Background

1 The aim is to achieve a major reduction in risk of serious or fatal injuries to people involved in clearing blockages or performing running repairs inside dangerous machines due to unexpected start-up and confined space work. This will be achieved by:

1. raising awareness about the risks and standards required for safe isolation and lock off and safe entry to confined spaces;
2. ensuring, through formal enforcement, that robust isolation and lock off procedures for machinery and robust safe systems of work for entry to confined spaces are implemented; and
3. ensuring that employers have, or put in place, sound risk control systems for managing these procedures.

Action required

2 Questionnaires with guidance notes have been produced for use during machinery and confined space inspections. These can be found at Appendices 1 Safe Interventions Enforcement Initiative Machinery Safety [202KB], and 2, Safe Interventions Enforcement Initiative Entry Into Confined Spaces [174KB]. Completed questionnaires should be sent to the national project manager as outlined in para 8. Examples of issues to consider include:

1. Is the hardware right?
2. Are the procedures right?
3. Does the employer have an adequate risk control system for managing those procedures and maintaining the hardware?

3 Note it isnt necessary to witness directly the isolation and lock-off procedures for a particular machine or entry into a confined space (this will often not be practical) evidence around this can be obtained from documentation and through discussions with management and importantly employees or contractors who carry out the interventions.

4 This is an enforcement initiative and where standards are found to be below minimum legal requirements, inspectors are expected to take formal enforcement action.

5 Where conditions found at the first inspection fall short of minimum legal requirements in any significant respect a return visit should be made after an appropriate period to check that the required improvements have been implemented. A further questionnaire should be completed in respect of the follow up visit. In this way the national project team will be able to measure the improvement in standards achieved by the initiative. In most cases the follow up inspection is likely to be the visit at which an Improvement Notice or Prohibition Notice served at the first visit is subsequently checked/discharged. In the case of a prosecution the return visit will be after the court case has been heard. Return visits are not required where standards encountered at the first visit are at or above minimum legal requirements.

Targeting

6 The project has run successfully within FOD for the last 4 years. As in 2007/08 inspectors are requested to undertake a safe interventions visit and complete the relevant machinery or confined space questionnaire at any manufacturing site where the issues are particularly relevant. This includes RIDDOR investigations where an unsafe intervention was an underlying causative factor.

Start and completion dates

7 Safe interventions inspections should be carried out between April 2008 and the end of March 2009.

Reporting procedures

8 Completed questionnaires should be returned to the national project manager, Ian Ellison at HSE, City Gate West, 1st Floor, Toll House Hill, Nottingham, NG1 5AT. Telephone 0115 971 2874 or VPN 513 2874.

9 At each visit counting towards the Safe Interventions Project a questionnaire must be completed along with an IRF1 for the inspection where relevant (FOD work recording instructions require that an IRF1 is completed at all inspections, with only very limited exceptions). Time spent on the project at a visit will not itself be recorded as category time in COIN (previously topic time in FOCUS). However, as every effort should be made to deal with this initiative at inspection visits made to deliver other parts of FODs programme, it is likely that other issues will be discussed. In these cases, the time spent discussing these should be recorded along with any rating details.

Publicity

10 Publicity for this initiative will be organised by the National Project team through the Manufacturing Sector.