The Workplace (Health, Safety and Welfare) Regulations 1992 form part of the ‘six-pack’ of controls introduced in 1992 as a result of EU directives. They impose requirements on a wide number of factors affecting workplace safety, such as cleanliness, segregation of traffic routes and the condition of floors – the sorts of issues on which regular health and safety inspections concentrate.
Good practice information is also provided on issues related more to comfort than safety – temperature, ventilation, provision of sanitary facilities and areas for rest and meals.
Duties to ensure that safety is not compromised already exist in the Health and Safety at Work etc Act 1974. The Workplace Regulations are used to expand on workplace specific requirements and practical guidance on best practice is provided in the Approved Code of Practice (ACOP). Failure to comply with the ACOP is not an offence, but can be used as evidence if a breach of law is alleged. If companies deviate from the recommendations, they must ensure their alternative measures are at least as good.
The Regulations also have a degree of overlap with the Management of Health and Safety at Work Regulations 1999 which introduce the need for risk assessments for areas of potential risk not specifically covered elsewhere. The workplace regulations do not explicitly require a written risk assessment, but it makes sense to work through the ACOP and write down what your company does to ensure compliance and, where this is inadequate, what actions need to be taken to improve the situation.
Key safety points
The Workplace (Health, Safety and Welfare) Regulations 1992 can be broken down into key topics.
The workplace and equipment to which the regulations apply must be maintained efficiently. This can be achieved through regular inspection, testing, adjustment, lubrication and cleaning.
A sufficient quantity of fresh air must be provided in the workplace, typically not less than 5-8 litres per second per occupant. This requirement is unlikely to be a problem on a timber or furniture site, with large buildings and frequently opening doors and shutters.
More problematic from a manufacturing perspective is the requirement for maintenance of a reasonable indoor workplace temperature. The ACOP says that temperatures should be kept above 16OC, unless work involves severe physical effort, in which case it should be above 13OC. It is difficult to maintain warmth in areas like loading bays, but efforts can be made to ensure doors and shutters are closed when not in use and that workers have appropriate clothing.
Adequate lighting should be provided to ensure workers can move around and perform tasks safely without eye strain. Natural lighting should be used where possible and lights should not be obscured by stacked goods.
The workplace should be kept clean. Where waste is produced by a process, it should be removed regularly. Floors and traffic routes should be cleaned at least once a week and areas around some woodworking machines more regularly.
Extracting dust
Wood dust which is not extracted may lead to breaches of the Control of Substances Hazardous to Health Regulations 1999. It may also cause slips and trips and pose fire risks. Consequently, many companies have a policy of removing dust from difficult to reach places, like the top of extraction pipes, at least once a year.
Solid timber off-cuts can also trip, or impede the progress of trolleys and vehicles. Care should also be taken with liquid wastes, such as veneer press washdown and glue, where this is prone to leaking onto the floor and traffic routes.
Workplace cleaning should use vacuums rather than brushes which mobilise dust. In addition, the practice of ‘blowing-down’ (using air lines to clean work pieces and people) should be avoided. It creates more dust, which will settle elsewhere and accidental injection of air into the blood stream can kill.
Legal issues with waste do not stop once the substance has been removed from the workplace. Part II of the Environmental Protection Act 1990 requires sites to keep all waste safe, secure and contained. It must be taken by an authorised carrier and accompanied by a transfer note.
Sufficient floor area, height and unoccupied space must be provided. The ACOP suggests a minimum of 11m³ per person (where any room is more than 3m high it is counted as 3m).
Many a slip
Manual handling injuries will rise if workers have to carry loads over uneven areas. Goods being moved by fork lift trucks and trolleys will be prone to shifting and falling, risking injury and damage to goods.
Floors and traffic routes should be suitable for purpose; sufficiently hard-wearing and able to take the weight of traffic. Holes should be repaired, any liquids should be contained or drained and a slip resistant coating should be provided where necessary. Roof condition is also relevant to the Regulations, as leaks can make surfaces slippery.
It is fairly common to find woodworking machines surrounded by piles of timber. These can hinder the operator and cause trips and slips – particularly dangerous in the vicinity of machinery.
It is good practice to mark out designated areas for traffic and others for storage. This should also help to avoid blocking fire exits.
The Regulations have specific requirements covering risks of people falling or being struck. Tanks, pits and structures must be covered securely or fenced. Fencing must also be used where there is a chance of falling more than 2m.
Openings like loading bays should be fenced as far as possible and climbing onto vehicles should be avoided.
Safety materials must be used for panes more than 25cm wide, eg in doors. These materials include those which are inherently robust (eg glass blocks), glass which breaks safely (eg wired glass) and ordinary annealed glass which meets thickness criteria specified in the ACOP.
Traffic control
A total of 26 fatal accidents have occurred in the woodworking industry since 1995, of which seven were attributable to works transport – typically a worker being struck by a reversing vehicle.
The Regulations stipulate the organisation of traffic routes to safeguard pedestrians; through speed limits, absence of sharp bends and blind corners, repair of poor surfaces and restriction of reversing locations. Other measures include the use of reflective vests, fitting reversing alarms, lines to indicate vehicle routes, provision of crossing points and driver training.
The ACOP details the minimum number of toilets and wash stations needed according to workforce size. Hot and cold water must be provided, along with soap and towels or driers. Drinking water and suitable vessels should be available.
Storage and changing facilities must be provided for special work clothing which is not taken home, plus storage for personal protective equipment. The latter should not be left on work benches as they can accumulate dust.
Seats must be provided for rest periods and an area must be set aside for eating – including facilities for making hot drinks. Eating at work stations should be avoided if contamination is likely. If smoking is allowed in eating areas, a non-smoking alternative must be provided.
