Inside Track

Last week I wrote about the effects of economic recession and recovery on workplace safety.  In essence, injury numbers and rates drop during the downturn,  but both are likely to increase as things pick-up.  So what about occupational health – is that affected by the economic cycle?

Well the picture is a little more complex.  Unlike the risks of injury, the risk of ill-health is actually lower for the workers in their first few months.  That seems logical as many conditions result from prolonged exposures.  So during economic recovery, new workers taken on are less likely to exhibit symptoms in their first months (though poor controls could be saving-up problems for the future).

The interesting and important issue is what happens as a result of increased working hours. Physical conditions linked to work seem to generally increase with working hours – again that makes sense if the length of exposure increases.  So is the only answer to strictly limit working hours, refusing employees overtime? 

That would be a very simplistic solution; time exposed is only one of many factors.  Good controls are more significant.  For example, providing good local exhaust ventilation for welding is going to be far more effective in preventing bad backs than reducing the time people are exposed from 9 hours to 8.  So certainly consider the effects of working hours, but don’t believe they’re the only variable you can control.

However, it is psycho-social conditions such as stress where working hours have a major impact.  HSE’s analysis suggests that, all things being equal, working more than 60 hours almost doubles the risk compared to a more normal 30-49 hour week.  That should matter to every company as well as to the Treasury.  Stress and depression are up there with back pain as the most common causes of sickness absence as well as being out of work and claiming long-term sickness benefits.  As business picks up, there is no more important time to ensure that employees are ‘happy, healthy and here’, winning new contracts and meeting demand.

So, double-dip permitting, how should businesses be responding as we lift out of recession?  Again, simply limiting working hours and banning overtime is a very crude response, time is just one influence of several influences, they need looking-at in the round.  The full range of factors, including working relationships and control over work need to be considered together.

Resources

• If you’re an EEF member you can access a wealth of information and support in our Sickness Absence Toolkit  and Health, Safety and Environment Guide..
• Our recent sickness absence and rehabilitation survey report and work organisation survey tool are freely available to all.
• Good guidance on stress and other topics is available on the Health and Safety Executive’s own web pages.
• If you’re interested in getting into this topic in more detail – improving business performance and adding a new string to your professional bow, EEF runs the NEBOSH Certificate in Health and Wellbeing at Work at venues all around England and Wales.

Earlier this week the Government put out its response to the House of Commons Environmental Audit Committee report on the role of carbon markets in preventing dangerous climate change.  The Government’s paper directly responded to the 19 conclusions/recommendations that the EAC put forward earlier this year.

To summarise the contents of the 14 page response very simply, The Government:

• Welcomed the EAC’s overall endorsement of the importance of global carbon markets in tackling dangerous climate change. Like the EAC, the Government supports a vision of a global carbon market, and considers that future linking of emissions trading systems may provide emissions reductions at lower cost and accelerate the scale of innovation.

• Considers the EU Emissions Trading Scheme (ETS) an effective system at reducing emissions, but argues that a deeper 30% EU emissions reduction target is required to help bring on the low carbon investments needed, especially in the UK power sector – A position EEF strongly rejects without comparative international action.

Going forward the Government will publish proposals in the autumn to reform the climate change levy to provide more certainty and support to the carbon price. Subject to this consultation, in which EEF will play an active role, the Government will bring forward relevant legislation in Finance Bill 2011.

Despite its shaky start there remains strong international support for a carbon market; support which is only set to swell.  Whilst currently receiving little press attention at the moment, the approaching November meeting of the United Nations Framework Convention on Climate Change (UNFCCC) is likely to reignite the debate about a global climate change agreement. 

Chief amongst these discussions is likely to be the role of a global carbon market.  While unlikely to generate the same level of hype and fanfare that surrounded the UNFCCC meeting in Copenhagen last year, the meeting is an important milestone which could mark a bright future for a global carbon market.  Watch this space….

There are some promising signs that we may yet avoid statutory licensing of health and safety professionals and the extra costs to business that could involve.  As I wrote earlier this month,  Lord Young’s wide-ranging review of health and safety is largely to be welcomed, but there have been worrying signs that he would pursue statutory accreditation of anyone giving health and safety advice.  The intention of stopping excessively risk-averse and unnecessarily bureaucratic advice is certainly laudable, but licensing would be a sledgehammer to crack a nut.  A voluntary scheme with recognition from HSE would be far more appropriate.

The professional bodies in health and safety, such as the Institution of Occupational Safety and Health and Chartered Institute of Environmental Health, started talks more than 2 years ago aimed at agreeing  a single accreditation system.  They were prompted by a 2008 report by the Work and Pensions Select Committee, but after all this time, and apparently little progress a deal seemed unlikely.

Lord Young’s proposal seems to have galvanised things: the professional bodies and HSE have agreed an accreditation scheme in principle, with a formal announcement expected soon.  The professional bodies would ensure that their members meet minimum qualification requirements as well as abiding by a common code of ethics.  In return HSE would formally recognise the standard, referring to it in relevant publications and web pages.  Importantly I understand the code of ethics will be just as strong on proportionality and minimising bureaucracy as on ensuring that significant risks are addressed. 

The scheme will assist employers in ensuring they get competent and proportionate advice.  But they will not be forced to employ expensive consultants for lower risk operations where a member of staff with some common sense and a NEBOSH certificate would appear to be quite capable.

So will this satisfy Lord Young or will he still recommend and pursue a statutory scheme?  We don’t have to wait long to find out – we expect his report to be published on the 8^th September.  Hopefully it will accept this as an appropriate alternative to regulation, perhaps undertaking to review the position in the future to ensure it is living up to its promises and the code of conduct is being applied in practice.  As they say – watch this space.

Come the 30 November will chemical substances be withdrawn from the European market causing massive disruption to manufacturing supply chains, or will the deadline pass uneventfully as was the case back in 2000 when the Y2K bug was set to wreak havoc across industry?  Quite simply, I don’t know.  Unfortunately, neither does the rest of industry, nor, possibly more importantly, the European Chemicals Agency (ECHA) who have the unenviable task of administrating and regulating the chemicals regulation REACH. 

Why is this?  Well REACH requires chemical substance manufacturers/importers to register each individual substance they place on the market.  However, the registration process does not require these importers/manufacturers to declare their intention to register, or not, a particular substance. 

It is this process flaw which is proving extremely worrying for manufacturers of aerospace, automotive, domestic, electrical and electronic products for example. They approach the deadline with the very real risk of not knowing whether certain substances they procure, and the specific uses in which they are applied, have been registered or not until after the deadline. 

The problems surrounding REACH are not limited to a handful of obscure chemicals.  ECHA remain unclear as to the fate of approximately 2000 chemical substances.  Those 2700 substances for which ECHA is aware of a ‘lead registrant’, and therefore a predicted registration, are listed in its website; however the specific industrial uses are not.

Part of the problem with REACH is that is a large and complex piece of legislation.  Whilst the objective it sets out to achieve is fully supported, it is nonetheless proving a difficult beast to manage.  ECHA have been beset by criticisms from the outset, whether for the guidance it produces or the IT systems it has introduced.  Just recently the UK government voiced its criticism of ECHA’s engagement strategy, arguing that “…better routes of entry and closer relations are needed with member states being seen as included partners”.

To avoid the potential withdrawal of business critical substances from the EU unnecessarily, and the subsequent collapse of related supply chains, EEF are coordinating industry sector activity and are writing to the environment and the business departments of Government to strongly encourage their support of our proposal for a 12-month delay of these substances from registration.  This action would permit downstream users to obtain necessary registration data from the European Chemicals Agency (ECHA), and subsequent action to prepare separate registration dossiers, source alternative suppliers, etc. This will ensure that existing manufacturing processes will not be sourced outside the EU.

Considering myself an optimist I am hopeful that come the deadline we will all be able to breathe a sigh of relief as was the case back in 2000.  To enjoy this moment of contentment will require an intelligent and practical interpretation of the REACH text to be agreed, and we still have some way to travel before this is realised.

The Government’s overarching approach to waste is to work towards a zero waste economy. Part of the work of the DEFRA Review of Waste Policies is to define more closely what this means, setting clear measurable objectives, and potentially accompanying this with targets in the short, medium and longer terms.

However, from the outset, the Government has made it clear that a zero waste economy is not where no waste is produced. The Government envisages that amongst others, the zero waste economy will have the following characteristics:

·         resources are fully valued – financially and environmentally.

·         one person’s waste is another’s resource.

·         over time, we get as close as we possibly can to zero landfill.

·         a new public consciousness in our attitude to waste.

DEFRA’s Call for Evidence is the first step in developing these ideas into something more holistic with clear and measurable outputs. As always your comments to this debate would be welcome.

Last year the fatal injury statistics for both manufacturing and the economy as a whole hit an all-time low: 30% down on the average over the previous 5 years.  And yet we are hearing calls for businesses to redouble their efforts - is this a case of zealotry from people who will never be satisfied until all indicators hit zero no matter what the cost? 

Well no, on this one they are absolutely right and EEF has joined in warning of the increased risks during economic recovery.  Experience shows that both the total number and the rate (number of injuries per 100,000 employees) go down in a recession, but then rebound sharply during a recovery.  This was one of the subjects we discussed with HSE's Chair Judith Hackitt, and Chief Exec, Geoffrey Podger when we met them last month.  Following this they shared some analysis carried out by their statisticians and economists - it makes interesting reading and some of HSE's graphs are reproduced with their permission in this blog.

It's pretty obvious that the total number of fatal injuries will increase during economic recovery:  more work = more employees = more people at risk.  But why should the rate of injuries per 100,000 employees go up as well?  There are a number of issues at play.

Firstly, as overtime and working hours increase to meet demand, the total time an employee is exposed to risk also increases.  If the average time worked rises from 40 hours / week to 42 hours / week, we would expect the injuy rate to go up by 5%.

Secondly, businesses take on new employees to meet demand - and new employees are at significantly higher risk than old hands.  As the graph below shows, someone in their first month of a job is three times more likely to be injured as an employee with 20 years experience who is exposed to the same conditions. 

Looking back at the recessions in the early late '80s and early '90s companies unsurprisingly took on significantly fewer new starters, but as the economy improved the proportion of new starters fairly rapidly increased above the original level before gradually settling down.  The graph below shows the percentage of the workforce who started their current job within the previous 6 months.  As it illustrates the same pattern is emerging for this recession; it's reasonable to assume that we will have an unusually high proportion of new starters and so an increased risk of injury.

So, what should businesses be doing to meet this challenge? 

• First and foremost make sure your employees are appropriately trained.   That means prompt inductions and task-specific training for all new starters so they know how to work safely.  Crucially also make sure that new managers and supervisors get the training they need - they will have a key role to play in ensuring the safety of new and experienced employees alike.  As ever EEF is geared-up to help with Working Safely and Managing Safely courses available at one of our centres or at your workplace.
• Ensure that risk assessments are carried out for any new processes or changed processes; it's all to easy to lose sight of this in the enthusiasm of new orders.
• Ensure that maintenance and monitoring are up to date.  In tough economic times these can go by the board only to emerge when things pick-up, resulting not just in harm, but also unscheduled downtime.  Check and get up to date before it's too late.

Next week I'll have a look at effects of recession and recovery on ill health and how certain types of condition are likely to be more affected than others.  In the meantime EEF members can find out more about managing health and safety in EEF's Health, Safety and Environment guide.

The UK has long been labelled ‘the dustbin of Europe’ because it far exceeds its neighbours in the amount of rubbish it sends to landfill.  The UK ‘truck and dump’ attitude to waste is very different to many other European countries whereby efforts to recover energy from waste and recycling had been pursed.

Whilst the UK approach to waste has been different to many of our northern European neighbours, this criticism is a little unfair.  One needs to put into perspective that conditions in the UK are more favourable to landfill than in other European nations, making it the most cost-effective waste management option.  For example, UK soils have a heavy clay content making it a suitable landfill liner (reducing the risk of leechate).  The UK is also not exposed to low lying areas (subject to flooding).  As a result European nations exposed to these risks have had to resort to alternate waste management systems.

The UK’s historic dependence on landfill does mean it now has the furthest distance to travel to ascend the European Commission’s Waste Hierarchy, which cites landfill as the least preferred waste management option and prevention as its preferred (landfill>energy from waste>recycling>reuse>prevention).  And which is now a priority order contained in the soon to be transposed revised Waste Framework Directive (rWFD).

The UK has had some success weaning itself off landfill, not that it could be argued it’s had much choice.  The management of waste is a European community issue which was first laid down in the original 1975 waste framework directive.  This has resulted in a number of European waste directives being introduced to limit waste airings.  Failure to comply with these directives, and the targets laid down in them, would result in infraction proceedings against a member state resulting in significant fines and national embarrassment. 

As a result of government activity to implement various waste legislation progress has been made over the past ten years.  Indeed a significant number of landfill facilities have had to close as a result of the impacts of this legislation - There are now around 450 landfill sites compared with 1,200 in 2001.  The move away from landfill has created new recovery and recycling markets.  However, EEF remains critical that the UK still lacks the necessary infrastructure and correct policies to divert significant quantities of waste from landfill cost effectively.

The new government clearly sees an improved role for waste management in the UK and the Secretary of State for Environment recently announced that DEFRA would perform a waste review for England.  

Why only England you might ask, well waste is a matter for each of the devolved administrations and is thus managed at national level.  However, the strategy is a bold and ambitious project whose results will no doubt impact each of the devolved government’s future policy strategies.

Waste has consistently eclipsed climate change as the priority environmental issue for manufacturers in EEF’s environment surveys.  This is in part down to the fact that waste is a clear and visible environmental issue impacting manufacturers on a daily basis and with direct financial consequences.  As a result EEF has established itself as a central figure on this issue with government and plays a critical role influencing a number of waste related stakeholder groups. 

We will make a formal response to DEFRA’s strategy review to ensure that waste continues to be diverted from landfill and that improved mechanisms are put in place quickly, to ensure that resources inherent in waste are extracted.  Your views on this issue would be most welcome.

More than a quarter of deaths in manufacturing are a result of accidents during maintenance work, and it is also responsible for many other serious injuries and ill health. So what goes wrong?

The fact that maintenance is not directly part of the manufacturing process means that it is all too easy to forget when thinking about health and safety. Last year the main causes of fatalities due to maintenance work were: falls from height; falling objects; vehicle movements and failure to isolate machinery.

Because of this, HSE inspectors are focusing on maintenance as part of their inspection programme this year and they have identified five priority areas, namely:

·         isolation, permits to work and entry into confined spaces;

·         falls from height (including roofs);

·         falls of heavy items; and

·         asbestos / ’duty to manage’ issues related to the building's fabric

·         selection and management of contractors (where relevant).

HSE are urging companies to:

·         Review maintenance risk assessments

·         Review competencies and equipment

·         Ensure they’re monitoring that maintenance is carried out with risk assessments

·         Have back up arrangements for dynamic risk assessments. 

So, the risks associated with maintenance work need to be assessed and checks made to ensure that there are controls in place and that they are working. By its very nature, maintenance varies from one job to the next, so dynamic risk assessments also need to be made while the work is going on. This requires competent people, capable of realising and understanding the risks, and how to deal with them to protect the safety of all involved, including themselves.

Ask yourself, do the managers who are commissioning and managing maintenance work they have the necessary skills, training and experience? Has your equipment and machinery been properly inspected and provided with the necessary guarding? Is the guarding adequately maintained? Can the machinery be properly isolated? Do you have a clear permit-to-work system?

And remember that temporary activities associated with maintenance are also high risk, such as working at height, as well as the movement of vehicles and loads.

EEF has teamed up with HSE and TUC in order to raise the profile of the issues with manufacturers, and will be running a series of events during the autumn as part of the EU’s Safe Maintenance campaign.

The half-day seminars only cost a nominal £25 and are being held in Newport (19 October), Sheffield (4 November), Warrington (9 November), Glasgow (23 November) and Leamington (30 November).

If you would like to know more about these events visit www.eef.org.uk/Safemaintenance or book direct on 0845 293 9850.

See also HSE’s Sector Information Minute which provides the guidance to inspectors on the inspection of maintenance activities in manufacturing premises.

One of the key themes set out in the new government's coalition agreement is reducing the burden of regulation.  Spearheading this is an ambitious commiment to "cut red tape by introducing a 'one-in, one-out' rule whereby no new regulaton is brought in with out other regulations beinc guct by a greater amount."  If that target of actually reducing regulation is deliverd that would have a major impact on the costs to business of complying with health and safety, climate and environment and employment legislation.

It's certainly bold, but haven't we been here before?  The Major government promised 'deregulation', whilst 'better regulation' was a constant theme of New Labour's appproach to business under both Blair and Brown.  And yet throughout that time the cost of regulation continued to rise every single year.

So are things different this time?  Well in some ways it's too early to say.  There are some promising signs, but structures are still being established and are yet to be tested (there are many proposals for regulation wating in the Whitehall wings, but I understand that civil servants are holding back, waiting for someone else to test the water first!)  However, work does seem to be progressing apace, with both Business Secretary Vince Cable and Cabinet Secretary Oliver Letwin driving things forward.  Regular progress updates continue, with EEF contributing to the debate.  So what do they have planned?  The key proposals include:

• ·       a review of all the regulatory proposals in the pipeline;
•         a ‘one-in-one-out’ system to tackle the rising regulatory burden whereby no new regulation can be brought in without the cost of other regulation being cut by a similar amount; 
• ·       ‘sunset clauses’ for all regulations and regulators to ensure that their performance and the ongoing need for them is kept under regular review; 
• ·       strengthening the scrutiny of all new regulatory proposals by giving greater powers to a body called the Regulatory Policy Committee - it was formed in late 2009 and has really hit the ground running.
• ·       giving the public and the business community the opportunity to identify and challenge the worst regulations - an eye-catching initiative but not one likely to have far-reaching impact;
• ·      ending the so-called ‘gold-plating’ of EU legislation whereby the UK government adds additional requirements that increase the regulatory burden on British businesses;
• ·       making greater use of alternatives to government regulation, such as co-regulation and professional standards, to achieve policy objectives; 
• ·       better targeting and a more risk-based approach to inspection;

There are some big opportunities to reduce unnecessary costs to business, whilst still maintaining essential protections.  But there are also some potential elephant-traps lurking.  For example sometimes the alternatives to regulation can be even more bureaucratic - just take a look at carbon trading and some British Standards.  And the reality is that half or more of all regulation comes from the EU, changing it's approach means building broad alliances with other member states.

All of that said, we have an unprecedented opportunity for change.  That is why an EEF Task Group on Regulation was formed to carry out a thorough review.  The Task Group, composed of senior representatives of EEF member companies, has heard from key figures in regulation.  Its report is just being finalised and is due to be launched in September - ahead of the party conferences and in time to inform development of the government's plans.  

That report is intended to be more considered than just a simple 'we don't like regulation'.  The reality is that regulation does have a place in a civilised society:  it provides important protections, and at its best ensures that everyone competes on a level playing field.  The challenge is finding the right balance point, between protections and the cumulative cost to business of complying.

This is likely to be an important area that has a very significant impact on all areas of regulation.  We'll keep you updated on developments.

More than six years have passed since the outbreak of serious respiratory disease at Powertrain and we still don’t know the cause.

Admittedly, it appears to be linked to the use of metalworking fluids but what the exact causative agent is in these fluids is unknown. Extrinsic Allergic Alveolitis can have a permanently debilitating and disabling effect, and like asthma can, in rare circumstances, also be fatal. 

Metalworking fluids (also known as suds, coolants, slurry or soap) have been said to be the ‘lifeblood’ of engineering. So, for manufacturers who depend on their use, what are they supposed to do? How can manufacturers best reduce the risk to their employees when they don’t know what to control? 

Fortunately, EEF has teamed up with HSE to put a mark in the sand and produce some clear guidance. EEF has agreed a six-step approach to the management of water-based metalworking fluids which means users need to:

• carry out and record a suitable and sufficient risk assessment
• eliminate or adequately control MWF exposure
• control bacterial contamination
• maintain MWF quality
• provide health surveillance where there is skin exposure or misting, and
• provide appropriate information, instruction and training

Essentially, as well as maintaining the quality of the fluid and minimising bacterial contamination, proper control boils down to having effective systems in place to control the mist arising from use of the fluids.

The amount of mist generated by machining depends on a number of factors including the speed of rotation of the machine tool, the pressure of application of the fluid and the geometry of the work-piece. As a result, some processes tend to create more mist than others and some produce high levels of very fine mist that can be inhaled deep into the lungs; for example grinding, whilst others, such as reciprocating sawing produce little or no mist.

Most modern CNC lathes are generally high speed and capable of creating coolant mist. So, the starting point for risk assessment of high speed machining will generally be to provide full enclosure as well as efficient local exhaust ventilation, vented to the outside.

In any event, your risk assessment needs to consider the particular conditions, working practices and experience at your workplace. However, it’s worth remembering that while proper control will reduce the incidence of respiratory ill-health, it may not prevent all cases.

HSE continue to undertake research in this area. Where cases of respiratory ill health arise despite all of the accepted control measures being in place, HSE enforcement action is unlikely to be justified given the current state of knowledge.