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Fibrax Limited

Health and Safety Manual


Volume 1
(General Arrangements & Procedures)

Rev. No. Date of Issue QC37 Change Detail


Ref.
2 02/07/2001
3 04/01/2002
4 06/08/2002
5 06/01/2003
6 01/08/2005
7 01/09/2006
8 02/04/2007
9 02/06/2008
10 25/07/2011 445 Major revision to all sections.
11 13/03/2013 453 Refer to change note
12 15/12/2016 485 Refer to change note

Unless an LQC21 controlled issue tag is affixed and signed (left), this is not a
Affix LQC21 Issue controlled document; unless so controlled, it should not be assumed that this
Control Label Here copy reflects the latest revision of policy. For the latest revision of this
document, contact the Health and Safety Practitioner on Telephone Ext. 234
Health & Safety Manual Volume 1 Rev.12

This page intentionally blank

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Health & Safety Manual Volume 1 Rev.12

Contents.
Section 1: General Arrangements
Header & Revision History 1
Section 1 Contents 2
Section 2 Contents 3
Section 3 Contents 4
Statement of Company Policy for Health & Safety 5
Organisation and Reporting Structure 7
Structure Diagram 7
Key Roles and Responsibilities 8
Arrangements for the Provision of Health & Safety 13
Individual 13
Requirements of Job Descriptions 13
Requirements of the Induction Process 13
Establishment of Competence 14
Reviews & Appraisals 14
Corrective Action 14
Systemic 15
Performance Measurement 15
Performance Review 15
Corrective Actions 15
Risk Assessment 16
Provision of Welfare Facilities 17
Provision and Management of Personal Protective Equipment 18
Communications 19
Internal 19
External 19
Managing Change 19
Control of Documentation 20

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Health & Safety Manual Volume 1 Rev.12

Contents (cont.)
Section 2: Procedures
General Procedures
HSP001: Conducting Activity Based Risk Assessments 21
HSP002: Management of Contractors 25
HSP003: Visitors to Site 29
HSP004: Site Security 31
HSP005: Electricity 33
General Safety 34
General Maintenance Requirements 34
Safe Working When Maintaining Electrical Systems 34
HSP006: Fire 36
Risk Assessment 37
Evacuation Procedure & Fire Drills 38
Testing and Maintenance of Portable Appliances 40
Testing and Maintenance of Fire Alarm Systems 41
Training 41
Inspections and Audits 42
HSP007: Control Of Substances Hazardous to Health 43
Risk Assessment 44
Introduction of New Substances,
Applications or Methods of Work 45
Monitoring Exposure Levels 46
Developing, Implementing and Enforcing Controls
And Emergency Procedures 46
Provision of Information 47
HSP008: Incidents & Accidents 49
Accident Books 50
Reporting Accidents to Management 50
Accidents Involving Visitors 51
HSE Reportable Accidents (RIDDOR) 51
Investigation & Reporting 52
First Aid Provision 54
HSP009: Manual Handling 55
HSP010: Noise Management 58
HSP011: Assisted Lifting Operations 63
HSP012: Display Screen Equipment & Workstation Management 68
HSP013: Accommodation for Young Persons 72
HSP014: Accommodation for New & Expectant Mothers 78
HSP015: Working at Heights 81
HSP016: Asbestos Management 84

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Health & Safety Manual Volume 1 Rev.12

Contents (cont.)
Section 2: Procedures
HSP017: Management of Hazardous Activities: Permits to Work 88
Permits to Work 89
Lone Working 90
Hot Work 90
Working in Confined Spaces 90
Live Work 91
Working at Height 91
HSP018: Provision for People with Disabilities 92
HSP019: Traffic Management 95
HSP020: Planning & Executions of Non-routine Operations 97
HSP021: Repair & Maintenance Operations 99
HSP022: Management and Use of Fork Lift Trucks 101
HSP023: Work Related Road Safety 107
HSP024: Housekeeping and General Standards of Cleanliness 112

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Health & Safety Manual Volume 1 Rev.12

Statement of Policy on Health & Safety


1.1. Based in North Wales, Fibrax Ltd produces polymeric components together with
associated assemblies.
1.2. Fibrax Ltd. acknowledges and accepts its legal responsibilities for securing the health,
safety and welfare of all its employees, of sub-contractors working on its behalf and all
others affected by its activities under the Health and Safety at Work Etc. Act 1974.
1.3. The Company will provide and maintain safe and healthy working conditions so far as
reasonably practicable.
1.4. Fibrax Ltd. is committed to the prevention of injury and ill health to all employees and
to others that may be affected by the undertakings of our business; this will be achieved
by identifying hazards, assessing related risks and managing those risks so far as is
reasonably practicable. The organisation will strive for the continual improvement of its
health and safety performance.
1.5. Fibrax Ltd. will operate a health and safety management system which provides the
framework for planning, implementing, checking and reviewing health and safety
performance throughout the organisation.
1.6. Annual objectives and targets will be set out for the continual improvement of the
management of health and safety; these will be reviewed periodically to ensure that
progress is being made and that objectives are being met.
1.7. Fibrax Ltd. Is committed to:-
• The provision and maintenance of plant, equipment and systems of work that
are safe and without risks to health and safety so far as is reasonably
practicable.
• The provision of arrangements for ensuring, so far as is reasonably practicable,
safety and absence of risks to health in connection with the use, handling,
storage and transport of articles and substances.
• The provision of such information, instruction, training and supervision as is
necessary to ensure the health and safety at work of our employees so far as
is reasonably practicable.
• The maintenance of any place of work under our control in a condition that is
safe and without risks to health and the provision and maintenance of means
of access to and egress from it that are safe and without such risks so far as
is reasonably practicable.
• The provision and maintenance of a working environment for our employees
that is, so far is reasonably practicable, safe, without risks to health, and
adequate as regards facilities and arrangements for their welfare at work.
1.8. We will provide adequate control of the Health and Safety risks arising from our work
activities.
1.9. We will establish and maintain emergency procedures to take account of unexpected
risks to health and safety, such as the outbreak of fire.
1.10. The company will ensure that all its employees are competent to carry out their tasks
and given adequate information, instruction, training and supervision.
1.11. The Company will encourage all employees to be actively involved in maintaining safe
operating conditions and practices and will consult with employees on all aspects of
company operation that relate to their health and/or safety.

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Health & Safety Manual Volume 1 Rev.12

1.12. This policy will be regularly reviewed to ensure that these standards of health and safety
are maintained.
Signed,

John O’Brien
Managing Director
21st March 2016

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Health & Safety Manual Volume 1 Rev.12

2. Organisation

Figure 1: Company H&S Reporting Structure

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Health & Safety Manual Volume 1 Rev.12

3. Specific Roles Within Reporting Structure

3.1. Managing Director (MD)


3.1.1. The Managing Director has overall responsibility for Health and Safety within the
company and for ensuring that the company complies with all relevant health and
safety legislation or any specific requirements established in the company
statement of policy relating to health and safety.
3.1.2. To assist in the management of health and safety and to provide specialist advice
over related issues, the MD will appoint a responsible person who is to be qualified
to NEBOSH General Certificate standard (or equivalent) as a minimum.
3.1.3. Specific duties of the MD with the HS management system are the establishment
and enforcement of health and safety policy and the organisation of periodic
reviews of health and safety performance, including follow up reviews in the event
that corrective actions are required.

3.2. Other Directors


3.2.1. Directors are responsible for the health, safety and welfare of all employees.
3.2.2. All Directors are responsible for encouraging a working culture that places the
Health and Safety of employees and members of the public at the forefront in all
undertakings on behalf of the company.
3.2.3. Directors are responsible for ensuring that any non-employees brought on site as
part of their activities comply with the requirements of this manual and are
adequately supervised so as to minimise, as far as is reasonably practicable, the
risks to the health and safety of themselves and others.
3.2.4. Section 37 of the Health and Safety at Work Etc. Act 1974 also makes company
directors personally responsible for offences by the corporate body if it can be
demonstrated that a breach of the act occurred as a result of neglect, or with the
consent or connivance of, an officer of the company. Directors are therefore to
ensure that their own conduct is sympathetic with the fostering of a health and
safety culture within the company.

3.3. H&S Practitioner


3.3.1. The H&S practitioner is appointed by the Managing Director (Para. 3.1.2) and is
responsible for the implementation of health and safety policy, as well for providing
advice on health and safety related matters to senior management, including
advice on health and safety policy.
3.3.2. The H&S practitioner will remain aware of changes to health and safety legislation
and relevant best practise, as well as to company undertakings and will update
the Health and Safety Manual as required to accommodate change.
3.3.3. The H&S practitioner is responsible for ensuring that adequate steps are taken to
ensure that all working under the scope of the Health and Safety Policy are
competent to undertake the role assigned to them.

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3.3.4. The H&S practitioner will chair the company health and safety committee and will
ensure that this committee meets with sufficient regularity as to satisfactorily
perform its function.
3.3.5. The H&S practitioner will collate and analyse information relevant to performance
of the health and safety management system including, but not limited to, analysis
of accidents and ‘near miss’ incidents as well as objective measurement of
exposure to noise, and to potentially hazardous substances.
3.3.6. The H&S practitioner will liaise with external stakeholders including legislative
authorities and trade bodies as necessary, including the reporting of any incident
conforming to the requirements of the Reporting of Injuries, Diseases and
Dangerous Occurrences Regulations (RIDDOR) 1995.
3.3.7. The H&S practitioner will provide a written report to the board of directors prior to
each board meeting; this report will summarise any accidents or incidents that
have occurred since the last meeting, provide advance notice of any forthcoming
changes to legislation together with an analysis of the consequences for the
company.
3.3.8. The H&S practitioner will also undertake any other unspecified duties as may be
necessary to ensure that the company conforms to relevant legislation and other
policy commitments.

3.4. Department Heads


3.4.1. On matters relating to Health and Safety, all department heads report to the
Managing Director through the H&S practitioner.
3.4.2. Department heads are responsible for ensuring that all employees within their
department are made aware of the risks involved with the activities they undertake
within their role in the company, and of any control measures implemented to
mitigate those risks.
3.4.3. Department heads are responsible for ensuring that all employees within their
department are competent to undertake the activities required by their role within
the department without compromising the health and safety of themselves or
others.
3.4.4. Department heads are responsible for ensuring that subordinate line managers
are provided with sufficient training in health and safety management to ensure
that they are able to determine and provide the levels of supervision required for
each employee when undertaking a required activity.
3.4.5. Department heads are responsible for ensuring that adequate supervisory
capacity is available to cope with the requirements of their department, in
particular where new skills are being learned and increased levels of supervision
are required.
3.4.6. Department heads have a responsibility to ensure that all employees within their
department are afforded sufficient time to attend training events as may be
arranged from time to time by the health and safety practitioner to accommodate
changes to legislation, best practise etc. or to simply refresh knowledge already
imparted.
3.4.7. Department heads are responsible for ensuring that all accidents and ‘near miss’
incidents are reported to the health and safety practitioner, so that action can be

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Health & Safety Manual Volume 1 Rev.12

taken where necessary to prevent recurrence. In order to encourage the reporting


of H&S issues, Department Heads are to foster a ‘no-blame’ culture as far as is
reasonably practicable in relation to accidents and incidents.
3.4.8. Department Heads are responsible for ensuring all activities undertaken by
employees within their department have been subjected to a thorough risk
assessment prior to the activity being undertaken. Where new activities are
introduced to a department, the Department Head will liaise with the health and
safety practitioner to ensure the required risk assessments are undertaken,
control measures put in place where necessary and all affected employees
properly trained and able to demonstrate competence in the new activity.
3.4.9. Department Heads are responsible for ensuring that members of the Health and
Safety Committee are provided with the time and resources needed to properly
fulfil their role.
3.4.10. Department Heads are responsible for ensuring that any non-employees
brought on site as part of the activities of their department comply with the
requirements of this manual and are adequately supervised so as to minimise, as
far as is reasonably practicable, the risks to the health and safety of themselves
and others. Where non-employees are undertaking work on behalf of the
company, the controlling Department Head is to ensure that safe methods of work
are agreed and employed.

3.5. Line Managers (Team Leaders & Assistants)


3.5.1. Line managers report to their own department head with respect to matters
relating to Health and Safety.
3.5.2. Line managers have responsibility to ensure that all employees under their
supervision are competent to undertake the activities assigned to them, or to
provide sufficient supervision as to mitigate any risk raised by a lack of
competence where an employee is training in order to develop competence.
3.5.3. Line managers have a responsibility to ensure that all control measures
established to mitigate risk to health and safety are employed when carrying out
the activity to which they relate.
3.5.4. Line managers are to ensure that all employees in their team work strictly to the
defined safe method of work for the activity being undertaken.
3.5.5. Line managers have a responsibility to report all accidents and ‘near miss’
incidents to their department head. Line managers are also required to ensure
that accidents are recorded in the company accident book in situations where the
casualty is unable to ensure this themselves.
3.5.6. Line managers have a responsibility to report to their department head, any
unforeseen change in circumstance within their team (relating to personnel,
working methods, environment or equipment) that may alter the risk of accident,
injury or occupational illness.
3.5.7. In the absence of the department head, a line manager may liaise directly with the
H&S practitioner in any health and safety related matter.
3.6. Health and Safety Committee

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3.6.1. The health and safety committee will comprise of the health and safety practitioner,
department heads with a substantial health and safety responsibility and all
employee’s health and safety representatives.
3.6.2. The health and safety committee will meet at regular intervals to ensure that health
and safety issues raised by employees are addressed and resolved and also to
ensure that any proposed changes to company operations, or forthcoming
changes to legislation are discussed and any subsequent issues are resolved.
3.6.3. The Works’ Council may fulfil the role of the H&S committee.

3.7. Health and Safety Representatives


3.7.1. Health and safety representatives are appointed by the employees of the
department they represent.
3.7.2. Should a majority of employees wish to appoint a union health and safety
representative, the following conditions will apply as listed in the Safety
Representatives and Safety Committees Regulations (SRSC) 1977:
3.7.3. The trade union must notify the company in writing of the intent to appoint
representatives and defining the employees to be represented.
3.7.4. The representative must have been employed by the company for the preceding
2 years (or, where this is not practical, had 2 years prior experience in similar
employment)
3.7.5. If employees wish to appoint representatives without union involvement, the Health
and Safety (Consultation with Employees) Regulations (HSCER) 1996 apply and the
preceding requirements are moot.
3.7.6. In either case, the following apply:
3.7.7. H&S Representatives have the right:
• To conduct independent investigations into potential hazards and dangerous
occurrences.
• To examine the causes of accidents in the workplace
• To carry out investigations into complaints by employees relating to health,
safety or welfare.
• To represent the employees they were elected to represent in consultations
with the company.
• To carry out inspections of the workplace subject to the provisions in SRSC or
HSCER.
• To bring to the company’s notice any unsafe conditions or working practise
that comes to their attention.
• To represent the employees they were appointed to represent in discussion
with enforcing authority inspectors
• To receive information from enforcing authority inspectors on behalf of the
employees they represent.
• To attend meetings of the company safety committee.
3.7.8. H&S Representatives have a responsibility to remain informed as to the
requirements of current legislation.
3.7.9. H&S Representatives have a responsibility to encourage co-operation between the
employees they represent and the company.

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3.7.10. H&S Representatives have a responsibility to bring to the company’s attention,


any unacceptable conditions that come to their attention.

3.8. All Employees


3.8.1. All employees have legal responsibilities under Sections 7 & 8 of The Health and
Safety at Work Etc. Act (HASAWA) 1974 and Regulation 14 of the Management of
Health and Safety at Work Regulations (MHSWR) 1999:
• To take care of their own health and safety and that of others who may be
affected by their acts or omissions.
• To co-operate with the company, so far as is necessary, so as to ensure that
the company can comply with its statutory obligations.
• To not interfere with, or misuse anything provided to mitigate risks to health and
safety.
• To use any equipment provided to them for the purposes of securing health
and safety in accordance with the stated method of use and any training given.
• Within the limits of their own competence, to inform their team leader of any
situation that represents a serious and immediate danger or a shortcoming in
the protection arrangements made by the company.
3.8.2. All employees have a responsibility to treat the welfare facilities provided for them
with respect.

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4. Arrangements for the Provision of Health & Safety


4.1. Individual Arrangements
4.1.1. Requirement of Job Descriptions.
All job descriptions shall include reference to the reporting structure for health
and safety.
Where the role being described has a specific element of health and safety
responsibility, this must be summarised within the job description, giving details
of the level and approximate number of employees for which the candidate will be
responsible.
4.1.2. Requirements of the Induction Process
A key aspect of the induction process for new employees is the imparting of
information pertinent to their health, safety and welfare, and to that of others that
may be affected by their acts or omissions.
Where a number of employees are taken on to undertake an identical role, group
inductions may be used to impart health and safety information but, where
individuals are to undertake roles that differ from other new starters, the health
and safety aspect of the induction process shall be tailored specifically to the
needs of that individual.
As a minimum, the induction process must provide the following to the new
employee:
• A review of all relevant risk assessments for the role undertaken.
• Training in the proper use of any controls provided to secure health and
safety in the role, including rotation of work, manual handling techniques, use
of guards and personal protective equipment.
• Training in the fire evacuation drill, including details of the alarm signal,
appropriate routes for evacuation, the location of muster points and the
actions to take after evacuation has occurred.
• Training in the site traffic management scheme, including hi-visibility and
pedestrian free areas.
If the specific role requires the provision of other information, this should also be
referred to during the induction process and, if necessary, dates for advanced
training arranged so that the new employee can become competent as quickly as
reasonably possible.
Where the role requires additional qualifications already held by the employee,
proof of this should be viewed during the induction and a copy of the proof taken
and retained with the employee’s personnel record.
As part of the induction process, the individual shall be required to sign a dated
document to confirm that they have received the health and safety information
necessary to allow them to begin their new role, and that they have understood it.

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4.1.3. Establishment of Competence


A key aspect of successful health and safety management is the establishment of
competence. In any role, the competence of the individual must be ascertained
or, if the individual is not yet considered competent, additional supervision must
be provided to mitigate the risk brought about by the lack of competence.
Competence can be defined as a combination of:
• Training in the skills needed to undertake the activity.
• Experience in completing the activity safely
• Ability to undertake the activity safely and repeatably.
• Knowledge of the activity and associated risks.
Note that training relates to the imparting of information whereas knowledge
relates to the retaining and useful application of that information once imparted.
Once an employee is considered competent to undertake an activity safely, this
shall be recorded as part of the training records for the department to which the
employee belongs. Where competence has been demonstrated, the nature of the
evidence of competence shall also be recorded and stored within the individual’s
personnel file.
4.1.4. Reviews and Appraisals
Health and safety performance shall be discussed at all employee reviews and
appraisals, with particular reference made to any accidents or incidents and to
any occasions where an individual has been warned for failing to employ control
measures established to ensure health and safety.
Reviews and appraisals should also be used as an opportunity to discuss any
welfare issues the individual may wish to raise.
4.1.5. Corrective Action
Where an individual is seen to be a contributing factor in an unusually high number
of accidents or incidents, or is known not to follow established safe working
practise, the company must take action to remedy this. Training, additional
supervision and, ultimately, disciplinary action should all be considered in such
cases. Managers should be aware that an individual failing to follow safe working
practises not only presents a risk at the time, but sets a bad example to others.
For this reason it is imperative that such cases are dealt with promptly.
Failure to take action could result in the individual managers or the board of
directors being held accountable for the actions of the individual under Section
36 or Section 37 of the Health And Safety At Work Etc. Act (HASAWA) 1974
respectively and, in extreme cases, the company could be held accountable under
the Corporate Manslaughter and Corporate Homicide Act 2007.

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Health & Safety Manual Volume 1 Rev.12

4.2. Systemic Arrangements


4.2.1. Performance Measurement
The company will make provision for proactive and reactive measuring of health
and safety performance. Specifically, the company will:
• Analyse accidents and near miss incidents using both trend and
epidemiological methods considering the type of activity, substances used,
location, individuals involved, equipment involved and time of accident to look
for key contributing factors.
• Monitor harmful emissions relating to its activities, specifically; exposure to
rubber fume in the moulding shop, exposure to dust in the cycles
manufacturing area, solvent concentrations in the cables PTFE coating area
and noise in the moulding shop.
• Audit key aspects of the system to ensure that the management system is
followed, is relevant and is effective.
4.2.2. Performance Review
The health and safety practitioner will review accident and incident data at monthly
intervals and report any significant findings to the board of directors.
The health and safety practitioner will review results of emissions tests as they
become available and will report any significant findings to the board of directors.
The health and safety practitioner will review the findings of internal audits at
monthly intervals and will report any significant findings to the board of directors.
The Managing Director will convene a cross functional team to review the health
and safety management system annually. This review will consider actual health
and safety performance, any changes made to the system in the preceding year
and any changes expected in the future. The review team may then make
recommendations on any revisions to the management system, or to the core
policy driving the system.
4.2.3. Corrective Actions
Where any aspect of systemic review highlights a shortcoming in the system, the
health and safety practitioner will undertake an investigation to determine the
root cause of the issue and implement permanent, effective corrective action.
Where the root cause is not immediately apparent, the Health and safety
practitioner will raise an 8D investigation form (Quality Form QC32) and enter
details of the NC into the company 8D register (Quality Form QC31).
Subsequent investigation of the NC will follow the standard 8D format:
D1 – Establish a team. Team sizes can vary depending on the nature of the
investigation and may be a single nominated individual if appropriate to the
NC.
D2 – Describe Problem. The NC must be described in terms of scope, nature
and potential/actual impact(s)
D3 – Contain Symptom. The Team must ensure that the effects of the NC are,
as far as possible, mitigated.
D4 – Find and Verify Root Cause. This should be achieved using a structured
analysis method such as 5-Why and should consider operating methods, NC
detection methods and systemic function. Quality Form QC73 should be used

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for this purpose. Any evidence for specific causes should be attached to the
8D report.
D5 – Choose Corrective Action. Appropriate corrective and preventative
actions should be selected to ensure that procedural failures are permanently
resolved.
D6 – Implement Corrective Action and Verify. Selected corrective and
preventative actions should be implemented in a controlled manner and the
results of such actions measured for a stated period of time to verify
effectiveness. Evidence of effectiveness must be provided before the 8D
investigation can be closed.
D7 – Resolve Systemic Failure. Since a non-conformity was allowed to occur,
it is essential that the H&S management system itself is analysed to determine
how. Systemic corrections must be made where possible to ensure similar
non-conformities cannot continue to occur. This stage of the 8D process is
essential to the development of a robust control system.
D8 – Congratulate Team. Take time to ensure that all involved personnel are
thanked for their work, and made aware of the results of the investigation.
Any resultant changes to the H&S management system will be controlled by the
change procedure defined in the company quality manual (Quality Procedure 9).
After successful investigation, a review will be held to determine if lessons
learned from the NC can be used to improve other areas of the H&S
management system. This review may be conducted by the Health and safety
practitioner alone, or through a formal panel, depending on the scale and nature
of the original non-conformance. If the non-conformity resulted in the involvement
of external regulatory bodies or agencies, a formal panel review must be
conducted.
After completion of the 8D review, the completed QC32 form and all related
evidence is to be filed by the health and safety practitioner and stored for a
period of at least 40 years.

4.3. Risk Assessments


4.3.1. Regulation 3 of The Management of Health and Safety at Work Regulations (MHSW)
1999 requires the company to undertake risk assessments for all activities carried
out on behalf of the company, and to record the findings. The H&S Practitioner will
work with individual employees, line managers and department heads to produce
activity based risk assessments for each employment role.
4.3.2. The H&S Practitioner will work with individual employees, line managers and
department heads to produce COSHH risk assessments for each employment role
(or logical group of employment roles if common substances are in use).
4.3.3. Whenever a risk assessment is undertaken or reviewed, the H&S Practitioner will
ensure that all affected employees are made ware of the changes and of any
related changes to control measures.
4.3.4. Risk assessments will be conducted in accordance with health and safety
procedures HSP001 (activity based) and HSP007 (COSHH). In addition, a fire risk
assessment will be carried out for all premises in accordance with HSP006 as
required by the Regulatory Reform (Fire Safety) Order (RRFSO) 2005.

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4.4. Provision and Management of Personal Protective Equipment (PPE)


4.4.1. Where a requirement for PPE is identified through risk assessment or incident
investigation, this will be provided by the company at no charge to them employee.
4.4.2. Any PPE provided by the company must be fit for purpose and of a suitable fit to
allow wearing without severe discomfort for the period required to conduct the
work. Where PPE is necessarily uncomfortable, time spent undertaking the work
should be limited through job rotation as much as is reasonably practicable.
4.4.3. Where standard issue items of PPE are medically unsuitable for a particular
employee, the company will source alternative equipment or, if this cannot be
accomplished, reassign the employee to different work. Medical unsuitability in
this case must be confirmed by a qualified doctor and the company reserves the
right to appoint a doctor for this purpose.
4.4.4. Where standard issue PPE is suitable for purpose but an employee wishes to
‘upgrade’, they may do so at their own expense and the company will reimburse
the value of the standard issue PPE on production of a valid receipt for the
equipment. In such cases the replacement equipment must at least meet relevant
test standards or the test standards to which the original equipment was certified.
The company accepts no responsibility for privately owned equipment should it
be lost, stolen or damaged other than to replace it with standard issue equipment
as for company issued PPE.
4.4.5. Employees issued with PPE have a legal duty of care to maintain the equipment
in a safe working condition and, while normal wear and tear is to be expected,
employees may be charged for PPE that is damaged wilfully or where PPE is
repeatedly lost.
4.5. Welfare and Provision of Welfare Facilities
4.5.1. In accordance with the Regulations 20-25 of the Workplace Health, Safety and
Welfare Regulations (WHSWR) 1992, the company will provide adequate facilities
to ensure the welfare of employees while at work including;
• Suitable and sufficient (at a minimum conforming to the 1:25 ratio required by
Schedule II of the regulations) sanitary conveniences with separate provision
for men and women.
• Suitable and sufficient washing facilities, which will be provided with hot and
cold, or warm running water, soap or some other means of cleaning and towels
or some other means of drying.
• A suitable supply of wholesome drinking water, which will be clearly marked as
such. If drinking water is not supplied in a jet form suitable for drinking directly,
a suitable supply of cups will also be provided.
• Suitable lockers to allow non-work clothing and other personal effects to be
secured during the work period.
• Suitable rest facilities, which will isolated from the workplace sufficiently as to
allow rest periods to be taken without any requirement for personal protective
equipment. Rest facilities provided will make provision for employees to eat
meals without risk of contamination from the workplace.
4.5.2. If welfare facilities are not maintained to a suitable standard, are in need of repair
or are considered to be insufficient for the numbers of employees for which they

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are expected to cater, employees should notify their health and safety
representative, their line manager or speak directly to the Health and safety
practitioner, who will assess the issue and either arrange for improvements to be
made or will provide reasons why improvements will not be made. If any employee
is unhappy with reasons given, he or she may use the company grievance
procedure to address this.
4.6. The H&S practitioner will monitor ambient working temperatures where necessary and
take action to minimise the risk from heat stress during summer months and to maintain
a comfortable working temperature during cold weather.
4.7. Communications
4.7.1. Internal
The company will ensure that any changes to operations that may have an effect
on health and safety will be brought to the attention of all affected employees in
good time to allow any resultant issues to be discussed and resolved.
The company will maintain notice boards that will provide general information on
health and safety and will pass role specific information through direct
communication with relevant employees. Where information is provided to
employees, each affected employee will be asked to provide a written indication
that they have received and understood the information provided.
The company will also ensure that employees’ health and safety representatives
are aware of any information relevant to the health and safety of the employees
they represent.
4.7.2. External
The health and safety practitioner will be the primary company contact for external
stakeholders including the enforcement agencies. Copies of any written
communication with external stakeholders will be maintained for at least 3 years.
While employees’ representatives (Union or H&S specific) will be the main point
of contact for employees to enforcement agencies should such contact be
necessary, any employee has the legal right make direct contact and shall not be
penalised by the company should they choose to do so.

4.8. Managing Change


4.8.1. Changes to company operations that have the potential to affect the health and
safety of employees, sub-contractors or other non-employees will be managed in
accordance with the standard company change procedure (Quality Procedure 9)
with the following exceptions (The introduction of new and novel equipment or
processes must always be considered to have the potential to affect health and
safety until demonstrated to be otherwise).
• The change MUST be processed as a level 2 change at minimum.
• The Quality Review Board must include the health and safety practitioner and
employee health and safety representatives from all affected areas of operation.
• A risk assessment must be undertaken prior to the review.
• The change must not be approved unless suitable and sufficient controls are
established to mitigate any risk as far as is reasonable practicable.

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• The plan for change must include provision for re-training and re-establishing
the competence of all affected employees.
4.8.2. Changes to documentation that clarify methods or correct administrative errors
but have no direct impact on health and safety may be managed as a level 1
change through the standard company change procedure.
4.9. Control of Documentation
4.9.1. By their very nature, it is essential that documents relating to the provision of health
and safety are updated as and when new information becomes available. To
ensure that documentation relating to the management of health and safety is
regularly updated, the following key documents will only be issued as controlled
copies:
• The Health and Safety Manual
• Risk Assessment Reports
• Material Safety Data Sheets
• Extracted Health and Safety Procedures (HSP’s)
4.9.2. The documents listed above are to be controlled using the company document
issue control procedure and can be identified by a silver metallic LQC21 label
which must bear an original signature. The location of these copies is to be
recorded on issue using Quality Department Form QC94 and subsequent updates
are to be provided when these documents are amended.

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Section 2: Procedures
1. HSP001: Conducting Activity Based Risk Assessments
1.1. Responsibility
1.1.1. The Managing Director is responsible for ensuring that sufficient resources are
made available to perform risk assessments where required and that
recommended controls are implemented where reasonably practicable.
1.1.2. All Directors have a responsibility to encourage a working culture that places the
Health and Safety of employees and members of the public at the forefront in all
undertakings on behalf of the company.
1.1.3. The Health and Safety Practitioner is responsible for ensuring that all activities
conducted as part of the business’ undertakings are subjected to adequate
assessment of risk and that any risk to health and safety is mitigated as far as is
reasonably practicable.
1.1.4. Department Heads are responsible for ensuring that all activities carried out by
their department have been subjected to a risk assessment, that all members of
their department have been made aware of the contents of assessments relevant
to their activities and that this information has been understood. Department
heads are responsible for ensuring that the health and safety practitioner is made
aware of the activities carried out by their department so that risk assessments
may be conducted.
1.2. Legislation
1.2.1. Regulation 3 of the Management of Health and Safety At Work Regulations
(MHSWR) 1999 requires that risk assessments be conducted for all activities
undertaken as part of an employer’s undertakings and that these be recorded if
an employer has more than five employees.
1.3. Procedure
1.3.1. Activity based risk assessments are to be reported on form HS002, the structure
of which guides the assessment activity.

(a) (b) (c) (d) (e) (f) (g) (k) (l) (m) (n) (o)
(h)
(i)
(j)

Figure 2: Form HS002 - Activity Based Risk Assessments

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1.3.2. The assessment should be conducted by a cross functional team consisting of at


least;
• An individual with experience of risk assessment, such as the H&S practitioner.
• An operator or other individual who routinely carries out the activity being
assessed.
• A technical specialist such as a Process Engineer or Maintenance Engineer
where the activity involves the use of specialist equipment that introduces
unique or hidden hazards to the activity.
1.3.3. The assessment essentially follows the FMEA technique that is routinely used in
design and process improvement activities. The activity or process is described
in column (a) and the potential hazards associated with the activity are listed in
column (b) (Note: only activity based hazards are considered as a separate
COSHH assessment will be conducted to assess the substances used in the
process).
1.3.4. After the associated hazards are noted, the risks and effects related to each
hazard are described in column (c) and the people affected listed in column (d).
The list of people affected should be comprehensive as this will be used to
determine training needs for individual personnel and exclusion from this list may
prevent essential training from being correctly targeted.
1.3.5. If any legal or other requirements for control (such as a policy commitment that is
outside or above legal minimums) are relevant, these should be noted in column
(e) and any controls already introduced should be listed in column (f).
1.3.6. Once the details of the hazard and associated risk have been recorded, scores
should be assigned to each of, the severity (g) of the effects of the hazard, the
amount of time to which each individual is exposed (h) and the likelihood that a
potential risk will be realised (i) as a result of exposure. These three values are
then multiplied together to give a risk priority number (RPN) (j), this number allows
apparently disparate hazards to be compared to allow corrective responses to be
properly prioritised.
1.3.7. In an ideal world, any risk to health and safety could be mitigated but in the real
world, this is sometimes not feasible. For this reason, the Health and Safety at
Work Act Etc. 1974 includes the term ‘reasonably practicable’ in its definition of
the requirements for the provision of a safe working environment. Reasonable
practicability requires the company to compare the risk against the time, money
and effort required to mitigate it and take action on this basis. Assessment of the
need for further control is therefore inherently subjective but when making a
decision where reasonable practicability is not clear cut, the assessor should
involve the department head, line managers and employee H&S representative
from the affected area of operation as well as the original assessment team and a
consensus decision should be made.
1.3.8. Should further action be required to mitigate a risk, this should be noted in column
(k) and the details of responsibility and due date noted in columns (l) & (o). The
assessment should be reviewed with any person made responsible for additional
actions and a review date set to ensure all required actions have been completed.
1.3.9. Once a required action has been completed, this should be noted on the HS002
form, at which point the assessment can be updated to reflect the new controls
and re-scored accordingly.

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1.3.10. Risk assessments must be re-visited and updated as necessary whenever the
activity itself or the environment in which it is conducted changes.
1.3.11. Risk assessments should be reviewed at no less than 12 month intervals to;
• Ensure they remain relevant
• Ensure those involved in the activity remain aware of the hazards and risks
• Provide an audit of the system as any required update at this stage indicates a
failure to review in the preceding 12 months.
1.4. Developing, Implementing & Enforcing Controls and Emergency Procedures
1.4.1. Where an assessment shows an unacceptable risk to an employee, the H&S
practitioner will work with managers, employees and technical staff to develop a
control regime that adequately mitigates that risk. Controls should be given
priority in accordance with the hierarchy shown in Figure 3 with elimination of the
hazard as the preferred option.

Figure 3: The Hierarchy of Control


1.4.2. Once a control regime has been developed, it is to be tested to ensure
effectiveness and, if successful, reference to any required checks, safe working
methods or PPE are to be written into the safe working method for the operation
or, where this is impractical a health and safety procedure may be created and
referred to in the safe working method.
1.4.3. Where the risks associated with a hazard are continuous, or nearly continuous,
and specific to an area of the site, suitable signs are to be erected informing of
any special precautions required.
1.4.4. Where a health and safety hazard requires a specific emergency response, a
health and safety procedure must be written detailing that response and all likely
affectees made aware of the content and implications of that procedure.

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1.5. Provision of Information


1.5.1. The H&S Practitioner is to ensure that any person conducting an activity is made
aware of the hazards, risks, controls and emergency procedures relating to that
activity. For new employees this information is to be provided during initial
induction.
1.5.2. Where new activities are introduced, all affected employees are to be informed,
before the change occurs, of all related hazards, risks and controls.
1.5.3. When employees are transferred to another role within the company, the
department head covering the new role is to inform the H&S practitioner of the
change and provide details of any activities required by the new role. The H&S
practitioner will ensure that induction training for the new role includes details of
hazards, risks controls and emergency procedures specific to those activities is
provided before the transfer occurs.
1.5.4. If any employee develops signs or symptoms that they suspect may be attributable
to a company activity, they should inform their H&S representative or the H&S
practitioner directly, the H&S practitioner must then conduct a full investigation
and, if necessary, introduce control measures.

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2. HSP002: Management of Contractors


2.1. Responsibility
2.1.1. The Managing Director is ultimately responsible for the health and safety of all
who may be affected by the undertakings of the business including employees,
non-employees on site and the general public.
2.1.2. All Directors have a responsibility to encourage a working culture that places the
Health and Safety of employees and members of the public at the forefront in all
undertakings on behalf of the company.
2.1.3. The Health and Safety Practitioner is responsible for ensuring that any person
carrying out an activity on behalf of the company works in a manner that does not
unnecessarily compromise the health and safety of themselves or others and does
not compromise the health and safety of the public (i.e. individuals not employed
by Fibrax in either a direct or sub-contract capacity) in any way.
2.1.4. The Subcontractor Controller (SCC) is responsible for ensuring that
subcontractors employed by the company are competent to undertake the work
required, that contractors are made aware of the company’s rules for work on site
and that they provide evidence of risk assessment and safe working methods
before work is undertaken. The SCC is also responsible for the issue and return
of permits to work for contractors and for ensuring any site of work is left in a safe
condition when work is suspended or completed.
2.2. Legislation
2.2.1. Section 2 of the Health and Safety at Work Etc. Act 1974 makes an employer
responsible for taking reasonably practicable measures to ensure the health and
safety of its employees.
2.2.2. Section 3 of The Health and Safety At Work Etc. Act 1974 makes an employer
responsible for taking reasonably practicable measures to ensure the health and
safety of non-employees that may be affected by the undertakings of the business;
this includes visitors, contractors and the general public.
2.3. Procedure
2.3.1. As the conduct of contractors working on site also has the potential to cause
environmental harm, this procedure also features in the Fibrax Environmental
Management System as procedure EMP027.
2.3.2. Any non-routine work carried out on site by contractors must be approved by the
nominated subcontractor controller (SCC). The current nominated SCC is:
Simon James: Engineering Manager
2.3.3. RISK ASSESSMENT:
Where the work to be conducted is considered significant, the Environmental
Manager and/or Health and Safety Practitioner are both to be notified and may
request a relevant risk assessment and/or method statement detailing the safe
working practises to be followed. Work shall not begin until this is provided and
approved.
2.3.4. ASBESTOS:
The Fibrax site utilises Asbestos Containing Materials (ACM's) in its construction.
Management of ACM’s is specifically covered by procedure HSP016. All
contractors performing work on site must be fully briefed on the nature of any

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ACM's located in areas relevant to the work carried out. Any ACM's present in
areas where work is to be conducted by subcontractors MUST be included in the
risk assessment.
2.3.5. Where the contractor is required to undertake high risk work where specific Fibrax
procedures exist, such as hot work, working in confined spaces or working at
height, the contractor is required to at least meet the requirements of those
procedures. Should a contractor of established competence request to use an
alternative method to ensure the safety of the environment and the health & safety
of all stakeholders, this will be permitted providing the SCC, Environment Manager
and H&S Practitioner are all agreed that the method proposed is adequate.
2.3.6. To enable information relating to environmental and health & safety issues to be
easily assimilated by contractors and other visitors working on site at Fibrax, a
single fact sheet (Figure 4) has been assembled, covering all information relevant
to short term operations on the Fibrax site.
2.3.7. Any person working on site (including, but not limited to, maintenance contractors,
builders and sorting agents) is required to read, understand and comply with the
EMT010-1 fact sheet (and risk assessment and/or approved method statement
where relevant) and sign to confirm this, if a company is contracted to perform
work on site, sufficient time should be allowed by the contractor for briefing
workers before work begins on site and the contractor in question MUST provide
copies of the EMT010-1 return slip signed by each worker to the subcontractor
controller.
2.3.8. After all reply slips from form EMT010-1 have been returned, and if the risk
assessment and method statement (if required) have been accepted as adequate,
the Fibrax subcontractor controller will issue the contractor with a permit to work
(Form EMF027), detailing the work to be conducted, the date on which the work
will take place, attaching (if required) the risk assessment and/or method
statement specific to the authorised work and listing the contract employees
authorised to work on site (i.e. those for which an EMT010-1 slip has been
received).
2.3.9. The subcontractor controller will then attach all signed reply slips to a copy of the
issued permit and retain this for reference while the work is in progress, a second
copy of the permit will be provided to the contractor and must be prominently
displayed at the work site.
2.3.10. If work is required to continue beyond the agreed date, the SCC will issue
additional permits each day to cover this and will inspect the work site at the end
of each work period to ensure any new hazards introduced by the contractor are
sufficiently isolated or controlled. If the site has been made safe to the satisfaction
of the SCC, he will sign off the issued permit thereby closing it and accepting
responsibility for the work site on behalf of Fibrax until work resumes with a fresh
permit.
2.3.11. Once the work is deemed complete, the SCC will inspect the work site and will
sign off the open permit as completed, thereby taking responsibility on behalf of
the company for the work site.
2.3.12. Once the work has been completed, the SCC will forward all related copies of
EMF027 and EMT010-1 cover slips to the Environment Manager for long term
storage in accordance with procedure EMP023 (Environmental Records).

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2.3.13. Within this procedure, the phrase 'working on site' is taken to mean performing
unsupervised work which has the potential to cause an environmental or health &
safety impact. Visitors to the site who are not performing such work are covered
by procedure HSP003 (Visitors to Site).
2.3.14. The term 'significant work' relates to work other than the provision of a routine
service (such as waste disposal) where the presence of the contractor is likely to
substantially increase the risk of environmental impact or is likely to pose an
additional health and safety risk. Examples of significant work would be the
movement, installation or servicing of major plant items; routine servicing of
external systems such as water chillers, building work or building maintenance of
any sort or any type of cleaning operation conducted on site.

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Figure 4: EMT010-1 Contractor's Fact Sheet

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3. HSP003: Visitors on Site


3.1. Responsibility
3.1.1. The Managing Director is ultimately responsible for the health and safety of all
persons affected by the undertakings of the business; this includes any visitors to
site.
3.1.2. All Directors have a responsibility to encourage a working culture that places the
Health and Safety of employees and members of the public at the forefront in all
undertakings on behalf of the company.
3.1.3. Any employee arranging for non-employees to visit the site (contract workers
excluded, see procedure HSP002) is responsible for ensuring the health and
safety of their visitors while on site. Personnel arranging such visits should take
into account any requirements for personal protective equipment, unfamiliarity of
their guest with the site and its hazards and the possibility of a need for evacuation
in the event of an emergency. Personnel arranging visits are also responsible for
ensuring that their guests sign in on arrival and out on departure.
3.2. Legislation
3.2.1. Section 3 of The Health and Safety At Work Etc. Act 1974 makes an employer
responsible for taking reasonably practicable measures to ensure the health and
safety of non-employees that may be affected by the undertakings of the business;
this includes visitors, contractors and the general public.
3.3. Procedure
3.3.1. This procedure covers the methods by which visitors to the Fibrax site (other than
those on site to undertake work as a contractor, who are covered by procedure
HSP002: Management of Contractors) are protected from hazards that may arise
as a consequence of the undertakings of the company.
3.3.2. Any Fibrax employee arranging for a non-Fibrax employee to visit the site is
responsible for the general health and safety of that visitor while they are on
Fibrax’s premises.
3.3.3. All visitors MUST report to reception upon arrival at the site.
3.3.4. Upon arrival of a scheduled visitor, the receptionist will:
• Request that the visitor read the summary of site rules on display in the
reception area.
• Request that the visitor sign the visitor’s book.
• Notify the visitor’s contact at Fibrax
• Request the visitor to remain in reception until collected.
The receptionist shall not request the visitor to relocate to another part of site to
meet the visitor’s Fibrax contact.
3.3.5. Visitors must be collected from the reception area by the person being visited or
his/her nominee. This person shall ensure that the visitor’s book has been signed
and that the visitor is familiar with the summary of site rules.
3.3.6. While on site, the visitor will be in the care of their host, who will be responsible
for ensuring compliance with all relevant health and safety procedures and for
safe evacuation from the building should this be required.

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3.3.7. The above requirements may be waived for visitors who routinely attend the site
and have acknowledged in writing that they are aware of the site rules and of the
site evacuation routes and procedures.
3.3.8. When a visitor leaves site, his/her host is to retrieve any visitor’s pass and ensure
the departure time is noted in the visitor’s book. Failure to record departure may
lead to unnecessary searching of the premises in the event of a fire and could
thus put lives at risk needlessly.

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4. HSP004: Site Security


4.1. Responsibility
4.1.1. The Managing Director is responsible for site security. He should understand the
security systems employed and be fully aware of the requirements of this
procedure. The Managing Director is also responsible for designating key holders
and for ensuring that the relevant authorities are notified as to their identities.
4.1.2. All Directors have a responsibility to encourage a working culture that places the
Health and Safety of employees and members of the public at the forefront in all
undertakings on behalf of the company.
4.1.3. The Engineering Manager is responsible for ensuring physical security measures
such as fences and gates are maintained so as to be effective as a deterrent and
do not become a hazard in themselves as a result of poor maintenance.
4.1.4. The Unit 1 Production Manager is responsible for ensuring that the site CCTV
systems are maintained and for ensuring the site is secured at all times at a state
appropriate to the level of activity on it.
4.2. Legislation
4.2.1. Section 3 of The Health and Safety At Work Etc. Act 1974 makes an employer
responsible for taking reasonably practicable measures to ensure the health and
safety of non-employees that may be affected by the undertakings of the business;
this includes visitors, contractors and the general public.
4.2.2. The Occupiers’ Liability Acts of 1957 & 1984 allow for the company to be held
liable for injury sustained to an individual while on Fibrax’s premises, even without
the consent of a company employee if:
• Fibrax can be shown to have been aware of the risk of injury or that Fibrax had
reasonable ground to believe that the risk existed (a lack of such awareness
would also indicate a breach of Regulation 3 of the Management of Health and
Safety at Work Regulations 1999).
• Fibrax can be shown to know or have reasonable grounds to believe that an
individual could come into contact with the hazard (whether that individual had
lawful authority to be present or not). An open gate to an apparently empty site
would certainly be considered ‘reasonable grounds to believe’.
• The risk is one to which Fibrax could be reasonably expected to offer some
protection.
4.3. Procedure
4.3.1. Given the potential for liability for injury to trespassers, it is essential that the site
remains secure when the factory is closed or when operating with minimal staff,
as at weekends.
4.3.2. When any of the three units on site is closed, it should be locked and the security
alarm system activated. When the whole site is closed, all gates to the site should
be closed & locked and all alarm systems should be active.
4.3.3. When operating with minimal staff, all gates to the site should remain closed and
only the picket gate at the north end of the site and the main central gate should
be unlocked. Both gates are monitored by passive infrared detectors linked to red
lights located in the moulding shop. Should these lights be activated, the
designated team leader for the period is to investigate or delegate somebody else
to do so and report back. If trespassers are found on site they should be politely
asked to leave and, if they fail to do so, the police notified. Employees are not,

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under any circumstances to give chase to, or detain trespassers as these actions
give rise to additional risk of injury for both parties.
4.3.4. At any time, authorised visitors to the site should be wearing either a ‘visitor’ or
‘contractor’ pass, or alternatively be accompanied by a Fibrax employee. Any
employee noticing a non-employee on site who does not meet these criteria should
politely enquire as to the nature of the non-employees business on site & the name
of their Fibrax contact and, if no valid reason is given, treat the individual as a
trespasser and act as described in paragraph 4.3.3. If the non-employee is able
to provide a contact name, they should be escorted to reception and the
receptionist asked to verify that their business on site is legitimate. Employees
are expected to use some discretion in this (for instance, should a non-employee
claim to have been asked to wait for a short time at a location by their contact, the
employee finding them may choose to wait with them until their contact returns)
but should not leave an apparently unauthorised visitor unattended and if delayed
in their work as a result should notify their team leader of the reason as soon as
they are able.
4.3.5. Should any employee feel that approaching an unauthorised person on site
presents a risk of violence then the employee should avoid contact and ensure
the police are notified as to the presence of the individual. No employee should
be placed at risk from physical violence in order to preserve the security of the
site.
4.3.6. The site is fitted with a CCTV camera network that plays an important role in
maintaining site security. Any employee who notices a fault in this network should
notify his/her line manager who will in turn inform the Unit 1 Production Manager.
4.3.7. Security alarm systems deployed on site are the responsibility of the Engineering
Manager, who is to ensure that they are maintained in a fully operational condition.
Any employee observing or suspecting a fault with such a system should inform
the Engineering Manager directly.

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5. HSP005: Electricity
5.1. Responsibility
5.1.1. The Managing Director is ultimately responsible for the health and safety of any
person affected by the undertakings of the business and must therefore provide
sufficient resources as required to properly maintain all electrical equipment and
installations used as part of the company’s undertakings.
5.1.2. All Directors have a responsibility to encourage a working culture that places the
Health and Safety of employees and members of the public at the forefront in all
undertakings on behalf of the company.
5.1.3. The Engineering Manager is responsible for ensuring that electrical equipment
and installations used as part of the company’s undertakings are maintained in a
safe condition by competent persons.
5.1.4. Department heads are responsible for ensuring that the Engineering Manager is
informed of any electrical equipment procured by the company for whatever
reason so that he may ensure this equipment is properly maintained and tested.
Department heads are also responsible for ensuring that any reports of damaged
or defective electrical equipment are passed on to the Engineering Manager
immediately and that the affected equipment is safely isolated from supply and
quarantined to prevent use until it can be repaired or replaced.
5.1.5. All employees have a responsibility to treat electrical equipment with respect so
as to prevent damage and to report any damaged or defective electrical equipment
to their line manager immediately.
5.2. Legislation
5.2.1. The Health and Safety at Work Etc. Act (HASAWA) 1974 requires an employer to
provide, so far as is reasonably practicable, safe plant, equipment and systems of
work, as well as a safe working environment.
5.2.2. Regulation 3 of the Management of Health and Safety at Work Regulations
(MHSWR) 1999 require an employer to carry out and record the results of risk
assessments into all activities conducted as part of its undertakings.
5.2.3. Regulation 6 of The Provision and Use of Work Equipment Regulations (PUWER)
1998 requires that equipment provided for use at work is subjected to regular
inspection so as to ensure it remains fit for purpose and safe to operate.
5.2.4. Part IV of The Provision and Use of Work Equipment Regulations (PUWER) 1998
deals with the requirements for power presses. While this procedure details the
requirements for maintenance of this type of equipment, further requirements for
the general use of power presses are stipulated in procedures dealing with
manufacturing operations that utilise them.
5.2.5. The Electricity at Work Regulations 1989 require the provision of safe and suitable
equipment and installations as well as requiring that persons conducting electrical
maintenance or installation be competent to do so.

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5.3. General Safety


5.3.1. Electricity has the potential to cause injury via several routes and must be treated
with respect at all times.
5.3.2. Risk assessments will be conducted as necessary to identify potential hazards
and ensure appropriate controls are implemented.
5.3.3. Only employees competent in electrical or electronic servicing (time served
electrical engineers or apprentice electrical engineers if adequately supervised)
may attempt to repair electrical equipment on the company’s behalf. Unqualified
employees should keep clear of any electrical equipment considered to be
defective and notify their team leader immediately. Team leaders should isolate
defective equipment if the defect presents a hazard and inform the duty
maintenance engineer of the need for repair.
5.3.4. It must be noted that water is an effective conductor of electricity and as such
should not be used anywhere near electrical systems unless those systems have
been specifically designed to accommodate this. When cleaning electrical
equipment it must therefore be isolated from the electrical supply and care must
be taken to ensure water is not allowed to accidentally contaminate the electrical
circuitry of the device.
5.3.5. If an electrical device is accidentally made wet to a degree that health and safety
may be compromised, it should be isolated from the supply at the closest safe
point and allowed to dry thoroughly. The equipment must then be inspected, and
declared safe, by a competent electrical engineer before being reconnected to
the supply.
5.3.6. All new equipment must conform to the relevant electrical safety standard and the
engineering manager must be informed of its procurement so that routine safety
testing can be arranged.
5.3.7. Any computer equipment purchased must be suitable for testing in accordance
with the relevant IEC code of practise.
5.3.8. General Maintenance Requirements
5.3.9. Portable Appliances: Any electrical device conforming to the requirements of the
IET Code of Practise for In-service Inspection and Testing of Electrical Equipment
is to be subjected to portable appliance testing in accordance with procedure
HSP021: Portable Appliance Testing.
5.3.10. All electrical installations and fixed electrical equipment are to be inspected,
tested and maintained as necessary to ensure they remain in a safe condition.
5.3.11. Safe Working When Maintaining Electrical Systems
5.3.12. Wherever possible, mains electrical systems should be isolated from supply
and locked out before work begins.
5.3.13. Where an engineer is required to perform work on live systems at mains
potential, the Engineering Manager is to issue a permit to work in accordance with
procedure HSP016 (Permits to Work), ensuring all prerequisites of HSP016 are
met.
5.3.14. Regardless of the current isolation status of equipment, engineers are required
to ensure that their work does not adversely affect the health and safety of other
persons on site. To this end, repair sites should be maintained in a tidy condition

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with special consideration being given to trip hazards as a result of trailing cables.
Where necessary, access to equipment or work areas should be physically
prevented using portable barriers.

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6. HSP006: Fire
6.1. Responsibility
6.1.1. The Managing Director is the ‘responsible person’ as defined in Part 3 of the
Regulatory Reform (Fire Safety) Order 2005 and, as such is responsible for
ensuring that the risk of fire is minimised; that, in the event of a fire, everyone on
site has the best possible chance of safe evacuation and that, where the nature of
the premises makes it necessary to provide hand fire-fighting appliances, that
these are available, of a suitable type, are regularly maintained and are certified
as being in full working order.
6.1.2. All Directors have a responsibility to encourage a working culture that places the
Health and Safety of employees and members of the public at the forefront in all
undertakings on behalf of the company.
6.1.3. The Health & Safety Practitioner is responsible for ensuring a fire risk assessment
is conducted for all areas of the premises and suitable control measures are put
in place to reduce the risk of fire outbreak as far as is reasonably practicable and
to provide the best possible chance of complete, safe evacuation should a fire
break out within the premises.
6.1.4. The Engineering Manager is responsible for ensuring that all fire alarms are
maintained and are routinely tested. The Engineering manager is also responsible
for ensuring that hand appliances are routinely tested and are recharged as
quickly as possible after use.
6.1.5. Department heads are responsible for the appointment of fire marshals within their
department to ensure that all personnel in the area are safely evacuated in the
event of a fire. Department heads are also responsible for ensuring that all
personnel within their department are given sufficient training as to be able to
safely evacuate the premises in the event of a fire.
6.1.6. Fire Marshals are responsible for ensuring that members of their department
vacate the premises in the event of a fire and for conducting a roll call to confirm
this after evacuation has taken place.
6.1.7. All employees have a responsibility to make themselves aware of their
surroundings and to determine the most efficient routes for evacuation from their
point of work, bearing in mind that alternative routes may be needed in the event
of a fire. All employees have a responsibility to report any actual fire or any
circumstances that unnecessarily increase the risk of a fire on site. In the event of
an emergency evacuation, all employees have a responsibility to ensure that any
unattended visitors are safely evacuated from the premises.
6.2. Legislation
6.2.1. Section 2 of the Health and Safety at Work Etc. Act 1974 makes an employer
responsible for taking reasonably practicable measures to ensure the health and
safety of its employees.
6.2.2. Section 3 of The Health and Safety at Work Etc. Act 1974 makes an employer
responsible for taking reasonably practicable measures to ensure the health and
safety of non-employees that may be affected by the undertakings of the business;
this includes visitors, contractors and the general public.
6.2.3. The Regulatory Reform (Fire Safety) Order 2005 requires an employer to conduct
risk assessments specifically relating to fire and to enforce controls to minimise

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the risk of fire. The order also requires employers to maintain premises so as not
to cause unnecessary risk to emergency services and to provide and maintain
portable fire fighting appliances as may be required to assist with evacuation in
the event of fire and to ensure that those who may need to use them are competent
to do so.
6.3. Risk Assessment
6.3.1. Fire risk assessments are to be reported on form HS003, the structure of which
guides the assessment activity.

(a) (b) (c) (d) (e) (f) (g) (k) (l) (m) (n) (o)
(h)
(i)
(j)

Figure 5: Form HS003 - Fire Risk Assessments


6.3.2. The assessment should be conducted by a cross functional team consisting of at
least;
• An individual with experience of risk assessment, such as the H&S practitioner.
• The team leader managing the area under assessment.
• A technical specialist if the area routinely stores or utilises significant quantities
of any COSSH substance.
6.3.3. The assessment essentially follows the FMEA technique that is routinely used in
design and process improvement activities. The location of the identified hazard
is described in column (a) and the potential itself listed in column (b) (Note: the
assessment should consider only hazards that may result in fire, or may impede
an evacuation attempt should fire break out).
6.3.4. After the associated hazards are noted, the risks and effects related to each
hazard are described in column (c) and the people affected listed in column (d).
The list of people affected should be comprehensive as this will be used to
determine training needs for individual personnel and exclusion from this list may
prevent essential training from being correctly targeted.
6.3.5. If any legal requirements for control are relevant, these should be noted in column
(e) and any controls already introduced should be listed in column (f).
6.3.6. Once the details of the hazard and associated risk have been recorded, scores
should be assigned to each of, the severity (g) of the effects of the hazard, the
amount of time to which each individual is exposed (h) and the likelihood that an
accident will occur (i) as a result of exposure. These three values are then

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multiplied together to give a risk priority number (RPN) (j), this number allows
apparently disparate hazards to be compared to allow corrective responses to be
properly prioritised.
6.3.7. In an ideal world, any risk to health and safety could be mitigated but in the real
world, this is sometimes not feasible. For this reason, the Health and Safety at
Work Act Etc. 1974 includes the term ‘reasonably practicable’ in its definition of
the requirements for the provision of a safe working environment. Reasonable
practicability requires the company to compare the risk against the time, money
and effort required to mitigate it and take action on this basis. Assessment of the
need for further control is therefore inherently subjective but when making a
decision where reasonable practicability is not clear cut, the assessor should
involve the department head, line managers and employee H&S representative
from the affected area of operation as well as the original assessment team and a
consensus decision should be made.
6.3.8. Should further action be required to mitigate a risk, this should be noted in column
(k) and the details of responsibility and due date noted in columns (l) & (o). The
assessment should be reviewed with any person made responsible for additional
actions and a review date set to ensure all required actions have been completed.
6.3.9. Once a required action has been completed, this should be noted on the HS003
form, at which point the assessment can be updated to reflect the new controls
and re-scored accordingly.
6.4. Procedure in Case of Fire
(This procedure is augmented by Environmental Procedure EMP019)
6.4.1. Alarm & Evacuation
6.4.2. If evacuation occurs while the H&S practitioner is off site, the moulding shop team
leader will assume the duties of the H&S practitioner until his arrival.
6.4.3. While it may be possible to extinguish very small, well contained fires using hand
appliances, this should only be attempted if the individual is absolutely certain that
doing so will present no risk to themselves or others.
6.4.4. Any employee or other person on site who notices a fire and is not confident that
it can be easily extinguished should raise the alarm by means of a ‘break glass’
call point and by shouting “FIRE” repeatedly, which will summon aid and warn
others in the vicinity.
6.4.5. Once the alarm is sounded, all personnel should quickly but calmly evacuate the
building using the nearest safe exit and meet at the fire assembly point marked in
Figure 6 (The visitor’s car park in front of reception). When evacuating, individuals
should not stop to collect personal belongings and should not attempt to move
vehicles to safety. Designated fire marshals should ensure that their individual
section is properly evacuated. If a fire marshal is absent from their designated
area at the time of the alarm, they should not attempt to make their way back to

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assist with evacuation and should instead evacuate and head directly to the
assembly point.

Figure 6: Evacuation routes, ‘break glass’ points and portable appliance locations

6.4.6. Once evacuation appears to be complete, fire marshals should conduct a role call
for their designated section. The fire marshal for Unit 2 Offices should ensure all
visitors are accounted for.
6.4.7. After completion of the roll call, fire marshals should report to the health and safety
practitioner if all employees in their section (and visitors in the case of Unit 2
Offices) are present, and the names and last known locations of any people not
present. The H&S practitioner will keep a written record of this information to assist
the emergency services should a search be necessary.

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6.4.8. Once evacuation is under way and the presence of a fire has been confirmed, the
H&S practitioner will notify the emergency services.
6.4.9. Notification
6.4.10. After safe evacuation, the H&S practitioner will (if necessary) contact the
Managing Director, Site Managers and Environmental Manager (contact details
are listed in section 2 of the EMP019 Emergency Response Plan).
6.4.11. Arrival of Emergency Services
6.4.12. As soon as all personnel on site are properly accounted for, the H&S
Practitioner is to detail a reliable employee (who must speak fluent English) to wait
at the gate for the emergency services and direct them to the incident location
before notifying the H&S practitioner of their arrival. After proper notification of site
staff where required, the H&S Practitioner is to relieve this individual personally
and await the arrival of the emergency services at the main gate to the site (unless
the emergency services have already arrived) and, in any case, is to ensure that
a copy of document EMP019 is made available to them upon their arrival. The
H&S practitioner will remain with the Emergency Services to provide additional
information about the site until relieved by an attending Director, or until the
incident is resolved.
6.4.13. Re-entering Premises
6.4.14. No employee may re-enter any building on site following an incident involving
the fire service unless the site has been declared safe by the senior fire officer
attending.
6.5. Fire Fighting Appliances
6.5.1. Any portable fire fighting appliance installed at Fibrax must conform to the
requirements of BS-EN3 and should be clearly marked to indicate the medium
and the volume or mass of the contents.
6.5.2. Portable appliances should be fixed in a position with the handle no more than
1.1m above the floor (1.5m for CO2 extinguishers Ǫ 2Kg). The exact height
should be set to take account of traffic and ensure visibility, as well as ensuring
that removing the extinguisher from its fixings when needed is not unduly
awkward or difficult.
6.5.3. Any fixed reel fire hose installed at Fibrax must conform to the requirements of
BS-EN 671-1.
6.5.4. Any fire fighting appliances installed at Fibrax must also be clearly marked using
photo luminescent signs conforming to BS5499-5.
6.5.5. Appliances should be mounted so that one containing the correct media type is
within 30m of a potential hazard.
6.5.6. All fire fighting appliances on site must be tested and certified at intervals of no
more than twelve months by a competent person or company. The test certificates
are to be retained by the H&S practitioner and copies displayed on the H&S notice
board.
6.5.7. The H&S practitioner is to inspect availability, marking and positioning of fire
appliances on site each month and to keep a record of the results.
6.5.8. In the event of an extinguisher being discharged, the relevant manager is to inform
the Engineering Manager who will arrange for the appliance to be refilled or
replaced immediately.

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6.5.9. The H&S Practitioner is to maintain a diagram of all fire appliances and recognised
fire exits (Figure 6).
6.5.10. The H&S Practitioner is to maintain a substance inventory showing all
substances likely to cause a hazard in the event of fire. A copy of this inventory
is to be provided to the Environment Manager for inclusion in procedure EMP019.
6.6. Testing and Maintenance of Fire Alarm Systems
6.6.1. Fire alarm call points should be located as identified in the fire risk assessment.
6.6.2. The alarm system should be fully inspected and tested annually and the certificate
of test held by the Engineering Manager.
6.6.3. The system should be tested weekly by activation using a different alarm call point
each week by rotation. This test will normally be conducted at 1pm on a Friday
and the alarm should be sounded for no more than 5 seconds. If the alarm is
sounded at any other time, or for longer than 5 seconds it should be considered
a genuine incident and the factory should be evacuated.
6.6.4. If any test indicates a fault in the alarm system, the Engineering Manager is to
ensure that repair or replacement is carried out without delay.
6.6.5. Records of alarm testing will be maintained by the Engineering Manager for at
least 3 years. And will be checked by the Managing Director annually as part of
the H&S management review.
6.6.6. Training
6.6.7. All employees should receive training on fire procedures as part of the induction
process, including;
• How to raise the fire alarm
• Action to be taken on discovering a fire
• Evacuation procedure
• Location and use (or non-use) of fire fighting equipment
• Location and use of exits and escape routes
• The names and locations of employee H&S representatives
• The name of the H&S Practitioner
6.6.8. At least two employees in each major department (Moulding, Finishing/Despatch
and Unit 2 Production) should be trained in the correct use of all fire fighting
equipment deployed on site. Such training must be given by a competent training
provider.
6.6.9. The Unit 1 Production Manager is responsible for reviewing training records and
for ensuring that the above requirements are met.
6.6.10. Fibrax Employees arranging for non-employees to visit the site for any purpose
are to make their visitors aware of the nature of the alarm sounder, evacuation
procedure and the location of the fire muster point upon their first visit to the site
and to verify that they are aware of this information on subsequent visits.
6.7. Inspections and Audits
6.7.1. The health and safety practitioner is to make documented weekly checks to ensure
that fire escape routes are maintained, adequately signposted and remain clear of
obstructions. The health and safety practitioner will also make documented weekly
checks of fire doors to ensure that where approved locking systems are fitted,

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these are functioning correctly. The H&S practitioner will keep the records of these
checks for at least 3 years.
6.7.2. Departmental fire marshals will conduct daily checks of fire doors in their
nominated area to ensure that they remain unobstructed and are not locked (other
than with an approved slam bar or ‘Redlam’ type bolt system. Fire marshals are
to report any issues to the H&S Practitioner.
6.7.3. All employees have a duty under Section 7 of the Health and Safety at Work Act
1974 to inform their employer of any shortcoming in the arrangements for health
and safety and must therefore notify their line manager, fire marshal or health and
safety representative if they notice any obstruction to, or fault with a recognised
fire escape route.
6.7.4. The fire safety systems employed on site will be audited within the routine audit
programme for the health and safety management system as required in
paragraph 4.2.1.

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7. HSP007: Control Of Substances Hazardous to Health (COSHH)


7.1. Responsibility
7.1.1. The Managing Director is responsible for providing the resources necessary to
effectively control hazardous substances on site.
7.1.2. All Directors have a responsibility to encourage a working culture that places the
Health and Safety of employees and members of the public at the forefront in all
undertakings on behalf of the company.
7.1.3. The Health and Safety Practitioner is responsible for conducting risk assessments
on all substances used as part of the undertakings of the company and for
ensuring that those contacting a hazardous substance are aware of any hazards,
associated risks and controls required to mitigate those risks. The H&S
Practitioner is also responsible for managing test protocols intended to monitor
exposure against prescribed limits where this is shown to be necessary as a result
of risk assessment.
7.1.4. All employees are responsible for ensuring that any substance they bring on site
as part of the undertakings of the company is accompanied by a Material Safety
Data Sheet and for forwarding this sheet to the Health and Safety Practitioner.
7.1.5. Department Heads and Line Managers are responsible for ensuring that, where
mitigating controls have been established, these are enforced to ensure that, as
far as reasonable practicable, use of a substance does not adversely affect health
and safety.
7.2. Legislation
7.2.1. Section 2(ii) of the Health and Safety at Work Etc. Act (HASAWA) 1974 requires
the employer to provide, as far as is reasonably practicable, safe plant, equipment
and systems of work.
7.2.2. Regulation 3 of the Management of Health and Safety at Work Regulations
(MHSWR) 1999 requires the employer to conduct risk assessments that take into
account agents (substances) used by employees.
7.2.3. Regulation 6 of the Management of Health and Safety at Work Regulations
(MHSWR) 1999 requires the employer to provide health surveillance to employees
where the risk assessments identify potential risks to health.
7.2.4. Regulation 10 of the Management of Health and Safety at Work Regulations
(MHSWR) 1999 requires the employer to inform employees of any aspect of their
work that might provide a risk to health or safety.
7.2.5. Regulation 14 of the Management of Health and Safety at Work Regulations
(MHSWR) 1999 requires the employee to follow instructions given in order to
mitigate a risk to health or safety.
7.2.6. The Control Of Substances Hazardous To Health Regulations (COSHH) 2002
require the employer to remove hazardous substances from the work place or,
where this is not reasonably practicable, to work with affected employees to
conduct risk assessments specifically relating to the use of substances and
introduce appropriate measures to mitigate the risks from exposure to substances
so used; to consider exposure limits for substances so used and introduce such
measurement protocols as are necessary to ensure these are not exceeded; to
provide health surveillance where necessary; to ensure that employees are

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informed as to the hazards relating to each substance and to have emergency


procedures to deal with accidents involving hazardous substances.
7.3. Procedure
7.3.1. Risk Assessment
7.3.2. COSHH risk assessments are to be reported on form HS001, the structure of
which guides the assessment activity.

(a) (b) (c) (d) (e) (f) (g) (h) (l) (m) (n) (o) (p)
(i)
(j)
(k)

Figure 7: Form HS001 - COSHH Risk Assessments


7.3.3. The assessment should be conducted by a cross functional team consisting of at
least;
• An individual with experience of risk assessment, such as the H&S practitioner.
• An operator or other individual who routinely carries out the activity being
assessed.
7.3.4. The assessment essentially follows the FMEA technique that is routinely used in
design and process improvement activities. The activity or process is described
in column (a), the substances associated with the process stage are listed in
column (b)⇓ and the reference number for the MSDS associated with the
substance is listed in column (c). Note: only substances are considered as a
separate risk assessments will be conducted to assess activity based hazards.
7.3.5. After the associated substances are noted, the risks and effects related to each
hazard are described in column (d) and the people affected listed in column (e).
The list of people affected should be comprehensive as this will be used to
determine training (and if necessary, health surveillance) needs for individual


Note: The Asbestos Management Plan (see HSP016) is to be consulted at this stage and any ACM’s likely
to be affected by the process stage are to be included in the assessment.

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personnel and exclusion from this list may prevent these services from being
correctly targeted.
7.3.6. If any legal or other requirements for control (such as a policy commitment that is
outside or above legal minimums) are relevant, these should be noted in column
(f) and any controls already introduced should be listed in column (g).
7.3.7. Once the details of the hazard and associated risk have been recorded, scores
should be assigned to each of, the severity (h) of the effects of the substance, the
amount of time to which each individual is exposed (i) and the likelihood that the
potential effect will occur (j) as a result of exposure. These three values are then
multiplied together to give a risk priority number (RPN) (k), this number allows
apparently disparate hazards to be compared to allow corrective responses to be
properly prioritised.
7.3.8. In an ideal world, any risk to health and safety could be mitigated but in the real
world, this is sometimes not feasible. For this reason, the Health and Safety at
Work Act Etc. 1974 includes the term ‘reasonably practicable’ in its definition of
the requirements for the provision of a safe working environment. Reasonable
practicability requires the company to compare the risk against the time, money
and effort required to mitigate it and take action on this basis. Assessment of the
need for further control is therefore inherently subjective but when making a
decision where reasonable practicability is not clear cut, the assessor should
involve the department head, line managers and employee H&S representative
from the affected area of operation as well as the original assessment team and a
consensus decision should be made.
7.3.9. Should further action be required to mitigate a risk, this should be noted in column
(l) and the details of responsibility and due date noted in columns (m) & (n). The
assessment should be reviewed with any person made responsible for additional
actions and a review date set to ensure all required actions have been completed.
7.3.10. Once a required action has been completed, this should be noted on the
HS002 form (columns (o) & (p)), at which point the assessment can be updated to
reflect the new controls and re-scored accordingly.
7.3.11. Introduction of New Substances, Applications or Methods of Work
7.3.12. Any employee intending to introduce a substance to the site is to obtain a
Material Safety Data Sheet (MSDS) for that substance and forward a copy of this
to the Health and Safety Practitioner. The substance may not be employed until
approval has been given by the H&S Practitioner (Environmental Procedure
EMP029 places additional constraints and should be consulted before action is
taken).
7.3.13. The Health and Safety Practitioner will enter the substance into the COSHH
register and ensure an electronic copy of the MSDS is properly tagged and
entered into the MSDS library on the main file server.
7.3.14. Any employee wishing to introduce a new application for an existing substance
or change an existing working practise relating to use of a substance is to inform
the H&S Practitioner and request a re-assessment, which must be conducted
before the change is introduced.
7.3.15. The H&S Practitioner will review the MSDS for new substances (or for existing
substances where new applications or method of working are proposed) and
consult with the employees proposing the substance use to determine the details

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of application and proposed method of use before convening a team (comprising


the H&S Practitioner, employees required to work with the substance and
technical experts as necessary) to review the relevant COSHH risk assessment to
include the proposed substance and define any necessary control measures and
emergency procedures in accordance with paragraph 7.5. A date for review of the
risk assessment after introduction of the substance will be set.
7.3.16. The substance may not be introduced into use within the company unless the
measures defined at risk assessment are introduced.
7.3.17. As with any control measure relating to health and safety, Department Heads
and Line Managers are required to ensure that COSHH control measures are
followed.
7.3.18. After the substance has been introduced, the risk assessment will be reviewed
to ensure that hazards and associated risks were properly identified and control
requirements may be added or removed as appropriate.
7.3.19. Where emergency procedures are required, their effectiveness will be
assessed using practise drills as part of the routine audit & checking programme.
7.4. Monitoring Exposure Levels
7.4.1. Where a risk assessment indicates use of a substance may expose employees to
concentrations that exceed recommended or mandatory exposure levels, the H&S
practitioner will ensure that suitable objective monitoring is introduced and
maintained while the substance remains in use within the company.
7.4.2. Air quality monitoring should be conducted in accordance with HSE method
MDHS 47/2 for rubber fume and HSE method 14/3 for airborne dust. A Casella
precision pump and sampling head are provided for this purpose.
7.4.3. Where solvents are deployed in significant quantities, vapour level monitoring
should be conducted and a Gastech or similar detector will be provided should
risk assessment indicate that this is necessary.
7.4.4. Where monitoring indicates exposure in excess of recommended or mandatory
limits, the H&S practitioner will determine a suitable control regime in accordance
with paragraph 7.5

7.5. Developing, Implementing & Enforcing Controls and Emergency Procedures


7.5.1. Where an assessment shows an unacceptable risk to an employee, the H&S
practitioner will work with managers, employees and technical staff to develop a
control regime that adequately mitigates that risk. Controls should be given
priority in accordance with the hierarch shown in Figure 8 with elimination of the
hazard as the preferred option.

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Figure 8: The Hierarchy of Control


7.5.2. Once a control regime has been developed, it is to be tested to ensure
effectiveness and, if successful, reference to any required checks, safe working
methods or PPE are to be written into the safe working method for the operation
or, where this is impractical, a health and safety procedure may created and
referred to in the safe working method.
7.5.3. Where the risks associated with a hazard are continuous, or nearly continuous,
and specific to an area of the site, suitable signs are to be erected informing of
any special precautions required.
7.5.4. Where a the health and safety hazards presented by a substance require a
specific emergency response, a health and safety procedure must be written
detailing that response and all likely affectees made aware of the content and
implications of that procedure.
7.6. Provision of Information
7.6.1. The H&S Practitioner is to ensure that any person working with a hazardous
substance is made aware of the hazards, risks, controls and emergency
procedures relating to that substance. For new employees this information is to
be provided during initial induction.
7.6.2. Where new substances, applications or working methods are introduced, all
affected employees are to be informed, before the change occurs, of all related
hazards, risks and controls.
7.6.3. When employees are transferred to another role within the company, the
department head covering the new role is to inform the H&S practitioner of the
change and provide details of any substance contact required by the new role.
The H&S practitioner will ensure that induction training for the new role includes
details of hazards, risks controls and emergency procedures specific to those
substances to be used and is provided before the transfer occurs.

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7.6.4. If any employee develops signs or symptoms that they suspect may be attributable
to a substance used within the company, they should inform their H&S
representative or the H&S practitioner directly, the H&S practitioner must then
conduct a full investigation and, if necessary, introduce control measures.

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8. HSP008: Incidents and Accidents


8.1. Responsibility
8.1.1. The Managing Director is responsible for ensuring adequate resources are
provided to ensure incidents and accidents are properly responded to,
investigated and reported.
8.1.2. All Directors have a responsibility to encourage a working culture that places the
Health and Safety of employees and members of the public at the forefront in all
undertakings on behalf of the company.
8.1.3. All company directors and managers have a responsibility for fostering a culture
that welcomes the reporting of incidents and accidents by, as far as possible,
ensuring blame does not become a primary motivator in any accident or incident
investigation.
8.1.4. The health and safety practitioner is responsible for conducting impartial
investigations into all reported accidents and incidents, for reporting same to the
HSE where required, for ensuring controls are improved where necessary
following an accident or incident and for collating and analysing occurrences of
accidents and incidents to look for trends or incident clusters and for taking
measures to improve controls to counteract such trends or clusters should this
be considered necessary.
8.1.5. The health and safety practitioner is also responsible for ensuring that an
adequate inventory of first aid equipment and supplies is carried by the company.
8.1.6. Appointed first aiders are responsible for providing treatment within the bounds of
their competence and for ensuring, where further treatment is required, that
injured employees are provided with suitable medical attention by the most
appropriate route. First aiders are also responsible for ensuring that a suitable
record is made in the company accident book for any accident where they are
required to provide treatment and for assisting in the monitoring of accident
statistics to aid continuous improvement.
8.2. Legislation
8.2.1. The Management of Health and Safety at Work Regulations (MHSWR) 1999
require the employer to conduct and maintain risk assessments for all activities
carried out by employees. Investigations after accidents or ‘near miss’ incidents
are necessary to properly address any shortcoming in those risk assessments.
MHSWR also require the employer to make arrangements for the monitoring and
review of preventative and protective measures, a requirement that also implies
the need for investigation should those measures fail.
8.2.2. The Reporting of Incidents, Diseases and Dangerous Occurrences Regulations
(RIDDOR) 1995 require that certain incidents are reported to the Health and Safety
Executive (HSE) and that a thorough investigation is required to comply with these
requirements.
8.2.3. The Health and Safety (First Aid) Regulations (FAR) 1981 require the employer to
provide equipment and facilities that are adequate and appropriate in the
circumstances for administering first aid to employees.

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8.3. Definitions
8.3.1. Incident: An incident is any unplanned occurrence that caused, or had the
potential to cause, loss.
8.3.2. Accident: An accident is an unplanned event that results in personal injury or
damage to property, plant or equipment.
8.3.3. Near-Miss: A near-miss is an unplanned event that does not cause personal injury
or damage but had the potential to do so. Examples of near-miss incidents include
objects falling in areas frequented by personnel, electrical short circuits and
detection of failed guarding systems during routine test.
8.4. Accident Books
8.4.1. All accidents involving personal injury MUST be recorded in the company accident
book, which is stored in the Unit 1 Production Office.
8.4.2. Once a record of accident has been entered into the accident book, the record
should be removed from the book by the person completing it and delivered to
the Health and Safety Practitioner in person or posted into the locked post box
secured to the wall in the Unit One Production Office. The Unit One Production
Manager will monitor the post box and ensure that the H&S Practitioner is made
aware of any accident at the first opportunity. The H&S practitioner will then file
the report in the accident records file (stored in the H&S locker in the Unit 1
Learning Centre) in order to maintain the confidentiality required by the 1998 Data
Protection Act.
8.4.3. The health and safety practitioner will review recorded accidents at monthly and
yearly intervals using trend and epidemiological analysis methods to ascertain the
nature of accidents occurring and to identify common causal factors. This review
will be in addition to the individual investigation of incidents detailed in paragraph
8.9.
8.5. Reporting Procedure: Employees
8.5.1. All accidents resulting in personal injury must be reported in the accident book
either by the injured person or, if this is not practical, by the first aider who treated
the injured person. The injured person (or attending first aider as above) should
inform the injured person’s line manager of the accident detailing, as far as
possible, the circumstances leading to it and any subsequent treatment required
as a result.
8.5.2. The line manager will ensure the health and safety practitioner and the relevant
employee health and safety representative are made aware of the accident.
8.5.3. The health and safety practitioner will ensure the incident is investigated in
accordance with Paragraph 8.9.
8.6. Reporting Procedure: Visitors
8.6.1. Any non-employee who is involved in an accident or near-miss incident while on
site must report the incident to the person responsible for inviting them on-site. If
this person is not available, the visitor should report the incident to any responsible
person.
8.6.2. All injuries, however minor, must be reported in the accident book. Non-employees
who are unable to enter an account personally should arrange for a responsible
Fibrax employee to do so.

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8.6.3. The H&S practitioner must be informed immediately of any incident involving a
non-employee and will ensure the incident is investigated in accordance with
Paragraph 8.9.

8.7. Reporting Procedure: Damage to Property & Near-Miss Incidents


8.7.1. All near miss incidents and accidents where personal injury does not occur must
be reported to the H&S practitioner by the line manager with authority over the
area in which the accident occurred.
8.7.2. The health and safety practitioner will ensure the incident is investigated in
accordance with Paragraph 8.9.
8.8. Compliance with RIDDOR
8.8.1. In the case of incidents meeting the criteria for RIDDOR, the H&S practitioner is
to be informed at the first possible opportunity so that the accident may be
investigated and reported to the HSE’s Incident Contact Centre (ICC) at the first
available opportunity. RIDDOR reportable incidents are:
• Personal injury to employees
─ Death
─ Major Injuries: Fracture other than to fingers, thumbs and toes;
amputation; dislocation of shoulder, hip, knee or spine; loss of sight
(temporary or permanent); chemical or hot metal burn to the eye or any
penetrating injury to the eye; injury resulting from electric shock that leads
to unconsciousness, requires resuscitation or results in hospitalisation for
more than 24 hours; unconsciousness resulting from asphyxia or
exposure to a harmful substance or biological agent; acute illness
requiring medical treatment, or loss of consciousness arising from
absorption of any substance by inhalation, ingestion or through the skin;
acute illness requiring medical treatment where there is reason to believe
that this resulted from exposure to a biological agent or its toxins or
infected material.
─ 7 Day Injury: A personal injury that prevents an employee from carrying
out their normal duties for a period of MORE THAN 7 days, not including
the day of the incident but including any weekends or rest days occurring
within the period.
• Personal injury to any non-employee that results in hospitalisation.
• Reportable diseases as listed in schedule 3 of RIDDOR
(http://www.legislation.gov.uk/uksi/1995/3163/schedule/3/made).
• Reportable dangerous occurrences:
─ collapse, overturning or failure of load-bearing parts of lifts and lifting
equipment;
─ explosion, collapse or bursting of any closed vessel or associated pipe
work;
─ electrical short circuit or overload causing fire or explosion;
─ collapse or partial collapse of a scaffold over five metres high, or erected
near water where there could be a risk of drowning after a fall;
─ a road tanker carrying a dangerous substance overturns, suffers serious
damage, catches fire or the substance is released;
─ explosion or fire causing suspension of normal work for over 24 hours;

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─ sudden, uncontrolled release in a building of: 100 kg or more of flammable


liquid; 10 kg of flammable liquid above its boiling point; 10 kg or more of
flammable gas; or of 500 kg of these substances if the release is in the
open air;
─ accidental release of any substance which may damage health.
8.9. Investigation & Reporting
8.9.1. While all incidents should be taken seriously, the level of investigation must take
into account the level of severity of the incident, the probability of recurrence and
the feasibility of implementing effective preventative measures.
8.9.2. For each serious accident or near-miss incident, Form HS006 - Incident
Investigation Report (Figure 9) must be completed by the departmental supervisor
or by the first aider providing treatment. The completed form should then be
passed to the H&S practitioner who will assign a reference number and enter
summary details as well as data required for long term analysis into the Incident
Report Log and Summary (HS007).
8.9.3. Both specific incident reports and long-term analyses of data will be reviewed by
the H&S committee at each meeting and will determine if action is required either
to prevent recurrence of specific incidents or to improve H&S performance in
specific areas if required.
8.9.4. For major accidents (i.e. anything meeting the requirements for reporting to the
HSE under RIDDOR), the following procedure is to be followed.
• The Manufacturing Director will arrange a meeting as soon as possible after
the accident to be attended by the relevant production manager, the H&S
practitioner, the relevant employee safety representative and any persons
involved in the accident. If the accident involved equipment failure or misuse
of equipment, the Engineering Manager will also be present.
• The sequence of events leading up to the accident must be established. If
witness accounts show discrepancy, a log of each discrepancy should be
produced. Form HS006 should be completed at this time.
• The chain of events leading to the accident should be analysed and each
contributing act, failure and decision identified.
• While the ultimate aim of the investigation must be to determine the facts and
not to assign blame, any breaches of procedure should be noted at this stage;
such breaches should be investigated in more detail at a later date and this
further investigation will determine if action should be taken against any
employee found to have breached safe working procedures.
• Once contributing factors have been identified, the team should determine what
systemic improvements are required to prevent recurrence, and produce an
action plan to implement necessary improvements as well as ensuring that
temporary safeguards are provided if these improvements cannot be
implemented with immediate effect. The action plan should also make provision
for checking that implemented improvements are effective. The H&S practitioner
is to be responsible for ensuring the action plan is implemented and will report
progress to the Managing Director at key intervals defined within the action
plan.

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Figure 9: HS006 Incident Investigation Report (front only)

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8.10. First Aid Provision


8.10.1. The H&S Practitioner will; in conjunction with departmental & line managers,
employee safety representatives and appointed first aiders; conduct and maintain
a risk assessment specific to the provision of first aid. This risk assessment will
be reviewed on at least an annual basis, but also whenever necessary as a result
of a change to the undertakings of the company, to relevant legislation or when
an incident has shown the current assessment to be deficient. The H&S
practitioner will determine what first aid provision is appropriate to the
undertakings of the company based on this risk assessment.
8.10.2. Where a shortfall in first aid provision is made apparent, the Manager of the
affected department will nominate sufficient employees to undertake training as
required. The H&S practitioner will ensure that training is provided at the earliest
opportunity and only by an appropriately qualified training provider. The H&S
practitioner will ensure that a copy of each registered first aid qualification in held
in the individual’s personnel file for reference.
8.10.3. The H&S practitioner will ensure that registered first aiders can be readily
identified through notices at information points throughout the premises.
8.10.4. Where a shortfall in equipment or supplies is made apparent, the H&S
practitioner will arrange for these to be made available and install a re-order
mechanism if required, to ensure stocks are replenished as required in future.
8.11. Conduct of First Aiders
8.11.1. Only employees registered as First Aiders by the H&S practitioner are normally
to provide treatment of any sort on site. Registered first aiders whose
qualifications have lapsed are to notify the H&S practitioner immediately so that
refresher training can be arranged within the constraints set in paragraph 8.10.2.
Employees who are appropriately qualified but not registered may provide
treatment in an emergency but should speak directly to the H&S practitioner
immediately after to allow qualifications to be verified and arrange registration.
8.11.2. Appointed First Aiders are to provide treatment only within their own level of
competence and should not attempt to provide treatment outside the scope of
training provided on a HSE approved first aid at work course.
8.11.3. Where a first aider is required to provide treatment as a result of an accident
on site, the first aider is to ensure that a record is made in the company accident
book and should complete this entry themselves if the injured party is unable to
do so.
8.11.4. Whenever a first aider is required to give treatment, regardless of the cause,
the first aider must keep a personal record of the incident, including the date and
time, name of the person treated, signs and symptoms, details of the treatment
provided and of any other actions taken (such as disposal to hospital) details of
any recommendations made to the individual being treated (such as to consult
with a doctor). Line managers are to ensure first aiders are given time to maintain
this record as necessary.
8.11.5. When first aid supplies are used to give treatment, the first aider is to ensure
that H&S practitioner is made aware of the supplies used so that replacements
can be provided. This can be accomplished via line management if necessary.

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9. HSP009: Manual Handling


9.1. Responsibility
9.1.1. The Managing Director is responsible for ensuring that sufficient resources are
available to conduct the necessary risk assessments required by this procedure.
The Managing Director is also responsible for ensuring that resources are made
available to provide alternative methods of handling where it is considered
reasonably practicable.
9.1.2. All Directors have a responsibility to encourage a working culture that places the
Health and Safety of employees and members of the public at the forefront in all
undertakings on behalf of the company.
9.1.3. The Health and Safety Practitioner is responsible for ensuring that risk
assessments are conducted for all significant manual handling operations, for
ensuring that these assessments remain relevant and for recommending actions
as may be necessary to mitigate unacceptable risks resulting from manual
handling operations.
9.1.4. Line Managers have a responsibility to ensure that any manual handling task
assigned is within the capabilities of the employee.
9.1.5. All company employees have a responsibility to ensure that any manual handling
undertaken is conducted in accordance with HSE method guidance & is within
their capabilities, or to inform their line manager where they feel unable to
complete a required manual handling operation.
9.2. Legislation
9.2.1. Section 2 of The Health and Safety at Work Etc. Act (HASAWA) 1974 requires the
employer to provide, so far as is reasonably practicable, safe systems of work.
9.2.2. Section 3 of The Health and Safety at Work Etc. Act (HASAWA) 1974 requires the
employee to co-operate with the employer to ensure safe working methods are
practised.
9.2.3. The Management of Health and Safety at Work Regulations (MHSWR) 1999
require the employer to conduct risk assessments for all operations, to record
significant findings if more than 5 people are employed and to convey the findings
of those assessments to all employees affected by them.
9.2.4. The Manual Handling Operations Regulations (MHOR) 1992 require the employer
to avoid, as far as is reasonably practicable, the use of manual handling operations
that may place an employee at risk, to conduct risk assessments and, where risk
cannot be completely mitigated, take action to reduce such risk as far as possible
and ensure information is provided to employees regarding the load being lifted
in order to allow the employee to make a reasoned assessment as to whether the
task is within their capabilities.
9.2.5. The Manual Handling Operations Regulations (MHOR) 1992 require the employee
to comply with any system of work introduced by the employer to reduce the risk
of injury as a result of manual handling.

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9.3. Definitions
9.3.1. Manual Handling Operations means any transporting or supporting of a load
(including the lifting, putting down, pushing, pulling, carrying or moving thereof) by
hand or by bodily force. [Section 2:Manual Handling Operations Regulations 1992]
9.4. Risk Assessment
9.4.1. Prior to the introduction of a manual handling operation, a risk assessment must
be conducted & maintained, and suitable control measures implemented using the
method detailed in HSP001 (Page 21).
9.4.2. If the manual handling operation forms part of another operation, manual handling
risks may be addressed as part of the risk assessment for the parent operation
but must be specifically addressed within that risk assessment.
9.4.3. Manual handling specific risk assessments should be conducted by a cross
functional team consisting of at least;
• An individual with experience of risk assessment, such as the H&S practitioner.
• The operator or other individual who routinely carries out the activity being
assessed.
9.4.4. Where an operation is considered to be identical to an existing operation, or
almost identical except for a lower load weight, an existing assessment may be
used as a starting point but care must be taken to ensure that the new operation
does not introduce hazards or increase risk in a way not previously considered.
Similarly, care should be taken not to over control the new operation based on
the requirements of the existing base operation.
9.5. After Risk Assessment
9.5.1. The subjective nature of manual handling operations MUST be considered at all
times; it should not be assumed that the level of risk assigned to hazards will
remain constant for any individual completing the operation as capabilities will
vary from operator to operator. Feedback from operators must therefore be
encouraged, acted upon and the relevant risk assessment revisited to reflect the
new information.
9.5.2. When any manual handling risk has been identified, the responsible department
head will ensure that all affected employees are provided with full training
(including but not limited to, lifting & lowering, transporting and use of PPE) to
allow such operations to be conducted in such a way as to minimise the risk and
will maintain a formal record that such training has been provided and was
understood by the employee.
9.6. Alternative Working Methods
9.6.1. Where it is reasonably practicable, Fibrax will provide lifting equipment to reduce,
or remove the need for manual handling operations.
9.6.2. Where alternative working methods that offer reduced risk are available,
employees have a legal responsibility to make use of them so as to avoid
unnecessary risks to the health and safety of themselves or others.

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9.7. Use of Fork Lift Trucks (FLT)


9.7.1. The use of fork lift trucks is regulated by an additional procedure (HSP022).
9.7.2. All other lifting trucks (pallet trucks) are to be maintained by the Engineering
Department as required and inspected every 12 months by a qualified mechanical
engineer in accordance with LOLER 1998, records of these inspections are to be
maintained by the FLT co-ordinator. Pallet trucks are not, under any
circumstances, to be used for transporting people.

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10. HSP010: Noise Management


10.1. Responsibility
10.1.1. The Managing Director has a responsibility to ensure the health and safety of
all employees as far as is reasonable practicable, including the provision of a safe
working environment. Specific to noise, the Managing Director is responsible for
ensuring sufficient resources are available to adequately monitor noise levels
where relevant, develop methods to reduce noise levels where monitoring
indicates noise above the relevant action limit and to protect employees from
exposure in the interim.
10.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
10.1.3. The Health and Safety Practitioner is responsible for monitoring noise levels
within the site, reporting the findings to relevant stakeholders and monitoring
progress of noise reduction programmes where these are required.
10.1.4. All employees have a responsibility to make proper use of any prescribed PPE
intended to reduce exposure to noise. All employees have a responsibility to
report any abnormal occurrence that leads to a perceived increase in noise.
10.2. Legislation
10.2.1. The Health and Safety at Work Etc. Act 1974 (HASAWA) requires the employer
to provide, as far as is reasonably practicable, a safe working environment.
10.2.2. The Control of Noise at Work Regulations 2005 (CNAWR) require the employer
to prevent or reduce, as far as is reasonably practicable, the risks to health and
safety from exposure to noise at work and to ensure affected employees are
provided with all necessary information, instruction and training.
10.3. Definitions
10.3.1. Sound Level Meter (SLM): A device to measure the intensity of a sound
pressure wave (noise level). SLM’s may simply provide a real time output of noise
intensity though more advanced models are able record noise levels at a pre-set
sampling frequency over time (data logging).
10.3.2. Noise Dosimeter: A specialised type of data logging SLM that can be worn by
an individual to determine a personal exposure level.
10.3.3. Decibels (dB): Unit of sound pressure (noise intensity) equal to 1/10th of a Bel
(The Bel is the SI unit of measure for noise levels). Because the Bel scale is
logarithmic, an increase of just 3dB doubles the energy in the sound wave.
Decibel scales are often weighted to give consideration only those frequencies
detectable by humans, this is known as an ‘A’ weighting (dBA), or to give equal
priority to all frequencies, known as a ‘C’ weighting (dBC).
10.3.4. Exposure Action Values: are levels at which employers are required to take
action, they are:
• A daily, or weekly exposure of 80dBA or a peak sound pressure of 135dBC. At
this action value, the employer must make hearing protection available, provide
information to affected employees regarding the risk and take action, as far as
is reasonably practicable, to reduce noise levels.

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• A daily or weekly exposure of 85dBA or a peak sound pressure of 137dBC. At


this action value, the employer must enforce the use of hearing protection,
provide information to affected employees regarding the risk and take action,
as far as is reasonably practicable, to reduce noise levels.
10.4. Procedure
10.4.1. H&S Practitioner will assess the risk to health and safety to employees by
means of a two tier sound survey.
• Firstly, a simple check on sound levels will be undertaken using a calibrated
Sound Level Meter. If ambient noise levels are noted to be below 75dBA, this
should be recorded using form HS005 and filed in the noise management file,
stored in the H&S locker.
• If noise levels in excess of 75dBA are noted, a detailed noise level survey of
the area should be undertaken using a data logging SLM using the method
detailed in paragraph 10.5.
10.5. Detailed noise level survey
10.5.1. A scaled plan view of the area to be surveyed should be produced (Drawing
FXM189 gives a plan of the site from which this can be extracted) and all potential
sources of noise accurately identified on it.
10.5.2. Sufficient test points should be identified on the area plan to provide a
comprehensive representation of variations in noise level throughout the area.
10.5.3. Sampling periods should be determined by the nature of the variation in noise
level experienced in the area. Thus, an area where noisy machinery operates
continuously, noise levels at each test point may be measured for a sample period
of 1 hour and the mean⇓ taken to indicate the exposure level for an 8 hour period,
where noise is generated sporadically or inconsistently, sample periods may be
longer and repeat samples over several days may be needed to determine a
realistic exposure level.
10.5.4. Once the required number and duration of samples has been finalised, a
sampling plan should be produced and sampling conducted accordingly.
10.5.5. Once all required samples have been taken these should be reviewed for areas
above or close to an action limit and more refined sampling conducted if
necessary to more precisely determine noise levels around the suspect test point.


Mean sound levels cannot be calculated directly, due to the logarithmic nature of the data. See Para
10.4.2 below for the method required

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10.6. Calculating Mean Sound Levels⇓


10.6.1. Because sound is measured on a logarithmic scales, an increase of 10dB (1
Bell) actually indicates a tenfold increase in sound level. Because of this, sound
measurements must be converted to a linear scale before the mean is calculated.
Once calculated, the mean must be converted back to a logarithmic scale. To
achieve this:
• Enter the values to be averaged into the column of a spreadsheet (such as
Microsoft Excel as used in the example shown in Figure 10).
• In the next column, divide each value by 10 to convert from Decibels to Bels (in
Excel, the formula would be “=[Decibel Value]/10” ).
• In the next column, raise 10 by the power of the Bel value (in Excel, the formula
would be “=power(10,[Bel value])” )
• Calculate the average of the values just calculated (in Excel, “=average([First
Value]:[Last Value])” )
• Convert the Average back to a base 10 Log scale (in Excel, “=log([Average
Value],10)” )
• Multiply the Log scale average by 10 to convert from Bels back to Decibels.

Figure 10: Sample of Average Noise Level Calculation Using Microsoft Excel

10.7. Constructing Noise Maps


10.7.1. Noise maps can prove useful in explaining noise issues to employees. At its
simplest, a noise map simply requires the average noise levels found during the
survey to be noted on the plan of the area surveyed at the point of measurement
to indicate the variation in noise levels throughout the area (Figure 12).
Alternatively, the ‘contour map’ produced by the Minitab software package can
used to provide a graphical representation, which highlights variation in noise level
very well (Figure 12). Whenever a detailed survey of noise levels is necessary, a
suitable noise map should be prepared to assist in the provision of information to
employees as required by CNAWR 2005.


This method may only be used if the sample measurements are of equal time duration (such as when
recorded using a data logging SLM)

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Figure 12: Example of a Simple Noise Map

Figure 12: Example of a Noise Map Utilising Output from Minitab


10.8. Determining Personal Expose Levels
10.8.1. The exposure action values listed in NAWR 2005 refer to personal exposure
over an 8 hour period rather than noise levels at a specific location, thus time
spent in different environments must be considered when assessing whether
mitigating action is required. To determine personal noise levels for employees
working in a variety of environments, the ‘Daily Exposure Calculator’ downloadable
from the HSE website should be used (a copy of this is also stored in the health
and safety folder on the company file server).
10.9. Reaching Action Levels
10.9.1. Upon recording a personal exposure at or above either action level, the H&S
practitioner will assemble a team to determine the source(s) of noise responsible
and propose methods to reduce that noise (any reduction is desirable, even if the
lower action level cannot be achieved). The team should try to reduce the loudest
sources first even if they occur intermittently as the logarithmic measurement scale

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means that these can have a significant effect on average levels. Where noise
levels cannot be reduced below the lower action level, action must be taken to
educate and inform all affected employees regarding the hazard & associated risk
and adequate hearing protection must be made available to them. Where noise
levels cannot be reduced below the upper action level, action must be taken to
educate and inform affected employees and the wearing of adequate hearing
protection must be enforced. In such cases, the immediate line manager will
ensure that affected employees make proper use of supplied hearing protection.
10.10. Effects of Frequency
10.10.1. Whilst the effects of noise level must be considered, the H&S practitioner must
also consider the effects of specific frequencies. Employees must be made aware
that, even at acceptable levels of overall noise, specific frequencies can cause
detrimental health effects and should report any unusual symptoms (such as
recurring or persistent headaches) to the H&S practitioner. Where specific sound
frequencies are thought to be responsible for detrimental health effects, the H&S
practitioner will ensure adequate blanket hearing protection is provided to affected
employees in the short term, arrange for suspect noise spectra to be analysed
and will then act as in paragraph 10.9 to reduce noise levels or, if necessary,
provide application specific PPE.

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11. HSP011: Assisted Lifting Operations.


11.1. Responsibility
11.1.1. The Managing Director has a responsibility to provide sufficient resources to
ensure lifting equipment is maintained to an adequate standard, to ensure that all
employees required to engage in lifting operations are competent to do so and
that the general culture of the company is such that lifting operations are engaged
in only in accordance with the requirements of this procedure and applicable
legislation.
11.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
11.1.3. The Health and Safety Practitioner has a responsibility to ensure that provision
is made for the testing and inspection of lifting equipment in accordance with UK
legislation, for conducting risk assessments into lifting operations and for ensuring
that suitable training is provided for all employees likely to be engaged in lifting
operations.
11.1.4. All Department Heads and Directors have a responsibility to inform the H&S
practitioner of any planned extra-ordinary activities that will require lifting
operations. Department Heads are also responsible for assessing the work
undertaken by members of their department and ensuring that suitable training in
lifting operations is provided where applicable.
11.1.5. All employees have a responsibility to treat lifting operations with due respect,
whether conducting such an operation or simply working near to where a lifting
operation is being conducted. All employees have a responsibility to report any
equipment used for lifting thought to be defective, whether used by them or not.
All employees have a responsibility to report lifting equipment not stowed at its
proper location when not being used in a lifting operation.
11.2. Legislation
11.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks.
11.2.2. The Lifting Operations and Lifting Equipment Regulations (LOLER) 1998 lays
down specific legal requirements for the provision & maintenance of lifting
equipment and for the conduct of lifting operations.
11.2.3. The Provision and Use of Work Equipment Regulations (PUWER) 1998 requires
that persons required to use work equipment receive adequate training and places
specific requirements on the provision of equipment used for lifting people.
11.3. Definitions
11.3.1. Breaking Strength: Is a theoretical maximum load for a material or piece of
equipment when tested under laboratory conditions.
11.3.2. Safe Working Load (SWL): Is a maximum load rating for a piece of equipment
intended to take account of variations in the manufacturing process, variations in
the method of use and variations in the environmental conditions in which the
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‘breaking strength’ but should NOT be exceeded. SWL does not take into account
extremes of environment, fatigue due to use or the effect of damage and wear.
11.3.3. Working Load Limit (WLL): Is a maximum load rating that is replacing ‘Safe
Working Load’ on newer equipment. WLL defines the maximum safe load the
equipment can carry under ideal conditions and may need to be modified by the
competent person undertaking the lifting operation to account for temperature,
side loading by cross winds etc.
11.3.4. Mobile Elevated Work Platform (MEWP): A device intended to elevate people
for the purpose of working at height.
11.4. Procedure
11.5. Equipment:
11.5.1. Any equipment intended for use in lifting operations is to be recorded in Form
HS008:Lifting Equipment Register (Figure 13), which will also record any
requirement for use in lifting people, the date of last inspection, inspection interval,
scheduled date for re-inspection and the SWL for the item. All registered
equipment will be checked in accordance with the following schedule:
• All items of lifting equipment such as hoists, A-frames, Cranes and Fork Lift

Figure 13: Form HS008 - Lifting Equipment Register


Trucks are to be thoroughly inspected and certified by a qualified, competent
person on an annual (12 monthly) basis. The date and result of the last
inspection is to be recorded in the Lifting Equipment Register. Any equipment
failing such an inspection is to be removed from service immediately and clearly
marked as such until remedial work has been completed and successful re-
inspection completed.
• All ancillary lifting equipment such as shackles, hooks, slings and eyebolts are
to be inspected by a qualified, competent person on a bi-annual (6 monthly
basis). The date and result of the last inspection is to be recorded in the Lifting
Equipment Register. Any equipment failing such an inspection is to be removed
from service immediately and clearly marked as such until remedial work has
been completed and successful re-inspection completed.
• Any equipment intended to be used at any time for lifting people is to be
inspected by a qualified, competent person on a bi-annual (6 monthly basis).
Where this involves an attachment for a fork lift truck, both the truck and the
attachment are to be inspected as equipment used for lifting people. The date
and result of the last inspection is to be recorded in the Lifting Equipment
Register. Any equipment failing such an inspection is to be removed from
service immediately and clearly marked as such until remedial work has been
completed and successful re-inspection completed.

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• Equipment purchased new must be CE marked and may be considered safe


for an interval equal to its designated inspection interval (i.e. initial inspection
is not required).
• Equipment purchased in used condition must either be supplied with a
certificate of inspection or be inspected before use.
11.5.2. Where risk assessment shows any item of equipment is likely to be subject to
higher than normal rates of wear or particularly susceptible to damage,
procedures may be created to require visual checks before use and/or inspection
intervals may be shortened from those listed above (in which case reasons for the
reduction must be noted in the Lifting Equipment Register).
11.5.3. Regardless of the required inspection period, damaged equipment is to be
removed from service immediately and clearly marked as such until remedial work
has been completed and successful re-inspection completed.
11.5.4. All lifting equipment must be marked with a unique serial number assigned
from, or recorded in, the Lifting Equipment Register, allowing reference back to
the register, controlled copies of which are to be provided to key personnel so
that equipment details may be quickly and accurately determined. Where space
permits this may be stamped, engraved or marked directly onto the equipment
using paint or indelible ink. On no account should punches or engraving tools be
used on any load bearing part of lifting equipment unless provision for this has
specifically been made by the equipment manufacturer.
11.6. Use of Fork Lift Trucks (FLT)
11.6.1. The use of fork lift trucks is regulated by an additional procedure (HSP022).
11.6.2. All other lifting trucks (pallet trucks) are to be maintained by the Engineering
Department as required and inspected every 12 months by a qualified mechanical
engineer in accordance with LOLER 1998. Records of these inspections are to
be maintained by the Unit 1 Despatch Supervisor. Pallet trucks are not, under
any circumstances, to be used for transporting people.
11.7. Routine Lifting Operations
11.7.1. The H&S Practitioner shall ensure that for all routine lifting operations, risk
assessments are conducted and suitable control measures implemented using the
method detailed in HSP001 (Page 21). The cross functional team conducting the
assessment must include a person, other than the operator, who is competent in
the kind of lifting operation being assessed. Where the lifting operation forms part
of another operation, lifting risks may be assessed as part of the risk assessment
for the parent operation but must be specifically addressed within that
assessment.

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11.8. Non-Routine Lifting Operations


11.8.1. Where a lifting operation is required that involves techniques, loads or lifting
equipment not routinely used on site, a competent individual must be appointed
to plan the lift and ensure the lift is executed in accordance with that plan. Before
execution, the plan must be reviewed and approved by the H&S practitioner and
the Engineering Manager, who will issue a permit to work specific to the lifting
operation in accordance with HSP017. As a minimum a plan for non-routine lifting
operations must include;
• A risk assessment specific to the lift.
• The type of equipment to be used and competence of those employed to
operate it.
• Positioning and installation of lifting equipment
• Consideration of ground condition and provision of a stable surface.
• Provision for pre use checks of equipment and test lift.
• Consideration of the method of load attachment.
• Amendments to site traffic routes to divert all traffic (vehicle and pedestrian)
away from the lift area.
• Assessment of, and provision for, obstructions including overhead cables and
buildings.
• Assessment of, and provision for, restricted sight lines.
• Arrangements for the appointment and briefing of the team executing the lift.
• Provision of a detailed timetable for the lift.
• Arrangements for notification to department heads as to the commencement
and conclusion of lifting operations.
11.8.2. Once a plan has been devised and approved, all affected department heads
will be briefed by the competent person so that they may make contingency plans
to minimise disruption to the operation of their department and ensure that all
employees not involved with the lifting operation do not enter restricted areas until
notified that the operation has been completed and the area made safe.
11.9. Lifting of People
11.9.1. Only equipment specifically designed for the safe lifting of people is to be used
for this purpose. Unless hired or otherwise procured, this limits the lifting of
people on site to use of the basket attachment for the fork lift truck, which must
be clearly marked as being designed for use in lifting people.
11.9.2. The lifting basket must be properly secured to the truck and prior to use the
latching mechanism on the gate should be tested. At all times, the marked
maximum load limits are to be complied with and, over and above the marked load
limits, no more than two people may be lifted in the basket at one time; if space is
limited by equipment needed to complete the work at height, this limit may be
reduced to a single individual. The lifting basket should be kept clear of
extraneous equipment to reduce the risk of slips and trips within the basket.
11.9.3. Lift trucks must only be operated by competent personnel with an appropriate
fork lift license when lifting people, in this context, ‘operating’ includes raising and
lowering of the basket as well as manoeuvring of the truck.
11.9.4. Other than minor positioning to improve access to the job, lift trucks must
remain in position on the floor when the basket is occupied. The lift basket must
never be used to transport personnel around the site.

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11.9.5. When planning an operation to lift people, the manager in charge of the
operation must conduct a risk assessment to determine if any additional controls
are required. This assessment should consider at least the following factors;
• Communication: Can the employee in the basket communicate effectively with
the driver taking into account ambient noise levels, interruptions to site lines
etc?
• Substances: Are there any hazardous substances such as asbestos in the lift
area that may be at risk of damage from the basket?
• Electrical Systems: Is there any risk of the basket damaging live electrical
circuits?
• Clearance: Are there any crush hazards or other physical obstructions that
might place the employee at risk when manoeuvring the basket at height?
• Falls: Is there a risk of the employee falling from the basket, is the basket close
enough to the job to remove the need to over reach?
• Falling objects: Is there any risk to personnel or equipment on the ground from
objects falling from the work site?
11.10. Ifadditional risks are considered significant in any lifting operation, the system of work
must be amended to include controls to mitigate those risks as far as is reasonably
practicable and all relevant personnel must be informed as to the nature of those risks.

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12. HSP012: Display Screen Equipment & Workstation Management


12.1. Responsibility
12.1.1. The Managing Director is responsible for providing sufficient resources to
ensure that risks to users of display screen equipment are properly identified and
actions taken to mitigate those risks as far as is reasonably practicable.
12.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
12.1.3. The Health and Safety Practitioner is responsible for determining which
employees are affected by the regulations (users), for ensuring that sufficient
workstation assessors are appointed and properly trained and that users are
aware of the risks presented by DSE and work stations and of the actions they
should take to minimise those risks.
12.1.4. Department heads are responsible for ensuring that all users are provided with
the equipment necessary to comply with relevant legislation and for ensuring that
the Health and Safety Practitioner is made aware of any change in circumstance
that might give cause for assessment or reassessment.
12.1.5. All line managers are responsible for ensuring that any issues raised by users
relating to the use of DSE are forwarded to Department Heads and ultimately to
the Health and Safety Practitioner.
12.1.6. Each user is responsible for ensuring they follow advice and instruction given
in relation to the use of DSE and workstations. Users are responsible for ensuring
that their line manager is made aware of any issues experienced in the use of, or
as a result of using DSE or workstations. Users are also responsible for managing
personal eye care.
12.2. Legislation
12.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks.
12.2.2. The Health And Safety (Display Screen Equipment) Regulations 1992
(Amended 2002) require each workstation employing display screen equipment
to be assessed for risk and for action to be taken to mitigate those risks as far as
is reasonably practicable. The regulations also require the employer to provide
information on risk inherent to DSE workstations to users and provide relevant
health screening where an assessment shows it to be warranted.
12.3. Definitions
12.3.1. Display Screen Equipment (DSE) is “any alphanumeric or graphic display
screen, regardless of the display process involved” with the following exception;
• Drivers’ cabs or control cabs for vehicles or machinery
• Display screen equipment on board a means of transport
• Display screen equipment mainly intended for public operation
• Portable systems not in prolonged use
• Calculators, cash registers or any equipment having a small data or
measurement display required for direct use of the equipment

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• Window typewriters.
Thus the regulations apply to both CRT and flat panel display types but do not
apply to (e.g.) control displays on moulding presses.
12.3.2. A Workstation is a combination of a DSE as defined above, a keyboard, mouse
(and any other input device), desk, chair and the immediate work area.
12.3.3. A User is an employee (or self employed individual using a client’s workstation)
who:
• Normally uses DSE for continuous or near-continuous spells of an hour or more
at a time.
• Uses DSE in this way more or less daily
• Has to transfer information quickly to or from the DSE
• Has to apply high levels of attention & concentration, are highly dependent on
DSE, have little choice about using DSE in their job or need special training &
skills to use the DSE.
12.3.4. A DSE Assessor is an individual who has received special training to be able
to perform risk assessments specific to DSE and associated workstations. A DSE
Assessor is also able to request action from a Line Manager of Department Head
if unacceptable risks are identified.
12.4. Procedure
12.5. Determining DSE Users
12.5.1. The Health and Safety Practitioner will maintain a register of employees
considered to be DSE users for the purposes of the regulations (Incorporated into
the Master Employee Register within the Environmental Management System Form
EMF014) and will ensure that all users are provided with education on the risks
and safe practises associated with DSE.
12.5.2. Department Heads are to ensure that the H&S practitioner is informed of the
appointment of potential new DSE users, including transfers and promotions within
the company that might result in an employee becoming a DSE user.
12.6. Training Users and Assessors
12.6.1. The Health and Safety Practitioner will ensure that all DSE users are provided
with education covering (at minimum) the following areas:
• The risks from DSE work
• The Importance of good posture and changing position
• How to adjust furniture to help avoid risks
• Organising the workplace to avoid awkward or repeated stretching movements
• Avoiding glare and reflection on or around the screen
• Adjusting and cleaning the screen and mouse
• Organising work to allow for activity changes or breaks
• Who to contact for help and how to report problems or symptoms
• Contributing to risk assessment
12.6.2. The Health and Safety Practitioner will appoint DSE Assessors and ensure that
they are trained to work with DSE users to identify workstation layouts & equipment
that may give rise to avoidable risk, to provide useful advice on minimising risk
and to make recommendations to Line Managers or Department Heads as

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necessary to ensure action is taken to mitigate risk as far as is reasonably


practicable.
12.7. Conducting Workstation Assessments
12.7.1. The Health and Safety Practitioner will ensure all workstations are assessed at
a minimum 12 monthly interval. This assessment will consider the suitability of the
workstation to the work conducted at it. In addition, the company 5S assessment
will be used to ensure that the organisation of each workstation is monitored and
where changes are noted, the Health & Safety Practitioner will arrange an
additional assessment to determine the reasons for, and suitability of, any changes
made.
12.7.2. Workstation assessment will follow 3 key stages;
• Initial User Questionnaire
The HSE DSE Workstation Checklist (contained in booklet HSG90) is to be
completed by the regular user of the workstation to be assessed and returned
to the assessor. The questionnaire is intended to obtain the user’s subjective
view of the workstation and the assessor should not, therefore, provide direct
input into the responses given: the assessor (or the H&S practitioner) should,
however, provide support to the user should they require assistance while
completing the questionnaire.
• Initial Interview and Workstation Assessment
After the user has completed the assessment questionnaire, the assessor will
visit the user at the workstation to review the questionnaire and to provide a
second opinion on the layout and condition of the work station and of the
environment in which it is situated. The assessor will discuss with the user any
issues noted by either and determine what potential courses of remedial action
are available and the user’s preference in each case.
• Reporting
Following the initial interview, the Assessor will produce a brief report detailing
the issues noted and the potential courses of remedial action with
recommendations. This report must be reviewed and approved by the
workstation user and then passed to the manager responsible for the user’s
department.
• Action Planning and Implementation
Once the report has been received and reviewed, the department manager will
assess the practicability of the proposed solutions and convene a meeting with
the assessor and user to plan the actions to be taken and the timescale for
completion. The manager may delegate an individual (this may be the user
themselves) to ensure the action plan is completed.
• Completion Review
Once all recommended actions have been completed, the manager responsible
(or their delegate) may call a final review to discuss any issues. Reviewing in
this way will allow feedback to improve the system and ensure mistakes are
less likely to be repeated.
• Follow Up

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The assessor will re-visit the user 1-2 months after all improvement actions have
been completed and conduct a follow up assessment. If issues are still
unresolved⇓ then the process should be repeated.
• Record Retention
Copies of DSE workstation reviews should be passed to the H&S practitioner
and retained on file.
While personal injury claims must be made within three years, this limit is set
from the date of ‘knowledge of the injury’. As upper limb disorders can take
considerable time to manifest symptoms, DSE assessments must be retained
for at least 40 years after the individual has left the company.


An issue that requires remedial action beyond what is considered reasonably practicable may be
considered resolved but should still be raised at any subsequent assessments in case alternative options
have become available in the interim.

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13. HSP013: Accommodation for Young Persons & Children


13.1. Responsibility
13.1.1. The Managing Director is responsible for ensuring that sufficient resources are
made available to ensure that young people can be employed in appropriate
positions without undue risk to their health & safety and that children may
undertake short term placements without undue risk to their health & safety.
13.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
13.1.3. The Health and Safety Practitioner is responsible for ensuring that, where
young persons are to be employed or provided with work experience placements
by the company, risk assessments are carried out (in cooperation with the
employee assigned as mentor) on all relevant aspects of their relationship with the
company including work activities, COSHH, manual handling requirements and
DSE usage. The H&S Practitioner is also responsible for ensuring that the young
person and the mentor assigned to them are aware of the contents of all relevant
risk assessments and the controls required to mitigate identified risks.
13.1.4. Where children are to undertake placements within the company, the H&S
practitioner is responsible for ensuring that risk assessments are carried out (in
cooperation with the employee assigned as mentor) on all relevant aspects of their
relationship with the company including work activities, COSHH, manual handling
requirements and DSE usage. The H&S Practitioner is also responsible for
ensuring that the young person, the mentor assigned to them and the parent or
legal guardian of the child are provided with, and made aware of the contents
of, all relevant risk assessments and the controls required to mitigate identified
risks
13.1.5. Department heads are responsible for ensuring that the H&S Practitioner is
made aware when any young person or child is to be employed within their
department, whether on a permanent or temporary basis (including limited
placements).
13.1.6. Department heads are responsible for ensuring every young person employed
by or child assigned a placement with the company is assigned a mentor to deliver
training as well as provide advice and guidance on all aspects of the young
person’s activities within the company. Department heads therefore also have a
responsibility to ensure that mentors assigned to young people are provided with
adequate resources (including time) to effectively plan, deliver and review this
training.
13.1.7. Department heads have a responsibility to assist with the training & education
of young people employed in other departments where a member of their own
department is considered best suited to deliver it.
13.1.8. Appointed mentors have a responsibility to assist with the assessment of risks
relating to the activities of their charge. Mentors are also responsible for ensuring
that young persons or children in their charge are made aware of and fully
understand the risks and mitigating controls for each activity they undertake and
to ensure that they are adequately supervised at all times while in the care of the

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company. Mentors are also responsible for the planning, delivery and review of
training & education provided to young persons in their charge.
13.1.9. All employees have a responsibility to ensure that young persons employed by
the company and children on placement are not allowed to act in a way that places
themselves or others at risk and to either report such actions or to intervene
directly if it is felt that the time taken to report would be such as to allow an
accident to occur.
13.2. Legislation
13.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks.
13.2.2. Regulation 10 of The Management of Health and Safety at Work Regulations
(MHSWR) 1999 specifically requires the company to provide the parent or legal
guardian of a child with information relating to the risks related to the activities the
child will undertake and the controls introduced to mitigate those risks. The
regulation requires that this information be intelligible to the parent or guardian
concerned.
13.2.3. Regulation 19 of The Management of Health and Safety at Work Regulations
(MHSWR) 1999 deals specifically with the protection of young persons.
13.3. Definitions
13.3.1. A YOUNG PERSON is any person employed by, or on placement with, the
company who is under 18 years of age.
13.3.2. A CHILD is any person employed by, or on placement with, the company who
is below school leaving age.
13.3.3. A MENTOR is an employee (who is not a young person themselves) who is
considered to have sufficient knowledge, experience, skill & ability to instruct a
child or young person in the aspects of the role they are to undertake within the
company. A mentor must also be proven to be responsible, level headed and
capable of setting a flawless example to the young person in their charge at all
times.
13.3.4. For the purposes of this procedure, the term ‘EMPLOYED’ is taken to include
young people working on site as part of a school placement, internship or other
scheme aimed at providing experience in the workplace, regardless of whether
the young person receives payment from the company. It must be noted, however,
that young people below school leaving age are not to be engaged in routine paid
work for the company.

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13.4. Procedure
Risk Assessment
13.4.1. Once it has been established that a young person is to be employed by the
company, the manager responsible is to determine the duties the young person is
to undertake and the training to be given before appointing a suitable Mentor and
notifying the Health and Safety Practitioner of the appointment.
13.4.2. On confirmation of the appointment of a young person to the workforce, the
H&S Practitioner will work with the appointed Mentor to conduct a complete set of
risk assessments relating to the role the young person is to undertake. In addition
to the aspects normally considered as part of a risk assessment programme, the
following key points must be considered:
• Any work given must not be beyond the physical or psychological capability of
the individual.
• The work must not involve harmful agents that; are toxic, are carcinogenic,
cause heritable genetic damage, cause harm to the unborn child or in any other
way chronically affect human health.
• The work must not involve harmful exposure to radiation
• The work must not involve the risk of accidents which it may be reasonably
assumed cannot be recognised or avoided by young persons owing to their
insufficient attention to safety, lack of experience, or lack of training.
• The work must not involve risk to health from; extreme cold, extreme heat, noise
or vibration.
13.4.3. Where the role of a young person who is not a child will involve exposure to
any hazard listed in 13.4.2 as part of necessary training, the risk assessment must
include the controls to minimise the risk to the lowest level that is reasonably
practicable and must include a requirement that the young person is supervised
by a competent person at all times while engaged in such an activity.
13.4.4. Children must not be exposed to any of the hazards listed in 13.4.2. If
necessary, the role or training plan must be revised to remove the possibility of
such exposure.
13.4.5. Having completed the relevant risk assessments, the H&S Practitioner is to
review them with the assigned Mentor and the manager responsible for the young
person within the company.
13.4.6. If the young person concerned is a child, the responsible manager is to arrange
to meet with a parent or legal guardian and, in the case of school placements, the
organising teacher to review and explain the contents of the risk assessment so
that those responsible for the welfare of the child can make an informed decision
about whether to proceed with the placement.
13.4.7. Whether a child or not, the young person must be shown the contents of the
risk assessment at induction and have the contents and their implications
explained clearly.
13.4.8. Once a risk assessment has been finalised and agreed, the controls stipulated
within must be introduced into the training and education programme for the
individual concerned.

Induction

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13.4.9. All young people employed on site must receive a formal induction.
13.4.10.While care must be taken not to patronise young people the induction process
must be tailored to allow for:
• reduced attention span
• the possibility of misunderstanding apparently common expressions
• Increased nervousness
13.4.11. The Mentor appointed to the young person must be present throughout the
induction process to explain and guide the inductee. The Mentor should not give
the induction themselves.
13.4.12. The induction process must be carried out on the morning of the first day with
the company and must cover the following at minimum:
• A review of the risk assessments relevant to the role. The contents and
implications of these should be carefully explained to the inductee.
• Explanation of the provision of welfare facilities. The inductee should be shown
the locations of lavatory, washing and canteen facilities. Facilities for making
drinks and entitlement to breaks should be explained.
• A tour of the site, taking time to highlight hazards, areas with special
restrictions, traffic control systems and other information relevant to the health
and safety of the inductee. Care should be taken to ensure the inductee is
made aware of major hazards within the site, even if these do not relate
specifically to the planned role of the inductee, so that the inductee is less likely
to venture into a hazardous area out of curiosity⇓.
• A thorough explanation of the actions to be taken in the event of an accident
and an introduction to first aid provision on site. The inductee should know
how to act upon discovering an accident, what will happen if they are involved
in an accident and where to find help wherever they are on the site.

Training & Education


13.4.13. Delivery of training and education of a young person on site is the responsibility
of the assigned mentor. The mentor should produce a documented training plan
to ensure that their charge is provided with adequate training for every task they
are asked to undertake; this must include a brief on the health and safety risks
involved for each tasks and the relevant mitigating controls.
13.4.14. A training record should be maintained for each young person employed on
site describing the specific sessions of on the job training and background
education provided. These records should confirm that all relevant health and
safety information relevant to the session was provided and the Mentor & trainee
should both sign the record to confirm this.
Hours of Work


The amount of information provided on hazards not relating to the role of the inductee is a matter of
balance. It is necessary to inform so that accidents do not happen through ignorance but managers &
mentors should also allow for the natural curiosity exhibited by young people and be aware that knowing an
area poses risk will often act as a draw rather than a deterrent. The best way to prevent accidents in these
cases is to provide the information and then ensure adequate supervision of the young person.

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13.4.15. Any young person who is over school-leaving age is not allowed to work more
than 8 hours each day and not more than 40 hours each week. In addition, they
must have 12 hours rest between each working day and 2 rest days each week.
13.4.16. Young people may not be asked to work between the hours of 10pm and 7am
Supervision
13.4.17. The mentor should be aware that young people exhibit certain traits that can
place them at greater risk than older employees. Amongst these are:
• Lack of experience, both of the job and of life.
• Over-enthusiasm, which may lead to a young person attempting a task without
due consideration of the risks.
• Curiosity. Young people will often attempt things just to see if they can, even if
logic suggests the activity to be hazardous.
• Under developed sense of mortality. Young people often cannot conceive that
an accident can happen to them.
• Peer pressure. Young people will sometimes engage in an activity they
consider hazardous simply because their peers encourage them.
Because young people are significantly more likely to engage in activities that may
be hazardous, the mentor must ensure that young people in their charge are
properly supervised. As the mentor/trainee relationship develops, the mentor will
be able to judge the level of ‘over the shoulder’ supervision required at any
particular time but must initially ensure that the whereabouts and activities of
young people in their charge are closely monitored either personally or by other
employees in a formal arrangement within the company.
13.4.18. Initially, and as the role of the young employee develops, they will be required
to learn new skills. The mentor is to ensure that young people in their charge are
properly trained in any new activity and are closely supervised until an adequate
level of competence and an appreciation of the hazards, risks and mitigating
controls have been demonstrated. Any new skills should be documented within
the training records for the trainee and the mentor should sign to indicate that
competence has been achieved.
13.4.19. Where children are employed within the company, the mentor must ensure that
they are accompanied at all times unless the activity and environment might
reasonably be considered low risk⇓. Even when engaged in such a ‘safe’ activity,
the mentor must be aware of the child’s location and the time they have been away
to ensure that they have not digressed into an activity or area that might place
them at risk.
Adulthood
13.4.20. When a young person reaches the age of 18, they are considered in law to be
adults. This does not mean that they immediately become mature and self
contained (indeed, a young person joining the company late in their 17th year is
likely to still be unfamiliar with the site and its workings). The mentor should meet
with the department manager to discuss the transition from young person to adult
and determine at what rate the mentor’s role should be reduced. Once this has
been determined, the mentor & manager should discuss this transition with the


The term ‘low risk’ here is intended to refer to activities such as breaks in the canteen or visits to the
lavatory. No activity required as part of the employment role is to be considered low risk in this respect.

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young person to ensure that the young person is aware of the change and is ready
to continue without the support of a mentor.
13.4.21. Upon reaching the age of 18, the young person should be provided with a brief
re-induction to ensure they are aware of relevant company procedures and the
management hierarchy within which they are expected to work.

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14. HSP014: Accommodation for New & Expectant Mothers


14.1. Responsibility
14.1.1. The Managing Director is responsible for ensuring that sufficient resources are
made available to ensure that new & expectant mothers can be employed in
appropriate positions without undue risk to their health & safety.
14.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
14.1.3. The Health and Safety Practitioner is responsible for ensuring that appropriate
risk assessments are carried out on all relevant aspects of the relationship of new
or expectant mothers with the company including work activities, COSHH, manual
handling requirements and DSE usage. The H&S Practitioner is also responsible
for ensuring that the new or expectant mother participates in, and is made aware
of, the contents and implications of all relevant risk assessments and the controls
required to mitigate identified risks.
14.1.4. Department heads are responsible for ensuring that the H&S Practitioner is
made aware when any employee notifies the company of their pregnancy, or
returns to work after giving birth.
14.1.5. Department heads have a responsibility to ensure that line managers and other
relevant personnel are properly informed of the condition of the new or expectant
mother and are full briefed on any special controls introduced as a result of the
subsequent risk assessment process.
14.2. Legislation
14.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks.
14.2.2. Regulations 16,17 &18 of The Management of Health and Safety at Work
Regulations (MHSWR) 1999 make specific reference to the care of new and
expectant mothers.
14.3. Definitions
14.3.1. An EXPECTANT MOTHER is any female employee who is pregnant and has
notified the company of this fact in writing.
14.3.2. A NEW MOTHER is any female employee who has given birth to a child in the
preceding 6 months or is currently breastfeeding a child.
14.4. Procedure
14.4.1. Upon determining that they are pregnant, the employee is required to notify the
company of this in writing. Newly appointed employees are required to notify the
company in writing if they have given birth in the previous six months or are
currently breastfeeding a child. The company will take not formal action with
respect to the employee’s condition until this notice has been received↓. New


Note the employee is not required to provide medical proof at this stage, written notification is required
only from the employee themselves.

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mothers returning to work following maternity leave are not required to provide
separate written notification of their status as new mothers.
14.4.2. Upon receiving written notification from a new or expectant mother informing
the company of their condition, the manager will notify the Health & Safety
Practitioner and will ask the employee to provide written confirmation of their
condition from either their GP or midwife. The law requires the company to allow
‘a reasonable time’ for the provision of written confirmation and, while no absolute
timescales are provided the company, following consultation with the arbitration
service ACAS, considers it reasonable to expect written confirmation by six weeks
from first notification. If the employee is unable to provide the requested
confirmation in this time, the company will normally take no further action in
respect of the employee’s claimed condition.
14.4.3. If the employee is unable to provide confirmation by the target date set in
14.4.2, the employee and manager should meet and set a new target date if this
is agreeable.
14.4.4. Upon the return to work of an employee from maternity leave, the relevant
manager will notify the H&S Practitioner of the expected return date.
14.4.5. As soon as the H&S Practitioner is informed of a new or expectant mother in
the workplace (regardless of confirmation from a GP or midwife), they will work
with the employee to conduct risk assessments⇓ on all aspects of the employee’s
activities addressing, at minimum, the following key areas:
• Manual handling
• COSHH
• Exposure to heat & cold
• Available space
• Exposure to Noise & Vibration
• Welfare facilities, including rest rooms
• Working Hours
While there are other areas of a working environment that can affect new or
expectant mothers such as exposure to radiation, exposure to violence or lone
working, these are not normally issues within Fibrax.
14.4.6. Having completed a risk assessment package with the employee, the H&S
practitioner will then brief relevant line managers on any special controls to be
introduced for the individual as a result of her condition.
14.4.7. Having been briefed of the controls required to ensure the health and safety of
the new or expectant mother, the manager must ensure that these controls are
met.
14.4.8. If the company cannot implement the controls required to ensure the health
and safety of the employee (and child), then the employee must be offered
alternative work to remove the relevant risk. If this option is taken then the
employee must not be paid less for doing the alternative work than she would have
been for her original role. If alternative work is not available, then the employee


Given the generic nature of many roles within Fibrax, it is considered good practise to maintain a generic
risk assessment package for key roles such as Trimmer/Inspector. This package must then be tailored to
suit the individual and any new hazards, risks & controls that are considered as part of this review should
also be added to the generic template to ensure that lessons learned are carried forward.

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is to be suspended on full pay until her condition changes (normally at least 6


months after the birth of the child, when the employee is no longer breastfeeding).
14.4.9. Risk assessments should be conducted as soon as the employee’s condition
is known and then, for expectant mothers, reviewed 14, 28 & 33 weeks into the
pregnancy as the changes experienced by the expectant mother can cause
hazards that were thought of as minor irritations in early stages to become
substantial sources of stress later in the pregnancy.
14.4.10. Risk assessments for new mothers will not normally require review after
completion as the effect of the workplace on the employee should be reduced
rather than increased over time. Unless specifically notified in writing from a GP
(either by letter or form MED3) of the need for exception, a new mother will be
expected to resume normal duties six months after the birth of her child.

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15. HSP015: Working At Heights


15.1. Responsibility
15.1.1. The Managing Director is responsible for ensuring that sufficient resources are
made available to ensure that employees are provided with the sufficient training,
equipment supervision and time to be able to conduct work at heights in as safe
a manner as is reasonably practicable.
15.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
15.1.3. The Health and Safety Practitioner is responsible for ensuring that risk
assessments are conducted, circulated and understood for all routine operations
that involve work at height.
15.1.4. The Health and Safety Practitioner is responsible for ensuring that all personnel
required to conduct non-routine work at heights are competent in the conduct of
risk assessments, aware of the requirement to conduct such assessments and
implementing such controls as are considered necessary prior to conducting such
work and of the requirements of the regulations with regard to equipment and
competence.
15.1.5. Department Heads are responsible for ensuring that the Health & Safety
Practitioner is made aware of any employee who is required to conduct non-
routine work at height and that such employees have been properly trained and
are competent to undertake the required work. Department Heads are also
responsible for ensuring that any contractors employed by the company are
approved by the Engineering Manager before work commences.
15.1.6. The Engineering Manager has a responsibility to ensure that any proposed
non-routine work at height is subjected to a thorough risk assessment, is
conducted in accordance with a method statement that details a safe working
method and controlled using the company permit system as detailed in procedure
HSP017.
15.2. Legislation
15.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks. The act also requires the employer to provide a safe place of work
including routes of access and egress.
15.2.2. The Provision and Use of Work Equipment Regulations (PUWER) 1998 require
the employer to provide equipment that is suitable to the task & well maintained
and to ensure that employees are suitably trained in the safe operation of any
equipment they are required to use in the course of their work.
15.2.3. The Work at Heights Regulations (WHR) 2005 require a suitable regime of risk
assessment, training, inspection and control for all aspects of work at height.
15.2.4. The Lifting Operations and Lifting Equipment Regulations (LOLER) 1998 makes
special provision for equipment used to lift people.

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15.2.5. The Provision and Use of Work Equipment Regulations (PUWER) requires that
persons required to use work equipment receive adequate training and places
specific requirements on the provision of equipment used for lifting people.
15.3. Definitions
15.3.1. WORK AT HEIGHTS denotes any work in a location that, where the regulations
not applied, would allow a person to fall a distance sufficient to cause personal
injury⇓.
15.3.2. WORK includes the act of gaining access to, or egress from, a place of work.
15.3.3. A ROUTINE OPERATION is one that is conducted every day as part of the
normal operation of the company’s primary function, including production tasks
and routine preventative maintenance activities such as topping up oil reservoirs.
15.4. Procedure
15.4.1. In accordance with procedure HSP001, a risk assessment is to be conducted
in advance of any activity undertaken on site on behalf of the company.
15.4.2. For routine operations, this risk assessment is to be conducted by the H&S
Practitioner in conjunction with the personnel (or a sample thereof) who routinely
undertake the activity and, if the activity involves work at height, this must be
specifically addressed within the assessment.
15.4.3. For non-routine operations, the manager in charge will appoint a competent
person to plan to operation including the conduct of a risk assessment and
provision of a subsequent method statement detailing a safe working practise for
the completion of the work.
15.4.4. When conducting the risk assessment , the competent person must consider,
at minimum, the following areas:
• Necessity to Work At Height
• Fall Hazards
• Falling object hazards & the need to cordon off the work area
• Equipment suitability
• The need for support from fragile surfaces
• Potential for deterioration of surfaces
• Hazards from sloping or lubricated surfaces
• Competence of personnel (including drivers of lift trucks)
• Familiarity of personnel with equipment, particularly hired equipment
• Involvement of young persons (See procedure HSP013)
• Proximity of ACM’s (See procedure HSP016)
• If outdoors, effects of weather
15.4.5. Where working at height places any individual at a remote location (factory
roofs etc.) the competent person must also produce an outline rescue plan to
ensure that, should an accident occur, the individual affected may be recovered
without unnecessary risk to themselves or the rescue party.
15.4.6. The competent person will then submit the risk assessment and method
statement to the Engineering Manager for approval. If the Engineering Manager


Note: The definition of work at height can also include working on the ground next to a pit or ditch, or even
below ground level if it is still possible to fall sufficient distance as to cause personal injury.

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agrees that the risk assessment is sufficiently thorough and sufficient controls are
planned to mitigate the identified risks as far as is reasonably practicable, they
will issue a permit to work in accordance with procedure HSP017.
15.4.7. Once work is approved, the submitted method statement must be followed
exactly. Where unforeseen circumstances require a deviation from this method
the changes must be attached in writing to the original statement and approved
by the Engineering Manager.
15.4.8. Mobile Elevated Work Platforms (MEWPs), including lifting cages for attachment
to lift trucks are considered to be lifting devices under the Lifting Operations and
Lifting Equipment Regulations 1998 and must be procured and maintained in
accordance with Procedure HSP011.

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16. HSP016: Asbestos Management


16.1. Responsibility
16.1.1. The Managing Director is responsible for ensuring that sufficient resources are
made available to ensure that Asbestos Containing Materials (ACM’s) used on site
are located, identified and managed so as to reduce the risks to health & safety
as far as is reasonably practicable. The Managing Director has specific
responsibilities in law to this end (Para.16.4.1).
16.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
16.1.3. The Health and Safety Practitioner has a responsibility to ensure that the site
is comprehensively surveyed for the presence of ACM’s, for ensuring that known
ACM’s are clearly identified, that all employees are made aware of any ACM
presence relevant to their activities within the company and for ensuring that any
activities undertaken by the company are carried out in such a way as to minimise
pollution & contamination from ACM’s as far as is reasonably practicable and to
at least comply with the requirements of current legislation.
16.1.4. All managers and department heads have a responsibility to be aware of ACM’s
present in the areas of site for which they are responsible and for ensuring that
employees and members of the public are not placed at risk of hazardous
exposure to ACM’s as a result of the company’s undertakings.
16.1.5. All employees have a responsibility to remain aware that ACMs are present on
site and to report anything they think might be an ACM to their line manager.
16.2. Legislation
16.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide a safe place of work including routes of access and egress.
16.2.2. The Control of Asbestos Regulations (CAR) 2012 require an explicit regime for
the management of asbestos and ACM’s.

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16.3. Definitions
16.3.1. ASBESTOS is a set of six
silicate minerals, three of
which have been in common
use for a variety of
applications:
• Crocidolite: Blue asbestos
was once commonly used in
the UK for fire protection
and insulation.

• Amosite: Brown asbestos


was used to strengthen
other asbestos insulation
products. Also found in old
pipe lagging.

• Chrysotile: White asbestos


is the most common type
and is found mainly in
reinforced cement sheeting
& guttering systems but has
been used in a wide range
of applications.

Asbestos can cause a variety of conditions including Asbestosis, Lung Cancer


and Mesothelioma, all of which are potentially fatal. Asbestos is usually contained
within another material and provides little risk unless that material is damaged or

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begins to degrade. While asbestos is often described by colour, the perceived


colour will be altered by other components of the material and the actual type of
asbestos contained in a material must be determined through laboratory analysis.
ASBESTOS CONTAINING MATERIAL (ACM) is any material that uses any of the
asbestos types as a component.
16.4. Procedure
16.4.1. The Managing Director (MD) is considered ‘The Dutyholder’ under the
regulation 4 of the Control of Asbestos Regulations 2012.
16.4.2. The Health and Safety Practitioner will, on behalf of the MD, commission a
comprehensive survey of the site by a qualified, licensed asbestos engineer to
determine the presence of ACM’s and the nature of the hazard they present.
16.4.3. Once a full survey has been completed, the H&S Practitioner will, taking advice
from the surveying engineer, produce a management plan for ACM’s on site
(Figure 14). This plan will detail the location of known ACM’s, the type(s) of
asbestos contained at each, the level of risk each ACM poses (accounting for
asbestos type, condition of material, accessibility & likelihood of disturbance) and
the proposed actions to be taken to mitigate any risk posed.

Figure 14: Excerpt from the Asbestos Management Plan


16.4.4. The H&S Practitioner will ensure that ACM locations are also maintained as a
layer on the site master drawing and that this information is included in the site
emergency procedure (See Environmental Management System, Procedure
EMP019).
16.4.5. The H&S Practitioner will brief all Department Heads on the presence of ACM’s
in their areas and provide access to the Asbestos Management Plan. Department
Heads will then inform the H&S Practitioner of any employees who are likely to
encounter a hazard due to the presence of ACM’s as part of their routine work.
16.4.6. The H&S Practitioner will ensure that asbestos awareness training is provided
for any employee identified as likely to encounter a hazard from ACM’s, either as
part of routine work or because the nature of their role involves non-routine work
that might conceivable involve contact with ACM’s.

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16.4.7. If materials are encountered on site, which are not listed on the Asbestos
Register but are suspected to be ACM’s, any work that might disturb those
materials is to be suspended until an asbestos engineer can verify the presence
or absence of ACM’s.
16.4.8. If new ACM’s are found on site, the H&S Practitioner will update the Asbestos
Management Plan and brief all affected managers on the new material. Where the
new material is at a location where it may pose a risk to employees as part of their
routine work, relevant risk assessments will be reviewed and controls modified to
mitigate the new risk as far as is reasonably practicable.
16.4.9. While ACM’s are generally safe while left undisturbed, they will degrade over
time and must be checked routinely to ensure they remain in a safe condition. For
this reason, best practise for ACM’s at low risk from damage is to leave in situ and
monitor for damage and deterioration. The H&S practitioner will establish a
schedule of inspection for all visible on site ACM’s and maintain a log to
demonstrate that inspections are undertaken.
16.4.10. Where an ACM is considered to be degrading, or at risk from damage due to
it’s location, the Engineering Manager will arrange for a suitably licensed
contractor to undertake the removal of the ACM and subsequent decontamination
of the area. Before such work begins, the contractor is to provide a risk
assessment and method statement for the planned activity as well as copies of all
licenses including those for waste transfer and hazardous waste disposal in
accordance with HSP017 and environmental procedure EMP007.
16.4.11.For all undertakings of the company, the presence of ACM’s should be
addressed as part of the relevant COSHH risk assessment (See procedure
HSP007).

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17. HSP017 : Management of Hazardous Activities: Permits to Work


17.1. Responsibility
17.1.1. The Managing Director has a responsibility to provide sufficient resources to
ensure that all work carried out as part of the undertakings of the company is
managed so as to be as safe as is reasonably practicable.
17.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
17.1.3. The Health and Safety Practitioner has a responsibility to ensure that the
company operates with sufficient systemic controls to ensure that any proposed
hazardous work is subjected to adequate risk assessment and that a safe method
of work is developed, circulated amongst relevant stakeholders and fully
understood before work commences, and to ensure that the site is left in a safe
condition both during and after completion of the hazardous work. The H&S
Practitioner is also responsible for administering the permit to work system in the
absence of the Engineering Manager, or where the work request is being made
by the Engineering Manager.
17.1.4. The Engineering Manager has a responsibility to verify that the risk assessment
for proposed hazardous work is adequate and that the subsequent method
statement offers sufficient controls as required to mitigate the identified risks as
far as is reasonably practicable. The Engineering Manager is also responsible for
administering the permit to work system used as the basis for control of hazardous
work.
17.1.5. All managers have a responsibility to verify through the permit notice board and
liaison with the Engineering Manager that no work is being conducted before
removing barriers or lockouts, or returning power to equipment that has been
isolated.
17.2. Legislation
17.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks.
17.2.2. The Confined Spaces Regulations (CSR) 1997 make special provision for
working in confined spaces and spaces with limited access/egress.
17.2.3. The Electricity At Work Regulations (EWR) 1989 require all work conducted on
electrical systems to be undertaken in a manner that is safe so far as is reasonably
practicable.
17.2.4. Regulation 3 of The Management of Health and Safety at Work Regulations
(MHSWR) 1999 requires the employer to undertake and document risk
assessments for all significant activities undertaken by employees on its behalf.
17.3. Definitions
17.3.1. A HAZARDOUS ACTIVITY is any activity where a risk assessment highlights
death, serious illness, disabling major injury or extensive damage to property as
the potential effect of a hazard and where automatic controls cannot be
implemented to completely mitigate the risk of occurrence.

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17.3.2. A CONFINED SPACE is any space where room to manoeuvre is restricted or


where limited access and egress is available making the employee difficult to
monitor and difficult to reach in the event of an accident. The term also applies
to any space with restricted ventilation or where the atmosphere may be
hazardous for other reasons.
17.3.3. HOT WORK is any activity that generates sparks or enough heat as to present
a fire risk. This includes, but is not limited to, welding, grinding & cutting steel.
17.3.4. LIVE WORK is any activity conducted on an electrical system that has not been
isolated from its power supply.
17.3.5. LONE WORKING is any activity where an individual is required to work at a
location that makes it unlikely that they will be seen or heard by anyone in the
event of an accident. Due to the public nature of the activity, driving a vehicle is
not considered lone working.
17.4. Procedure
Permitting
17.4.1. All contractors MUST have a permit to work specific to the activity being carried
out (See procedure HSP002).
17.4.2. Before undertaking work thought to be hazardous, the manager responsible for
undertaking the work must undertake a documented risk assessment and
determine the controls needed to mitigate any identified risks as far as is
reasonably practicable. After completion, the assessment must be reviewed and,
if the definition of a ‘hazardous activity’ listed in 17.3.1 is considered to apply, the
assessment must be approved by the Engineering Manager or, in his absence (or
if the Engineering Manager is seeking to perform the work), the H&S practitioner.
17.4.3. In the case of live work for the sole purpose of fault finding & testing equipment,
the duty production team leader may deputise for the H&S practitioner if the work
is required outside normal office hours but must ensure all conditions listed in
17.4.12 are met.
17.4.4. Once the risk assessment has been approved, the manager responsible is to
produce a method statement detailing the system of work to be used and the
controls that will be implemented from the risk assessment.
17.4.5. The Engineering Manager will review the method statement and, if satisfied that
the risk assessment and subsequent controls are sufficiently robust, will, except
in cases where lone working is the only hazardous activity, issue a permit to work
(Form EMF027) for the activity that details any specific PPE considerations as well
as identifying services to be isolated while the work in underway and any required
additional safety measures.
17.4.6. The Engineering Manager will provide a copy to the individual in charge of the
hazardous work and post a second copy in the Production Office so that
employees can quickly determine the reasons for service isolation etc. and thus
reduce the risk of injury through ignorance.
17.4.7. The second copy of the permit is to be displayed prominently at the place of
work at all times while work is underway.
17.4.8. When work is completed, the area is to be inspected by the Engineering
Manager to ensure that the area has been made safe.

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Additional Safety Protocols


17.4.9. Lone Working: While lone working is not in itself hazardous, the chances of
assistance being provided should an accident occur as a result of another hazard
are greatly reduced. Before lone working is approved, a risk assessment must be
conducted looking specifically at the activity when lone working. In addition, a
robust monitoring system must be implemented using either routinely monitored
CCTV, panic systems or a scheduled check-in with another employee using a
buddy system.
17.4.10. Hot Work: When conducting hot work, the preceding risk assessment must
consider the risk of fire, both from ejected hot debris and from the residual heat
of the work. Measures that should be considered are;
• The removal of flammable substances from the work area
• The removal of flammable substances from the item worked on (such as pipe
lagging which may be affected some distance from the work point due to heat
conduction)
• The need for a fire watch. Hot work can cause fires hours after the work has
finished due to hot debris landing near a fuel source and smouldering. It may
be necessary to post a fire watch in the area while work is carried out and for
several hours after the work has finished.
17.4.11.Working In Confined Spaces: The following provisions must be made before
work is approved:
• Before considering working in a confined space, the relevant manager must
demonstrate to the Engineering Manager that the work cannot be conducted in
any other way. If the manager wishing to carry out the work is the Engineering
Manager, or in his absence, necessity must be demonstrated to the satisfaction
of the H&S Practitioner.
• Work must be planned so that the minimum reasonably practicable amount is
conducted in a confined space.
• No employee is to be allowed to work in a confined space unattended and must
remain in audible or visual contact at all times.
• Where work is required to be carried out in spaces with poor ventilation, the
system of work must include the testing of the atmosphere in the space before
work commences.
• Where work is required in spaces where the atmosphere is hazardous, suitable
respiratory protective equipment must be used as part of the system of work.
Where respiratory protective equipment is used, full training must be given by
a competent person and all instruction pertinent to the safe use of the
equipment must be followed.
• The method statement for such work must also make provision for the recovery
of the employee should an accident occur. This provision must take into
account any specific known hazards and ensure that the health and safety of
the recovery party is not put at risk so far as is reasonably practicable.
17.4.12. Live Work: Live work may not be undertaken by company employees unless
there is no reasonable way to undertake the work with the circuit isolated from its
power source. The following provisions must be made before work is approved:
• Live work may only be carried out by competent electrical engineers and
appropriate insulation safeguards must be taken.

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• The method statement for live working must identify the most appropriate means
of isolating all exposed systems in the area of work, and provision made to
ensure that this can be accomplished immediately in the event of an accident.
• The person working on the live system must be watched throughout by an
assistant who has the authority to isolate exposed systems immediately in the
event of an accident.
• The method statement for such work must also make provision for the recovery
of the employee should an accident occur. This provision must take into
account any specific known hazards and ensure that the health and safety of
the recovery party is not put at risk so far as is reasonably practicable.
• The method statement must require a qualified first aider to be available and
must identify an individual responsible for summoning medical help in the event
of an accident.
17.4.13. Working at Height: has a separate procedure (HSP015) which must be followed
prior to the issue of a permit to work.

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18. HSP018: Provision for Persons with Disabilities


18.1. Responsibility
18.1.1. The Managing Director is responsible for ensuring that sufficient resources are
made available to ensure that the health and safety of all employees is assured so
far as is reasonably practicable.
18.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
18.1.3. The Health and Safety Practitioner has a responsibility to ensure that individual
risk assessments are carried out for any disabled personnel.
18.1.4. All department heads have a responsibility to ensure that the H&S Practitioner
is informed when a person with a disability is employed or being considered for
employment. Department heads also have a responsibility to ensure that any
special controls identified as a result of a subsequent risk assessment are
provided.
18.2. Legislation
18.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks. The act also requires the employer to provide a safe place of work
including routes of access and egress.
18.2.2. The Equality Act 2010 makes it an offence to discriminate against a person on
the grounds of disability unless the person is unable to fulfil a requirement of the
occupation as a consequence of a disability.
18.3. Definitions
18.3.1. A DISABILITY is defined by the Equality Act 2010 as a physical or mental
impairment that has a substantial and long-term adverse effect on a person’s
ability to carry out normal day-to-day activities. Where long term means in
existence for at least 12 months and likely to be present for at least another 12
months. However, this procedure is also to be applied to employees who are able
to work while suffering from temporary impairments that have similar effects.
18.4. Procedure
18.4.1. The Health & Safety Practitioner should seek professional advice in any
situation where they have insufficient knowledge of a disability to make an
informed decision.
Reporting of a Disability by Existing Employees
18.4.2. As soon as the a department head is made aware that a person working within
their department has a recognised disability, they are to inform the H&S
Practitioner and provide a detailed description of the role that person will
undertake.
18.4.3. If the employee’s disability warrants it, the H&S Practitioner will work with the
individual employee and their line manager to conduct a complete set of risk
assessments for the individual in their role and will report on any changes to
working practise, modifications to premises or equipment, or provision of auxiliary

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aids or services that will be required to allow the individual to safely fulfil the
requirements of the role for which they are employed. The H&S Practitioner and
line manager will also report on any adjustments needed to allow the disabled
employee to perform the role at a standard comparable to that expected of an
able bodied employee.
18.4.4. If it is found that the individual is no longer capable of fulfilling the role for which
they were employed safely, even if all reasonable adjustments are made by the
company, the H&S Practitioner will inform the relevant department head who will
arrange for alternative work for the employee until the issue can be resolved. The
employee must not suffer financially as a result of this interim change of duties.
Employment Candidates
18.4.5. When recruiting new employees, department heads are to inform the H&S
Practitioner of any disabled applicants that would be suitable for the post if able-
bodied. Where the recruiting process involves more than one interview, the H&S
Practitioner need be informed only if the candidate successfully reaches the
shortlist for final interview. The department head should also provide a full
description of the anticipated role of the new employee to the H&S Practitioner.
18.4.6. If the candidates disability warrants it, the H&S Practitioner will work with the
candidate and their prospective line manager prior to final interview to conduct a
complete set of risk assessments for the individual in their proposed role and will
report to the recruiting department head on any changes to working practise,
modifications to premises or equipment, or provision of auxiliary aids or services
that will be required to allow the individual to safely fulfil the requirements of the
role for which they are employed. The H&S Practitioner and line manager will also
report on any adjustments needed to allow the disabled candidate to perform the
role at a standard comparable to that expected of an able bodied employee.
18.4.7. The manager in charge of the recruitment process will ensure that the applicant
(and/or their representative if they have one) is aware that the risk assessment
process in no way implies that they have been successful and that it must be
completed prior to a decision being made.
18.4.8. If the risk assessment finds that the individual would not be capable of fulfilling
the role for which are being considered safely, even if all reasonable adjustments
were made by the company, the H&S Practitioner will inform the relevant
department head who must discount the applicant or amend the role to remove
the relevant risk(s) to health and safety (in which case the assessment process
must be repeated). The department head must ensure that any health and safety
issues that cannot be resolved are explained in detail to the candidate.

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Effects of Change on Disabled Employees


18.4.9. Where the company plans to make changes to working methods, equipment,
premises or any other aspect of operation, the H&S Practitioner will be required
to review existing and conduct new, risk assessments as determined by the nature
of the change. Where such change is likely to significantly impact upon the ability
of a disabled employee to fulfil their role within the company, the H&S Practitioner
and employee will review relevant risk assessments to determine if the company
will need to make additional adjustments to accommodate the needs of the
employee as a result of the proposed change and report those requirements back
to the relevant department head for inclusion into the change management
programme.

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19. HSP019: Traffic Management


19.1. Responsibility
19.1.1. The Managing Director is responsible for ensuring that sufficient resources are
made available to ensure that site traffic is managed to reduce risks to health and
safety as far as is reasonably practicable.
19.1.2. The Board of Directors are responsible for ensuring that traffic on site is
managed to an extent that risks to health and safety are mitigated as far as is
reasonably practicable.
19.1.3. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
19.1.4. The Health and Safety Practitioner is responsible for reviewing provision for
traffic management and reporting any deficiencies or suggestions for improvement
to the Board of Directors.
19.2. Legislation
19.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks. The act also requires the employer to provide a safe place of work
including routes of access and egress.
19.2.2. Regulation 3 of The Management of Health and Safety at Work Regulations
(MHSWR) 1999 require employers to make risk assessments of all activities that
might pose a risk to the health and safety of employees or non-employees that
might be affected by the undertakings of the company.
19.3. Definitions
19.3.1. TRAFFIC may refer to moving vehicles or pedestrians.
19.3.2. TRAFFIC MANAGEMENT describes the formal controls in place to prevent
accidents through the interaction of vehicles, fixed obstacles and pedestrians.
These controls refer to traffic inside buildings on site as well as outside.
19.4. Procedure
19.4.1. The Health and Safety Practitioner will conduct a risk assessment based on
existing traffic management provision. The Health and Safety Practitioner will
provide the company directors with a report describing current traffic management
provision on site detailing any significant risks identified and proposing improved
controls to mitigate those risks.
19.4.2. When assessing traffic management provision, the H&S Practitioner will
consider:
• Parking provision
• Widths of roadways, aisles and walkways
• Presence of blind corners
• Pedestrian crossing facilities
• Speed limits
• Warning notices

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• Use of PPE
• Risk from drivers unfamiliar with the site
• Risks to the public from traffic entering or leaving the site
19.4.3. The company directors will determine which controls are reasonably
practicable and arrange for their introduction.
19.4.4. Traffic Management will be reviewed using the method detailed in 19.4.1 -
19.4.3 at 12 month intervals and whenever a significant change is made to the
operation of the site.

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20. HSP020: Planning & Executions of Non-routine Operations


20.1. Responsibility
20.1.1. The Managing Director is responsible for ensuring that sufficient resources are
made available to ensure that any actions taken as part of the undertakings of the
company are managed to reduce risks to health and safety as far as is reasonably
practicable.
20.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
20.1.3. The Health and Safety Practitioner is responsible for ensuring that personnel
with responsibility for arranging, planning or executing non-routine activities are
competent to do so.
20.1.4. All managers are responsible for ensuring that the H&S Practitioner is made
aware of any significant non-routine operations to be conducted as part of the
undertakings of the company and for ensuring that a competent individual is
nominated to manage the activity.
20.2. Legislation
20.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks. The act also requires the employer to provide a safe place of work
including routes of access and egress.
20.2.2. Regulation 3 of The Management of Health and Safety at Work Regulations
(MHSWR) 1999 require employers to make risk assessments of all activities that
might pose a risk to the health and safety of employees or non-employees that
might be affected by the undertakings of the company.
20.3. Definitions
20.3.1. NON_ROUTINE denotes any activity that does not fall within the scope of day-
to-day company operations. Thus, servicing a moulding machine is routine
operation whereas replacing the tie-bars on the same machine is non-routine.
Routine operations will have a statement of safe working practise contained in
Section 3 of this manual; non-routine operations will not.
20.4. Procedure
20.4.1. The H&S Practitioner will maintain a register of individuals considered
competent to undertake non-routine operations with details of specific areas in
which that competence lies. The H&S Practitioner will also hold copies of any
specific qualifications required to demonstrate competence.
20.4.2. Before undertaking a non-routine activity, the responsible manager will
nominate a competent person to plan and execute the activity.
20.4.3. The competent person will determine a method for undertaking the work and
then undertake a risk assessment for the operation based on the proposed
method. Upon completion of the risk assessment, the competent person will
amend the proposed method as required to mitigate any identified risks as far as
is reasonably practicable. The competent person will then produce a method

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statement for the activity. This statement will provide a step by step summary of
the work to be undertaken including, at minimum, the following information:
• Services to be isolated and the procedure to be used to ensure lockouts remain
in force while required.
• Diversion or quarantine protocols required to prevent unplanned intrusion into
the work area.
• PPE to be worn by each person involved in the activity
• Any other specific controls to be enforced while the operation is in place
• A brief description of each stage of the activity (e.g. ‘Remove fixed guarding
from press’) with specific levels of competence and activity specific care points
or controls where required
20.4.4. The completed method statement will be reviewed by the Engineering Manager
or the H&S Practitioner and, if approved, a permit to work can then be issued in
accordance with procedure HSP017.
20.4.5. If an unforeseen hazard is discovered at any time during the activity, work may
continue only so far as is required to make the area safe, at which time the risk
assessment should be reviewed and amended and the method statement updated
to accommodate any new controls. The competent person will then inform the
manager responsible for issuing the original permit to work of the proposed
changes to method and the reasons for them. If satisfied that the proposed
changes are suitable, the issuing manager will then amend the permit as
necessary to accommodate the requested changes.

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21. HSP021: Repair & Maintenance Operations


21.1. Responsibility
21.1.1. The Managing Director is responsible for ensuring that sufficient resources are
made available to ensure that any actions taken as part of the undertakings of the
company are managed to reduce risks to health and safety as far as is reasonably
practicable.
21.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
21.1.3. The Health and Safety Practitioner is responsible for ensuring that activities
routinely undertaken by the company’s Maintenance Department are properly risk
assessed and that subsequently, safe working practises are developed,
communicated and understood.
21.1.4. The Engineering Manager is responsible for ensuring that all members of the
maintenance department are competent, or if currently training in a new aspect of
departmental operations, are adequately supervised by a competent person at all
times.
21.2. Legislation
21.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks. The act also requires the employer to provide a safe place of work
including routes of access and egress.
21.2.2. Regulation 3 of The Management of Health and Safety at Work Regulations
(MHSWR) 1999 require employers to make risk assessments of all activities that
might pose a risk to the health and safety of employees or non-employees that
might be affected by the undertakings of the company.
21.3. Procedure
21.3.1. All aspects of maintenance operations can be adequately controlled through
the following procedures contained within this manual.
• Routine maintenance activities should be risk assessed in accordance with
HSP001.
• Non routine maintenance activities should be managed in accordance with
procedure HSP020.
• Any operations involving artificial lifting aids should be managed in accordance
with HSP011.
• Any operation requiring working at height should be managed in accordance
with HSP015.
• All substances used by the maintenance department should be subject to a
COSHH risk assessment in accordance with HSP007.
• Any hazardous operations undertaken by the Maintenance Department are to
be managed in accordance with HSP017.
• All maintenance activities are to be subject to a safe working method, which is
to be published in Section 3 of this manual in the case of routine operations,
or produced prior to beginning non-routine operations.

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22. HSP022: Management and Use of Fork Lift Trucks.


22.1. Responsibility
22.1.1. The Managing Director has a responsibility to provide sufficient resources to
ensure all work equipment is maintained to an adequate standard, to ensure that
all employees required to use equipment are competent to do.
22.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
22.1.3. The Health and Safety Practitioner is responsible for conducting risk
assessments into lifting operations and for ensuring that all employees required
to operate a fork lift truck as part of their role are qualified to do so.
22.1.4. The Engineering Manager has a responsibility to ensure that provision is made
for the testing and inspection of lifting equipment in accordance with UK
legislation.
22.1.5. All Department Heads have a responsibility to inform the H&S practitioner of
any employees who will be required to operate a fork lift truck as part of their role
but are not yet qualified to do so.
22.1.6. All employees have a responsibility to treat fork lift trucks with due respect,
whether operating them or simply working in an area where FLT’s are in operation.
All employees have a responsibility to report any noticeable defects on fork lift
trucks, whether used by them or not.
22.2. Legislation
22.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks.
22.2.2. The Lifting Operations and Lifting Equipment Regulations (LOLER) 1998 lays
down specific legal requirements for the provision & maintenance of lifting
equipment and for the conduct of lifting operations.
22.2.3. The Provision and Use of Work Equipment Regulations (PUWER) 1998 requires
that persons required to use work equipment receive adequate training and places
specific requirements on the provision of equipment used for lifting people.
22.3. Definitions
22.3.1. Safe Working Load (SWL): Is a maximum load rating for a fork lift truck. SWL
does not take into account extremes of environment, fatigue due to use or the
effect of damage and wear.
22.3.2. Mobile Elevated Work Platform (MEWP): A device intended to elevate people
for the purpose of working at height. This includes Fork Lift Trucks with ‘man-
baskets’ attached.
22.3.3. Operate: Operation of a fork lift truck includes operation of the lifting & tilting
mechanisms as well as driving.

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22.4. Procedure
22.5. Personnel:
22.5.1. Only people qualified to do so are to operate Fork Lift Trucks (FLT’s).
Evidence of qualification must be presented to the department head to which the
employee reports and a copy of this evidence is to be kept with all training
records in Kaizen Department
22.5.2. All employees required to operate FLT’s as a part of their role within the
company are required to undertake refresher training at three and a half year
intervals at most.
22.5.3. Department heads are to maintain a written, published list of personnel within
their department who are qualified to operate FLT’s including the specific
categories of truck they are qualified to operate and the date they are required
to undertake refresher training.
22.5.4. Employees who are qualified but have passed the date at which they require
refresher training should not operate FLT’s on site.
22.5.5. No employee should attempt to operate an FLT if feeling unwell to a degree
that their ability to safely operate the equipment could be compromised and
should notify their immediate line manager if this is the case. If notified that an
employee is unable to operate a FLT due to illness, line managers should find
alternative work for the employee and arrange for a substitute driver.
22.5.6. Any employee diagnosed with any of the following medical conditions must
inform their immediate line manager at the earliest opportunity so that a medical
review and subsequent risk assessment may be conducted;
• Any form of Diabetes
• Ischaemic Heart Disease, Hypertension, Arrhythmia or any other cardiac
event
• Any loss of vision
• Any loss of hearing
• Nervous disorders including Parkinson’s Disease, dizziness, vertigo and loss
of balance
• Epilepsy
• Alcohol or drug dependency
• Psychiatric disorders
• Any form of dementia including Alzheimer’s Disease
• Any other condition that might affect the employee’s ability to safely operate
the equipment
Upon being informed that an employee required to operate FLT’s has been
diagnosed with any of the above conditions, the relevant line manager is to find
suitable alternative work for the employee until a medical review and subsequent
risk assessment can be made.

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22.6. Equipment:
22.6.1. Any equipment used for lifting is to be managed and maintained in
accordance with procedure HSP011.
22.6.2. Prior to use each day, all FLT’s must be subjected to a safety check by a
competent person at the beginning of each shift, covering all items listed for
inspection by ‘User’ on forms HS009: Routine Inspection of FLT’s for Unit1 (Figure
15) and HS021 for Unit2: Routine Inspection of FLT’s (Figure 16Figure 15).
22.6.3. Competent people responsible for routine User checks on FLT’s are;
Any person trained to operate FLT where date of the latest passed test is not
greater than 3.5 years.
22.6.4. In addition, items listed for inspection by Maintenance are to be conducted by
a competent member of the Maintenance Department⇓ and the results noted on
the HS020 form.
22.6.5. All FLT inspection sheets are to be forwarded at the beginning of each week
for HS009 and HS020 and at the end of each month for HS021 to the Unit 1
Despatch Supervisor for review and archive storage.
22.6.6. As with all lifting equipment, FLT’s must not be used to lift a weight greater
than their rated safe working load.
22.6.7. If any attachments (such as fork extensions) are used to allow the carrying of
difficult loads, the effect on the vehicle must be assessed and an accurate safe
working load calculated for the vehicle while using the attachment. This new
SWL must not be exceeded while the attachment is in use.


As FLT checks are routine and unchanging, these can be conducted by engineering apprentices or other
employees as long as adequate levels of competence and supervision are established in accordance with
procedure HSP013.

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Figure 15: Form HS009 - Routine Inspection Record for Fork Lift Trucks

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Figure 16: Form HS021 - Routine Inspection Record for Fork Lift Trucks (Unit 2)

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22.7. Operation
22.7.1. FLT’s must at all times be operated in accordance with the training received by
the operator prior to qualification.
22.7.2. All FLT’s must be operated with due regard to other traffic (both road and
pedestrian) and site speed limits must be obeyed at all times in accordance with
procedure HSP019.
22.7.3. When transporting large volumes of hazardous liquids such as hydraulic oil
stored in Intermediate Bulk Containers (IBC’s), the following additional precautions
must be taken;
• A suitably rated counter-balance Fork Lift Truck must be used if movement is
required outdoors. Reach trucks must not be used to transport hazardous
liquids on roadways or other rough terrain.
• The IBC must be sealed, with the taps closed and covered using screw caps
or, if a pouring snout is fitted and can be seen to contain a residual amount of
oil, cable tied polythene bags (Figure 18): all screw lids are to be tightly closed.
• The IBC must be secured to the forks Lift Truck using a suitable webbing strap
or dedicated strops fitted with safety hooks (Figure 17).
• The FLT must be driven at a speed no faster than 4mph (or a fast walking
speed) while outdoors, the existing 3mph limit stands while indoors.
• Additional care should be taken when cornering or ascending/descending
slopes as movement of the liquid within the container can alter the balance of
the load
22.7.4. FLT are not, under any circumstances, to carry passengers.

Figure 18: Sealing of pouring spout on IBC Figure 17: IBC Secured to FLT for Transport

22.7.5. Before lifting, drivers are to ensure that the load is in a safe condition.
22.7.6. Drivers are to wear seat belts at all times while driving the FLT.
22.7.7. Where possible, the vehicle should not be driven with the forks higher than
150mm (6”) from the ground.
22.7.8. When not in use, keys are to be kept at the nominated safe location for each
truck. Keys must not be left in unattended FLT’s. The nominated safe locations
are;

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• Tool Changer’s FLT: Keys to be held in Unit 1 Production Office key press when
no tool setter is working. Tool changers may keep keys on their person while
on shift.
• Unit 1 Logistics Dept FLT’s: Keys are to be kept in the logistics office when
FLT’s are not in use. Individual employees may hold keys on their person if
temporarily leaving an FLT unattended.
• Unit 2 Stores: Keys are to be kept in the top drawer of the stores desk. The
storeman may keep keys on his person if temporarily leaving the FLT
unattended.
• Yard FLT: Keys to be held in Unit 1 Production Office key press when FLT is
not required. The Yard Operative may keep keys on his person if temporarily
leaving the FLT unattended.
22.7.9. When used as a MEWP, the FLT must not be moved while carrying people,
other than to make small adjustments as required to allow access to the work
being carried out at height. Care must be taken to ensure that persons working
at height are not put at risk from impact with objects above the normal line of sight
of the driver (including ceilings).

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23. HSP023: Work Related Road Safety


23.1. Responsibility
23.1.1. The Managing Director is responsible for ensuring that sufficient resources are
made available to ensure that company employees required to travel by road on
behalf of the company are kept as safe as is reasonably practicable.
23.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company.
23.1.3. The Health and Safety Practitioner is responsible for ensuring that vehicle
drivers are aware of the company’s requirements for journey planning.
23.1.4. Designated custodians for company cars are responsible for ensuring that cars
in their charge are maintained in a roadworthy condition and properly equipped.
23.1.5. Individual drivers are responsible for ensuring that appropriate planning is
undertaken for journeys in accordance with this procedure.
23.2. Legislation
23.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 requires the employer
to provide safe equipment and systems of work as well as information, instruction,
training and supervision to ensure that employees are aware of the risks relating
to the undertakings of the company and of any controls implemented to mitigate
those risks. The act also requires the employer to provide a safe place of work
including routes of access and egress.
23.2.2. Regulation 3 of The Management of Health and Safety at Work Regulations
(MHSWR) 1999 require employers to make risk assessments of all activities that
might pose a risk to the health and safety of employees or non-employees that
might be affected by the undertakings of the company.
23.3. Definitions
23.3.1. Company Vehicle: Any vehicle owned by, and used as part of, the
undertakings of the company.
23.3.2. Custodian of a Company Vehicle: An individual given responsibility for the
maintenance and monitoring of a particular vehicle. Designation as a custodian
does not imply that the vehicle in question is available for personal use and should
not, in itself, affect the taxation status of the individual.
23.3.3. Personal Vehicle: A company vehicle provided as part of a salary agreement
and intended to be used primarily by one employee (and by request, the
employee’s spouse).
23.3.4. Pool Vehicle: A company vehicle provided for use by any employee requiring
use of a vehicle in their role within the company. Pool vehicles are not provided
for personal use and only employee’s are covered by company insurance for
these vehicles.
23.3.5. Private Vehicle: A vehicle not owned or insured by the company.

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23.4. Procedure
23.5. General
23.5.1. This procedure applies to all road travel undertaken by company employees,
whether in company owned vehicles or not.
23.5.2. Employees asked to drive on behalf of the company may only do so if they hold
a full driver’s license that is valid in the UK (and EU as required). Any employee
regularly required to drive on behalf of the company is required to notify their line
manager at the earliest opportunity if they receive endorsement points to their
license (whether this is as a result of company operations or not). Any employee
required to drive on behalf of the company is required to inform their line manager
at the earliest opportunity if they are banned from driving in the UK.
23.5.3. The company does not endorse dangerous driving and will not normally offer
support to a ‘loss of livelihood’ request for leniency made to the courts by any
employee faced with a driving ban.
23.5.4. It follows from 23.5.3 that the company expects all employees to drive with due
regard to prevailing speed limits & road conditions, and to show consideration for
other road users.
23.6. Company Cars
23.6.1. Company cars are to be maintained in a roadworthy condition by their
designated custodian. Custodians are to make sure that vehicles in their charge
have current MOT test certificates (where applicable) and have current road fund
licenses. Insurance cover is to be maintained by the company secretary for all
company vehicles.
23.6.2. All vehicles must be equipped with the following items.
• Rescue hammer with integrated webbing blade
• 4 x High visibility jackets (to suit normal occupants)
• 0.6Kg (minimum) Dry Powder Fire extinguisher
• Standard warning triangle
• First aid kit containing, at minimum:
─ Scissors ─ 1 x 7.5cm contour bandage
─ High intensity light stick ─ 2 x Sterile triangular bandage
─ Resuscitation shield ─ 1 x roll hypoallergenic tape
─ Guidance leaflet ─ 20 x hypoallergenic adhesive
─ 1 x No. 8 sterile dressing dressings
─ 1 x No. 9 sterile dressing ─ 10 x alcohol free wipes
─ 1 x No. 16 sterile dressing ─ 2 pairs latex gloves
─ 1 x No. 1 ambulance dressing ─ 6 x Assorted safety pins

23.6.3. Vehicles must display a ‘no smoking’ sign conforming to the requirements of
The Health and Safety (Signs and Signals Regulations) 1996 in a position visible to
passengers.
23.6.4. Key information such as fuel type and manufacturer’s recommended tyre
pressures are to be recorded in a written document and kept in the glove
compartment of the vehicle.

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23.7. Goods Vehicles


23.7.1. Company goods vehicles are to be maintained in a roadworthy condition by
their designated custodian. Custodians are to make sure that vehicles in their
charge have current VOSA HGV test certificates and have current road fund
licenses. Insurance cover is to be maintained by the company secretary for all
company vehicles.
23.7.2. All vehicles must be equipped with the following items.
• Rescue hammer with integrated webbing blade
• 3 x High visibility jackets (to suit normal occupants)
• Fire extinguisher to suit vehicle
• Standard warning triangle
• First aid kit containing, at minimum:
─ Scissors ─ 1 x 7.5cm contour bandage
─ High intensity light stick ─ 2 x Sterile triangular bandage
─ Resuscitation shield ─ 1 x roll hypoallergenic tape
─ Guidance leaflet ─ 20 x hypoallergenic adhesive
─ 1 x No. 8 sterile dressing dressings
─ 1 x No. 9 sterile dressing ─ 10 x alcohol free wipes
─ 1 x No. 16 sterile dressing ─ 2 pairs latex gloves
─ 1 x No. 1 ambulance dressing ─ 6 x Assorted safety pins

23.7.3. Vehicles must display a ‘no smoking’ sign conforming to the requirements of
The Health and Safety (Signs and Signals Regulations) 1996 in a position visible to
passengers.
23.7.4. Key information such as fuel type and manufacturer’s recommended tyre
pressures are to be recorded in a written document and kept in the glove
compartment of the vehicle.
23.8. Private Vehicles
23.8.1. Employees using private vehicles must have a current, valid MOT certificate, a
current road fund license and be insured for business use if the vehicle is to be
used on behalf of the company (this does not include journeying to and from their
place of work).
23.8.2. Private vehicles use for company business must be equipped with the following
items.
• Rescue hammer with integrated webbing blade
• 4 x High visibility jackets (to suit normal occupants)
• Fire extinguisher to suit vehicle
• Standard warning triangle
• First aid kit containing, at minimum:
─ Scissors ─ 1 x 7.5cm contour bandage
─ High intensity light stick ─ 2 x Sterile triangular bandage
─ Resuscitation shield ─ 1 x roll hypoallergenic tape
─ Guidance leaflet ─ 20 x hypoallergenic adhesive
─ 1 x No. 8 sterile dressing dressings
─ 1 x No. 9 sterile dressing ─ 10 x alcohol free wipes
─ 1 x No. 16 sterile dressing ─ 2 pairs latex gloves
─ 1 x No. 1 ambulance dressing ─ 6 x Assorted safety pins

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23.9. Planning the Journey


23.9.1. As with any other company activity, The Management of Health and Safety at
Work Regulations 1999 require risk assessments to be conducted for road
journeys. While each journey will of course be unique, it is not possible to foresee
the hazards that make it so and it is therefore the responsibility of the driver to be
aware of, and avoid hazards as they occur. Despite this, many hazards can be
predicted and their effect lessened through prior planning and the Health and
Safety Practitioner will therefore conduct generic risk assessments for road
journeys from which, safe methods of work will be produced.
23.9.2. Goods vehicle drivers are to ensure that their vehicle is operated in accordance
with The European Agreement Concerning The Work of Crews Of Vehicles
Engaged in Road Transport (AETR) - (VOSA Document GV262-03 refers).
23.9.3. The following factors should be considered when planning any journey in a
goods vehicle:
• Types of road en route: Are they suitable for the class of vehicle?
• Overhead obstructions: Will the vehicle be required to pass under low bridges,
tunnels etc? If so, is there sufficient headroom?
• Vehicle Weight: Are deliveries and collections scheduled to ensure the vehicle
is not overloaded?
• Journey Time: Can the planned journey be safely completed within AETR rules
on driver’s hours?
• Load: Is the vehicle of a design suitable for the load?
• Weather: Are weather conditions expected that might make the journey more
hazardous? If so, can the journey be delayed?
23.10. Drivers
23.10.1. Drivers should be medically fit. Any employee required to drive as part of their
job is required to immediately notify their line manager if diagnosed with any of
the following medical conditions so that a medical review and subsequent risk
assessment may be conducted;
• Any form of Diabetes
• Ischaemic Heart Disease, Hypertension, Arrhythmia or any other cardiac event
• Any loss of vision
• Any loss of hearing
• Nervous disorders including Parkinson’s Disease, dizziness, vertigo and loss of
balance
• Epilepsy
• Alcohol or drug dependency
• Psychiatric disorders
• Any form of dementia including Alzheimer’s Disease
• Any other condition that might affect the employee’s ability to safely operate the
equipment
Upon being informed that an employee required to operate a vehicle on the
company’s behalf has been diagnosed with any of the above conditions, the

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relevant line manager is to find suitable alternative work for the employee until a
medical review and subsequent risk assessment can be made.
23.10.2. Drivers must be made aware of the need to take rest breaks, where appropriate
this should include information on AETR rules though drivers of company cars
should also be made aware of the dangers of driving whilst fatigued.
23.10.3.Drivers must be made aware of the risks of driving home from work when tired,
and of driving out of work hours following a long journey while at work.
23.10.4.Drivers are to consider the safety of themselves and others at all times. To this
end, drivers should ensure the following:
• That they are familiar with all key controls and settings for the vehicle including
those used for normal operation, the location of the hazard indicator switch, the
adjustment procedure for head restraints to prevent whiplash, how to adjust
headlamp alignment to compensate for load and the correct pressures for the
vehicle’s tyres.
• Journeys should be undertaken at speeds appropriate to the prevailing speed
limit and conditions. Arrival time is of secondary importance to these.
• Mobile telephones must not be used by drivers except through a suitable hands
free adaptor. Telephone calls must not be initiated by the driver whilst in motion
unless the hands free adaptor provides the facility to dial using voice
recognition.
• Where used, GPS based navigation systems are only an aid to route finding
and should not be considered an authority on the suitability of any particular
route. In addition, if displayed, the expected time of arrival shown by the
navigation system is for information only and is not a target to be achieved.
23.10.5. If a fault is noticed when driving a vehicle, the driver is to report that fault directly
to the custodian of that vehicle, who will arrange for the fault to be corrected. If
the fault is sufficient to render the vehicle unsafe to drive, the driver is to remove
the vehicle from the road and arrange recovery. The custodian of the vehicle will
then ensure that it is then removed from service until the fault is corrected.

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24. HSP024: Housekeeping


24.1. Responsibility
24.1.1. The Managing Director is responsible for ensuring that sufficient resources are
made available to ensure that all areas of the site can be maintained in a safe and
tidy condition.
24.1.2. All Directors have a responsibility to encourage a working culture that places
the Health and Safety of employees and members of the public at the forefront in
all undertakings on behalf of the company and that stresses the need for effective
housekeeping as a key element of this.
24.1.3. All managers are responsible for ensuring that areas of the site over which they
have influence are maintained in a safe and tidy condition.
24.2. Legislation
24.2.1. The Health and Safety At Work Etc. Act (HASAWA) 1974 Section 2 specifically
requires the employer to provide safe working environment, including routes of
access and egress.
24.3. Definitions
24.3.1. Place of work: refers to any specific area, machine or other logical sub-division
of the site at or in which an individual is expected to perform their job function.
24.3.2. Means of Access: within the procedure should always be taken to also refer to
means of egress where applicable. Means of access can include, but is not limited
to, roads and paths from the factory gate to individual buildings, main aisles &
spaces between machines and racking along which employees are expected to
pass.
24.4. Procedure
24.4.1. The H&S Practitioner will maintain a detailed layout diagram of the site that
indicates responsibility for the maintenance of housekeeping standards in each
area (Figure 19).
24.4.2. Managers responsible for each area will define a documented housekeeping
standard for that area, taking into account all relevant risk assessments and
ensure that employees achieve and maintain that standard.

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Figure 19: Areas of Responsibility for Housekeeping

24.4.3. Managers responsible for each area will inspect that area on a circa bi-weekly
basis without prior warning to ensure that published standards are being
maintained. Such inspections are to be documented as to the date & time of
inspection; any issues noted and, where necessary, follow up reviews scheduled.

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