Underground Services The Inconvenient Truth

1. Underground Services The Inconvenient Truth

2. Introducing RPA Safety Services • RPA Safety Services • Independent chartered safety advisers, providing competent occupational safety support for the geotechnical sector • Representing: • Consultancies • Geotechnical contractors • Drilling contractors

3. Introducing RPA Safety Services • RPA Safety Services • Trainers for the geotechnical sector through Equipe Training • IOSH Safe Supervision of Geotechnical Sites • IOSH Avoiding Danger from Underground Services • Site safety • Appointed persons • Manual handling • ……… to name but a few

4. Introducing RPA Safety Services RPA Safety Services Trainers for general construction and other sectors Relevant to this presentation? Mansell Construction Services IOSH Avoiding Danger from Underground Services

5. Underground services Background The number one safety issue for the geotechnical industry, yet service strikes remain largely unreported Costs companies £1000s every year (average repair around £5000) Staff rarely have a complete ‘safe system of work’ which would stand scrutiny In training courses for geotechnical companies, it is often easier to ask who hasn’t struck a service - which in my experience makes the industry unique

6. Underground services Post credit crunch, we live in a new landscape The HSE are facing a 35% reduction in their grant As a result, they have announced a 33% reduction in proactive inspections Good news?

7. Underground services • Probably makes no difference, although there will be less guidance • If there is a fatality, the enforcing authorities will visit • Common law offence of gross negligence manslaughter • Statute law offence of corporate manslaughter • Or a serious injury • Section 2 or section 37 offences under HASAWA 1974

8. Insurable losses? Cover would be questionable The typical cost of a service strike to a geotechnical company is £5,000 Striking an oil filled cable (above) is very expensive. The environmental clean-up of this strike in Leicester was £70,000 This is repair cost. If a company has a profit margin of 10%, then the real cost of this strike would be more like £700,000

9. Uninsurable losses A Kent-based construction and engineering company has been fined after an employee suffered severe burns when his jack hammer touched unexposed underground electricity cables. The 28 year old operative from Ashford suffered 62 per cent burns to his upper body, face, neck and arms when he inadvertently struck the 11Kv cable while working at a construction site in Tovil, Maidstone. Today (12 October 2010), the company was fined £20,000 and was also ordered to pay costs of £14,532 Pacestone Construction have been fined £13,000 and £3,870 costs from a service strike which in the words of the prosecuting inspector was: “…entirely preventable had the company taken sensible precautions. Using a cable detector, marking the location of cables and only allowing workers to use hand tools.”

10. Underground services • Carry on then? • Well the current accepted method • Scan the area with a CAT • Dig a pit to 1.2m • Only confirms nothing is in the hole we have just dug • How about below the pit? • How about next to the pit?

11. Underground services What are the alternatives? We should be looking for an accepted code of practice which will be understood throughout the industry and by clients Why is there resistance to HSG47?

12. Maps and plans Planning the work Digging practices Locating devices Underground services Maps and plans for all sites Positive identification of services on site, through careful hand digging if necessary Safe digging techniques Use of appropriate locating devices If this method is compared to current practice, how would it stand up?

13. Underground services What status HSG47? An HSG document is issued by the Health and Safety Executive but following the guidance is not compulsory You are free to take other action, but if you do follow the guidance you will normally be doing enough to comply with the law Health and safety inspectors seek to secure compliance with the law and may refer to this guidance as illustrating good practice

14. Underground services Well can’t we get HSG47 changed then? Not likely according to Eddie Tarn, HM Inspector for this area Off the record discussion with Eddie and other inspectors suggest they feel HSG47 is broadly fit for purpose. With current constraints on budgets, the likelihood of any amendments are slim If it is updated, then it is likely to increase the threshold for good practice to include technological developments such as insulated tools, fire retardant overalls, GPR, air tools etc.

15. What is the resistance to HSG47? • Most contractors feel that to do the work correctly, in accordance with the guidance laid down in HSG47, would place them in an uncompetitive position • We regularly see and hear about: • Truncated start times by main contractors or client • Work regularly starting without maps and plans • Poor / non existent training for staff • Unskilled engineers supervising the work • Lack of understanding of the risks • ‘If we don’t take the work, someone else will’

16. Could progress be a competitive advantage?

17. Could progress be a competitive advantage?

18. You can lead a horse to water Will main contractors force the issue? Will contractors follow willingly? Will there always be a safety ‘underclass’?

19. How long until we look back and say.. I remember when we used to do that!

20. So what are the fundamental issues? ‘CAT scan the area then dig a 1.2m deep pit’ This is the current industry accepted method, which perpetuates what has always been done. Contractors often find they are paid a flat rate for digging pits no matter what the ground conditions As a result, pits are generally dug because they have to be and not because they add any value They certainly aren’t dug with care Not once are they mentioned in HSG47

21. So what are the fundamental issues? • As long as we continue as we are: • Pits will continue to be dug with inappropriate tools • They won’t be dug with care • They will stop at EXACTLY 1.2 m • …..and we will continue to hit services

22. Forget 1.2 m Everyone has 1.2 m set as an arbitrary depth As far as we can determine, 1.2m was derived from the Construction (General Provisions) Regulations 1961 – which required protection if there was danger of collapse and a person was liable to be struck from a height of more than 1.2m This guidance on excavation has long ceased to exist and was revoked and incorporated in The Construction (Design and Management) Regulations 2007 – regulation 31. 1.2m has no relevance to depths of underground services

23. Forget 1.2 m Relying on 1.2 m deep pits is flawed There are services which regularly run below 1.2 m (high voltage electricity, reinstated or landscaped areas, directional drilling etc.) which won’t be found Hand digging has a place in satisfying the primary demand of HSG47 to locate and positively identify services in the area. Starter pits are not a replacement for this demand and if used, should add value to the process of risk assessment They must only be done once all other areas of HSG47 have been undertaken. They provide a final check and help reduce the risk to a level as low as reasonably practicable but there should be no arbitrary depth.

24. What else can be done? It requires an industry wide change of philosophy and an examination of current working practices

25. Industry codes of practice With the HSE strapped for cash They will be encouraging industries to develop their own codes of practice HSG documents are likely to be a thing of the past

26. Industry codes of practice Revised extracts from the UK specification for Ground Investigation 3.8.3 The use of locating devices should wherever possible prove the positive presence of services shown on the drawings rather than purely their absence 6.1 The use of inspection pits should, wherever possible, prove the location of services rather than their absence Further guidance on avoiding danger from underground services is given in HSE publication HSG47

27. CDM Duties • Client shall ensure the team has: • information that it needs about the site and any existing structures • the time, money and other resources available for projects • Contractor shall ensure • clients are aware of their duties • that they and anyone they employ or engage are competent and adequately resourced • ……and on notifiable sites: • check that a CDM co-ordinator has been appointed and HSE notified before they start work

28. Training • Risk Assessment • Everyone on site is responsible for carrying out a continual process of risk assessment. • The ability to understand why the CAT may not pick up a certain cable, or when a cable might not be shown on a plan is a fundamental competency. • Understanding what is in the ground • How to spot a poor map or plan • How to dig safely • How to use a CAT and signal generator

29. Maps and plans Reasonably practicable? Maps and plans should be available on site for the use of staff and they must be suitable and sufficient. They can generally be obtained within 7 working days and in some cases, even faster. Electronic versions, which are now becoming popular, are available almost instantly. They are generally free or available for a very minimal cost. We can see no reason why they can’t be provided

30. Forget 1.2 m • Positive identification • Is the only way to ensure we are not directly on top of a service • Principal Contractors are beginning to demand it • HSG47 suggests it • The utility providers put it on their plans

31. Consider alternative digging techniques

32. Reasonably practicable What is reasonably practicable? Based on the level of risk and potential harm, what would it be reasonably practicable for you to do? £

33. Any questions?