The stores, warehousing and distribution industries are potentially dangerous places in which to work. For example, large vehicles, mechanical equipment and people come together, working at speed and often under pressure. It is essential, therefore, that management plans for safety to minimise the risk of accident and injury. The law has recognised the key role played by employers in controlling health and safety at work. Important obligations and restrictions have been placed on employers by legislation, originating in the UK parliament and in the EU. These are examined in the following sections under ‘Health and Safety at Work’, adapted with permission, from the Institute of Logistics and Transport Open Learning materials covering the Introductory Certificate in Logistics.
HEALTH AND SAFETY AT WORK
The Health and Safety at Work etc. Act 1974 (HASWA) is primary legislation defining principles and objectives. It is very general in its scope, and places responsibility for the health and safety of workers into three categories, namely:
• the responsibility of the employer • the responsibility of the employee • the responsibility of manufacturers.
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Regulations
HASWA clearly states that it is the responsibility of employers to maintain the health, safety and welfare of all employees, including provision of a statement of health and safety policy, safety equipment and training staff. HASWA also states that employees have an obligation to the employer to undertake the training when provided, to use equipment provided for safety as trained, to report any unsafe practices and not to misuse safety equipment. The manufacturer of equipment has a specific responsibility under HASWA to ensure that the product is safe to use in the environment it was designed for in normal circumstances and is fit for its purpose. All managers need to be aware of their obligations under HASWA, which may mean undertaking specialist training or liaising with an appointed health and safety manager. It is prudent for managers, when assessing any operation or new development, to liaise with a suitably qualified health and safety professional to ensure compliance with the legislation. More specifically, to aid managers in their dealings with health and safety issues in the workplace, there is a wealth of supporting approved codes of practice (ACOP) and other regulations which are all legally binding and underpin HASWA. MANAGEMENT OF HEALTH AND SAFETY
The Management of Health and Safety at Work Regulations 1999 support managers in fostering a proactive approach towards building a health and safety culture within the organisation. In the past some employers merely responded to unsafe practices in order to limit damage, minimising the impact on production, sales and direct costs. Under these regulations organisations are encouraged to be proactive in their approach to accidents and unsafe practices, which means that the logistics manager must ensure that systems are in place for planning, organising, monitoring and reviewing operations with regard to the health and safety of staff at work. (In other words, all employers have to have at least one competent person to assist in carrying out the health and safety obligations.) Display screen equipment The Health and Safety (Display Screen Equipment) Regulations 1992 apply to visual display units (VDUs) for computers or microfiche, in that
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the risks associated with the use of VDUs – mainly eyestrain, backache and limb pain – are minimised by providing staff with suitable training and equipment that can be adjusted for each individual at that workstation. This includes the ergonomics of the workstation layout.
Personal protective equipment The Personal Protective Equipment Regulations 2002 state that employers are required to provide PPE to employees where there are risks to their health and safety which cannot be controlled by other means, e.g. mechanisation. PPE is described as being any equipment designed to be worn or held by the person to protect them from one or more risks. This could be simply gloves and goggles or warm clothing or heated cabs on MHE for use in temperature controlled warehouses.
Provision of equipment The Provision and Use of Work Equipment Regulations 1998 (PUWER) require employers to ensure that equipment provided for use at work complies with the regulations (for example, MHE, staple guns, wrapping or weighing machines). Work equipment must be:
• suitable for intended purpose • assessed for risks associated with use • subject to a recorded inspection • maintained in efficient working order.
Reporting injuries The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) require employers to notify the Health and Safety Executive of fatal and major workplace accidents and those causing more than three days incapacity, work related diseases and any dangerous occurrence, whether or not anybody is injured. In the case where an accident occurs to an employee away from the normal place of work, e.g. delivery drivers, the Health and Safety Executive suggests that the occu
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pier of the premises where the incident occurs should advise the person’s employer as soon as possible.
Workplace regulations The Workplace (Health, Safety and Welfare) Regulations 1992 deal with preventing hazards that result from poor housekeeping and include cleanliness and waste materials. Waste materials should not accumulate, creating slipping or tripping hazards or obstructions to fire exits and fire doors. In addition, these regulations impose requirements on management for the maintenance of the fabric of the workplace, ventilation, lighting, space planning and provision of washing facilities and changing rooms.
Risk management For managers, the role of the risk assessment is to assess what is probable, and not what is possible. This means making an informed judgement based on the balance between the needs of the business, the operation and the customer. Risk assessment requires the employer to ensure that assessments are undertaken and the findings acted upon, recorded, and communicated to employees. The control measures introduced as a result of assessment must be monitored and reviewed to ensure that they are effective. Risks may include:
• slips, trips and falls • pedestrian and vehicle movement • objects falling • fire • power failure • eating, drinking or smoking in the workplace.
Handling of loads Handling of loads applies to both mechanical and manual handling (Manual Handling Operations Regulations 1992). The Health and Safety
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Executive publish specific guidance notes for the safe operation of mechanical handling equipment. More recently, employees are turning to litigation for damages as a result of manual handling incidents. Therefore managers must be confident that all staff have been adequately trained in the correct lifting and carrying techniques, commensurate with the operation in which they are working. A risk assessment might imply that a manual handling operation should be replaced by mechanical handling. If the logistics manager cannot eliminate the hazard, there is a responsibility to reduce the hazard by providing aids (e.g. scissor lift or hand pallet transporters) to reduce the risk of injury, or reduce employee exposure (for example, by reducing the distance or the frequency the load has to be carried).
Hazardous goods The Control of Substances Hazardous to Health (COSHH) Regulations 2002 are designed to further protect the health and safety of people at work and place additional responsibilities on employers to assess the risks to employees working with hazardous substances. Again, this involves logistics managers assessing the risk of exposure to chemical hazards and taking steps to minimise any such exposure. Managers must inform employees of risks that exist and provide training in safety procedures and monitor the working environment. Options to reduce risks include removing employees from exposure risk and mechanising the process or contracting out the process to a specialist organisation. In addition, manufacturers and suppliers of hazardous goods are required to classify, package and provide information on substances listed in the Chemical (Hazard Information and Packaging for Supply) Regulations 2002 (CHIP 3). The Transport of Dangerous Goods (Safety Advisers) Regulations 1999 stipulate the requirements for movement of dangerous goods by road, rail and inland waterway. It makes employers responsible for loading, transport and unloading of dangerous goods and requires employers to have a sufficient number of qualified safety advisers to sign off and supervise the loading and unloading of dangerous goods.
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HEALTH AND SAFETY ARRANGEMENTS
It can be seen from the above section on HASWA, and its sub-sections, that the employer must therefore have arrangements in place to cover health and safety, and that these arrangements must include:
• planning to eliminate risks • a suitable organisation structure • control systems to ensure decisions are implemented • monitoring and review procedures.
Health surveillance If the risk assessment shows the likelihood of employees, etc., being exposed to disease or adverse health conditions, the employer must introduce appropriate health surveillance.
Information for employees The employer must provide employees with comprehensive and relevant information on matters such as:
• the risks to health and safety identified in the assessment • the preventive and protective measures • the identity of the people nominated to assist in this safety work.
Training All employers must ensure that their employees are provided with adequate health and safety training. This should begin at recruitment, be supplemented whenever an employee is exposed to a new risk, and be ‘topped-up’ by means of refresher training.
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Working environment The Workplace (Health, Safety and Welfare) Regulations 1992 replaced many of the requirements previously laid down in the Factories Act 1961 and the Offices, Shops and Railway Premises Act 1963. The major provisions contained in the regulations are backed by approved codes of practice and deal with: ventilation, falling objects, temperature, windows and skylights, lighting, toilet and washing facilities, cleanliness, drinking water, room dimensions and space, clothing and changing rooms, workstations and seating, meals and rest, and floors.
Administration and enforcement of health and safety legislation The Health and Safety at Work etc. Act 1974 set up three bodies:
• The Health and Safety Commission. This advises the Government on future health and safety policy, and on strategy. It also helps to prepare new regulations. • The Health and Safety Executive. This carries out policies and is responsible for the Health and Safety Inspectorate. • The Health and Safety Inspectorate. This enforces the regulations. Health and safety inspectors have the right to enter premises to make inspections and at any other time if they have reason to suspect a dangerous situation. They have wide powers, and two principal weapons are: – Improvement notice. This is issued where the inspector believes that a statutory provision has been breached and that the occurrence is likely to be repeated. The notice will specify the breach and will lay down a period within which the situation must be remedied (minimum 21 days). – Prohibition notice. This is issued when the inspector is of the opinion that an activity involves a serious risk of personal injury. This notice will order the immediate cessation of the specified activity until the situation is remedied.
Appeals can be made to employment tribunals, but the employer must comply with the requirements of a prohibition notice until it is withdrawn.
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WAREHOUSE HEALTH AND SAFETY RISKS
Management and operators need to be able to answer the following questions on safety.
Health and safety checklists Layout • Has an up to date risk assessment (see below) been done on all hazards? • Are people/vehicles segregated? • Are one-way systems used? • Are aisle and gangway widths adequate to stop collision damage? • Are emergency exits marked, open and accessible? • Are surfaces flat and unobstructed? • Are markings clear and visible? • Is beam load guidance followed? • Are rack end uprights protected?
Floors • Is load bearing adequate? • Are floors slip-proof? • Are floors flat, level and free from holes/ ‘sharps’? • Do mezzanine floors have clearly marked safe load-bearing capacities? • Are all openings and edges guarded on mezzanine floors? • Are self closing gates fitted to mezzanine floors?
Heating • Is a reasonable working temperature maintained for people working in the warehouse, in recommended ranges from 18 to 28°C? (Where a high physical effort is needed, a low of 13°C can be acceptable.) • Where reasonable working temperatures cannot be maintained, such as in warehouses storing frozen food products, is an area available to allow employees to warm up?
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Lighting and visibility • Is lighting sufficient to give safe and workable conditions? (For example, minimum levels are receipt/despatch 30lux, racking 60lux, offices 100lux.) • Is documentation clearly written in large letters? • Do all packages contain clear details/marking?
Noise • Normal conversations are at 50–60dB(A), a loud radio is 70dB(A), and a busy road with lorry traffic is 80dB(A). Levels over 85dB(A) – for example, a circular saw cutting wood at a distance of 1 metre – require preventative action and levels over 140dB(A) require immediate action. A busy warehouse with exposure to goods vehicle engine noises can lead to such preventative action being needed.
Housekeeping • Are aisles kept clean? • Is there a check to ensure that stock does not project from racking/shelving? • Are spillages immediately cleaned up? • Are packing materials used the correct ones for the job? • Are waste packing materials contained and correctly disposed of?
Fire risk (Source: www.thefpa.co.uk. Reproduced by permission of the Fire Protection Association.)
• Is a written fire risk assessment in place? • Are fire procedures in place? • Are there emergency escape routes? • Is there emergency lighting? • Are the emergency routes indicated by signs? • What are the means of raising the alarm? • What are the means of fire fighting? • Is all the equipment maintained and up to date?
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• Has all staff had annual fire training? • Have the fire procedures been reviewed recently?
The Fire Precautions (Workplace) Regulations 1997 and the Fire Precautions (Workplace) (Amendment) Regulations 1999 cover the legal requirements and are published in www.hse.gov.uk (ISBN 0 11 341 1693). Meanwhile it should be noted that people cause the vast majority of fires in warehouses. Thankfully, arson is rare in warehouses, but the most common cause is human error with 40% of fires starting between 2200 and 0600 hours. The human error may be in failing to identify a risk, failing to have in place preventative measures, or failing to respond correctly and quickly to a fire that has just started. Accordingly, staff training is now a mandatory requirement of the regulations. All open fires and hot surfaces are sources of risk, such as shrink wrapping equipment, cutting/welding equipment, smoking and heaters. Such ignition sources need to be controlled and operated correctly in the right location. Electrical equipment is another fire source emphasising the need for adequate maintenance programmes and inspections. Key exposure areas come from high-intensity discharge (HID) lamps, where violent failures can cause fragments of 1000°C to land on vulnerable surfaces.
Organisation health and safety • Have all health and safety aspects of the warehouse operation been assessed? • Has an organisation (and arrangements) for securing such safety been detailed in the safety policy? • Has a person been appointed to be responsible for warehouse safety? • Have safe systems of work been set up? • What monitoring is carried out to ensure that the systems are followed? • Have all drivers/operators of mechanical equipment been adequately trained and tested? • Is there a satisfactory formal licensing or authorisation system for equipment users/drivers? • Have all personnel been trained, informed and instructed about safe working practices where warehousing operations are involved?
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• Is there sufficient supervision? • Has an update risk assessment been done on all hazards? • Are people/vehicles segregated? • Remember the Accident Pyramid: – For every one serious injury, there are 100 minor injuries. – For every 100 minor injuries, there are 1000 close calls. – Investigating the close calls can therefore cancel the one and the hundreds.
Warehouse external and internal roadways and aisles • Are they of adequate dimensions? • Are they of good construction? • Are they well maintained? • Are they well drained? • Are they gritted, sanded, etc., when slippery? • Are they kept free of debris and obstructions? • Are they well illuminated? • Are there sufficient and suitable warning signs? • Are there speed limits? • Is there a one-way system (as far as possible)? • Is there provision for vehicles to reverse when necessary? • Are there pedestrian walkways and crossings? • Are there barriers by exit doors leading onto roadways? • Is there a separate vehicle/equipment parking area?
Loading and unloading • Do loading positions obstruct other traffic, or do pedestrian ways need to be diverted? • Are there special hazards, e.g. flammable liquid discharge, and do pedestrians need to be kept clear? • Is there a yard manager to supervise the traffic operation, to control vehicular movement and to act as a banks man during reversing? • Has the yard manager received satisfactory training in the use of recognised signals, and has that person cover during absences? • Will the layout of loading docks prevent trucks falling off or colliding with objects, or each other?
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• Can any mechanical hazards be caused by dock levellers, etc? • Are methods of loading and unloading assessed? • Are all loads stable and secure? • Are safe arrangements made for sheeting? • Is there a pallet inspection scheme?
RISK ASSESSMENTS
Full risk assessments form a feature of the Health and Safety legislation. The six stages involved on conducting risk assessments are:
1. Gathering necessary information: for example, see the following manual handling task analysis. 2. Considering the elimination or reduction of hazards and assessing the level of risk. 3. Recording significant facts under 1 and 2 above. 4. Improving safety arrangements in relation to 1–3 above. 5. Recording the findings of the assessment. 6. Developing an emergency plan and carrying out necessary staff training.
Manual handling task analysis The following questions are a guide to analysing manual handling:
Tasks • Are loads held at a distance from the body? • Do body movements involve stooping or twisting? • Is excessive pushing or pulling involved? • Is frequent and prolonged effort involved? • Are there sufficient rest periods?
Load • Is it heavy, bulky, difficult to grasp, unstable, hot or sharp?
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Work environment • Does the space available prevent a good posture? • Are there uneven, slippy or unstable floors? • Are there variations in floor levels? • Are there poor light conditions? • Are temperature levels satisfactory?
Individual capability • Does the job require above average strength? • Is the job a hazard to people with special health needs? • Does the job require special training?
Manual handling principles As a result of wide-ranging research, in 2003 the HSE published the following principles:
1. Think before lifting: plan the lift and decide where is it going to be placed. Use handling aids as appropriate; do you need help with the load? Remove any obstructions; think of the best way to do it. If it is a long lift, is there somewhere to rest if necessary? 2. Keep the load close to the waist. 3. Adopt a stable position: have your feet slightly apart with one leg forward. 4. Get a secure hold: keep the load as close as possible to your body (hug the load?). 5. When starting, slightly bend your back, hips and knees: this is preferable to fully flexing/stooping or squatting. 6. Do not flex your back any further when lifting or when starting to lift. 7. Avoid twisting or leaning, especially if your back is bent: keep shoulders level and in the same direction as the hips; it is better to turn by moving your feet after lifting. 8. Keep your head up when handling: after securing the load look ahead and not down.
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9. Move smoothly. 10. Do not lift more than can be easily managed. 11. Put the load down, and then adjust, for example, by sliding the load into position.
Source: http://www.hse.gov.uk/research/rrhtm/rr097.htm (2003). Reproduced by permission of Her Majesty’s Stationery Office.
FORK-LIFT TRUCKS: HEALTH AND SAFETY
The following principles are involved to assist in ensuring that the employer’s duty of care is undertaken:
• Select only those operators who show a concern for health and safety. • Ensure that operators and supervisors are trained. • Ensure that driving is only undertaken by people who are authorised. • Ensure that pre-shift equipment checks are conducted. • Follow the manufacturer’s operating handbook. • Follow preventative maintenance practices. • Use equipment within the rated capacities only. • Ensure that the company complies with PUWER-98 (see above) and LOLER-98 (see below).
LOLER regulations The Lifting Operations and Lifting Equipment Regulations 1998 state that all lifting equipment (such as fork-lift trucks, pallet trucks, tail lifts on road transport vehicles, etc.), has to be thoroughly examined:
• at least every 6 months (if lifting people, or is a lifting attachment) • at least every 12 months for all other lifting equipment • after installation, and before using for the first time • each time lifting equipment has been involved in an accident.
This means that thorough inspections are required by a competent person who is sufficiently independent and impartial to make objective decisions.
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It can be seen that this requirement is very similar to the MOT required for cars and large goods vehicles. After the inspection, a report has to be completed for the customer and/or the employee, which notifies of any defects that are or could become a danger. Serious defects have to be reported to the Health and Safety Executive. Usually fork-lift truck suppliers can arrange inspections at an appropriate charge related to the speciality of the specific equipment.
Lifting operations Preparation When using cranes or other lifting machines, the load, the task to be performed, the lifting equipment and the site will all need investigation before undertaking the actual lift; this represents the necessary preparation to be undertaken (fuller details are available from Lifting Equipment – A User’s Pocket Guide, LEEA). The following will then need to be observed when undertaking the actual lifting:
Cooperation • The person responsible needs to ascertain that the people who are lifting have the authority to use the equipment and to make the lift. • The lifters should be able to clearly communicate with the crane driver and others involved by an agreed code of signals. • The activity will not conflict with other activities in the area or in the path of the lift.
Check the equipment • Does it have adequate capacity? • Will the speed of the equipment make it easy to control and position the load? • Is there adequate headroom for the height of the lift? • Is it possible to position the hook so that it is over the centre of gravity of the load?
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• If operating a special lifting installation, has it been tested and examined by a competent person?
Select the lifting gear The person responsible for the required lifting gear should ensure the following.
• If the load cannot support itself, additional support will be provided. • The load will stay together and pieces will not fall off. • The safe working load (SWL) for the lifting gear will account for both weight and type of use. • The load will not be damaged by the lifting gear or the environment. • The load can be controlled in the air, using a tag line if required.
Check the lifting gear • Is it fit for use?
Assemble the lifting gear • Position the hook vertically above the centre of gravity. • Attach the lifting gear so that all pieces can align correctly. • Hoist up to take up the slack, keeping parts of the body clear. • Check that the gear is correctly positioned.
Make a trial lift • Check that the load is still not fixed down. • Lift the load slightly off the ground.
Lift and travel with the load • Warn exposed people to clear the area. • Avoid obstacles and people. • Check that the landing site is prepared. • Lower the load, stopping just clear of the ground.
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Make a trial landing • Check the position and that packing materials/supports will support the load without trapping the slings. • Gently lower, but do not allow the gear to go slack. • Ensure that the load is safe and will be stable after removing the gear. • Slack off the gear and remove it by hand.
Clear up • Check the gear. • Return it to safe storage.
Maintenance and care of equipment The PUWER and LOLER regulations require that all equipment is maintained and inspected regularly so that it is kept in efficient working order. We therefore examine below what this means for fork-lift trucks and for racking.
Fork-lift truck maintenance This will be more readily facilitated by adhering to the following:
• What is on the manufacturer’s data plate? • Are you working within this data? • Are brakes, lights, warning devices, safety locks and overhead guards in safe and working order? • Are all drivers properly trained and do they attend refresher courses? • Are trucks maintained daily, weekly, six monthly, in accordance with the following checks? • Are drivers’ defect reports (see below) completed daily and acted upon?
Periodic checks • Daily check: At the start of each shift, check by the driver/supervisor. – Ensure that tyre pressures are correct (for pneumatic tyres only!). – Note and advise on any tyre damage.
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– Ensure that all brakes are operating efficiently. – Ensure that all lights are working correctly. – Check fluid levels, in engine trucks (fuel, water, lubricating oil, hydraulic oil). – Ensure that batteries, where appropriate, are adequately charged. – Ensure that lifting and tilting systems are operating correctly.
At the end of each check, a written report should be completed.
• Weekly check (or 50 hours or period recommended): Check by the supervisor/maintenance. – Agree with all daily checks. – Check the operation of steering, lifting gear and other working parts. – Check the condition of mast, fork, attachments and lifting mechanisms. – Check the hydraulic system for leaks/damage.
At the end of each check, a written report should be completed.
• Six monthly check (or 1000 hours or period recommended): Check by supervisor/maintenance. – Check all working parts.
At the end of the check, a certificate should be completed.
Racking maintenance and care This will be facilitated by the following:
• Is the racking on sound and level floors? • Was it installed in accordance with instructions? • Are double-sided runs connected and spaced with appropriate run spaces? • Is racking fixed securely to the floor? • Are the aisles wide enough to allow adequate manoeuvring? • Are the beam connector locks securely fixed at both ends? • Are the correct maximum load notices displayed?
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• Are all racks and beams aligned? • Are the correct pallets being used? • Is there any physical damage? • Are end protectors fitted? • When was the last inspection undertaken? • Is all reasonable care taken for accident prevention and racking safety? • Have there been any changes to product/handling equipment since the original specification?
People awareness Most accidents are a result of people not being adequately trained and, not reporting possible hazards or ‘near misses’. Remember the Accident Pyramid:
– For every one serious injury, there are 100 minor injuries. – For every 100 minor injuries, there are 1000 close calls.
Therefore investigating the close calls can cancel the ‘ones’ and the ‘hundreds’. Managers, therefore, can usefully ask if all the people involved are able to:
– define the best methods of carrying out the job – determine the right equipment to use – know how to operate equipment – know what dangers are associated with its use – know what the safety precautions are – clean equipment safely – know how to report faulty equipment – use the appropriate personal protective equipment.
Managers should also ensure that all people involved have undertaken formal training on safety hazards. Recall that a manager’s duty of care means that all individuals who report to them are aware of all potential hazards, that risks have been assessed and that corrective action has been taken.
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Where this has not been satisfactorily done and it goes ‘wrong’, then Magistrate’s courts can levy up to £5000 for each breach of regulations of Health & Safety at Work Regulations, plus up to £20000 for breach of the Health and Safety at Work etc. Act. Crown Courts give an unlimited fine and up to two years’ imprisonment. Additionally private prosecutions from ‘no win, no fee’ companies are increasing, putting individual managers potentially directly ‘in line’. The paperwork generated by this increasing trend causes additional work, time and effort.
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