Ensure you keep your staff out of the danger zone
Monday, July 18, 2016
On the whole, print has a reasonably good safety record. According to the Health and Safety Executive’s (HSE) annual statistics, the printing sector has a lower accident rate than associated industries such as paper and board production.
Yet there is certainly no room for complacency. Sloppiness has potentially terrible ramifications. Several years ago, the HSE issued specific safety requirements for using hand-fed platen (die-cutting) machines following five fatal accidents around the world since 2007. Two of these deaths occurred at UK printers.
More recently, a less serious but still nasty incident saw a printer in Leeds fined £18,000 plus costs in 2015 after a production worker had the end of his thumb severed in a gluing machine. The HSE found the front of the unit where the worker was injured had no guarding and that employees had not been provided with adequate instructions.
“The main risks within the industry are slips and trips, guarding of machinery, manual handling and dermatitis,” says BPIF Head of Health, Safety & Environmental Lynda Taylor. “The BPIF team undertake health checks to our members on a daily basis and these seem to be the main areas where companies don’t have any control or systems in place. The majority of firms [where issues are highlighted] have insufficient guarding on their machines and poor risk assessments which are leaving companies open for improvement/ prohibition notices from the HSE.”
There is, of course, a cost attached to falling short of HSE standards. The ‘Fee For Intervention’ (FFI) for a material breach of H&S laws was introduced in late 2012 and currently stands at £129 per hour. The amount of money HSE may seek to recover through FFI has caught a number of businesses by surprise and appears to be escalating.
The total is based on the amount of time it takes HSE to identify and conclude its regulatory action in relation to the material breach. This includes associated office work rather than merely time spent on site by inspectors addressing the issue. The time spent is multiplied by the hourly rate, including part hours.
According to a report in Health & Safety at Work magazine in September 2015, the average cost of an FFI invoice issued by HSE is £715 – a 40% rise on when the scheme was first brought in three years earlier.
Unsurprisingly, manufacturing has a higher total exposure to FFI costs than any other sector.
The recipe for avoiding HSE penalties – or indeed, far worse – should come from the top, leadership teams need to set the right tone and demonstrate genuine commitment to H&S.
“Having strong and effective leadership in the organisation is important,” says Jo Carter, technical publications officer at the Institute of Occupational Safety and Health (IOSH), the chartered body for
health and safety professionals. “Committing to protect employees from incidents and by ensuring that they are healthy and safe in the workplace is not only a legal requirement but essential to a successful business. This can be done by developing and monitoring health and safety management systems, setting good examples by following procedures and motivating employees to participate to ensure effective health and safety in the workplace is carried out.”
An effective way of managing risks in the workplace and producing a high-performing workforce is through engagement. Carter says that by giving a workforce the right skills and getting them more involved shows that their health, safety and wellbeing is being taken seriously. This, she asserts, is more likely to create a culture where employees will raise concerns and offer solutions but also to generate greater awareness of workplace risks and how to control them more efficiently.
IOSH’s guide Promoting a Positive Culture recommends that “employers should find out what their managers and employees actually believe about health and safety and make clear what’s expected of them in terms of health and safety values, beliefs, attitudes and practices and consider the most appropriate interventions to address any differences between expectations and reality in the organisation’s health and safety culture.”
At Wyndeham Group, the circa £130m magazine and commercial print group, which employs more than 1,000 staff, Miranda Hayward has the unusual title of group HR/HSEQ/IT director. As part of a lean structure designed to aid effective reporting and decision making, Hayward covers these three important overlapping areas and provides a direct link between managers and the board so any problems highlighted can be quickly resolved.
“The significant risks to health and safety of individuals at work, come from contact with moving machinery like forklift trucks and conveyors, manual handling and slips trips and falls,” says Hayward.
“Ensuring the appropriate processes are in place for individuals to follow with regard to stopping machines as needed to clear jams and not take risks, ensuring all guards are in place and a guard check process is in place daily and ensuring good housekeeping standards are maintained, and all receive induction training which includes manual handling and regular updates, are key to managing these risks.”
Companies need to be mindful of the Provision and Use of Work Equipment Regulations (PUWER). Time and again, BPIF’s Taylor points out, printers fall into the trap of relying on the CE marking in the belief it complies with the regulations.
Another issue is the age of machines. Taylor says she constantly hears that machines ‘were installed and came like that’. This is not an acceptable excuse. When the PUWER regulations were adopted in 1998, companies had 10 years to retrospectively fit guards to all machines. The regulations are explicit in stating that if there is access to moving parts, then the machine has to be guarded.
However, as the print industry evolves to become more automated, with greater emphasis on use of technology such as digital printing, the focus for H&S risks is turning towards manual handling issues. Work-related lifting or posture may trigger musculoskeletal disorders (MSD).
“There is always a need for staff to lift and move printed product within the factory, until this process could become cost-effective to automate – which is a long way off,” says Delga Press Group operations director Ian Conetta. “We find that as litho printing presses are on the decline, the types of injuries which were more common 20 years ago such as trapped hands in rollers or dropping cylinders on feet are becoming very rare. It is more likely that someone may get carpal tunnel syndrome now from a repetitive task such as working in a pre-press studio, hunched over a desk.”
What is the best way, then, to go about setting up effective H&S policies? Ideally the statement should be written by people within your organisation as they have the clearest idea of how you operate. Informed external advice can be extremely valuable, however, although it is always important to ensure the policy is appropriate for the needs of your business and mindful of business objectives and targets.
“Large organisations are expected to retain at least one member of staff qualified to NEBOSH (The National Examination Board in Occupational Safety and Health) General Certificate level, if not to the higher Diploma level – as we do,” says CFH Docmail operations director/deputy managing director Adam Harwood. “This provides essential consultative resource in awareness, advice and review to ensure best practice. We supplement this by training key staff in IOSH managing safely. The policy will benefit from staff input due to their day-to-day experience and this will give a better route to gain commitment in delivering the aims of the policy.”
CFH Docmail is a large organisation with multiple sites. To address this, it has in place an overarching corporate policy that covers general issues. It is supported by more detailed policies relating to individual sites or activities. This, says Harwood, allows the definition of responsibilities and gives control to individual site management.
Communicating a policy is of course essential and there is a range of options here. If it is short enough, you may decide to give a written copy to each employee.
For larger organisations or if your policy is lengthy, channels such as notice boards, intranets and group briefings may be used. It is important that all communication uses clear and concise language to ensure maximum effectiveness and understanding. But it shouldn’t stop there. “Monitoring that the policy is still effective is vital,” says Harwood. “There are many ways that this can be done, including carrying out spot checks or safety inspections using prepared checklists. More formally, effective monitoring can be achieved through audits and by reviewing management reports and accident investigations.”
At CFH Docmail, the review process is consolidated and managed by the implementation of a Health and Safety Committee with full representation from all levels of the business. There is also an annual review “that will inform necessary changes to the policy and other relevant instruments”.
There is more to H&S than regulatory must-haves. Experts believe that those businesses prepared to go the extra mile may reap commercial rewards.
IOSH’s Carter says that ensuring employees are healthy and safe in the workplace is not only a legal requirement but essential to a successful business, while the BPIF’s Taylor points to “improvements in morale, a happier workforce and a reduction in accidents and time off” at companies that give it serious attention, adding that by providing guidance on how to implement H&S effectively and the best way to involve the workforce improves quality and production. In other words, a safer business is a better business – and not just in terms of its employees’ wellbeing.
Rules & regulations
The Health and Safety at Work Act, 1974 and the Management of Health and Safety at Work Regulations, 1999 make it a legal requirement to ensure that adequate provisions are made to ensure that the health, safety and welfare of the workforce and others who may be affected by the work activities are managed effectively
To comply, employers are required to identify the risks arising from their work activities
Risk assessment findings need to be recorded
A health and safety policy will also need to be written. This doesn’t have to be very complicated but does need to be carefully prepared and well thought out; it will need to be followed by the workforce and be regularly reviewed
Consulting the workforce by providing them with training and information is not only a legal requirement under health and safety regulations but benefits the workforce by ensuring they are competent to carry out the work effectively, leading to a more efficient workplace
Further regulations that apply to the print industry include the Control of Substances Hazardous to Health Regulations 2002 and the Provision and Use of Work Equipment Regulations (PUWER), 1998. Organisations can comply with these regulations by: assessing the risks; deciding how to prevent harm; providing control measures and making sure they are used; keeping all control measures in working order, providing information, instruction and training for employees and others; providing and monitoring health surveillance where required; and planning for an emergency
Getting your policy right
All companies in the printing industry with five or more employees should have an up-todate written statement of their H&S policy. The policy should be owned and signed by the most senior person
It needs to hold certain information, including a statement detailing how safety will be managed and how the company will commit to health and safety effectively
There should be a section on responsibility, detailing where responsibilities are allocated and how employees fit into the management system
There should also be a section detailing the arrangements, such as information about how specific activities and functions that have been set out in the statement will be managed
The expectation is that you should be striving to achieve continuous improvement in health and safety at work
Although the policy should ideally be written by someone senior internally, it may make sense to seek advice from an external expert
There are no hard and fast rules about the length of the policy. The important thing to remember is to link the aims of the policy to the level of risk
A robust risk assessment process will determine how explicit you need to be in the arrangements section
Your H&S policy requires you to address the health and safety matters relating to employees and those affected by your work. As such, many organisations broaden the scope of their policy to take into consideration the safety of others who might be affected by their activities, such as volunteers, contractors, visitors and the general public
Your safety policy should include arrangements for monitoring implementation as this is a regulatory requirement
Monitoring should include spot checks and more detailed inspections. Reports of all accidents, near misses and ill health caused by work should be studied to identify emerging trends or patterns. If improvement is necessary, you must act
First aiders & fire marshals
There is specific training for first aiders and fire marshals, with different rules for these depending on the types of risks and the organisation. Requirements should be decided by the outcome of a risk assessment
There must be a written fire risk assessment for every one of your premises. As Aviva notes in its risk management for printing industry advisory, this should outline the nature and location of possible fire hazards, how fire is detected, how warnings of fire are communicated, what fire-fighting equipment is provided and where it is located, and how people can safely evacuate the building in case of fire
Employers should find out what their managers and employees actually believe about health and safety and make clear what’s expected of them in terms of health and safety values, beliefs, attitudes and practices and consider the most appropriate interventions to address any differences between expectations and reality in the organisation’s health and safety culture
Involving staff in health safety policy and arrangements promotes positive attitude, inclusion and a healthier working environment
Be sure to communicate your H&S policy to employees effectively. The language you use should be clear, concise and easy to understand
With or without a written policy, all employers have a duty of care to protect their employees and others from harm arising from work activities
Ensure that all providers of advice and training hold accredited qualifications consistent with HSE guidelines
The HSE has produced several publications relating to particular hazards relevant to the printing industry as well as the overall Printer’s Guide to Health & Safety