HS Manual Vol 1 Iss 12
HS Manual Vol 1 Iss 12
HS Manual Vol 1 Iss 12
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
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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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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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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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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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2. Organisation
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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.
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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.
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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.
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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.
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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)
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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.
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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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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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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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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)
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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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(a) (b) (c) (d) (e) (f) (g) (h) (l) (m) (n) (o) (p)
(i)
(j)
(k)
⇓
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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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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8.3. 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.
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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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⇓
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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Figure 10: Sample of Average Noise Level Calculation Using Microsoft Excel
⇓
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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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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‘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
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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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• 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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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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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.
⇓
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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↓
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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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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16.3. 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.
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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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• 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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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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• 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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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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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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23.4. 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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23.7.3. 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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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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24.4.3. 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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