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.
Once suitable control measures have been identified, the employer must ensure that they are used properly.
This is usually best achieved by means of training the operators on the proper use of control measures and effective supervision of their implementation. There should also be an effective means of reporting any defects in control measures such that remedial action is prompt. This is particularly important if wear and tear on the LEV system, caused for example by abrasive materials such as RCS, is liable to mean that the system’s effectiveness will degrade between routine testing. Use indicators such as pressure gauges to identify quickly and easily if controls are not working correctly.
Employees also have a duty under the COSHH Regulations to make full and proper use of control measures.
In the case of engineering controls such as LEV systems, the employer must ensure that they undergo Thorough Examination and Testing (TExT) at least every 14 months (or other stipulated frequency) by a competent person.
A suitable record of each TExT must be made by the tester and maintained at the site. This should usually include the following information:
■ the name and address of the employer responsible for the LEV;
■ the date of the thorough examination and test;
■ the date of the last thorough examination and test;
■ the identification and location of the LEV, and the process and hazardous substance concerned;
■ the operating conditions at the time of the test and whether this was normal production or special conditions;
■ a simple diagram of the LEV layout and location, with test points;
■ the general condition of the LEV system, including hood serial numbers and, where appropriate, photographs of relevant parts;
■ information about the LEV plant which shows:
– its intended operating performance for adequately controlling the hazardous substance for the purposes of COSHH Regulation 7. (Note: If there is no information available on this, it indicates a need for a further assessment in accordance with Regulation 6 to show compliance with Regulation 7);
– whether the plant is still achieving the same performance;
– if not, the adjustments, modifications or repairs needed to achieve that performance;
■ the methods used to judge performance and the action to be taken to achieve that performance, eg visual, smoke test, airflow measurements, pressure measurements, dust lamp, air sampling, and tests to check the condition and effectiveness of the filter;
■ the results of any air sampling relevant to LEV performance;
■ information on the way operators use the LEV;
■ information on general system wear and tear and whether components may need repair or replacement before the next test;
■ the name, job title and employer of the person carrying out the examination and test;
■ the signature of the person carrying out the examination and test;
■ the details of any minor adjustments or repairs carried out to make the LEV system effective;
■ the details of any critical defects identified
This is the fifth in a series of articles about raising awareness of the dangers of RCS, you can catch up on the others here. The next article will focus on exposure monitoring and health surveillance. If you would like to talk further please email [email protected].
