Workplan 2012-13: FOD Visits to Motor Vehicle Repair (MVR) premises using isocyanate containing paints and lacquers, and/or two post lifts
SIM 03/2012/05
Summary
This guidance sets out FOD's proactive contribution to delivering the Manufacturing Sector priority for intervention activity in MVR. No specific number of visits is required, but the information in the SIM will be of use to FOD Band 2, Band 3 Inspectors and DIOs in identifying appropriate premises for proactive inspection on:
- Respiratory ill health associated with the use of isocyanates (in 'two pack' paints), and/or
- Safety risks arising from the use of two post lifting equipment.
These matters could also be pursued where a reactive visit is carried out and it is appropriate to undertake an inspection.
Introduction
The purpose is to improve health and safety outcomes by reducing the incidence of serious injury and ill health within MVR premises.
These inspections are a component of the overall intervention strategy ie to provide feedback to the dutyholder and employees identifying areas of concern, taking enforcement action where appropriate. The inspections complement promotional Sector activity on these two issues through trade associations and media. The Sector will use COIN data to feedback information on FOD activity to industry stakeholders.
Action
Visiting staff are asked to carry out inspections in appropriate MVR premises during work year 2012/13; such visits may be proactive or immediately following an investigation. It is expected that enforcement action will be taken where appropriate, in line with the Enforcement Management Model.
Background
1 Paints containing isocyanate
Isocyanate is the biggest single cause of occupational asthma (OA) in the UK and 'vehicle paint sprayers' are the work group at greatest risk. It is estimated that this group is 80 times more likely to suffer occupational asthma than the average UK worker. Allowing for under reporting it is estimated that upwards of 50 cases of OA occur each year to vehicle paint sprayers. Most sufferers will not continue to work in MVR. This is despite the fact that air-fed RPE has been increasingly supplied to, and used by, MVR paint sprayers.
'Two pack' paints contain isocyanates and are used in virtually every MVR bodyshop. There is currently no other product that gives such a hard wearing, and high quality finish. 'Water-based' paints frequently contain isocyanates and there is no isocyanate-free topcoat (ie lacquer). The paint industry continues to research substitute paints but any paint having similar properties is likely to be highly reactive and have similar adverse health effects.
More needs to be done to ensure that :
- suitable rpe is being supplied, used and maintained;
- sprayer behaviour doesn't result in inadvertent exposure;
- biological monitoring of sprayers is carried out (to help identify where higher exposures are occurring before the onset of symptoms and asthma).
2 Two post lifting equipment
Between 2004/05 and 2009/10, the average number of fatal incidents in MVR was 5.4 per year. The incidence rate far exceeds the average for the manufacturing sector as a whole. The majority of these incidents involve lifting incidents where persons become trapped under vehicles. Two post lifts are now the dominant vehicle lifting equipment used in MVR and reports of vehicles falling from this equipment are becoming more frequent.
Several factors can lead to these incidents (alone or in combination) including poor design, manufacture, installation, use and maintenance. In particular the design of the arm locking mechanisms and the 'free play' in the telescopic arms continues to cause concern. In use, vehicles must be positioned on the arms properly to ensure stability. Problems can be compounded by operators applying forces to the elevated vehicle and by removing or installing large components (eg gearbox) which alter the centre of gravity. Operators seldom check whether the automatic arm locks are fully engaged.
Targeting - Identifying premises for proactive visits
The MVR industry sector has large numbers of dispersed small/micro businesses, but MVR activities are also carried out within larger organisations across industry. Good health and safety performance is more common across national chains involved in vehicle servicing and parts replacement, also where linked to sales of internationally recognised vehicle brands. The Manufacturing Sector Strategy identifies this differential and divides the motor vehicle repair industry into two distinct groups:
- all bodywork repair and refinishing businesses, and small and micro businesses carrying out mechanical repair.
- workshops attached to vehicle showrooms of internationally recognised vehicle brands, and to national chains involved in vehicle servicing or parts replacement.
Proactive inspections should be paid to premises in the first group as this is where our robust evidence and intelligence indicate that health and safety is of serious concern and where inspection is the most effective intervention to secure compliance. The second group should not normally be targeted for proactive inspection work.
SIC 2007 code 45200 will identify the vast majority of standalone garages and bodyshops. Some other SIC codes may be used on COIN (45111/45112) for the sale of new and second hand cars where some MVR activity takes place. MVR activities may also be found in industries which have and maintain their own vehicles (eg for goods delivery) although more likely in the 'transport' sector, for example where servicing is undertaken in-house at transport undertakings (SIC 49410) or at coach/bus operators (SIC52213).
Divisional Intelligence Officers (DIOs) can produce lists of possible premises using the above SIC codes, coupled with employment numbers (to concentrate on small or micro businesses) and local knowledge about whether the premises is connected to a showroom of an internationally recognised vehicle brand, or to a national chain involved in vehicle servicing or parts replacement.
Work recording
Report through normal COIN arrangements. Manufacturing Sector would be pleased to receive information on exceptionally good or poor practices.
Further information / links
The Manufacturing Industries – Sector Strategy
Isocyanates:
- HSG 261 H&S in MVR and related industries (Paragraphs 45 - 134)
- INDG 388(rev1) Safety in MVR – Working with isocyanate paints
- Inspection Topic Pack "Control of isocyanate exposure in motor vehicle repair (MVR) bodyshops Disease Reduction programme"
- COSHH Essentials sheets MR(0 to 5) series covering isocyanates in paints
- Web36 Management of Spray Booths and Spray Rooms
- SIM 03/2012/01 Reducing ill health from isocyanate exposure in the motor vehicle (MVR) industry
Two post lifts:
- HSG 261 H&S in MVR and related industries (Paragraphs 193 – 199)
- INDG 434(rev1) Working safely under motor vehicles being repaired
- SIM 03/2010/2 Risk of vehicles falling off two post vehicle lifts in MVR
- SIM 03/2008/12 Defective locking devices identified on modern 2-post lifts
Contact point(s) for further information
Manufacturing Sector/Engineering Industries Team, Birmingham