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Not allowing women to wear skirts on shopfloor
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Posted By Jon Hookings Here's a nice contentious thread that I would like some assistance on.
The organisation I work for has recently implemented a 'Safety First' initiative where health and safety is the top priority over production, quality etc. This should make my life easier ( in theory ) but unfortunately some adhoc decisions have got out of hand.
The 2 plants I cover have both power press operations and manual and robotised spot welding processes. The Plant Director has made a decision that anyone who enters the sub assembly ( welding ) area must wear gloves and armlets or a company supplied workwear jacket to prevent burns. He wants all exposed skin covered.
This has moved on to the extent that female office staff ( working for HR, logistics, quality etc ) will not allowed into this area if they are wearing skirts because their legs are uncovered. They will be expected to wear or change into trousers.
I have been asked to complete a risk assessment on this issue, and because there are no recorded accidents, and the risk is very low, I have advised the Director that we cannot discriminate against women, and as long as they stick to the recognised pedestrian walkways and gangways, and their skirts are of a reasonable length ( knee length minimum ) we will be doing all that is reasonably practicable.
This does still give me a problem with one individual who works for the quality department, who audits parts next to the spot welding machines.
Does anyone have any ideas of how I progress this one?
Thanks in advance
Jon
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Posted By Timothy Capner Dear Jon
You're going to have fun with this one!
It is entirely apropriate to insist upon a 'dress code' for the plant, particularly if exposed skin is at risk. Staff waring skirts should be offered the opportunity to change into a coverall that would cover their arms and legs and offer the protection your risk assessment would determine.
Also bear in mind ethnicity - a Scotish chap may prefer to wear a kilt whilst at work.
Och aye and bye for now
Tim C
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Posted By Sean Fraser Jon,
I think you've taken a reasonable and practical approach to this and I would support your compromise, as long as you are sure that:
1] The walkways are clear, unobstructed and away from the work areas with most potential to cause harm, and
2] People actually use them.
Safety is all about assessing actual risk and taking appropriate and reasonable action - which is not the same as being risk-averse, simply risk-aware. What are the chances of harm? If they go where they are guided then none.
But there are always unreasonable people who see the bogeyman everywhere and won't let it lie. After persuasion and discussion fails, you will be forced to use authority and rank.
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Posted By Merv Newman Jon,
Let's go back to your risk assessment. What kind and level of injuries were you assessing and what frequencies did you estimate ? What were your "worst cases" ?
Apart from slips, trips and falls and so forth which can occur in almost any workplace, the main risk I have seen from robot welding installations is the stream of sparks given off by worn or maladjusted electrodes. These can spray out 5 metres or more. I used to flinch when one came in my direction but found that by the time it reached you the sparks had mostly cooled off and it became an eye protection issue.
Operators are more directly exposed and I do see some with small burns on work clothing. But it is hardly the level of injury which would send them running to medical.
So, for your quality controller, I would expect that the level of injury is very low even though frequency of exposure could be high - each visit to the area.
Safety shoes, safety glasses, work overall, suitable gloves, head covering and maybe hearing protection in the press area are about all I would ask for.
The "worst case" I can see is a hole in her (or his - musn't be sexist) tights.
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Posted By Jon Hookings I've gone back a couple of years, and although there are occasionally burns reported in the accident book, there haven't been any to the legs.
Most of the female staff spend very limited time in the area so there is generally a very low risk. The quality auditor has been doing the job for years, and has never reported a problem.
Using the hierarchy of controls, any specific sparking problems should be reduced using engineering controls first, and PPE as a last resort.
Jon
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Posted By steve e ashton Jon,
If the plant director has had problems in the past when workers in the assembly area have taken to wearing shorts whilst welding or attending the machines, then I can see why he may have concluded that a 'covered leg' policy is essential. If that policy now takes in the occasional visitors to the area - and it should - to ensure the people working there do not see the imposition of leg-covering as just another management bully boy tactic - then, you've got to support him. Yes, visitors to an area must comply with the PPE code appropriate to the area. If that means no skirts, then no skirts (or kilts...) is the rule!
And walkways - if your assembly area is anything like some I have seen, with a variety of different sized and shaped pieces being worked each day, then the 'walkways' largely become a matter of convenience and worker recognition of the need to leave space between jobs.. If you have clearly marked and enforced clear routes to and through - and if you are certain that there will be no injury or damage risk for those using the walkways - then you may have a case for relaxing the rules on the walkways. But.... As a previous respondent has observed, robot welders have a wide splash zone, so your walkways will need to be pretty far away from these machines to be clear of the hazard zone.
Back to first principles - why do non-welders need to pass through the assembly area? Would it be possible to rearrange the plant layout to avoid the need for traffic through the work area? (And at the same time reduce the 'other' risk of distraction for those working at safety critical tasks). Design out the risk, keep non-essential personnel out of the designated area. (But your auditor must comply with the rules).
Good luck in sorting this one - it has the potential to be very interesting!
Steve
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Posted By Hilary Charlton I've never really considered this but because I know a lot of my work is on the shop floor I wear trousers 99.9% of the time. I can see your manager's point of view and I think it is very sensible - whether it is lawful or not I really don't know - I would guess it probably isn't.
Good luck with this one - I think you are opening a can of worms.
Hilary
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Posted By Nick Higginson Jon
Not really on the subject I know, but I always have a problem with "safety first" initiatives.
If safety really becomes the top priority above production and quality, there won't be a problem with skirts because the company will be bust within 12 months.
Regards
Nick
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Posted By Merv Newman As I said above, I do not feel that burns from spot welders are a significant hazard. The sparks have the same temperature and similar composition to "sparkler" fireworks which we have all played with and probably given to our children. (though I understand that they are in the process of being banned)
While the operator is frequently and closely exposed, probably within 1 metre of the welder, I would maintain that "spark burns" are insignificant. Eye protection for operators AND all visitors is essential. A cloth cap is also usefull in keeping spark dust out of the hair (from where it can fall into the eyes)
The most modern welding shop I know of has about 600 robots, mostly spot welding. The central roadway is about 10 metres wide, including a 1 metre pedestrian alley on each side. Naturally these alleys run parallel with the welding installations, on both sides. ALL visitors wear safety shoes and eye protection. In addition, employee "visitors" wear work overalls.
After a few "dust in the eyes", employees were requested to wear a cap (smart black with red company logo)Which they do.
If anyone is interested I can e-mail that site's HSE manager asking for injury stats. Can't garauntee (how do you spell that ?) a reply.
Happy bonfire night everyone
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Posted By Merv Newman Safety First
no, I'm not trying to hijack this thread. Just a comment on "putting safety first".
The only reason a company has for existing is to make money for the owners. So cutting costs and increasing profits allways come first in the minds of shareholders and senior management. Now, if we can do that safely, so much the better.
What does "safety first" mean ? It never ever means "stop working untill every little possibility of harm has been totally and finally eliminated". Does it ?
We do our risk assessments, set priorities and draw up the action plans. First we have to deal with the "significant" risks. The moderately significant or insignificant risks have to wait. We know they exist, but we tend to accept the little problems while sorting out the big ones. And we get criticised for doing it that way. Some of us try to do all three at once and we get criticised for doing it that way.
Anyone remember the video "take two" ? The message was : before you start the job, take two seconds, two minutes, two hours, whatever, to think first about the safety of what you are going to do. That is putting safety first. And it doesn't cost a lot.
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Posted By Nick Higginson Merv
I am all for putting safety on an equal footing with other objectives, but it can never come totally first.
I would say that asking employees to take "2 hours" to think about safety before they start may bring industry grinding to a halt.
Nick
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Posted By Jonathan Breeze Nick,
I am in agreement with the majority of what you say, but I don't think Merv was suggesting taking 2 hours at the start of every shift (or worse between every piece of work!) just to "think" about safety.
That would be stupid!
I interpreted him to mean that safety should be considered in business decisions at all levels and not tacked on as an afterthought.
Perhaps this is worthy of another thread.
Re: the original question, I would suggest that office staff should not visit the shop floor, but if they had to it would be reasonable to request them to wear suitable PPE for a welding shop (i.e. coveralls).
This should cover all office staff irrespective of gender.
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Posted By neil poyznts-powell Nick,
Firstly, in the eyes of the law safety does come first!
If you are ever summoned to court following an accident. Please let me know as I would like to be present whilst you explained to a court that your company puts production (profit) before safety.
The argument that worker safety puts businesses at risk, has been used throughout industrial history as an excuse for companies to injure and kill their workforce for the sake of expediency and profit.
Also, it is possible to intergrate health, safety and environmental concerns into a companys quality system. Therefore, making Health & Safety as much a part of the operation as the product itself.
Regards,
Neil
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Posted By Katie Hoyland to be serious for a moment ( it seems that these threads always drift into stupididty), an obvious solution long term would be for your company to implement a positive discrimination policy with regards to recruitement aimed at employing a proportionaly high number of lesbians , therefore killing two birds with one stone in terms of minority employment and avoiding the risk of having a buiding full of skirt wearing ladies. This seems like a workable solution. Obviously recruitement advertisments etc would need obvious yet subtle re-wording.
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Posted By Karen Todd I recall a case, but can't remember the name of the company. I think it involved the female staff on the channel tunnel trains. Their uniform was a skirt and blouse. They said they didn't want to be forced to wear skirts; they wanted to have the choice to be able to wear trousers and they thought trousers were more practical. They won.
However, this was not a safety issue.
Regards,
Karen
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Posted By Nick Higginson Neil
I don't ever recall advocating putting productivity before safety. I simply said that safety should be of equal importance to production, quality etc.
You appear to infer that you wish I would go to court so that you could come along and laugh - hardly a helpful response to a thread.
Let me know when you are in the MD's office being handed your P45 for wasting company money, and I'll come and sell him some consultancy services that take note of the meaning of the phrase "reasonably practicable".
Regards
Nick
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Posted By Richard Altoft I assume you have done the obvious such as talking to those who do the actual job and their safety reps or employees reps for safety. Company should provide overalls appropriate to the job as assessed as PPE regs require. this also means company has prevented contaminated clothing being taken outside factory and they will prevent damage to persons own clothing from sparks etc/ HASWA reg 7 and Management reg 14 and PPE reg 10 apply and refusal to wear can lead to dismissal. BUT BUT BUT if a staff member can be trusted with QA and welding up quality work then their opinions should be at least taken into account. Consultation brings ownership brings cooperation. big stick comes apoor second to informed sign on by those affected Regards R
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Posted By Hilary Charlton I agree with Nick on this one - if Safety came absolutely first you would be running a safety consultancy and not a manufacturing plant or chemical plant, railway or anything else. We have health and safety very very high on our agenda - it is the second rule to which we prescribe. The first rule is "make a product and stay in business". If there is no product and no business then safety is somewhat academic isn't it?
Hilary
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Posted By fats van den raad Like my MD said "We can make the bussiness completely safe! We can ensure without a doubt that no person is involved in an accident while in our employ. We just close the bussiness and let everybody go. It wont be a bussiness no more, but it would be safe!!"
Take it from me,(and I have been around the block a few times) "Safety First, above and beyond all else" is an empty slogan that is never true and is always found out. The best we could hope for is safety at least equal to any other bussiness concerns, such as quality, productivity, profit, etc. Thats why its so important that we keep on working on making safety make a positive, demonstrable contribution to the bussiness
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Posted By neil poyznts-powell Nick,
1. Your whole inferance throught the thread has been that safety is not your first priority. In my mind a strange position for a 'health & safety proffesional' to take.
2. I would not be coming to court to laugh, but to see justice takes its course.
3. The reason I am with my current employer is because of ineffective service in the field of Health & Safety, from consultants. As a Health & Safety Officer my first conideration is the Health, Safety and Welfare of the company employees, if I was asked to make this not my main priority I would not need a P45 , I'd be gone. There again as a consulatnt I can see the pressure you have on you tell clients what they want to hear!
Also, I can not recall mentioning or infering the spending of money in my response. Good health and safety does not have to be costly to be effective. The only waste of money with regards to my function, was the hiring of consultants prior to my arrival.
With regards to helpful responses. Deriding a fellow proffesionals safety initiative, I would see as both unhelpful and unproffesional.
Finaly, 'Reasonably Practicable' is easy to use as a cop out, until scrutinised and picked apart by a court of law. Hindsight is great tool!
Regards,
Neil
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Posted By Jim Mc Nally I think that this is an interesting issue. From a management viewpoint, a decision has been made which they feel reduces the possibility of an accident. The discussion seems to be around how severe the accident may be and as such if it is only minor then the policy is over the top. If you follow this approach, then you wait until someone does perhaps wander into the wrong area or some other unexpected situation may arise and an accident occurs. There are too many examples of managers not taking any interest in the safety of their employees, perhaps in this case, this management team needs to be applauded.
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Posted By Merv Newman I think I'm getting general support for my opinion on "safety first" Some points come to mind -
1. In court : I have read reports where management said "safety is very high on our agenda, if not the first"
2. "Take two" means take a little bit of time to think of the safety of what you are about to do. If I am going to place an orange cone on the floor I'll take two seconds to look around to make sure I'm not about to be hit by a FLT. If I'm going to demolish a building it may take between two hours and two days to think about doing it safely. etc. whatever it takes
3. And I think this is important.(consider that underlined) A risk assessment for a welding operators job is only applicable to the welding operator. A separate RA would be required for the quality auditor's exposure, as it would for visitors. Asking an occasional visitor to dress up in the same protective equipment strikes me as a bit thick.
I have and wear all appropriate personal protective equipment, sometimes more than the client requires. The only times I have been asked to wear overalls was for going down the mines. The overalls were white, as opposed to employee's blue, to show employees that they would have to be a bit more careful 'cause there was an idiot visitor coming through. (Do I remember margaret thatcher going through the same business once, or was it the queen ?)
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Posted By neil poyznts-powell I agree with each of Merv's statements as they seem well thought out and based in common sense.
I believe that a distiction needs to be made between the priority of a health and safety professional and the priorities of a business.
The priority of the business is to make as much profit as possible. In my opinion the H&S proffesional involved with the business, should do all in their power to ensure that this is not achieved to the detrement of the employees health, safety and welfare.
Regards,
Neil
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Posted By Nick Higginson All points made are valid of course, but it is very easy to spout forth on what we believe, when it is practically useless.
The modern day Health and Safety Professional has to see beyond safety first at all costs. If we are to become truly integrated into 21st Century Management and be taken seriously at boardroom level, we have to move on from this outdated attitude. It is this kind of attitude that is giving us all a bad name re: conkers, poppies, xmas decorations etc. etc. etc.
Merv
Your point about in court is well made. I cannot think of one solicitor worth his salt who would not advise his client to say these things.
Jon
Despite (unfounded) allegations to the contrary, I have in no way criticised any safety initiative of yours, just trying to make an interesting point.
Regards
Nick
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Posted By fats van den raad Neil Two points I feel I have to raise here. 1. Your description of what you see as the function of the H&S professional is as archaic and outdated as your previos description of your own job title as "Safety Officer" This description indicates an individual going round the bussiness fighting the proverbial safety fires (You can't do this, you cant do that). The profession have evolved from those early days and is now much more focussed on being proactive rather than just reacting to what has happened. 2. Your statement seems to indicate that safety is an "add-on" to the bussiness, something that has to be tolerated, but that inj essence is not really part of the bussiness. Funny enough, bussinesses where the argument about what is top priority, safety or production, still rage, are those that still have not managed to fully intergrate safety into the whole bussiness strategy. If you have achieved this, it will become clear that the important issue is not which one is top priority, but that in the end there can only be one aim and that aim is to maximise the bussiness in a way that does not adversely affect stakeholders, the environment or society in general. This is called sustainability and part of this is Corporate Social Responsibility. It's not good enough to just strive for ultimate production, profit or safety. In todays world you have to strive to achieve ALL.
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Posted By fats van den raad Oh yeah, Merv... Of course I'm gonna stand up in court and say "Profit is our first concern, we don't really give a toss about safety!!"
(Just kidding)
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Posted By Nick Higginson Fats
Amen.
Nick
PS Must go now, have to write a method statement for putting up Xmas decorations and prepare a COSHH assessment on silly string.
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Posted By Merv Newman Fats,
We do strive to do it all at once, knowing that it is virtually impossible and something will go wrong before we get around to it.
I talked with an american consultant a few weeks ago. He holds that it is the most unlikely accidents that happen the most often. could he be right ? We usually start by asking "what is the most likely accident to happen ?" then we deal with it. then we say "what's next ?" and so on. Meanwhile...
Makes a mockery of Risk Assessments, action priorities and so on :
He may well have been consulting to some of our conker banning colleagues. "Don't worry about that contractor swinging off a 20 ladder. First make sure that woman doesn't get a hole in her tights".
That's the lot from me tonight. I declare this thread well and truly hijacked.
I'm off to Lyon to teach another 50 or so plant managers how to be kinder to their employees. Ho Hum
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Posted By Stuart Nagle People. Let's get back to basics here...
Jon is asking if and why and how...
As I recall there is a hierachy of procedures that need to be followed;
1) There is a risk of welding splatter from robotic welding machines - seen it often (as mentioned above)
2) There is a legal duty to protect employees from hazards such as this
3) Employees working in the area (e.g. on the shop floor) need to be protected from the hazard as well as from residual risk of injury from such processes as do other persons (employees or not) entering the area
4) PPE is not regarded as the first means of defence to protect from harm - engineering solutions are - therefore, if reasonably practicable such engineering solutions should be considered and implemeted first. This might for example be screens, curtains, barriers etc - or indeed safe routes that prevent contact with the Hazardous area or from emmisions from the hazardous area(guarded as necessary - if necessary).
5) If 'other persons' not engaged in the hazardous activity have to gain access to aa hazardous area, then they will be subject to the same safe systems of work and protection afforded to those who normally work in those areas.
6) In the case of welding and splatter this is likely to include overalls (fire proofed) that cover extemities (arms/legs etc) and other PPE such as eye/face/head protection, gloves, boots, hearing protection if noisy etc...etc...
This should apply to all staff/employees and visitors, and entry of personnel into these hazardous areas on an ad-hoc basis, if not wearing the correct PPE (regardless of their status) should be controlled and not be permitted unless properly controlled.
7) Signage (mandatory) complemented by training and tool-box talks will assist, and the procedures for operation in the areas concerned should be reviewed and updated as appropriate given the findings of risk assessments in light of the above matters.
8) To simply provide employees (or others) with PPE and permit access to hazardous areas is NOT suitable and sufficient
9) PPE assessments should also be carried out to ensure the PPE is suitable for the indiviual and compatable with other PPE employed. Training and demonstration of the PPE use and it maintenance and cleaning will also be required.
Regards...
Stuart
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Posted By Merv Newman Stuart,
I think you have misunderstood the situation. We have been talking about robot spot welding. No welding rods. Spatter of molten metal does not occur. You sometimes get a shower of sparks which can fly for several meters. These, while spectacular, have no more power to burn than a child's sparkler firework. Exposure to repeated showers of these low energy sparks can leave you with a residue of dust on your clothes and your hair. Leading to a possible "dust in eye" hazard
My previous comments stand
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Posted By Lynchy
Blimey Jon - look what you've started!!!
If I might add a very minor but neverthe less I feel very important point??
What if the ladies are wearing tights and were caught by sparks?? I think that this could result in a very nasty & painful burn even if very tiny. You know how that sort of material melts instantly and sticks to the skin!
I can remember once a long time ago a friend of my parents was very badly burned about her legs when her tights ignited during using a gas camping stove in bright sunlight - not the smae scenario I know but I do recalll that she was very badly injured and in very severe pain - so I think it is a serious question and I would always drop on the side of proper clothing - whether male or female is not really the issue is it??
Regards
Lynchy
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Posted By David Sinclair Jon,
There have been some very good responses to the health and safety aspect of your question so I will not seek to add to those.
I would however like to clarify the postion with regard to sex discrimination. Obviously, as I don't know the full facts of the case I can't comment on this particular matter. However, by section 1(1)(a) of the Sex Discrimination Act 1975, "a person discriminates against a woman... if on the ground of her sex [or marital status] he treats her less favourably than he treats... a man".
My understanding is therefore, that provided you also ban men wearing skirts, etc. in the plant you are not discriminating against women.
David
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Posted By Sue Powell Don't wish to hop into a quagmire here but there seems to be two threads here now, one being the important question firstly raised and the other a discussion about where safety should fit into priorities. There have been plenty of helpful ideas to the original question so I don't feel the need to add to it.
But as to whether Safety First campaigns are valid - Of course they are. My view is and always has been clear. My goal with all those I advise is to
a) get them to put Health and Safety as No.1 on the Management/Directors meeting agenda instead of just above/in AOB. b) champion a company culture where health and safety isn't a separate issue but is a natural part of the thought process in any decision being made anywhere in the company, from the shopfloor to boardroom.
and that means getting Health and Safety uppermost in the corporate brain.
When we cross the road we don't think "separately" as we look both ways and look again - its all a natural learned experience of risk assessment.
For some companies it may now be second nature but to most putting safety first is the only way to kick-start the process!
Maybe this is old fashioned stuff and too black and white for the new age "out of the box" thinking people but in my experience it works friends!
Sue
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Posted By Merv Newman Lynchy,
Where burns and tights melting are concerned I don't think any comparison is possible between the affect of a picnic stove and the very low residual energy in a spot welding spark. The particle size is very small, the eneergy content is very low and cooling is rapid. I may even have been exagerating when I suggested a hole in the tights as a "worst case". This will be strongly dependant on the distance travelled by the sparks and the available cooling time. As said above, direct exposure of the operator will likely be many times more than that of the quality person. Different RAs and, probably, different action plans.
I have e-mailed the HSE manager of a car making plant for info on their injuries and next week I will be visiting a "white van" factory where I will ask again
Merv
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Posted By John Murgatroyd The worst possible case is that the clothing catches fire. I can think of many cases where a small spark has caused a large fire. Surely you cannot have a risk assessment where fire due to sparks is not considered ? I've been a welder since 1973, and have had many burns caused by small sparks...and if the spot welding machine is badly adjusted, or damaged, then the sparks are far from small and it can even spit globules of molten metal a large distance.
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