Health and Safety
Executive / Commission
Operational
SIM 03/2008/08 Version 2
Author unit / section: Manufacturing Sector, Policy Group
Target audience: All HSE and LA visiting staff
OG status: Partially Open
The metal recycling industry has consistently had a very poor fatal accident rate for several years (2004/5 – 2006/7 it was 15.1 fatalities per 100,000 workers). This represents 8 fatal accidents in a very small population. This SIM highlights areas which make a significant contribution to those figures and identifies how inspection can be used to target those areas.
1 The introduction of the End of Life Vehicle Regulations has resulted in a significant change to the make up of the scrap industry as every vehicle scrapped now has to be de-polluted and waste materials accounted for. This environmental legislation requires premises de-polluting vehicles to register as “authorised treatment facilities (ATFs)” and meet the pollution control standards enforced by the Environment Agency. ATFs often feed into larger regional processing centres with fragmentisers. Additionally, as the value of scrap metal increases there is an increase in the volume of reprocessing hard to retrieve metals such as electric cabling and batteries.
2 In 2004 figures from registers held by the Environment Agency show that there were 1470 licenced metal recycling/ vehicle dismantlers (A19) and other metal recycling facilities (A20) registered in England and Wales. This number is likely to have remained static. In Scotland it is estimated that there are approximately 220 registered sites. There is anecdotal evidence of a significant number of premises without a waste management licence.
3 Fatal accidents in the industry in the last 3 years have included:
4 The industry has been attempting to improve its performance with the provision of a Health and Safety Manual for members of the British Metals Recycling Association (BMRA) and the introduction of the BMRA/ Metskills Health and Safety Passport qualification.
5 This inspection initiative has been designed to address the main causes of accidents and reinforce the work that the industry is undertaking to improve its performance.
6 When visiting scrap metal/ metal recycling premises the following areas should be given priority:
7 Guidance will be provided to the industry on the Health and Safety in the Waste Management and Recycling Industries on this initiative, including the inspection checklist. The Manufacturing Sector will be working with trade bodies to ensure that their members are aware of the initiative and areas it will cover.
8 It is recommended that inspection follows the Inspection Guide [PDF 76KB]
as this will allow evaluation to be carried out. Initial enforcement expectations and model enforcement notices have been drafted. An explanatory commentary on the specific issues is provided.
9 The Manufacturing Sector has a list of metal processing plants holding a Waste Management Licence, this is available on request. It is likely that there are a significant number of premises without a waste management licence in each areas, therefore, it is recommended that local business directories and local knowledge is used.
11 There is the potential to examine other programme topics during these visits. In particular inspection topic packs will help cover the topics of:
12 The Manufacturing Sector would welcome and provide support for locally arranged seminars, workshops, SHADs etc aimed at the metal reprocessing industry.
13 The Manufacturing Sector will be supporting the inspection initiative with trade press and HSE website promotion of the standards.
14 The inspection proforma [PDF 76KB] should be completed and returned to the Manufacturing Sector (Lisa Weston, Cardiff Office). Contacts should be recorded on COIN as normal, no keywords are required.
15 Examples of action plans, enforcement notices, best practice and other noteworthy information should be forwarded to the Manufacturing Sector for use to support and promote the initiative.
16 It is recommended that Band 3 inspectors make visits.
17 An inspection protocol [PDF 76KB], initial enforcement expectation and commentary are provided with this SIM. These provide all information necessary to deliver this initiative.
18 The Manufacturing Sector has provided briefings and joint visits to groups of inspectors when necessary. These are still available when there is a sufficient need.
19 The BMRA Health and Safety Manual is available to HSE Inspectors on the intranet. Use of the manual can be promoted at visits but it should not be copied to members or non members of the BMRA.
20 Inspection of scrap metal and metal recycling sites has the potential to expose HSE staff to risks to their safety. Before visits to these premises inspectors should ensure they are following the instructions set out in the Lone Working section of Your Health and Safety. In particular inspector should follow the following procedures:
21 Before visiting, it is recommended that inspectors consult COIN “Site Restriction” notes and any local registers of potentially high-risk sites.
22 The topic packs on Migrant Working [220KB], Duty to Manage Asbestos [671KB], and Worker Consultation and Involvement [263KB] may be relevant and useful when engaging with this sector, and also the Diversity & Delivery pages.
23 For further information please contact; Colin Mew, Manufacturing Sector, Government Buildings, Ty Glas, Cardiff, CF14 5SH: VPN 511 3063, tel 02920 263063 or colin,mew@hse.gsi.gov.uk
Section S30 – disclosing this information is likely to prejudice HSE’s investigation into this company.