The main aim of the COMAH regulations is to prevent and control the effects of major accidents involving dangerous substances like liquid petroleum gas, explosives and arsenic pentoxide, etc. A ‘“major accident” means an occurrence (including in particular, a major emission, fire or explosion) resulting from uncontrolled developments in the course of the operation of any establishment and leading to serious danger to human health or the environment, immediate or delayed, inside or outside the establishment, and involving one or more dangerous substances’. (

Basically, all establishment owners must prevent major accidents and limit their effects on the environment. In England and Wales, COMAH is enforced by the Health and Safety Executive and the Environment Agency and the Health and Safety Executive and the Scottish Environment Protection Agency in Scotland. These enforcing bodies must prohibit the operation of an establishment if there is evidence that measures taken by the establishment are not in the interests of the safety of people and the environment. The main industries that are under these remits are the chemical industry, nuclear sites and others. The process that identifies the way chemicals can cause harm is called classification. This criteria includes physical hazards (eg explosivity), health hazards (eg an irritant to skin) and environmental hazards (eg harm to aquatic life). As well as these hazards, the supplier/operator must also consider how certain it would be that the chemical would have this effect and how serious the effect might be.

It is the general duty on all operators to prevent major accidents and limit their conequences to the public and environment. Prevention should be based on the principle of reducing risk to a level as low as is reasonably practicable for human risks and using the best available technology not entailing excessive cost for environmental risks.

A new set of COMAH regulations will come into force on 1 June 2015. The Competent Authorities (CA) will make guidance available so that safety reports can be updated by organisations when the new regulations come into force. Important changes to be made include the classification of hazardous substances, more detail about site surroundings and how information is made available to the public. Also, the Competent Authorities are planning to provide an IT system to host public information regarding  establishments. Establishments will need to consider that new information will need to be included in major accident prevention policies and off-site emergency plans. Safety reports may need to be updated in line with the forthcoming regulations. A safety report is a document prepared by the site operator and sent to the CA. The safety report demonstrates all the necessary measures that have been taken by the establishment to prevent major accidents, and, should an accident occur, how it will be mitigated so that the public and the environment as least affected.





The Plant Protection Products (Sustainable Use) Regulations 2012 came into force on 18 July 2012. These regulations cover obligations to businesses who use and supply pesticides. Part III of the Food and Environment Protection Act 1985 (FEPA) also deals with regulating pesticides. The Department for Environment, Food and Rural Affairs (DEFRA) also gives practical guidance on the storage and transport of pesticides and the obligations on those who store for sale and supply. The use of pesticides are also regulated by the Control of Substances Hazardous to Health Regulations 2002 and the EU Directive 2009/128/EC which establishes a framework for Community action to achieve the sustainable use of pesticides. The Control of Pesticides Regulations (COPR) 1986 is also pertinent.

Pesticides are used to protect plants/crops from pests and diseases. Pesticides include insect killers (insecticides), mould and fungi killers (fungicides), weedkillers (herbicides), slug pellets (molluscicides), plant growth regulators, bird and animal repellents, and rat and mouse killers (rodenticides). Professional farmers who supply food to the country and internationally, breeders of animals and anyone who produces, supplies or uses pesticides, whether for home or commercial use, has an obligation to the environment and the public to be responsible in their use. Everyone who uses pesticides has the responsibility to ensure that they use them correctly and effectively. The products to be used must be authorized for use. The HSE has publishes a database of pesticide products and information on them. This includes changes to the register, products subject to withdrawal, active substances in the product, information on crops, aerial usage and marketing companies for the product. When using pesticides one should always read the label. This will include user restrictions, the crop or situation to be treated, operator protection or training requirements, the maximum application amount and permitted number of treatments, the products’ active ingredients, hazards, the safe disposal of the product and its registration number (Ministerially Approved Pesticide Product, MAPP).

There is also guidance on aerial spraying of pesticides, for example, there is guidance on precautions to be taken to prevent spray drift. When spraying by aircraft, one must provide notification to the public. In all situations it should be considered how the pesticide will affect other people’s health and the environment (as in a COSHH assessment). The COSHH regulations apply to a pesticide product if it is classified as very toxic/corrosive, has a ‘workplace exposure limit’ (WEL) and/or includes a micro-organism dangerous to health. For work with most pesticides one must wear suitable PPE to protect themselves (such as overalls, suitable gloves and boots). For those spraying pesticides they will need to wear respiratory protective equipment so they do not breathe in the fumes.


According to the HSE, it is estimated that about one third of RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) reports in health and social care are incorrectly recorded. Accidents in residential care homes, hospitals, dental practices, health care clinics, in patients own homes and in any care setting should be appropriately recorded and reported according to the RIDDOR regulations. Employers and others are required to report deaths, certain types of injuries, some occupational diseases and dangerous occurrences that ‘arise out of or in connection with work’. When an accident is reported via RIDDOR, this alerts the enforcing authorities to investigate the more serious incidents. Reports enable the HSE or the local authorities to identify where and how health and safety risks arise, reveal trends and help target activities. The report should be done by the ‘responsible person’ who may be the employer, a self-employed person or someone in control of the premises.

Death of any person, whether or not at work, if it was in connection with work, must be reported. However, there are certain instances where a death does not need to be reported. One is where a self-employed person in a premises where they are the owner or occupier. Other incidences include the death of the employee after one year from the date of the accident, if there is a suicide and where a disease is contracted not due to an accident (for example, contracting Legionnaires’ disease due to poor maintenance on a hot water system). However, this latter incident may be investigated and litigation brought forward under the HSW Act. If an employee (or self-employed person) is injured in a health or social care environment and has to take more than three days off work, then their injury needs to be reported. Injuries can be anything in connection with work and can include fractures, burns, any crush injury, reduction in sight etc. Also, if a person is off work for more than seven days the accident must also be reported. Records must be kept.

If an employee (or self-employed person) contracts a disease at work, it is reportable. Examples can include occupational dermatitis, hand-arm vibration syndrome, carpal tunnel syndrome, a disease attributed to a biological agent, etc. An example could be where a paramedic becomes hepatitis B positive after contamination with blood from an infected patient. A sharps injury must be reported. Sharps that do not cause diseases do not need to be reported (i.e. sharps not containing a blood borne virus). Injuries and ill health not involving people at work need to also be reported. The incident must arise out of or in connection with work being undertaken by others, for example, where a patient is scalded by hot bath water and taken to hospital for treatment. A fall is reportable under RIDDOR when it has arisen out of or in connection with a work activity. This includes where equipment is involved. Dangerous occurrences in health and social care should also be reported.  An example could be the failure of load-bearing parts of lifts and lifting equipment, an electrical short circuit or overload that could or has caused a fire or explosion. Although these may not result in a reportable injury, if they have the potential to cause harm they need to be reported.


The HSWA (Health and Safety at Work etc. Act 1974) has existed for more than 40 years and is the primary piece of legislation covering occupational health and safety in the UK. It is enforced by the HSE. Basically every employer and self-employed person has a duty of care to ensure that they are not putting people’s lives and the environment at risk. Employees also have a duty to report any risks they foresee or experience to their colleagues or their employers. Even visitors have a duty of care and should speak up if they see anything wrong.

Employers may install their own health and safety systems or may need outside help. Competent persons may be outsourced to help the employer meet the health and safety standards as outlined by the HSWA and other regulations pertinent to the business. The competent person should have the knowledge and experience to fulfil this task. One of the first things a start up business does or an established business has, is the production of a health and safety policy. This policy states who does what, when and how. However, if an employer has fewer than five employees they do not need to write down a health and safety policy, although it is always a good idea to write things down for ease of understanding and direction. Parts of such a policy could include what to do in an emergency, i.e evacuation plans, the periodic testing of equipment if appropriate, and, inductions for staff and contractors. It can be as simple or as elaborate as necessary.

A critical part of working according to the HSWA is the control of risks within the business. A risk assessment must be carried out and it must be investigated what could cause harm, to what extent it could cause harm and who to (including the environment). Once risks are identified they must be controlled by changing work processes, supplying protective equipment or asking the experts what to do. Although risks may not be totally eliminated within the workplace, measures must be taken so that risk is reduced to what is ‘practically possible’. Significant findings should be recorded on the risk register and reviewed as there are changes to the workplace environment.

Sometimes the employees themselves may be more aware of certain risks because of their work within the environment. Employees should always be consulted. They should also be trained in how to mitigate against risks (as it pertains to their job), and information and PPE available to them as required. Contractors and the self-employed must also be included. Vulnerable persons such as the young, migrant workers, expectant women and disabled persons must be helped in whatever way best brings about the best quality of life for them in the work environment. There must be first aid facilities on site, an accident record book (RIDDOR reporting system), health and safety display information (eg posters) clearly visible and employers liability insurance.


By nature, we all live to the tune of our internal clock or ‘circadian rhythm’. This pattern of living is imprinted in the brain and governs our waking and sleeping biological activities. Our heart rate, body temperature and blood rate is increased during the day, whereas at night these biological activities slow down. Shift work schedules require abrupt changes to this pattern. Our internal clock can change gradually but does take some time. Some individuals adapt easier than others. Where one doesn’t get enough sleep at the proper times (i.e. during the night) ,performance and errors are more likely. Although, it’s rarely possible to fully adjust to working at night or outside normal working hours, shift work can be managed to lessen to risk to the body and the work environment.

Short term effects of shift work include gastrointestinal problems, insomnia, a general feeling of unwell and increased risks of injuries. Long term effects can include cardiovascular disease, diabetes, obesity, depression, cancer and problems with fertility and pregnancy. Some of the serious risks can develop over decades and some over a shorter period of time. However, if you work in nursing, are a doctor, firefighter, or work in the police force or emergency services, or basically have to work at night, what can you do?

All employers, under the Health and Safety Act have a duty to ensure that they have minimised the risks to a level that is reasonably practical. Risk assessments should be carried out to ascertain the risks that workers may be exposed to. The risk assessment should take full account of the hazards associated with fatigue. It should also be established who might be harmed by shift work. Even though all workers are at risk from shift work, some might be more vulnerable than others. More vulnerable persons may include older workers, younger workers, expectant mothers, workers with pre-existing health conditions, temporary workers and sub-contractors who may find it difficult to adhere to current shift work patterns. Members of the public may also be at risk if they are in the environment where shift work takes place. Data should be collected about the shift work arrangements and used to identify areas where improvements can be made, if necessary. Past accident record books should be consulted. Shift workers should have safety representatives to speak on their behalf.

If practical, demanding work periods should be scheduled when workers are more alert, for example, at the beginning of a shift. Those who work on a more permanent night shift basis should have information regarding the risks. At shift handover, there should be brief communication liaison meeting so that the next set of shift workers are aware of the current situation. There should be adequate rest time between shifts. If practical, shifts should be rotated every 2 to 3 days as the internal body clock doesn’t adapt this quickly and sleep loss can be recovered. Permanent night time work and shifts of more than 8 hours should be avoided. Rest facilities and breaks should be part of the shift pattern. The work place temperature should be adjustable as the body cools down at night. Healthy living strategies should be promoted at work such as eating well, exercising and regular check-ups with the doctor.


Competent running of sports clubs and amateur sports centres come under the Health and Safety at Work Act 1974. These laws apply to the employers and the self-employed involved in running these centres. The employers must also use the Act in this situation to protect those not officially at work, i.e. volunteer staff, visiting teams and spectators. Everybody at the leisure centre and in connection with it, should not be at risk. Sports can mean anything from swimming clubs to hockey teams to gymnastics. Anyone who controls premises like sports grounds and work out areas must ensure that all equipment is in good working order. Management must ensure that no one is at risk, in both indoor and outdoor areas. Management at sports clubs have a duty of care to ensure they regularly check sports equipment and premises to ensure all is safe and in good working order.

However, health and safety law does not cover injuries incurred by players in competitive sports. The safety of participants in competitions and those partaking in training at these sports clubs may go beyond the set workplace health and safety rules. Sports governing bodies specifically regulate sports and leisure centre related environments. Every sport has a different governing body that defines how that particular sport is operated through its sports societies and clubs. National and international sports federations create common sets of rules and guidelines for competitions and sports related activities. A federation can be different from a national governing body due to government recognition requirements. There are also professional leagues and many other local and international sport bodies that have health and safety rules in place. The Sport and Recreation Alliance is the umbrella organisation in the UK, representing the different governing and representative bodies, and, has 320 member organisations. These member organisations run their sport or activity, promote participation and set the rules and conditions under which it takes place.

When planning and running low risk sports events and activities, the club/premises owners are required to consider the safety of all concerned. Areas that must be considered are the weather conditions, access roads and paths, seating areas, playing areas, parking, first aid provision and emergency procedures. For example, some leisure centres have swimming pools; these would need to be managed in a risk controlled environment because of the risk of drowning. Pool operators would have to display safety signs in clear view, have first aiders on site and respiratory equipment within easy reach. Simple sensible precautions may be enough for some aspects of an event or sport club centre. Other areas will involve meticulous risk assessment with control of those risks.



Two thirds of all accidents in engineering workshops occur during the movement of people, goods and equipment. Accidents can happen to operators using automatic, manual and CNC machines. CNC stands for computer numerical control. These machines are programmed by computers to control feed rate, speed and coordination etc. These machines are very useful and are mostly used in the manufacturing of plastics and metals. However, they still need human operators interacting with them and so pose a risk to one’s health. Accidents can occur during the loading or unloading of components, the taking measuring, feeding etc. There is more operator interaction with manually operated machines. Machine movements include cutting, shearing and sawing etc. Automatic machines that pose a risk are presses, milling machines, drilling machines, grinding machines and guillotines. Hands and fingers are most frequently injured, however, knocks to the eyes, disentanglements of clothing leading to injuries, lacerations and broken bones can all happen.

To help prevent accidents with manually operated machines, fixed guards should be used to unload and load components to the tool working edge.  For both automatic and CNC machines, all dangerous body movements (not just interaction with tools) should be guarded against with guards in place and PPE in use. To safeguard against noise, noise enclosures or controlling noise at source should be adapted. For some one-off tasks, the machine and guard may have to be adjusted continually and be under close observation. With all risky processes, interlocking should be in place so that the power to dangerous machine parts is removed when interlocking guards are open or the movements are limited to safe increments or speeds. Enclosing guards should be used to contain hazardous emissions such as metalworking fluids, mists and fume vapour. Where there is a change in a machine function from manual to automatic or vice versa, new risks may be introduced; the operator needs to be apt at making sure the new risk control settings are in place during each new operation.

Under the law, the provision and use of work equipment regulations 1998 place duties on employers and the self-employed to ensure proper training for operators, information on the dangers, proper lighting, ventilation and a PPE system is in place. Warning labels, control systems, protection for the operator (i.e guard rails etc.) and the safe automatic shutdown of machines in emergency are all part of these regulations. Regular inspection and the necessary maintenance should be carried out where there is a risk of injury that may occur from the incorrect installation of the equipment and the deterioration of the work equipment over time. Records should be kept of all fittings done, maintenance and inspection dates. All new machinery procured should have the ‘CE’ mark and have conformity with the Supply of Machinery (Safety) Regulations. According to Section 6 of The Health and Safety at Work etc Act 1974, machinery should be constructed so that it is safe and without risks to health and has accompanying instruction information.


Your lungs are so important. What goes into them and comes out of them determines how you live. Striving for quality of life is inherent in us all. Lung disease is not. We must endeavour to give our lungs the best shot at life, free from carcinogens, irritants, chemicals and fumes.

Rubber manufacturing usually consists of the processes of raw materials handling, milling, extruding, component assembling and building, curing, inspecting, finishing and storage and dispatch. Hazardous substances can include fumes and fine dusts. COSHH (Control of Substances Hazardous to Health Regulation 2002) requires employers to assess the risk to health caused by dusts and fumes. Exposure must be prevented or adequately controlled by doing a risk assessment. For controlling dust fumes, employers can use dust suppressed materials, for example, pellets and oil coated powders. Enclosed and automated bag and powder handling is also a safe way of handling dusts. Workers should refrain from handling powders directly; automated system machinery should be in use. An effective local exhaust system should be used and maintained regularly during the work processes.

PPE should be worn, for example, gloves, aprons and safety glasses. Adequate personal washing facilities should be available and separate from the eating and rest areas. Good housekeeping should be the norm and industrial vacuum cleaners used. Respirators would not be needed if adequate fume and chemical controls are in place. However, they may be needed for short term exposures, for example, when filter bag changing or general maintenance. Training of workers in the use of respirators is essential. Because the rubber industry is ever changing, new processes may introduce new risks. Hopefully, they can be learned from without dire consequences happening to highlight the risk. Whilst COSHH doesn’t set out specific requirements for the rubber industry, it does set out the basic system of managing risk to health.


Simple steps to making a COSHH assessment in any industry

  • Simply walking around the work place can highlight obvious and taken for granted risks. Some substances will have workplace exposure limits (WELs); the limits need to be maintained.
  • The employer should have safety data sheets on information about their workplace. Workers can be exposed to dust, fume, vapour and dermal contact with liquids and dusts. Some dusts are very fine and might not be immediately apparent.
  • The hazards should be identified, mitigated against and a control system set up to be in place.
  • It should be ascertained who is likely to be harmed, how and when, and, the health severity to the worker.
  • The accident book may be a good reference when redesigning processes to make them safer and when considering a new factory floor layout. There can be lessons learned.



The HSE has developed Draft Guidance on the Construction (Design and Management) Regulations 2015. The final versions of both the draft Regulations and guidance will be available on 6 April 2015.

The Regulations will come into force on 6 April 2015. There will be a transition period of 6 months from 6th April to 6th October 2015.


The key changes likely are:

  • Clients will need to appoint a Principal Designer and Principal Contractor
  • There will no longer be an official role of CDM coordinator
  • The domestic client is no longer exempt under the CDM regulations and has duties
  • Designers and principal designers must have suitable skills, knowledge and experience.
  • Client’s duty to provide pre-construction information



If all goes well, new mining regulations will come into effect in April of 2015. These will update the current Mines Regulations 2014. Changes include the current Approved Codes of Practice being replaced by new guidance and a modern set of regulations in place to focus on the control of risks. Other changes include the mine operator being the duty holder (not the mine manager), and, coal mines will no longer be required to participate in a rescue scheme. However, rescue provisions must be in place. The new regulations will remove unnecessary burdens on businesses by providing a sound legislative framework.  As well as the Mines Regulations 2014, there are currently many acts and regulations that govern working in mines, from the Escape and Rescue From Mines Regulations 1995 to the Mines and Quarries Act 1954.

In the 1800’s, the shocking truth of working conditions in mines, and especially that involving children, led to The Mines and Collieries Bill being passed by parliament in 1842. This prohibited all underground work for women and girls and for boys under 10 years of age. However, young boys and men were still at risk, in terms of health and fatalities. In 1872, the Coal Mines Regulation Act required pit managers to have certification of their training. Things were still bad over the decades and up until the early 1900’s health and safety law was not a frugal part of the mining environment.

Mines have many hazards and risks associated with them, including that associated with fires, inrushes of gas/materials, dust, floods and explosions. Accidental fires or explosions can be devastating in terms of loss of life, damage to property and business continuity. Risk assessments are crucial when mining, and, include identifying the hazards and the sources of fuel. Sources of fuel include firedamp (a naturally occurring mixture of hydrocarbon gases), coal dust, wood, diesel and some explosives. Sources of ignition include electrical sparking, hot surfaces, and compression of air. The risk of a fire or explosion must be evaluated, it must be ascertained who might be harmed, these findings recorded and an emergency plan in place. An inrush of water or material can occur at mines. An ‘inrush’ is the sudden arrival of a material or gas. To prevent an inrush, the plans of the underground workings must be accurate and up to date. It must be confirmed whether workings are being carried out in a hazardous area, i.e whether material is likely to flow from nearby areas if it got wet. It is imperative that medical aid facilities and emergency evacuation procedures are in place in mines. The first aid at mines section of the Mines Regulations 2014 will not change in the New Year.