Workplan 2012-13: Molten metal interventions

SIM 03/2012/06

Open Government Status: Fully Open
Author Unit/Section: DCE/OPSTD/Manufacturing Sector/Engineering, Metals & Minerals
Target Audience: All FOD visiting staff, Specialist Inspectors (Occupational Health, Occupational Hygiene, Mechanical, Noise & Vibration)

Summary
Introduction
Action
Background
Publication date
Review date
Appendix 1: Inspection organisation
Appendix 2: Inspection aide mémoire
Appendix 3: Further information on the industry and its initiatives

Summary

This operational guidance is about the 2012/13 planned workstream in FOD for the continuation of an inspection-based industry initiative in the high risk molten and basic metal manufacture sector. It also provides details of proposed FOILE type approaches to two large employers and information about SHAD events to be run by HSE Manufacturing Sector.

This work supports the Manufacturing Sector Strategy and Implementation Plan which aims to reduce the incidence of injury and ill health in molten metals workers in this high risk industry by targeting those higher risk activities through a programme of inspection visits and taking enforcement action where appropriate.

Introduction

The purpose of this guidance is to promote a consistent approach to inspection and enforcement in the molten and basic metal manufacture sector. It will also make FOD staff aware of the broader activity in this industry sector lead by the Manufacturing Sector.

Action

This work will consist of four main workstreams:

FOD Inspection (Band 3/4)

The main proposal for FOD activity in 2012- 2013 is for:

Undertake a series of 40 proactive inspection nationally during the 12/13 work year, focussing on safety risks within foundries, and on any obvious failure to meet existing standards for health risks (eg LEV, PPE).
This Inspection activity should examine the keys areas promoted in the HSE Strategy 'The Health and Safety of Great Britain \\ Be part of the solution' which are known to affect health and safety performance. Specifically:
1. Leadership – Is there clear leadership from the top of the organisation and does it permeate through the rest of the company structure.
2. Competence – are all workers suitably competent to carry out what they are asked to?
3. Worker Involvement – is the workforce involved in all aspects of the safety system.

NOTE: The FOD work proposal for 2012/13 is set against a background of broader activity by Manufacturing Sector with industry stakeholders through the Foundries Project.

The Foundries Long Latency Health Risks Project ("Foundries Project") is looking at foundry substance control with a view to establishing benchmarks for the industry and for HSE enforcement purposes. This work is being carried out in conjunction with Cast Metals Federation (CMF) and expects to report 2012/2013 with an expectation for a further inspection initiative in 2013/2014 based on the outcomes of the project.

FOILE (Band 1/2/3/4/VO)

National rollout of FOILE intervention with Tata (Corus), piloted in South Wales, to secure consistent health and safety performance across the Tata GB operations.

The South Wales pilot has had effective outcomes and good buy-in from the company and unions with impressive results (a European Benchmark Standard of 1 LTA per 100,000 man hours). It demonstrates performance can be improved but this requires HSE commitment and resource over the agreed timescale.

Manufacturing Sector will liaise with the relevant Band 1/2/3/4 resource allocated to the intervention.

FOILE intervention with SSI – Teesside

FOD Newcastle have already approached SSI to develop a relationship. The company are currently working towards starting production. Once this goal is reached they will be formally approached about an ongoing initiative.

Manufacturing Sector will continue to liaise with relevant FOD staff.

SHADs (Band 3/VO)

Sector organised and ran a successful SHAD funded by CMF in Q3 of 2011/12. This SHAD was for SHIFT (see below) members and it is planned that two more will be organised during 2012/13.

Sector has made an in-year bid for HSE funding for SHADs for non-SHIFT members.

Sector will agree with Divisions volunteering to participate, the arrangements for HSE- funded SHADs for which FOD (Visiting Officers) could contribute by assisting with delivery in conjunction with the Manufacturing Sector.

This awareness raising will support the Foundries Project and the LLHRD Dust & Fumes Project (foundry strand) in getting key messages on dust/fume control to targeted audiences. (See Further information).

Background

The Industry

'Molten metals' is made up of base metal production and manufacture of articles from molten metal. There are approximately 72,000¹ employed in the UK molten metal industry (SIC 24) by 1800 companies. 80% of which are employed by SMEs (50% by employers of less than 50). The main areas of production are W Midlands, Yorkshire, Humberside and the E Midlands.

The UK steel industry employs approximately 18,900² in 26 Companies, all of which are members of UK Steel, an affiliate of the Engineering Employers Federation (EEF).

There are 26 major production sites mainly in the areas a referred to above plus the North East, South and North Wales. Tata (Corus) is the largest employer.

There are about 800 companies engaged in the casting of metals employing approximately 18500. There are about 380-400 foundries; the Cast Metals Federation (CMF) is the leading foundry trade body with about 200 members.

Justification that it is 'high risk'

The industry has been identified as one of the high risk areas where proactive intervention is to be retained and that proactive inspection remains necessary as part of the overall regulatory support ('Good Health & Safety, Good for Everyone' – March 2011³).

Base metal production is inherently a high hazard industry due to scale/nature of operations, in particular during lifting/movement etc of large/heavy loads, and due to molten metal.
RIDDOR statistics for 2008/09 and 2009/10⁴ shows that SIC 24 has a high incidence rate (IR of 1014.3), and in particular SIC 245 'casting of metals' has one of the highest accident incidence rates in manufacturing with an IR of 1781.54. The Manufacturing Sector average is 771.8.
There are an estimated 14,000 workers in the foundry sector who are exposed, as a result of casting activities, to nickel compounds, silica and other substances presenting a risk of cancers, silicosis etc. A study of UK steel foundry workers found an almost 50% excess of lung cancer cases.

Footnotes

1. Data supplied by CSEAD Statistics Branch. Back to reference of footnote 1
2.Source: UK Steel. Back to reference of footnote 2
3. DWP, 21 March 2011. Back to reference of footnote 3
4. CSEAD injury rates for 2009/10 are provisional. Back to reference of footnote 4

Publication date

2 May 2012

Review date

2 May 2015

Appendices

Appendix 1: Inspection Organisation

Timing

40 Inspection visits are invited for 2012/13 and may be undertaken throughout the work year.

Targeting

Identification of dutyholders for intervention

(i) FOD Inspection

Although the molten metal sector is identified as high risk it is suggested the following hierarchy is used to identify premises for inspection in the period 2012/13:
1. Premises within SIC (2007) 24 to include:
  - 241: Manufacture of basic iron and steel and ferro-alloys (IR 864.9**)
  - 242: Manufacture of tubes, pipes, hollow profiles and related fittings (IR 488.9**)
  - 244: Manufacture of basic precious and other non-ferrous metals (IR 751.0**)
  - 245: Casting of metals (IR 1781.5**)
  and
2. Not a signatory to SHIFT
  or
3. meeting definition of "poor performer" (as defined in the FOD Intervention Categories)
  
  Initial inspection activity, ie in 2012/13, should focus on those parts of the steel sector where there is poor performance and those foundry companies within scope which are not signed up to the SHIFT strategy (for which there are targets and stakeholder engagement activity). However, if a SHIFT member meets the definition of poor performer then it is within scope for inspection this year. The aim is to defer inspection of the "foundry" sector so that the results of the Foundries Project can be built into any subsequent inspection intervention proposed for 2012-2014).
  
  FOD Divisional Intelligence Officers should contact Manufacturing Sector to assist in targeting of premises for inspection.
Where should the work be done
Geography is relevant. Steel plants are concentrated in Wales, Yorkshire & NE and Midlands Divisions.

Foundries follow a broadly similar pattern of distribution.

Steel and Foundry sites will be supplied to FOD Divisions by Sector in May 2012.
Who should do this work
The Inspection workstream should be undertaken by Band 3 Inspectors.

The FOILEs should be carried out in accordance with operational guidance.

The SHAD should be undertaken by Sector staff supported by VOs with participation by Band 3/4 for development purposes if required.

SG Inspector input may be required to support enforcement action

Note: Molten metal PPE is likely to be required by visiting HSE staff. This should be taken into account when allocating the work.
Feedback/info gathering
No special reporting arrangements apply. Normal COIN work recording arrangements apply to this work.

Manufacturing Sector will interrogate COIN records with the aid of Qlikview but would be pleased to receive any narrative information on exceptionally good or poor practices.
Outputs
EMM justified enforcement action (notices, prosecution) will be monitored by Sector at Quarterly–reporting intervals. This information will be fed back to Foundries Advisory Committee, trade bodies and the Foundry Partnership Team as motivators for improved compliance by those not visited.

Injury-reduction will be monitored through CSAG outputs of RIDDOR data and injury statistics collected by trade bodies.

Inspection/enforcement standards guidance and support
RDNA: Inspectors should have undertaken the FOD Specific Knowledge Molten Metal module of RDNA to assess their knowledge and identify development needs, using the associated GRIP
- Support for operational activities:
  - Sector can provide or source support for Inspectors on technical and enforcement issues is available from the Engineering, Metals & Minerals team of the Manufacturing Sector (see Sector Contact).
  - Support for inspection/enforcement should also be available from the relevant Specialist Group
  - Advice should be obtained from an Occupational Health/Medical Inspector before taking any enforcement action regarding health surveillance
  - An Inspection aide-memoir to assist with inspection is reproduced at Appendix 2
Background information on casting processes may be found at the Cast Metals Federation website.

Outcomes
1. Inspections: delivery of key messages relating to HSE strategy and to raise awareness of industry-specific hazards/risks and control measures with a view to securing improved compliance through appropriate enforcement action. Targeted hazards to be used as indicators of the effectiveness of health and safety management.
2. FOILE: to secure improved performance across the Tata group using the S Wales model as a benchmark and ensure a consistent approach by HSE in interventions with a major company.
3. SSI FOILE – early and ongoing intervention to secure effective management of health in safety in high risk industry from the start.
4. SHAD: to raise awareness of key issues on hazard and risk control for those employers, primarily SMEs, not included in the initial inspection phase.

Diversity

Visiting staff should be aware of the diversity needs of the target group. They should give consideration to, and factor in issues such as literacy, English as a second language and disability (eg access needs).

The Diversity & delivery intranet pages give more information on these and other issues, including the communications and EIA toolkits.

Health and safety issues

Please note the Health and Safety Supplements relating to site visits.

Appendix 2: Inspection aide mémoire

Molten metals - Inspection aide mémoire

Introduction

This document provides guidance to Inspectors on the inspection of work premises where basic and molten metal products are manufactured. It provides details of the key hazards and what to consider as you go through the inspection process. It also provides links to more detailed guidance on the HSE Molten Metals website.

The Industry

There are approximately 400-450 foundries operating in Great Britain with approximately 25,000 employees. They generally use iron, steel, aluminium and copper with a few other more specialised foundries using zinc and magnesium. The process of casting has evolved considerably over time and foundries now employ a range of processes depending on the metal, shape, quantity, size etc of the component required. Detail on the various casting processes used can be found on the Cast Metal Federation website at the Casting processes section.

Trade Association

The Cast Metal Federation (CMF) is the main trade association for the industry. CMF sit on the Foundry Industry Advisory Committee (FIAC) along with representatives from individual foundries, The Casting Technologies Institute, the Unions and HSE. CMF run the Safety and Health Foundries Targeted Initiative (SHIFT). This initiative was set up with the aim of reducing the number of accidents in the sector by focusing on the main causes of accidents and ill health. It has helped to reduce the number of accidents amongst its members by over 40% over the last five years. HSE is now working in partnership with the CMF in a Long Latency Health Risks project looking at controlling exposures to dusts and fumes within the foundry environment.

Inspectors should ask dutyholders if they are a member of the CMF or if they are aware of the SHIFT initiative. Details of both can be obtained on the respective websites or from the manufacturing sector.

Guidance

The aide-mémoire below provides links to much of the relevant guidance. Further operational guidance can be found via links on the relevant GRIP page within the RDNA tool.

Whilst some of the guidance signposted is old, it still gives valuable background information and improves knowledge of the industry sector.

Inspection aide mémoire - Topics to consider during a Foundry Inspection
Issue	Problem areas	Standards/Action	References
Machinery Guarding	Check guarding on: Wood machinery in pattern shop Mould and core making machinery Sand handling equipment Shake outs, sand mixers and shotblasts	Ensure guarding in line with PUWER and specific guidance sheets. Consider interventions, maintenance and cleaning of machinery.	FNIS 2: Foundry machinery guarding – Introductory sheet FNIS 3: Foundry machinery guarding – mould and core making machinery FNIS 4: Foundry machinery guarding – sand handling equipment FNIS 5 – Foundry machinery guarding – Shakeouts, sand mixers and shotblasts PUWER 1998
Noise	Fettling, dressing, rumblers, shotblasting	Check that the hierarchical approach for control of noise has been considered: Noise risk assessment Elimination if possible- better mould design to reduce need for removal of excess metal Purchasing policy on new machinery such as grinders etc. to ensure noise levels are acceptable. Automation of fettling and shotblasting where it is reasonably practicable. Enclosures and separation of fettling in appropriate booths Personal hearing protection Health Surveillance	Hazards associated with foundry processes: Fettling – noise hazards Control of Noise at Work Regulations
Vibration	Fettling, dressing	Check that the hierarchical approach for control of vibration has been considered: Vibration risk assessment carried out with appropriate vibration data used. Has risk control been considered correctly? Elimination through alternative methods Low vibration tools selected Suitable purchasing policy Tool maintenance Work station design Work schedules/rotation Health surveillance	FNIS 8: Hazards associated with foundry processes: Hand-arm vibration – the current picture FNIS 9: Hazards associated with foundry processes: Hand-arm vibration – symptoms and solutions FNIS 11: Hand-arm vibration in foundries: furnace and ladle relining operations FNIS 12: A purchasing policy for vibration-reduced tools in foundries Hand-arm vibration in foundries L140: Hand-arm vibration – The Control of Vibration at Work Regulations 2005 HSE Vibration website – foundries page Vibration Calculator
Molten metal burns	Melting and casting	Have working methods been designed to reduce the risk of spills and splashes of molten metals AFAIRP? Has an appropriate assessment for the need for and selection of suitable molten metal PPE been carried out? During selection of PPE you should consider: Work practices and methods Other controls in place The metal and quantities likely to be splashed The level of PPE required as described in EN 11612 PPE cleaning and maintenance Is the selected PPE worn and is this monitored?	The selection, use and maintenance of molten metal protective clothing EN 11612
Lifting and slinging	Large casting boxes, irregular shaped castings, harsh working environment	Have the risks been appropriately considered? Look for evidence of planning for unusual lifts. Has appropriate equipment been selected? Are slings, chains etc, stored appropriately and checked before use? Is lifting equipment thoroughly examined? Has training been carried out?	Safe use of lifting equipment. Lifting Operations and Lifting Equipment Regulations 1998
Dust	Casting, fettling, furnace wrecking, sand recovery. Respirable crystalline silica from sand processing and handling can be generated in many areas of the foundry	Look for the following methods of control: Enclose all sand handling plant where it is reasonably practicable Look for enclosures at mould and core making where possible Look for extraction at knock out booths and shake out tables Significant sand residues on castings should be removed by enclosed shot blasting where possible Fettling should be carried out in extracted booths All extraction equipment should be maintained and tested Air monitoring should be carried out to check if the WEL of 0.1mg/m3 is being met. Where the WEL is not being achieved with other control methods RPE must be provided. Fit testing must be carried out by a suitably competent person. RPE must be suitably maintained and stored Training in all areas of control of exposure to silica is critical.	COSSH essentials for foundries FD0 – Advice for managers FD4 – Sand plant FD5 – Core making and shell moulding (small scale) FD6 – Knock out, shake out etc FD7 – Fettling small castings FD8 – Fettling large castings Controlling airborne cabinets at work – HSG 258
Fume	Mould and core making, casting Possible exposure to a number of different chemicals generally associated with the binder systems used in mould and core making. The following chemicals have been found in monitoring carried out in foundries: Metal fume Furfuryl alcohol Benzene Toluene Formaldehyde Isocyanates Aniline Polycyclic aromatic hydrocarbons (PAH)	Look for evidence of the following: COSHH assessments and an understanding of what fumes may be given off from the binder systems in use and other processes Has consideration been given to the possible substitution of a binder system if it produces harmful fume during the production process Look for high level air vents or extraction fans and low level air inlets Look for good general ventilation LEV at mould and core making as above RPE as above	COSSH essentials for foundries FD0 – Advice for managers FD1 – Fume: General ventilation FD2 – Molten metal fume: Melting FD3 – Molten metal fume: Pouring and casting FD12 – Spray coating a large casting (open workshop) Relevant chemical publications for Foundries
Transport	Delivery of raw materials, despatch of product. Loading and unloading, transport of molten metal	Look for WPT site risk assessment. Have they considered how vehicles are loaded and unloaded If molten metal is transported are the risks controlled	HSG 136 Workplace transport safety - An employer's guide Load safety website

Appendix 3: Further information on the industry and its initiatives

HSE chairs the Foundries Advisory Committee (FAC) which facilitates stakeholder engagement and influence.

Current work includes:

Foundries Long Latency Health Risks Project: this is a major HSE/HSL/industry research project which is intended to identify realistic benchmark standards for control of exposure to hazardous substances.

Industry is facilitating the site work by providing sites for the project and will use the information gathered to generate products (eg guidance (written, web-based), toolbox talks, toolkits, DVDs etc) which will be made available to help duty holders comply with the law.
Safety & Health in Foundries Targets initiative (SHIFT): The initiative was launched in July 2003, in response to the Revitalising Health & Safety agenda. After a period of inactivity it was re-launched in 2007 with the introduction of quarterly SHIFT Forums to explore current health and safety issues, share good practice and provide networking opportunities for problem solving. Lead partners are Cast Metals Federation (CMF) / Foundries Advisory Committee (FAC).

Its key targets and objectives are:
- Reducing accident rates over a 5-year period by 30% in-line with RHS; and
- Recording accident rates accurately, as RIDDOR classifications are not adequate for the foundries industry. Once a true picture is obtained, it will be easier to identify and tackle the key issues.
  
  The initiative is open to non-trade association members.
  
  There was an industry re-commitment to the initiative on 20 March 2012.
Aluminium Industry Made Safer (AIMS): This scheme was launched in March 2007 by the Aluminium Federation (ALFED).

Its Key targets and objectives are:
- To achieve a 10% reduction in lost-time incident rate (compared to a 2006 baseline) over a three year period to 2010
- To promote effective risk management by:
  - Sharing good-practice
  - Organising demand-driven workshops on specific topics
  - Holding a biennial safety conference for members
  - Providing the opportunity for networking
  - Liaising with regulators
- Members are required to sign up to AIMS, produce an action plan and submit LTI statistics annually to the Aluminium Federation (ALFED). The scheme is monitored by the ALFED Health & Safety Committee.
  
  The scheme is open to non-trade association members. It is free for ALFED members. For non-trade association members there is a small fee.
HSE LLHRD Dust & Fume Project – Foundries Partnership: this project is intended to deliver key messages eg through posters, pocket cards etc to secure behavioural change in employers and workers leading to improved control over exposure to hazardous substances. This work is now delivered through FAC.