Posted By Ken Chappell
PLEASE HELP.



I am new to the Health and Safety profession.



I have been asked by my manager to look at the DSEAR Regs to see whether our factory premises are compliant.



My manager has given me the ACOP and told me to find out what we, as an organisation must do.



To be honest I haven't a clue where to start.



Can anyone please give me some advice as to what to do.



Any help is greatly appreciated.



Many thanks and kind regards.



Ken Chappell.

Posted By Allan St.John Holt
Ken,

I suggest you start by identifying your organisation's appointed competent person (a requirement of the Management Regulations) and asking for some help in identifying your current controls in this area. Then you can use the ACoP to carry out a gap analysis, and work together to fill the gaps. This would be the easiest way in my opinion.

I have the feeling that you aren't too comfortable with this task!

Good luck,

Allan

Posted By Dave Daniel
You are not alone. I've been in H&S for 31 years and I can't determine what is required - at least, what standards are expected to be applied.

Having watched the HSE squirm over being invited into a car recycling yard to see how petrol in fuel tanks is removed I can also confirm the HSE also have no idea how to apply the regs. The array of white faces when the man with the bronze pickaxe and a bucket emerged to show the "traditional way" was a sight to be seen.... A most entertainng day out!

Zoning is a particular issue since having made it a legal requirement no-one seems to have thought of the practical implications. In the above scenario and the subsequent visit to a proper vehicle decontamination station at my own client's site the subject of zoning was raised but mysteriously failed to be mentioned in the following letter which only arrived 3 months later....

I was also told that existing pre-DSEAR guidance will NOT be re-written but you will be expected to use if as guidance, presumably skipping the references to obsolete laws.... What can I say?

At the present time I would advise you determine where you might have substances falling inside DSEAR, apply sensible obvious standards, set any zoning carefully to a minimum area. Without any specific guidelines themselves, I cannot see how the HSE can challenge any assessment or situation which is not a blatant and obvious risk.

Dave Daniel
Technical Director
Practical Risk Management Ltd
D.R.Daniel@ntlworld.com