Alison Cook, lead consultant at mangosafety.co.uk, enjoys working with the waste industry to secure sustainable safety performance. Here she explains how to address the potential health and safety hazards around workplace transport
Workplace Transport Risk – Don’t Drive Blind into Danger
Leedale Limited, an earth moving business with a turnover in excess of £6m, were prosecuted by the Health and Safety Executive (HSE), in 2016. Leedale had crushed their employee, Mr Lambert, to death, between their own parked heavy goods vehicle and a reversing one. While I was still working for HSE, I clearly recall attending the scene with police and a colleague in order to start the investigation and identify what immediate improvements in health and safety were needed on site.
Before working with industry, I spent 16 years at the HSE; repeatedly experiencing the impact a serious incident has upon individuals and businesses. Working with thousands of firms in different industries to improve their health and safety, I know what secures effective risk control. But what always concerns me is how blind directors and managers can be to the actual risks they are exposing workers to. In the waste industry, workplace transport (WPT) is one of the biggest causes of deaths and major injuries – but because it is a ‘low frequency’ event, optimism bias takes over – it hasn’t happened today, why would it go wrong tomorrow?
Top Workplace Transport Tips – Be Intentionally Safe:
Know your own WPT risk profile
Acknowledge that the HSE views waste and recycling as a high risk sector. Your profit is driven by at source segregation, volume and commodity prices. This means that vehicle movements and yard congestion is affected by stock levels or process waste volumes. Risk profiling is understanding what your significant mechanisms of harm are, their potential impact, your key controls to reduce the likelihood of an incident, how well those controls are in place and ensuring key decisions that impact your risk control are carefully considered.
Often waste firms forget that:
- Your risk profile changes as your level of activity or inventory changes – review your controls when you increase volume of throughput on sites to see if people are still safe on site.
- Risk profiles for each site will be different. Is one site smaller and busier than the others?
- Directors need to monitor aggregate risk profile – are there common themes in how risk control is failing or is there best practice to share from one site to your other sites?
Set a clear standard of WPT risk control:
Ensure you have clearly identified, through risk assessment and an effective traffic management plan, what controls stops your business from running people over. A traffic management plan maps out how vehicles, mobile plant and pedestrians circulate on your site. Ensure it follows the legally required principles of prevention (Management of Health and Safety at Work Regulations 1999, Regulation 4, Principles of Prevention within schedule 1). These require you to go for the easy wins where you can:
- Eliminate un-necessary vehicle movements and pedestrians.
- Where you cannot eliminate, go for segregation of pedestrians from vehicle/mobile plant movements by time, distance or barrier.
Honestly measure how well you control WPT risk:
You should have in place a risk assessment and audit arrangements. However, what I often find missing is a measurement of actually how well these management arrangements contribute to risk control on site. Frequent failings include:
- Risk assessments that don’t cover the scope of the site operations, such as work outside daylight hours.
- Risk assessments do not measure risk (number of movements vs pedestrians) and don’t decide upon realistic fit for purpose risk control.
- Audits that measure if you have a risk assessment, if it has been reviewed and if persons are aware of them. Such audits do not tell you if the assessment has resulted in effective risk control or not!
- Audits that are not tailored to your risk profiled priorities, including WPT.
I used to be an HSE Inspector. So I know that at waste sites the HSE will be looking for robust arrangements to control the risks from workplace transport. These controls must follow the hierarchy of control measures as it is the easiest way to reduce the risk. They will look at your assessment and if it does not cover your activities, or if it includes phrases such as ‘where possible’, this will be taken to indicate that you have not decided what risk control measures are appropriate and therefore that you are not controlling WPT risk. This the worst failing of all; your business knows WPT poses a serious risk, yet your arrangements indicate that you think a risk assessment equates to compliance. It doesn’t. And, more importantly for your workers, it doesn’t equate to risk control.