HAVS: Where do we need to be? Sharon Mawhood HM Inspectors of Railways ORR RSSB HAVS conference 21 February 2018

The Control of Vibration at Work Regulations 2005 Regulation 5: Assess the risk relative to exposure action and limit values Regulation 6: Control the risk by eliminating or reducing exposure to lowest level reasonably practicable Regulation 7: Provide suitable health surveillance for employees at risk of harm Regulation 8: Provide suitable and sufficient information, instruction, and training Regulation 3(4): extends employers’ duties to anyone working on their premises and who may be affected by their work, except for health surveillance

Where do we need to be: risk assessment? Role of continuous monitoring technology? Support risk assessment: identify high risk tasks and tools Sample checks on adequacy of control Possibly for emergency work, or employee with HAVS restrictions in place? Not to facilitate working until the ‘red light flashes’ ELV not safe level HSE FAQ on vibration exposure monitoring

Where do we need to be: health by design? Resources: cost monitoring v improved control? Change the process or method of work Prefabricate components off-site? Remote control breakers? Pneumatic tools rather then petrol or electric? RRV or jig mounted equipment e.g. rail grinders, saws? Share good practice: ORR web site

Health by design: hydraulic concrete bursting

Health by design: remote control breaker

Where do we need to be: power tools? Tool procurement policies: drive lower vibration emissions Higher vibration tools remain in use: time limited product acceptance? Planned preventive maintenance Accuracy of portable tool registers? Sharing of real world emission data to supplement manufacturers’ test data? Over reliance on job rotation to manage exposures – how effective is site supervision?

Where do we need to be: training? Line managers enabled to: Support their staff Monitor vibration exposures and participation in health surveillance Investigate exceedances Workers need to understand for behavioural change HAVS in mandatory training and task briefings? HAVS in work planning and engineering functions? Safety reps role in driving change

Where do we need to be: health surveillance? Protect at risk individuals but also drive better control Failure to monitor and ensure return of questionnaires and clinic attendance? HAVS health surveillance compliance rates as leading indicator? Referral for face to face appointment every 3 years (even if no reported symptoms) universal good practice? Labour only workers often not captured: uncertainty on who is the employer and who is at risk of harm New RPCG guidance on HAV in supply chain to close the gaps between labour users and labour suppliers

HAV in the supply chain: who does what? Challenge: 50,000+ rail agency workers: zero hours, umbrella companies, nominal self employment – who is the employer? Users of labour: the contractor in control of the work manages HAV risk on site for all workers Labour suppliers: act as nominal employer for labour: ensure fit for work, assurance on control HAV risk on site, health surveillance for at risk workers Relies on exchange of information between users and suppliers on HAV risk control, vibration exposures, and health surveillance outcomes

New RPCG guidance: our view? Fair and workable solution deserves industry support Contractors’ key role to enable labour suppliers to do more Challenges around timely exchange of HAV exposures? Fits existing standards and codes – primary sponsor employer for H & S Not a legal requirement but industry good practice Cost benefit: More efficient than complex assessment of employment status for each labour only worker? Reputational benefit: rail can lead on this…concerns around gig economy Skills benefit: rail is a great place to work

Thank you