We have gone down the route of obtaining welding hoods with air supply and filters because LEV isn't a suitable control for our processes, at the moment you can't get hold of these hoods due to the demand and we are on a "wait list" with the manufacturer!!

So is that 1 nut a year, a month, a week, a day, an hour or a minute or even every 30 seconds. I think if you have welding equipment on site it may be hard to prove you use it say for only for 30 seconds once a week. Their notice seemed absolute “regardless of duration”.

Also, nut made out of mild steel or Stainless or??

Obviously document your usage etc so it does not sound as if you are making it up on the spot. If the HSE visit and say nope mask not good enough you should have LEV have an improvement notice. You then buy LEV.

 I think the important thing here is that you ensure you are not harming your employees. Is it worth buying LEV so you don’t have to keep buying masks for ever and a day, with all the fit testing, clean shaven etc that goes with it?

There are other ways to make a nut captive and or stop it rotating when putting a bolt in ?

Chris

Originally Posted by: stephen1974

Hi all, resurrecting this one.

The clients I am having to advise do a tiny amount of welding, on occasion. Less than a minute or two at a time maybe two or three times a month.

Obviously they don't want to be spending thousands if there is no need. The problem is, the information out there doesn't seem to take in to consideration these types of user.

IOSH did have a link on their website (may still do) to a company called breathe freely who had a tool on their website to assess requirements and they were advising general ventilation only for the above, yet the HSE has said that is no longer acceptable.

I then go on the HSE website and look at their Do you need extraction or rpe? page and extraction or rpe are still listed as n/a when welding out doors.

IS there no black and white - this is what you need to do guidance?

The other problem is 'extraction' can mean any number of solutions, how do you go about identifying which one is the most appropriate?

The 'tiny' amount of welding is more than I've ever done in my lifetime, so I'm at no point stipulating I'm an expert in welding practices. However, the recent guidelines (February 2019 - http://www.hse.gov.uk/safetybulletins/mild-steel-welding-fume.htm?utm_content=&utm_medium=email&utm_name=&utm_source=govdelivery&utm_term) states that all welding fume can cause lung cancer. 

Reading the change in enforcement note, it addresses via heirarchy of control. LEV is the ideal, if welding has to be carried out. LEV isn't necessarily expensive, and if this task is ongoing for years, then it is likely to be a valuable investment (it'd be cheaper than a lung cancer civil claim at the least, anyway). 

The note also says that e.g. LEV, not explicitly, so extraction can be used, but should be supplemented with RPE, as mentioned. The combination of extraction and RPE and their associated costs might outweigh the cost of LEV. 

If this is a very temporary task, why not hire someone in for the small duration? It would likely be more expensive than doing it yourself, but if they're worth their salt, they should be able to provide suitable control measures for the task they're going to carry out.

The extraction measure that is most appropriate would be the one that completely removes welding fume from the vicinity. I.e. one with a suitable level of draw, suitable filter and close enough to the task. There are companies who should also be competent in advising on this, from the view of extraction + RPE vs LEV vs other, along with typical costs etc.

Lastly, I would argue that it does account for those types of users. It accounts for all welding activities so this is both large and small-scale welders.

The HSE guidance WL3 on Welding Fume Control has now been updated in November 2019:

http://www.hse.gov.uk/pubns/guidance/wl3.pdf

Originally Posted by: John Carver

The HSE guidance WL3 on Welding Fume Control has now been updated in November 2019:

http://www.hse.gov.uk/pubns/guidance/wl3.pdf

Thank you for highlighting this has come out.

Well that is significantly different to what they put out in Feb which stated

“Control of the cancer risk will require suitable engineering controls for all welding activities indoors e.g. Local Exhaust Ventilation (LEV).”

And

“Regardless of duration, HSE will no longer accept any welding undertaken without any suitable exposure control measures in place”

My bold and underlining. I think this should have been produced and issued 8 months ago just after their alert.

Chris

This was discussed on these Forums when the earlier guidance came out from HSE in February.

HSE's announcement then, in effect completely ignored the concept of reasonable practicability and failed to recognise that for some carcinogens WELs have been set, which means that always defaulting to a worst case assumption is inappropriate within what COSHH requires in the U.K.

In some scenarios those who have welding operations might do well to allocate resources to other things where the overall reduction in risk would be much more cost effective.

This is not to suggest that welding may not pose significant risks. It does and that hasn't changed for decades or longer. Even the medical understanding hasn't developed that far over the last few decades. We knew it was bad news, but mostly concentrated on safety risks instead.

The guidance WL14 has also been updated, oxy-acetylene LEV not specified

http://www.hse.gov.uk/pubns/guidance/wl14.pdf

and for Plasma cutting WL15 only talks about fixed equipment - no mention of portable kit. For fixed equipment LEV is expected and in that case says RPE not normally needed.

http://www.hse.gov.uk/pubns/guidance/wl15.pdf

John

Edited by user 18 November 2019 20:26:33(UTC)  | Reason: typos