COSHH what are the barriers to achieving good exposure control presentation to the North East Region meeting of the Bri

1. Andy Gillies, BOHS COSHHwhat are the barriers to achieving good exposure control?presentation to the North East Region meetingof theBritish Occupational Hygiene SocietyJune 23rd 2005 Andy Gillies President-Elect, BOHS

2. June 2005 Andy Gillies, BOHS COSHH 2002 (amendments 2004)�Adequate control� Statutory duty to apply Principles of good control practice Compliance with WEL�s For Carcinogens, Mutagens and Asthmagens � exposure ALARP Regularly inspect and maintain controls

3. June 2005 Andy Gillies, BOHS What is meant by �Good control practice�? �Good control practice� is a consensus view of the hardware, systems of work and other measures that need to be put in place to control the risk� ACoP�s and HSE guidance Industry standards (trade associations, lead players) Professional bodies (e.g. BOHS Technical Guides) Journals, reference books, published papers �Good practice� definition taken from HSE�s �Policy and Guidance (to inspectors) on reducing risks as low as reasonably practicable in Design�. Generally accepted that the concept of Good Practice is not consistently understood by industry (companies with similar processes may disagree on how far to go to reduce risks to acceptable levels). Plenty of written guidance available if people know where to look (easier for larger companies with in-house specialists). �Good practice� definition taken from HSE�s �Policy and Guidance (to inspectors) on reducing risks as low as reasonably practicable in Design�. Generally accepted that the concept of Good Practice is not consistently understood by industry (companies with similar processes may disagree on how far to go to reduce risks to acceptable levels). Plenty of written guidance available if people know where to look (easier for larger companies with in-house specialists).

4. June 2005 Andy Gillies, BOHS COSHH amendments 2004Principles of good control practice Adequate control means: Applying the principles of good practice Not exceeding WEL Reducing exposure ALARP for carcinogens, mutagens and asthmagens Maintenance of control measures: Physical controls (incl. PPE) must be regularly maintained Systems of work and supervision must be regularly reviewed and revised New COSHH Regs. Introduce �Principles of Good Practice� for the first time as mandatory (nothing new, just a re-jig of long-established �hierarchy of control�). Stronger emphasis on control at source, reliance on good design and physical measures rather than procedural controls and PPE as main ways to reduce exposure. A broader �whole task� view of controlling exposures � all routes of exposure, interaction with overall H&S. New COSHH Regs. Introduce �Principles of Good Practice� for the first time as mandatory (nothing new, just a re-jig of long-established �hierarchy of control�). Stronger emphasis on control at source, reliance on good design and physical measures rather than procedural controls and PPE as main ways to reduce exposure. A broader �whole task� view of controlling exposures � all routes of exposure, interaction with overall H&S.

5. June 2005 Andy Gillies, BOHS Case studyLead foundry This case study covers work governed by the Control of Lead at Work Regulations 2002, but has been used to illustrate how the principles of good exposure control may apply in practice

6. June 2005 Andy Gillies, BOHS Case studyLead foundry The task� Melting lead ingots Manual casting into moulds Dressing casts (welding, grinding, polishing, etc.) Existing controls� LEV at melting pots and benches PPE (respirators) housekeeping Small company (<10 employees) set up in modern industrial unit on industrial estate. Cash flow an issue and investments in exposure controls put off to release money to lease/buy adjacent unit for expansion. MD is hands-on with production work and leads by example. HSE visit prompted health surveillance and airborne dust/fume monitoring. Established need to improve. Careful evaluation of LEV options suitable for their working environment. Real difficulties to design effective systems for casting, and for dressing products of wide range of shapes and sizes (bench and floor work). No �COSHH Essentials� guidance sheets apply! �Industrial Ventilation� manual examples not relevant to particular layout and situation.Small company (<10 employees) set up in modern industrial unit on industrial estate. Cash flow an issue and investments in exposure controls put off to release money to lease/buy adjacent unit for expansion. MD is hands-on with production work and leads by example. HSE visit prompted health surveillance and airborne dust/fume monitoring. Established need to improve. Careful evaluation of LEV options suitable for their working environment. Real difficulties to design effective systems for casting, and for dressing products of wide range of shapes and sizes (bench and floor work). No �COSHH Essentials� guidance sheets apply! �Industrial Ventilation� manual examples not relevant to particular layout and situation.

7. June 2005 Andy Gillies, BOHS Case studyLead foundry Principle a: Design and operate processes and activities to minimise emission, release and spread of substances hazardous to health List all work groups and unit operations Melting, casting, finishing, cleaning, office work, maintenance Design to minimise exposure Pot temperature, separate casting shop, layout/material flow, segregated mess room Reduce number and size/quantity of emission sources small scale batch production, manual casting (hand ladles)

8. June 2005 Andy Gillies, BOHS Case studyLead foundry Principle b: Take into account all relevant routes of exposure Inhalation Fume from melting & casting, finishing (flame �welding�) Dust from finishing (filing, manual abrasion and use of hand grinders), cleaning (equipment, work bench, end of shift), work clothes, secondary sources Ingestion Meal breaks, smoking, hand-to-mouth Which is most significant?

9. June 2005 Andy Gillies, BOHS Case studyLead foundry Principle c: Control exposures by measures which are proportionate to the health risk What is the health risk? Chronic toxicity: inhibits haem synthesis, anaemia, nervous system effects, kidney damage, impairs male fertility? affects foetal and infant development? How far do we go? Exposure standards (air and biological) Consider severity of harm, likelihood of harm occurring, and uncertainty associated with the standard Precautionary approach

10. June 2005 Andy Gillies, BOHS Case studyLead foundry Principle d: Choose the most effective and reliable control options that minimise escape and spread of substances hazardous to health For each unit operation and the overall situation Focus on the most significant sources first Casting? flame welding? hand grinding? others�. Hierarchy of controls �Eliminate� not an option, enclose melting pots? automated casting and finishing? grade of abrasive paper? customer requirements, LEV, general ventilation, wet cleaning (care!), work clothes (type, storage, cleaning), welfare facilities, effective PPE, working technique & behaviour Who designs and chooses best options?

11. June 2005 Andy Gillies, BOHS Case studyLead foundry Principle e: Where adequate control of exposure cannot be achieved by other means, provide, in combination with other control measures, suitable PPE PPE � the �last resort� but often critical RPE programme (selection, use, maintenance): correct type? (technically adequate, comfortable, fit tests), trained users, storage, filter changing, clean and repair Protective clothing: overalls, footware, gloves, aprons, storage? laundering, individual issue? Compatibility of PPE

12. June 2005 Andy Gillies, BOHS Case studyLead foundry Principle f: Check and review regularly all elements of control measures for their continuing effectiveness Management system to schedule checks on all elements of control measures How do you know that control measures are effective? Qualitative and Quantitative checks

13. June 2005 Andy Gillies, BOHS Case studyLead foundry Principle g: Inform and train all employees on the hazards and risks from substances with which they work, and the use of control measures developed to minimise these risks Training programme Do operators understand the health risks? Have the limitations of exposure controls been explained? Are you confident that the control measures in place are effective? easy to use? proven to work long-term? Are operators equally confident?

14. June 2005 Andy Gillies, BOHS Case studyLead foundry Principle h: Ensure that the introduction of measures to control exposure does not increase the overall risk to health and safety Other H&S risks Explosion (water, O2/Ac torches), fire, molten lead splashes, skin burns, thermal stress, combustion products (CO), manual handling and ergonomic aspects, trips and falls, electrical equipment, New risks? �A good control solution is one which minimises the health risk while reducing maintenance burdens, being relatively fool-proof, and not introducing other risks�

15. June 2005 Andy Gillies, BOHS Case studyLead foundry HSE visit prompted health surveillance and dust monitoring: blood Pb data OK; airborne dust/fume above exposure limit No �off the shelf� solutions. No CE control guidance sheets apply Real difficulties to design effective systems for casting, and for dressing products of wide range of shapes and sizes (bench and floor work). Major investment needed for effective LEV SME - cash flow a constant issue �Good practice� solution not obvious. Cost and difficulty of implementing control options possibly over-estimated

16. June 2005 Andy Gillies, BOHS Why good practice is not universal:barriers to implementation �Real life� barriers to implementing �good practice�. Have I missed any significant ones? We may want to give some sort of priority to these � e.g. money and lack of perceived enforcement threat may be more important generally than lack of knowledge or unproven solutions. PPE not only seen as �quick & cheap�, but also adequate. Lack of visibility of health effects; short termism of modern management. �N.I.M.T.O.� = Not In My Term Of Office!!! Note the arrow I�ve suggested in the slide.�Real life� barriers to implementing �good practice�. Have I missed any significant ones? We may want to give some sort of priority to these � e.g. money and lack of perceived enforcement threat may be more important generally than lack of knowledge or unproven solutions. PPE not only seen as �quick & cheap�, but also adequate. Lack of visibility of health effects; short termism of modern management. �N.I.M.T.O.� = Not In My Term Of Office!!! Note the arrow I�ve suggested in the slide.

17. June 2005 Andy Gillies, BOHS BOHS Conference 2005Workshop summary Most barriers are �institutional�, not �hardware� (barriers of perception rather than resources) Top 5: No history of health problems Lack of competent people Low profile of health issues in the company Lack of communication Poor understanding of health risks

18. June 2005 Andy Gillies, BOHS What are the barriers to achieving good exposure control? OPEN DISCUSSION