In the next 6 articles, Morag McWilliam takes a look at employees’ exposure to Respirable Crystalline Silica and who might be at risk. Morag details what employers must do to manage the health risks, control measures which should be applied, exposure limits, the use and maintenance of Local Exhaust Ventilation (LEV) systems, health surveillance, exposure monitoring and training.
What must I do to manage the health risks associated with exposure to respirable crystalline silica (RCS) to ensure that my people and my business are protected?
RCS is process-generated i.e. It only occurs as a result of applying a high-energy process (e.g. Cutting) to a crystalline silica-containing material. However, it is still classified as a carcinogen, and exposure to it should therefore be controlled in a manner similar to any other hazardous material with an associated serious ill health effect.
The Control of Substances Hazardous to Health (COSHH) Regulations, 2002 (as amended) and the associated Approved Code of Practice, provide the legal framework for managing the health risks associated with work-related exposure to RCS. Copies are available to download here:
- (Control of substances hazardous to health: The Control of Substances Hazardous to Health Regulations 2002. Approved Code of Practice and guidance L5 (Sixth edition) HSE 2013 https://www.hse.gov.uk/pubns/books/l5.htm)
Prior to implementing these, however, the employer must consider whether they can avoid exposure and prevent the release of RCS in the first place.
Matters to consider include:
- The removal or substitution of materials containing silica from the work process – it may be possible to use a different material, for example substituting olivine or another safer material for silica sand in abrasive blasting.
- Taking account of RCS dust control at the design stage of a project g. by planning in recesses for services such as water, gas and electrics so there is no requirement to cut or drill masonry later in the project.
- If it is not possible to protect operatives from exposure to RCS silica at the design stage of a project or by changing processes or materials, then employers must assess and control the exposure risks.
Regulation 6 of the COSHH Regulations and the associated Approved Code of Practice and Guidance details what should be included in a suitable and sufficient assessment and who should undertake it.
Generally, more dust will be released during tasks which involve the use of power tools, are carried out on dry rather than wet material, and are undertaken for a longer duration and/or at a greater frequency.
Remember that if tasks are undertaken indoors in poorly ventilated areas, the build-up of RCS is likely to be greater.
Once the risks have been identified, the employer must identify effective measures to be implemented to control exposure to RCS.
It is important to involve employees in the risk assessment so that they have a better understanding of it and why any control measures may be needed.
It is also important that the risk assessment is documented clearly so that the employer is able to demonstrate that the risks of each task have been assessed, as well as the thought process which informed the selection of control measures.
If a risk assessment is revised, for example in the event of a process change, it is good practice to keep a record of any historic risk assessments in order to demonstrate compliance with the legislative requirements of the time. This should be an integral part of an employer’s claims resilience plan.
Recording risk assessments are a legal requirement only where five or more people are employed, however, doing so is a good way of demonstrating that the risks of each task have been assessed in a suitable and sufficient way.
This is the second in a series of articles about raising awareness of the dangers of RCS, you can catch up on part one here. The next article focuses on following the hierarchy of controls to control any exposure to the substance. If you would like to talk further please email [email protected].