Report Safety

Safety Group Report

- by

Julian Lovell, Chairman, AGS Safety Working Group writes:

Below is the latest report from our Safety Group which this quarter has been tackling issues on guidance, the new CDM regulations and collaboration with the British Drilling Association (BDA).

AGS Safety Guidance

The working group has been working consistently to progress the guidance available to the industry. Progress has been steady throughout the year. Most guidance goes through two if not three reviews which effectively means 3 to 6 months from initial draft and the most effective reviews are carried out by the committee either in a face to face meeting or on one occasion an on-line meeting.

Guidance which has been published since the last meeting:

  • Use of Scaffolding/Temporary Working Platform
  • Lifting Operations and Equipment used in Drilling Operations Guidance on CSCS Registration
  • Driving at Work

Guidance close to completion:

  • PPE
  • Manual Handling
  • Training and Competence
  • AGS Health and Safety Training Standards Health Surveillance

Website

Currently all published guidance is freely available from the AGS website. The SWG has discussed this matter and believes that all of the safety guidance should be freely available in front of the member’s portal.

Where individual guidance links together we would like hyperlinks so that you can move between them. This should be part of the new website functionality specification. The web pages should have photographs and images and not just a list of links to guidance. The guidance will also be split into sections to try to make it easier to find what you want. Currently, we are waiting for the development of standard templates before we can provide further input to the new section within the new website.

BDA

The BDA has completed a new version of its Safety Manual and this is likely to be available digitally in the next month or so. Currently, they are deciding how and who it is distributed to but it is likely to be free to members. Unsure if it will be sold on the wider market.

There have also been ongoing discussions between the BDA and AGS regarding a closer working relationship. The AGS SWG has discussed on numerous occasions how much of an overlap there is and has offered to set up a joint working group. The BDA have reported back that they initially want to establish their own safety committee which has not met for over 12 months. They will then re-visit the idea of working with the AGS.

BDA have agreed to sponsor a session at Geotechnica which will be a Health and Safety session.

The BDA also spoke to the SWG about the BDA Audit. This scheme has been brought in to allow companies to assess the ongoing competence of the drill crews and to comply with BS 22475: Part 2. The auditee has to have already achieved the Land Drilling NVQ but this will look more closely in to how the driller is operating on site and complying with legislation, guidance and good practice. The BDA Training and Education Committee is currently working with Equipe to strengthen the Audit so that it requires the auditee to be able to prove a high standard of knowledge and application of both quality and safety. It is hoped that this will be linked in to the work to improve the current Land Drilling NVQs and in time to develop a Level 3 Advanced Lead Driller qualification.

Safety awareness and CSCS

The CSCS have been advised by the construction industry that there are too many loopholes in the CSCS card scheme. The CSCS card should represent the work activity being performed on site by that individual. The current clamp down has seen the requirement to attend a one day approved Health, Safety and Environmental awareness course if a GREEN labourer’s card is required. This is in addition to the CSCS touch screen test. Whilst this sounds initially like a good initiative to reduce the number of generic cards and promote training there are concerns. The concerns are that

  • it may lead to similar generic cards such as the WHITE Construction Related Operatives (CRO) card requiring something similar or being withdrawn
  • the promotion of generic Health and Safety training.
    The CRO card is commonly used across the geotechnical industry under the title Ground Specialist.New Standards BS EN 16228 – Drilling and foundation equipment.The new standard is seen to be the European wide requirements for rig guarding but they are actually a lot more detailed and cover all safety aspects of operating drilling equipment across sectors and rig types. Most organisations have still not looked to see if changes to UK practice or obligations on rig users or manufacturers has changed. AGS has told BDA that as the trade body for drilling they should be advising industry on these matters. One AGS member believes that it downgrades the importance of guarding in reference to trapping distances. There will undoubtedly be other areas which need to be considered. The BS was live from the end of October 2014.

    Construction Design and Management Regulations, 2015

    The changes to the CDM regulations was discussed, majority of the group felt more responsibility had been passed onto the client and they would now have to consider risk as well as the cost of the project. Julian Lovell noted the HSE encourages industry interpretation, and thought it was important guidance was produced to reflect the industry. The group agreed and recognised the re-education of clients would be the hardest transition. It was agreed joint industry guidance with the BDA and the Federation of Piling Specialists (FPS) would be ideal. Julian, Madeleine Bardsley, Adam Latimer and Jon Rayner agreed to contribute to the joint industry guidance on behalf of the AGS. Ann-Marie Casserly raised the proposal at the FPS Safety & Training meeting and Julian contacted BDA. Currently all parties agree that it would be a good initiative but neither FPS nor BDA could provide time or resources at the moment.

    Equipe are currently arranging a FREE one day seminar/discussion forum for Health and Safety in the geotechnical industry on 4th March at their training rooms near Banbury. The day is aimed to open up debate on HS&E matters including:

  • How the industry should adopt and interpret the requirements of CDM 2015
    • Can we educate the client?
    • Can CDMCs become Principal Designers?
    • Can the industry cope with the increased demand to act as Principal Contractor?
  • Will it increase resources and costs to complete CDM jobs?
  • Why companies might consider Health Surveillance

Safety Alerts

The Safety Working Group would like to receive copies of safety alerts relevant to member’s activities so that lessons can be learnt. The most valuable messages often come from Near Misses and it is hoped that we can start a regular item in the newsletter but we have to have items sent from the membership.

Article Contaminated Land

Understanding Bandings

- by

It’s a red site. So what?

It was the 15th century Swiss medical pioneer Paracelsus, who noted in his journals: “all substances are poisons; there is none which is not a poison. The right dose differentiates a poison.” Although he made this statement almost 500 years ago, it is now known and proven to be correct with substances known to be essential for human existence, such as salt, defined as toxic when administered in sufficient quantities. For this reason the classification used by the British Drilling Association (BDA) Guidance for Safe Intrusive Activities on Contaminated or Potentially Contaminated Land and part four of the Site Investigation Steering Group (SISG), where sites are classified into green, amber or red sites, must be fully understood and not applied casually. Failure to fully appreciate the relationship between quantity and substance classification could be as dangerous as doing nothing or impose expensive non essential protection measures.

The BDA guidance classifies red sites as the most hazardous, attributing this classification to sites where there are: ‘Substances that could subject persons to risk of death, injury or impairment of health. Examples would be any substances that are corrosive, acidic, carcinogenic, cause skin irritation or respiratory problems, affect the nervous system, affect the organs, etc.’ Unfortunately this classification takes no account of the quantities present which are critical to determining the risk category as even uncontaminated soils and dusts, if present in the correct quantities and form, could act as a skin irritant or be harmful to the respiratory system. It would be a rare site investigation which did not include these hazards and on this basis, all sites would be classed as red.

In the BDA guidance, reference is made to the need for a risk assessment and this is the key to correctly determining the nature and category of the site. The green, amber, red categorisation system provides a simple warning and flagging system but where the presence of hazards is known or suspected, an assessment of both the nature and the quantity of the substances is required and this poses a problem for conducting work on contaminated land. In the majority of cases the purpose of conducting a site investigation is to determine the presence and quantity of contaminants for human health risk assessments. Until such time as this is done it is impossible to produce a definitive risk assessment and as such some assumptions need to be made.

To make an assessment there needs to be an understanding of the site and surrounding areas. A desk study should be able to identify the history of the site, in particular the industrial uses to which it has been put. This is the first stage but by no means the end of the process as not all uses may have been logged or recorded and they may not reflect the current use. Nothing substitutes a visit to site to examine the visible evidence but commercially, particularly on small sites, this is not always possible so any evidence such as photographs, discussions with clients etc. will help to build the picture.

Once the history and past uses of the site has been identified, an indication of the potential contaminants can be gathered but the available sources of guidance do little to clarify the situation. There are a number of publications used commonly to determine the presence of substances for the purposes of human health risk assessment, with the Environment Agency publication CLR8 – ‘Potential Contaminants for the Assessment of Land’ being recognised as the closest thing to definitive but the purpose for which it was developed does not fully suit our needs in term of occupational safety and health.

CLR8 is intended as an aid to determining the substances to be tested in a contamination study for human health but is not specific enough to assist completely in determining the requirements for the successful management of exposure in the course of site work or activities. CLR8 suggests everything is present in some quantity on nearly all sites but provides little indication of possible concentrations, the form of the substance or the exact location on the site. As an example, CLR8 identifies the presence of ‘oil / fuel hydrocarbons’ at airports, which although suggestive of contaminants which will certainly exist at some points on the site provides little guidance for occupational safety risk assessment. Hydrocarbons used for fuel vary from heavy oils such as diesel and more volatile substances such as pentane and if the whole site is treated as containing such substances, all area would be classified as ‘red’ under the BDA guidance as it is likely these hydrocarbons could contain benzene (a carcinogen), pentane (produces narcosis in higher volumes) and possible lead (causes damage to the peripheral nervous system).

A study undertaken by the author of this article, cross referenced all the potential contaminants present on sites as indicated by CLR8 with the risk phrases attributed to the compounds, suggested every site identified should be rated as the highest possible risk, if the categorisation of sites is dependant on the presence of substances alone, as suggested by the BDA guidance, all geotechnical sites would be classed as ‘red’ which is clearly unfeasible.