By Nigel Mair
Health & Safety is one of the major issues facing the waste sector at the moment, with a recent study reporting an accident rate nearly 5 times the national average.
The issue of safety was really brought home by an extremely bleak 8-week period at the end of last year when there were 9 fatalities in the industry. These were all tragic and unnecessary losses.
Although the short period over which the accidents happened was unusual, the causes were, unfortunately, all too common and unless H&S is given a higher profile within the industry these tragedies will keep occurring.
In this article I will be covering some of the skip hire industry’s core H&S responsibilities and also highlighting some of the major risk areas that you should take a closer look at in your business.
We haven’t had an accident, so we haven’t got a problem?
That is a nice thought but I wouldn’t be so confident if I was you. You may be right, but you need to have a good look at your systems and make sure that it is thorough design and not just luck that accidents have been avoided.
In H&S speak you will need to be able to demonstrate that you have introduced safe systems of work (SSOW).
What is a safe system of work?
That is a good question, as many people think that it is about having risk assessments. In part that is correct, but a safe system of work is much more than having a file with “Risk Assessments” written on the front. In order to be effective a SSOW is about having demonstrable safety systems in place. This will include not only risk assessments, but also information provision, staff competence and appropriate control measures and precautions.
So what do I need to do?
Read on and I’ll cover some of the core topics here.
H&S Policy
One of your basic legal responsibilities under the Health and Safety at Work Act is to produce an H&S Policy - this must be documented where the company employs 5 or more members of staff (to include part time staff).
The Policy is made up of 3 core requirements:
1. A Statement which sets out the organisations broad commitments with regard to H&S. It should be signed by a senior officer, such as the MD and should be clearly displayed around the organisation and made available to others upon request.
2. An Organisation structure should be produced, setting out the responsibilities of the different roles within your organisation. It will not necessarily include names, but will refer to work roles, such as Directors, Managers and Site Operatives. Each of these will have clear duties and responsibilities with regard to H&S.
3. An Arrangements document will also need to be prepared. This will set out the way the company meets the commitments set out in the Statement. For example, it might refer to the completion of risk assessments, the delivery of training and also the undertaking of audits and drills.
Risk Assessments
Risk assessments are probably the H&S “bits” that most of you will be familiar with. They are also an area that from my experience causes a lot of difficulty.
As with the H&S policy, undertaking risk assessments is a legal requirement- no matter what size your organisation. For smaller companies you will not have to write them down, but again, this becomes a legal requirement where you employ 5 or more staff (to include part timers).
How do I complete a risk assessment?
This is not that simple a question as there are lots of different approaches so it is not really a case of “one size fits all”. The bottom line is that you must undertake assessments that are “suitable and sufficient”…whatever that means.
This is a difficult one to put to bed as what may seem suitable and sufficient to you, may not be in the eyes of a HSE inspector. Whatever you decide is a “risk” you would have to justify should something go wrong. This means that you would have to be able to show that you have given it some thought and there is a reason behind your judgement…in effect, that you think it is “suitable and sufficient”.
Doesn’t H&S cost money?
That is a bit of a “glass half empty” question, as the cost of not having good H&S is likely to be much, much more. There is something in your favour though, as you are able to make use of the term “reasonably practicable”. That doesn’t mean that you can penny pinch, but it does mean that you can bring some cost benefit calculations into the decision making process. For example, if a member of staff got a minor cut on their finger and the only way to stop it happening again was to spend £1 million, then this would be thought of as unreasonable and you would not need to introduce the precaution. This is obviously at the extreme end, but in most cases for each of the risks you identify in your risk assessments you will be able to consider costs when thinking about any precautions. But again, be aware that you might need to justify your decision.
Personal Protective Equipment
This is often viewed as being the first line of defence, when really it should be the last. Whenever I go around sites it is frightening how many people seem to think that wearing hi-viz clothing turns them into some sort of superhero who can walk into the path of vehicles without fear...believe me, it WILL still sting if you get hit!
We will come back to this another time, but remember that PPE must be appropriate and staff must understand why they need to wear it and not only how it might protect them, but also what it will not do.
COSHH
This stands for “Control of Substances Hazardous to Health” and many of you may say that this doesn’t affect you as you don’t deal with anything hazardous. I can almost guarantee that that isn’t strictly correct, as I would imagine that at the very least you put one type of hazardous substance in your vehicle fuel tanks and use others to keep the engines working and the parts lubricated. All of these would fall under the COSHH regulations.
From my experience this is one H&S issue that is poorly satisfied in skip companies…….ask yourself do you have any Safety Data Sheets? If the answer is “no”, then this is something you should think about addressing.
Vehicles and Plant
Probably the most dangerous aspects of your business are your vehicles and plant. These are responsible for more accidents and deaths than anything else. In fact, it is suggested that over 60% of the waste industry accidents involve workplace transport.
Issues you will need to think about are how you ensure that they are safe to use (defect checks), how they are operated correctly (training, safe systems) and that people and vehicles are kept apart as far as possible (one way systems, barriers etc).
Visitors and contractors
Many people think that their responsibility only goes as far as their staff. This is not true…the Health and Safety at Work Act says that you have a responsibility for your employees and anybody else affected by your activities. This would mean visitors, contractors, members of the public and even in some cases those little angels that may break into your site from time to time!
You may well say that you have a big dog that keeps them at bay. This might be the case, but don’t forget that you will need to build it into a safe system of work, risk assessments and all!
The HSE’s Waste and Recycling Section is currently working to deliver a three-year programme to improve the performance of the industry. This is being delivered through an increased number of inspections - so, be warned, if you choose to ignore the advice given here, they may come knocking on your door very soon!
Nigel Mair is a WAMITAB assessor and verifier and runs the North West Regional Assessment Centre, delivering WAMITAB qualifications and other H&S, waste and environmental training.
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