Rank: Forum user
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I was wondering if members could offer some advice on a situation?
We're a medium/large manufacturing site and as a result employ engineers who on occasion use hand tools. The use is very limited and tends to be about 10 minutes a week on average (obviously depending on what work needs doing. This is limited to battery drills, dremels that sort of thing i.e. nothing heavy.
To demonstrate that we've controlled the situation what we currently do is:
1. Ascertain m/s2 figures for all the equipment in use from either HAVTEC or manufacturers readings doubled as per HSE guidance.
2. Have a controlled replacement list so that like-for-like (or better) equipment is purchased
3. Brief the employees with the ratings of the tools they use as part of training and how long they should ues each for over the day and in combination.
4. Risk assess the use of handtools (which due to low use shows low risk)
5. Do spot log checks whereby each engineer on a quaterly basis records a weeks worth of hand tool use to demonstrate typical exposure levels.
6. Convert this recorded useage as per the HSE calculator to generate an exposure rate.
7. Record/file information
To me, we dont believe we have an issue due to the low use and relatively low rating of the tools used and so its just a case of demonstrating this belief by all of the above. The problem is that we've now had it recommended to use following an insurers audit that we ask the engineers to record ALL use of handtools. This means that they'd have to record every single time they use a handtool and fill the record log out.
Whilst I can see the value in this in that you'd have a 24/7/365 record of each individuals exposure, its totally disproportinate to the level of risk. As you can imagine, the engineers arent particularly happy about it either.
Any advice?
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Rank: Forum user
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If you are unhappy with the recommendation you can go back and challenge the auditor/insurance company citing exactly what you are doing and why.
At the end of the day, if you do not adopt the recommendation, what will that mean? Does it affect your insurance premiums?
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Rank: Forum user
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No, its just a recommendation at this stage. But with most things the insurers 'recommend' you have to have a good reason not to adopt it otherwise it'll become an 'insistance' on their next audit. I think the system we currently have is adequate so I guess I'm just looking for external validation of either the insurers view or of our system.
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Rank: Super forum user
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There are electronic systems which can automatically record tool usage for you, trigger times, daily use, weekly etc against each individual, they are however expensive and probably more suitaed to high risk tools. Tool monitors can also record trigger times, either inline pnuematics or tool attached small meters.
I have seen issues where employees believe this to be big brother looking at how hard they are working, chances are with a paper based system they will over estimate their exposures.
The only thing that I see you are missing in your list is health surveilance, however in 10 minutes use the tools would have to be very high vibration to exceed the 2.5m/s².
Agree it sounds like in normal use it is unlikely they would exceed the lower action limit and daily recording seems a bit OTT. I dont know many places that do that.
Des
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Rank: Super forum user
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Jason
First thing is that there have been changes to the HSE advice on ‘doubling up’ see http://www.hse.gov.uk/vi...ion/hav/publications.htm
It is difficult to believe that the sort of exposures you are looking at would result in your staff reaching anywhere near the the EAV let alone the ELV.
The HSE ready reckoner shows that a 15 minute exposure of around 14 – 15 m/s2 would be required to reach the EAV and around 25-26 m/s2 to reach the ELV. We use blowers, strimmers, chainsaws, hedgecutters etc that aren’t anywhere near those levels; so (without knowing the vibration levels) I very much doubt that a Dremmel or similar would likely be a significant problem.
I suggest you go back to your insurer and in a diplomatic way tell them to have a rethink. I would think you have far bigger fish to fry.
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Rank: Super forum user
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Jason, I'm an insurance surveyor and if you'd shown me the measures you already have in place, I'd have left a very happy man. We still struggle to get some civil engineering contractors to put these measures in place.
I suspect that the surveyor does not fully understand the vibration regs and is asking all their clients to carry this out - in which case they need to be challenged.
The only thing that could justify it is if you have a history of VWF claims (perhaps try ons, or for exposure elsewhere) and the insurer wants you to keep records in order to disprove the claims. From the way you have described the activities though, I would not have expected to see any.
As for recommendations and requirements I always think about it like this.
If the client does not do what I ask, would we need to consider cancelling the policy. If so, it's a requirement.
If not, it's Advice (or recommendation). If advice is not followed, most insurers in the current soft market are not going to make an issue of it.
Explain that you are not even reaching the EAV and the regs do not require any further action on your part. Challenge the insurer via your employer's insurance broker.
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Rank: Forum user
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Thanks for all the replies. Most appreciated.
I forgot to mention that we do cover health surveillance off too. All employees undergo an annual medical whereby one of the issues approached is symptoms of vibrational damage.
Stevie, I think you're right on the reasoning. The response I got when I asked the question was 'how do you demonstrate that for the period you're not monitoring that the employees arent using power tools 8 hours a day?'. We dont have a history of related claims and perhaps he was just having a bad day.
thanks again everyone.
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Rank: Super forum user
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I concur with stevie40. My rationale for requirements is a significant breach of legal duty or serious inability to defend claims. Remainder are recommendations.
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