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

2. 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

3. 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

4. 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

5. Health by design: hydraulic concrete bursting

6. Health by design: remote control breaker

7. 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?

8. 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

9. 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

10. 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

11. 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

12. Thank you