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I have a discussion on going with an engineering company regards safety glasses. The question is are the options either mandatory or nothing regards signage as some staff wear them and others do not. They are looking for offical signage to reflect the practise Thoughts
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Not sure what you mean by options? What does the risk assessment say, must wear or not.
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The current RA is very grey in detail and does not state either way, I have picked up this current issue from someone previous. The reason for the question was staff say it was originally left up to them but there are several notices with a mandatory wear safty glasses. I feel this may be one where its best to start from scratch
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If your equipment is fully and suitably guarded it is likely no eye protection would be required HOWEVER as soon as you have a drill, lathe, grinder etc. that can eject items at velocity it becomes non-negotiable. NOTE the eye protection should primarily protect against impact except where you also have coolants/lubricants pouring over the workpiece then goggles become more appropriate. Typically though in an engineering shop different equipment is running at different times which is when it is not the operators at significant risk but those merely passing through (office / warehouse / toilets / canteen) - these tend to be the people mandatory zone protection signage is directed towards as opposed to mandatory signage on individual pieces of kit.
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If your equipment is fully and suitably guarded it is likely no eye protection would be required HOWEVER as soon as you have a drill, lathe, grinder etc. that can eject items at velocity it becomes non-negotiable. NOTE the eye protection should primarily protect against impact except where you also have coolants/lubricants pouring over the workpiece then goggles become more appropriate. Typically though in an engineering shop different equipment is running at different times which is when it is not the operators at significant risk but those merely passing through (office / warehouse / toilets / canteen) - these tend to be the people mandatory zone protection signage is directed towards as opposed to mandatory signage on individual pieces of kit.
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“The current RA is very grey in detail and does not state either way”: this is one of my bugbears when it comes to doing risk assessments and in particular using matrices(grids) to establish whether a control is good enough. IMHO the whole point of a risk assessment is to tell you whether a particular course of action is appropriate eg do you need to wear PPE. People create these big 5 x 5 matrices and then proceed to fill them with various shades of yellow/amber, which means they still haven’t established whether a particular course of action is the correct one. They use weasel words like “proceed with caution” or “review every 4 months” as if that will reduce the effect of a accident if it all goes wrong. Making a control “advisory” is another example of this; if someone asks you if “do you have a risk assessment for this activity” you can say “YES” despite the fact that is useless and almost certainly no ”suitable and sufficient”. risk assessment is not an exercise in sympathetic magic where by simply completing it, it provides some form of protection ( from accidents or from legal sanctions) . So if wearing eye protection is seen as providing addition safety (taking into account other controls built into the process) then you must use it.
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Originally Posted by: Martin.D  The current RA is very grey in detail and does not state either way, I have picked up this current issue from someone previous.
Based on your wording, this is not a grey area. If the RA doesn't say eye protection is required, then it isn't required based on that assessment. There is absolutely no requirement within RA methodologies to state what controls are not required.
Having said that, as the previous comments make clear, whether or not the RA was correct is another issue. Rather than picking out the specific pieces of equipment within a workshop for which eye protection is required, and demarcating the area where anyone approaching the machine should don eye protection (protection of others), a more coherent policy (MHSW Reg 4, schedule 1 (g) General principles of protection) is to introduce a mandatory requirement throughout the workshop. It may initially be unpopular but is likely to be the best solution overall. It should be the risk assessment/s that ultimately dictates the actual requirements. Hope it helps, Tony.
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3 users thanked antbruce001 for this useful post.
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I’d like to echo and support AK’s fine words. You may be deemed, or personally believe, that you don’t need eye protection because you don’t work up close to the hazard. Whoever manages the area should be asked to justify it with the addition of saying “your honour” at the end. It either is, or is not necessary. It is never half necessary. I’ve seen someone just walk past new kit that was being tested and a hazardous substance under pressure spat out and very nearly hit them in the eyes. The (correct) response was “Right everybody, goggles or you can’t come in anymore.”
Oh, and 5x5 matrices are the work of the devil.
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5 users thanked DH1962 for this useful post.
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It's great that you're discussing safety glasses with the engineering company. When it comes to signage, having clarity is crucial. You could consider introducing official signage that encourages the use of safety glasses, rather than making it mandatory. This way, you're promoting a culture of safety while respecting individual choices. Learning from each other's perspectives could further enhance the safety practices.
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This idea of 'advisory' use of PPE goes against the generally accepted approach to RA. How can telling someone they should consider wearing PPE reduce the risk? But, what is often forgotten is the term didn't come out of nowhere. It was actually used in the Noise at Work Regulations back in 1989! It introduced the concept of a level at which education, provision and advice to wear PPE (Lower Action Level) was required but there was no requirement to enforce. This approach, IMHO caused a massive dent in the uptake of PPE across the broad as many dutyholders instinctively believe this can be read across to all forms of PPE. The government at the time shot itself in the foot by trying to appease industry.
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The point about advisory hearing protection in the noise regs is an interesting one. But I think it's also just fear of making a decision that may be unpopular or lead to conflict, and this kind of useless non-requirement goes much further than PPE.
Here's my own contender for "most useless non-requirement in a risk assessment ever". Back in the day, before I knew anything about H&S, I had a job which occasionally involved shifting 25 kg sacks. This was quite probably beyond what I could safely handle (I'm not a big strong person). Someone was sent off to do a course on manual handling assessment. In due course I was solemnly informed that a manual handling assessment had been completed, and that the conclusion in respect of my handling of 25 kg sacks was that "consideration should be given". I received this information with bafflement. Consideration should be given to what? by whom? So as I hadn't received any specific instructions, of course I just carried on exactly as I had been doing. (The only other thing that happened was that I was trained in how to pick up a cardboard box.)
Telling people that eye protection is advisory is in effect saying "If you value your eyes, well protect them then. I don't give a stuff about your eyes personally. I have more important things to think about such as how I can avoid making a decision that someone may disagree with."
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4 users thanked Kate for this useful post.
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Kate This is the fundamental point of H&S training. Without the training you may simply suspect that you are doing something wrong, once trained you know you are doing something wrong!
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Originally Posted by: Zaki Masood It's great that you're discussing safety glasses with the engineering company. When it comes to signage, having clarity is crucial. You could consider introducing official signage that encourages the use of safety glasses, rather than making it mandatory. This way, you're promoting a culture of safety while respecting individual choices. Learning from each other's perspectives could further enhance the safety practices.
Clarity in signage is crucial which is why there are three types typically deployed in UK businesses - the yellow warning triangle, the red prohibition circle and the blue mandatory circle. Following ISO rules the pictograms for eye protection are applied to the mandatory sign.
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Rank: Super forum user
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Originally Posted by: Zaki Masood It's great that you're discussing safety glasses with the engineering company. When it comes to signage, having clarity is crucial. You could consider introducing official signage that encourages the use of safety glasses, rather than making it mandatory. This way, you're promoting a culture of safety while respecting individual choices. Learning from each other's perspectives could further enhance the safety practices.
Clarity in signage is crucial which is why there are three types typically deployed in UK businesses - the yellow warning triangle, the red prohibition circle and the blue mandatory circle. Following ISO rules the pictograms for eye protection are applied to the mandatory sign.
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Following on from Kate’s excellent post (#11), risk assessments IMO tend to be littered with words such as ‘wear suitable’, ‘use appropriate’, ‘assess ????? before starting task’ etc. This all sounds great to the assessor because they believe the decision can then be pushed to the person doing the task and they are in the clear. This appears to work for years, over many assessments and therefore the perception that this is suitable and sufficient is embedded. Until ………….. proper regulator scrutiny kicks in and the question is asked “who is doing the actual assessment of the risks; the employer or employee? Any such phrase as above can be taken as Prima Facie evidence that the employer is not assessing the risks before the work takes place but leaving it to the employees during the execution of the work. This leaves the employer in obvious breach of Regulation 3 of the Management Regs. I cant find the references now, but a previous employer (at a different site to me) was prosecuted for just this scenario and then was taken apart at appeal court where in summary the Judge said something like “ the appellant showed a flagrant and reckless disregard for their employees safety by in effect leaving it to the employees to determine their own safe system of work. By virtue of Reg 3 it is quite clear to the court that the requirement to conduct a risk assessment is an employers duty and it is an omission of that duty to leave any assessment to the employees that can reasonably be assessed before the work takes place”. I’m not normally a fan of quoting law or case law but in this case it feels appropriate. This is also a textbook example of the fallacy of dynamic or point of work risk assessments that do anything other than confirm the actual risk assessment is appropriate to the on the day conditions that couldn’t be foreseen.
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5 users thanked Holliday42333 for this useful post.
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Zaki - I quote: "You could consider introducing official signage that encourages the use of safety glasses, rather than making it mandatory."
Any idea where one would procure such signage compliant with the relevant Regulations in the UK (or parallel legislation in those parts Europe that are subject to the requirements of the parent EC Directive) ? I have never seen a sign suggesting that eye protection should be "encouraged" but not "mandatory" that complies with said Regulations. You are very unlikely to find one in the catalogue of any major supplier of safety signs for UK workplaces. Whilst agreeing with the point made about the problems that arose following the making of the Noise at Work Regulations 1989, there is a big difference between hearing protection and eye protection. Exposure to noise is usually about incremental harm over a relatively long period. Being hit in the eye maims in one go.
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3 users thanked peter gotch for this useful post.
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Some of the useless things I've seen in risk assessments:
Read the safety data sheet [well go on then! what do you conclude from it?]
COSHH assessment to be performed [isn't this it?]
Wear a respirator if the area is not well ventilated [and all manner of similar rubbish copied from the sds]
And my personal all-time favourite useless control measure:
Take care [of what? how?]
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1 user thanked Kate for this useful post.
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Originally Posted by: Kate Some of the useless things I've seen in risk assessments:
Read the safety data sheet [well go on then! what do you conclude from it?]
COSHH assessment to be performed [isn't this it?]
Wear a respirator if the area is not well ventilated [and all manner of similar rubbish copied from the sds]
And my personal all-time favourite useless control measure:
Take care [of what? how?]
You can add Manual Handling to that. Words like "Complete Manual Handling assessment before starting work" or "Use TILE methodology to assess load" always have me wondering how a risk assessment can conclude that a risk assessment has to be completed, by someone else presumably.
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Originally Posted by: Kate The point about advisory hearing protection in the noise regs is an interesting one. But I think it's also just fear of making a decision Which spawns the blanket policy approach. First iteration of Hearing Protection and any area at or above was drenched in signage and hearing protection dispensers. Then came the smart Alec's who correctly point out that during maintenance shuts the machine is no longer creating noise BUT a mandatory sign exists at every access point.
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Originally Posted by: Kate The point about advisory hearing protection in the noise regs is an interesting one. But I think it's also just fear of making a decision Which spawns the blanket policy approach. First iteration of Hearing Protection and any area at or above was drenched in signage and hearing protection dispensers. Then came the smart Alec's who correctly point out that during maintenance shuts the machine is no longer creating noise BUT a mandatory sign exists at every access point.
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2 users thanked Roundtuit for this useful post.
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Originally Posted by: Roundtuit Originally Posted by: Kate The point about advisory hearing protection in the noise regs is an interesting one. But I think it's also just fear of making a decision
Which spawns the blanket policy approach. First iteration of Hearing Protection and any area at or above was drenched in signage and hearing protection dispensers. Then came the smart Alec's who correctly point out that during maintenance shuts the machine is no longer creating noise BUT a mandatory sign exists at every access point.
Had a Maintenance engineer who took it on himself to put hearing protection signs on all the plant rooms in our new building - none of which have any noisy equipment in them - you could hear a pin drop in most! He was most upset the next time he asked for the access key and we refused to give him it until he got some ear protection. He Insisted ALL plant Rooms needed these signs BY LAW but did not know what they meant or the consequences of displaying them.
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Originally Posted by: peter gotch Zaki - I quote: "You could consider introducing official signage that encourages the use of safety glasses, rather than making it mandatory."
Any idea where one would procure such signage compliant with the relevant Regulations in the UK (or parallel legislation in those parts Europe that are subject to the requirements of the parent EC Directive) ? I have never seen a sign suggesting that eye protection should be "encouraged" but not "mandatory" that complies with said Regulations. You are very unlikely to find one in the catalogue of any major supplier of safety signs for UK workplaces. Whilst agreeing with the point made about the problems that arose following the making of the Noise at Work Regulations 1989, there is a big difference between hearing protection and eye protection. Exposure to noise is usually about incremental harm over a relatively long period. Being hit in the eye maims in one go.
Procuring compliant signage that suggests encouragement rather than making the use of eye protection mandatory might require exploring custom solutions. Major suppliers of safety signs might not have such options readily available. Considering customization and seeking advice from safety professionals or regulatory experts could help navigate this challenge effectively.
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</p><p>Procuring compliant signage that suggests encouragement rather than making the use of eye protection mandatory might require exploring custom solutions. Major suppliers of safety signs might not have such options readily available. Considering customization and seeking advice from safety professionals or regulatory experts could help navigate this challenge effectively.
</p> One piece of signage this forum requires is a health warning for post like these and posters such as yourself. Which part of my previous post where signage is defined in law and international standards did you not comprehend? along with the fact true safety professionals will default to those regulations and standards when providing advice ( similarly for regulatory experts).
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</p><p>Procuring compliant signage that suggests encouragement rather than making the use of eye protection mandatory might require exploring custom solutions. Major suppliers of safety signs might not have such options readily available. Considering customization and seeking advice from safety professionals or regulatory experts could help navigate this challenge effectively.
</p> One piece of signage this forum requires is a health warning for post like these and posters such as yourself. Which part of my previous post where signage is defined in law and international standards did you not comprehend? along with the fact true safety professionals will default to those regulations and standards when providing advice ( similarly for regulatory experts).
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That reply about the safety signs sounds artificial. Is Zaki a bot?
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Given the banal content, a lack of response to the posts of others I think you may be on to something - except wouldn't a bot learn? Or has someone deployed the free version?
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Given the banal content, a lack of response to the posts of others I think you may be on to something - except wouldn't a bot learn? Or has someone deployed the free version?
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To follow on from Holiday’s fine post (#15) I recall a colleague some years ago showing me a bunch of documents and exclaiming in despair: “These aren’t risk assessments. They’re evidence for the prosecution!” The despair was mostly because he realised he’d have to rewrite all of them. Another bugbear with risk assessments is use of the third person, such as “gritting will be done” in icy weather. Then nothing about by who, with what, how or when. Argh. Luckily I’m in place with very little of that these days.
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As a general rule of thumb when critiquing a Risk Assessment is whether the author has detailed a particular control measure for example.... 'when using equipment within an engineering environment is to consult the user guide/manual for that particular peice of equipment'.......the manual will then advise the user on the wearing of safety glasses.....they even write these things in the majority of spoken languages.
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