Health safety & wellbeing; testing times ahead?

Worker’s health, safety and wellbeing is literally being placed at the very heart of corporate thinking as ESG (environment, social and governance) reporting requirements in Europe affect any company that wishes to trade with the EU under the Corporate Sustainability Reporting Directive. The ‘carrot’ for companies that put ESG obligations at their core is that it will unlock a new source of competitive advantage and, by meeting customer, employee, and regulator demands, they are protecting the planet, creating a world that works better for people, and becoming the next generation of business. And, of course, good health, safety and wellbeing leads to a happier, engaged and more productive workforce which is vitally important as recruiting and retention is proving to be such a post pandemic challenge.

The stick? In extremis there is always the prospect of a charge of corporate manslaughter, although not part of health and safety law (in the UK), is nevertheless a criminal offence that refers to a crime committed by a company or organisation that leads to a work-related death. But on a day-to day basis who has responsibility?

Hierarchy of controls

According to the ILO [1], occupational surveillance involves active programmes to anticipate, observe, measure, evaluate and control exposures to potential health hazards in the workplace. Environmental surveillance is used to document potential exposure to contaminants for a group of employees, by measuring the concentration of contaminants in the air, in bulk samples of materials, and on surfaces.

This tends to be cross functional responsibility depending on the size of the organisation and includes dedicated Health & Safety professionals, Facilities Managers and Occupational Hygienists, the latter in sectors such as mining & mineral extraction, oil & gas, petrochemical and pharmaceutical. The individual employee also has a major part to play in using the controls and equipment provided and reporting issues through the ‘chain of command.’

Occupational Hygienists will routinely conduct a risk assessment of physical and chemical agents, often backed by objective measurements of parameters such as noise, vibration, dust, and vapours and then make recommendations by applying the hierarchy of controls as a systematic approach to protect workers from hazards in the workplace. It involves identifying and ranking safeguards based on their effectiveness in reducing or removing hazards. The five levels of the hierarchy of controls are:

• Elimination: This method removes the hazard at its source. For example, changing a work process to stop using a toxic chemical eliminates exposure altogether. Elimination is the preferred solution because no exposure can occur.
• Substitution: This involves using a safer alternative to the hazardous source. For instance, using plant-based printing inks instead of solvent-based inks. When considering a substitute, it is essential to compare the potential new risks with the original risks. Effective substitutes reduce harm without creating new risks.
• Engineering Controls: These controls modify equipment or the workspace to prevent hazards from coming into contact with workers. Examples include protective barriers, ventilation systems (LEV), and equipment design. Engineering controls are most effective when part of the original equipment design and require minimal user input.
• Administrative Controls: These establish work practices to reduce exposure duration, frequency, or intensity. Examples include job rotation, work process training, and ensuring adequate rest breaks. While administrative controls are essential, they are less effective than elimination, substitution, or engineering controls.
• Personal Protective Equipment (PPE): PPE includes items like gloves, masks, and safety glasses. It is the last line of defence and should only be used when other controls are not feasible. PPE requires proper training, fit, and consistent use.

Effectiveness of controls?

Ongoing responsibility for checking he effectiveness of engineering controls will normally fall within the remit of the facilities manager (FM) which is why a report mentioned in Health & Safety Matters ^[2] portray a rather worrying trend. They state that Watco’s research ^[3] has revealed that almost two thirds (60%) of FM’s have had their budgets cut by up to 25% in the past year with a further fifth (20%) hit even harder with a reduction of 25-50%. A third (33%) agree that budget cuts have posed risks to safety within their business in the past year.

The survey of 250 senior FM professionals highlighted the tangible impact of these budget cuts on the frequency of incidents in the workplace. But it is not just budget cuts that are impacting health and safety. Over a quarter (28%) of FMs say that employees are not aware of potential hazards and do not know how to control or report risks. Furthermore only 34% undertake a thorough site audit/risk assessment at least once a year and almost half struggle to find the time to complete repair jobs as soon as they are spotted.

Ironically making a risk assessment or checking the effectiveness of controls using measuring instrumentation has never been simpler. Plus, there is a wide choice of traditional air sampling pumps or increasingly, real-time solutions.

Air sampling pumps are typically used for compliance purposes in accordance with well-established UK ^[4] & US ^[5] methods which are also recognised on a global basis. The pump itself should comply with the latest version of the ISO standard ^[6] and be calibrated (for flow rate) both before and after use because the hazard concentration is directly proportional to the flow rate which subsequently gets compared with the statutory limit values such as those published by the HSE ^[7].

Walk through survey

Real-time, direct reading solutions on the other hand give instantaneous results which is beneficial when conducting a walk-through survey for example. The purpose of this initial survey is either to systematically gather information to judge whether a potentially hazardous situation exists and whether further personal monitoring is required or to check that local exhaust ventilation (LEV) is performing satisfactorily.

LEV is probably one of the most common forms of control of dust and fumes. According to a leading service provider [8] proactive measures are vital to ensure that such ventilation systems function optimally and effectively to eliminate hazardous substances from the air. Regular assessments allow for the early detection of any issues or malfunctions, enabling prompt corrective actions. Moreover, LEV testing is a matter of best practice and a legal requirement in the UK under the Control of Substances Hazardous to Health (COSHH) Regulations 2002.

Companies that fail to comply with these regulations face many potential consequences and risks!

References

1. ILO Encyclopaedia of occupational health and safety, part 4 tools and approaches.
2. Health & Safety Matters, Feb/Mar 2024, News page12
3. www.watco.co.uk/overcoming-the-fm-landscapes-complexities
4. Methods for the determination of hazardous substances guidance (hse.gov.uk)
5. NIOSH Manual of Analytical Methods (2014-151) | NIOSH | CDC
6. ISO13137:2022 Workplace atmospheres. Pumps for personal sampling of chemical and biological agents - Requirements and test methods
7. EH40/2005 Workplace exposure limits (hse.gov.uk)
8. Essential LEV Testing Checklist: Your Guide to Staying Compliant (autoextract.co.uk)