Posted By Sean Nuttall All, having a little dilemma at the moment with the HSE over managing exposure to RCS. I drafted a generic coshh assessment covering all activities where we would be likely to expose people to RCS. This document included all the right items to reduce exposure at source such as LEV on saws, use of wet cutting with diamond tipped blades where there was issues with electrical supplies making LEV less practicable, backed up by PPE and instruction etc etc. It was impossible to include exposure and duration information on the generic as the tasks were wide and varied but have had a ticking off for not including it and not making the document more specific. Now seeing as exposure to RCS could occur whilst drilling one hole in a wall or cutting one slab or 50 slabs, the inference is that an assessment should be written for every bladdy activity. Given our activities then we would need to employ people purely as coshh assessors on each site !! My understanding of moving towards WELS was to get away from useless pages of information that no guy on the ground would understand and put in place measures to get the exposure as low as possible by available practicable means which guys on the ground would understand and which is exactly what my assessment did. The HSEs own circular SIM 2/2004/02 indicates that improvement and prohibition notices are to be issued for any occurrences where exposure could have been controlled at source and yet when you try and do something about it, all you get is a kicking !! To put this into perspective, I was in Manchester city centre yesterday and happened to pass four significant construction projects and took a little time out to witness operations. As could be expected there was bench saws and Stihl saws being used everywhere and not one of them had any extraction system or wet suppression system fitted. If the big players can't get it right then what does the HSE expect of smaller companies. Has anyone experience of drafting a generic for RCS that has passed scrutiny by the HSE ??

Posted By Sean Nuttall Peter, thanks for the reply. Yes I am fully aware of the proposed changes and am also aware that in general the construction industry does not put measures in place to deal with the existing exposure limit. Am sure I will be inundated with yes we all do e mails but fact of the matter is, we don't. The reason for not wishing to undertake vast amounts of monitoring is simple. I want to reduce to as low as is practicable exposure to RCS so we are investing and hiring in the best kit available and PPE. As the tasks are unavoidable this is the best position that we could ever hope to achieve. All the monitoring will do in this place is tell me that for many activities we will be over the existing and proposed WEL and therefore should put in place what we already are doing ! I appreciate the reasoning and requirements behind determining exact exposures but in this case don't believe its worthwhile. Actually this has just triggered a thought, someone must have posted typical exposures on the net somewhere to give an indication. Thanks for the response Regards Sean

Posted By Sean Nuttall Its not worst case scenario really but if you have observed someone cutting flags or blocks with a typical Stihl saw then you will know they and anyone near them is borted in dust. Cutting inside buildings as routinely observed is even worse as the airborne concentration is significantly higher. If someone is drilling god knows how many holes in blockwork then they are equally borted by the close of play. Simple extraction kit is available for drilling from all the hire companies and they will reduce to the lowest levels possible which is how I interpret coshh and move away from OELs to WELs.