and requested the use of a contractor used widely within the reinforcement industry to provide a quotation for the manufacture and installation of the new safety controls identified, the quotations was very competitive and it was decided to use this contractor (Marsh Engineering).
Once I had any feedback from Bob Wellington, I completed the revised risk assessment and safe working procedure ready for consultation process. I then carried out a safety consultation process with all bending machine operators including supervision covering the hazards and risks identified within the risk assessments and discussed the control measures in place, we also reviewed the safe working procedure during this process.
Having completed the revised risk assessment and safe systems of work as required within the improvement notice I sent all the relevant documents to the HSE Inspector for approval, after a number of days I received notification via e-mail that the risk assessment and safe systems of work and associated consultation documents were adequate and complied with the requirements of the improvement notice.
I was then able to convey the information of completion of the HSE improvement notice to the Health and Safety Committee who are expected to communicate it to the workforce. Site manager also briefed supervisors through management lead weekly team briefs and these briefs were also used to get the health & safety message across.