1. PURPOSE OF THE PROCEDURE
1.1 This procedure has been devised to aid managers and heads of departments to meet statutory obligations.
1.2 NHS Fife attaches the greatest importance to the Health, Safety and Welfare of its employees, and in particular recognises the significance of the risks to health caused by exposure to lead, lead compounds, dust, fumes or vapour at work.
1.3 It is the policy of the NHS Fife to ensure that:
- No work will be undertaken which is liable to expose any employees to lead unless an assessment of the risk created by that work to health of those employees has been carried out.
- Where assessment of the work concerned is likely to result in the exposure of any employees to lead as ‘being significant’ the measures needed to prevent or adequately control exposure shall be identified and implemented in accordance with the Control of Lead at Work Regulations 2002.
- Where assessment of the work concerned is likely to result in the exposure of any employees to lead as ‘not being significant’ the measures needed to prevent or adequately control exposure shall be identified and implemented in accordance with the Control of Substances Hazardous to Health Regulations 2002 (COSHH)
2.1 This procedure has undergone consultation and been developed and agreed through the Estates Department Steering Group and has been approved by NHS Fife Strategic Management Team.
2.2 This document applies to all employees of NHS Fife, alongside contractors and volunteers.
3.1 Responsibilities for the implementation of this procedure align with the responsibilities set out in the NHS Fife General Health and Safety Policy.
3.2 The Director of Human Resources is the nominated Executive Director with a responsibility for Health and Safety and will act on behalf of the Chief Executive in overseeing how the procedure is put into practice and meeting the aims set.
3.3 The Director of Acute Services is responsible for:-
Understanding all relevant legislation, arranging for appropriate funds to be made available to meet the requirements of the procedure and ensuring all staff are trained in Health and Safety matters to level required to fulfil their duties efficiently.
Although an organisation-wide approach has been established, detailed arrangements for controlling risks to health of employees caused by exposure to lead remain the responsibility of Directors, Heads of Departments and Operations Managers. All departmental Health and Safety Policies should deal with the risks arising in the course of the work of the department.
3.4 Management/Supervisors have to ensure that steps are taken to implement the requirements of the procedure. They have a responsibility to: -
- Identify hazards and ensure the process of risk avoidance, risk assessment and risk reduction, is implemented within their particular area of responsibility. They can nominate competent staff to assist in this process. Departments where work with lead takes place should carry out a risk assessment as required by the Management of Health and Safety at Work Regulations 1999.
- Ensure that all staff receive information, instruction, training and supervision in relation to working with lead and the precautions to be taken.
- Provide equipment and encourage the use of relevant equipment where provided, ensuring that there is a procedure in place for cleaning, and maintenance of all equipment in efficient working order
Inform the employee if exposure to lead is likely to be 'significant', and where specific requirements of the Regulations will be triggered, i.e. the need:
- to provide employees with protective clothing;
- to monitor lead-in-air concentrations;
- to place the employees concerned under medical surveillance.
- Follow up all accidents, incidents, near misses associated with exposure to lead, investigate their cause and to review control measures.
- Maintain records of incidents, and maintenance for individual employees.
- Monitor trends of sickness absence related to risks in exposure to lead.
- Employers must report to the enforcing authority, any case of lead poisoning occurring amongst their workforce. The NHS Fife Adverse Events Policy should be used, and the Legal Administrator will be required to make reports under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR).
4. OPERATIONAL SYSTEM
4.1 Outline of the Regulations
4.1.1 A diagrammatic presentation of the main provisions of the Regulations is shown in Appendix 1.
4.2 Types of lead work liable to result in significant exposure
4.2.1 High-temperature lead work (above 500°C), e.g. smelting, melting, refining, casting and recovery processes, lead burning, welding and cutting.
4.2.2 Work with lead compounds which gives rise to lead dust in air, e.g. any work activity involving a wide variety of lead compounds, paints, colours and lead-acid batteries,
4.2.3 Abrasion of lead giving rise to lead dust in air, eg dry discing, grinding and cutting by power tools. Blast removal and burning of old lead paint.
4.2.4 Spraying of lead paint and lead compounds and low-solubility lead compounds
4.3 Types of lead work not liable to result in significant exposure
4.3.1 Low-temperature melting of lead (below 5000C) i.e. Plumbing, soldering. (Such low temperatures control the fume but some care is still required in controlling any dust from dross).
4.3.2 Work with materials which contain less than 1% total lead.
4.3.3 Work with lead in emulsion or paste from where the moisture content is such and is so that lead dust and fume cannot be given off throughout the duration of the work.
4.3.4 Handling of clean solid metallic lead, e.g. ingots, sheets, etc.
Note: The guidance given in the tables 4.2 and 4.3 is not exhaustive as the nature of exposure will vary in different situations.
4.4 Developing a Safe System of Work
4.4.1 Information gathered during the risk assessment will be used to develop a written safe system of work when the hazards cannot be physically eliminated and some element of risk remains. This document will give information and instruction to the employees who are to carry out the work including safe means of access and egress.
4.4.2 This will include all the information and training needed to work safely with lead, including what to do in an emergency. How the employee should make full use of all the control measures, systems of work and equipment which is provided and the instructions to follow, including those for using the equipment.
4.5 Adequate Control of Exposure
4.5.1 The measures used to control exposure to lead where prevention is not reasonably practicable should include where appropriate one or more of the following:
- using substitute lead-free material or low solubility lead compounds;
- using lead or lead compounds in emulsion or in paste form to prevent or minimise the formation of dust;
- using temperature controls to keep the temperature of molten lead to below 500 deg/C (the temperature at which fume emissions become ‘significant’), though the formation of lead oxide and the emission of lead dust may still be a problem below this temperature;
- containment of lead, lead material, compounds, fume or dust in totally enclosed plant and in containers such as drums and bags;
- if total enclosure is not reasonably practicable, using effective exhaust ventilation system;
- wet methods of treatment;
- providing and maintaining a high standard of cleanliness;
- methods for safe handling, storage and transport of lead, and of waste containing lead, at the workplace;
- appropriate hygiene measures including adequate washing facilities.
- where the exposure to lead is, or is liable to be, significant, suitable and sufficient protective equipment will be provided
- where there is exposure to lead, control of that exposure shall, so far as the inhalation of lead is concerned, only be treated as being adequate if -
- the occupational exposure limit for lead is not exceeded; or
- where that occupational exposure limit is exceeded, the employer identifies the reasons for the limit being exceeded and takes immediate steps to remedy the situation.
4.6 Working Facilities and General Hygiene
4.6.1 For work involving exposure to lead, washing facilities should allow employees to meet high standards of personal hygiene so as to minimise the risk of ingesting or otherwise absorbing lead.
4.6.2 To further reduce the risk of ingestion of lead employees must not eat, drink, or smoke in places which are contaminated or likely to be contaminated by lead arising from work activities.
4.6.3 Employees must be informed of the reasons why washing is required before eating or drinking and why eating and drinking are not allowed in contaminated work places.
4.7.1 Training will be required for all employees required to work with lead or lead based compounds.
4.7.2 Training will be required for all employees responsible for assessing and controlling working with lead.
4.7.3 Training will be provided to enable employees to be competent and confident with procedures, legislation and equipment associated with control of lead at work.
5. RISK MANAGEMENT
5.1 A local risk assessment of all areas where lead is used and stored must be carried out at least annually and when any significant changes are made to the use or storage of lead. This assessment must be carried out by the department user and Estates as required.
5.2 All staff involved in the maintenance, storage, handling, and administration of lead must have suitable training, and be aware of the hazards associated with the use of lead, and the importance of managing the risks posed by these.
6. RELATED DOCUMENTS
6.1 NHS Fife policy GP/M1 – Manual Handling.
7.1 The Workplace (Health, Safety and Welfare) Regulations 1992. Approved Code of Practice and guidance L24 HSE
7.2 The Management of Health and Safety at Work Regulations 1999. Approved Code of Practice and guidance L21 SE
7.3 The Control of Substances Hazardous to Health Regulations 2002. Approved Code of Practice and guidance L5 (Fourth edition) HSE
7.4 Control of Lead at Work (3rd edition) – Control of Lead at Work Regulations 2002. Approved Code of Practice and Guidance L132 HSE
7.5 Lead and you: A guide to working safely with lead Leaflet INDG3O8(revl) HSE