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Europe commits respirable crystalline silica to the Carcinogens Directive. What does this mean for foundries?

The latest in health and safety news from the Cast Metals Federation

After long and protracted meetings and reviews, coupled with lobbying from the 19 NEPSI signatories, the necessary actions to commit respirable crystalline silica (RCS) to the Carcinogens & Mutagens Directive (CMD) has taken place and is likely to appear formally from late September 2017. While the battle to keep RCS out of the directive has been lost, one battle within it has at least been won – for now!

As part of the proposal the objective was to halve the exposure limit from its current 0.1mg/m3 8hr TWA in the UK, to 0.05mg/m3, and this was to take place across all European countries. For a number of reasons this is being held off until the next formal review, in five years’ time, when, pending scientific understanding and occupational health data, the lower limit is likely to reappear and be enacted.

There are those working in occupational health, and organisations dedicated to protecting employees’ health, who may state that, as a consequence of this deferral, the health of exposed people is not being taken seriously. But there is a key point to remember. The directive sets the maximum exposure level – it does also allow member states to set lower levels of their own. Plus, it must also be remembered that under COSHH or the CMD, there is a key requirement to ensure that exposures are as low as reasonably practicable, so working towards zero exposure or RCS levels remains the target to aim at.

Consequently, what should employers do now? The HSE has an active strategy for tackling occupational lung disease, which has been well publicised and covered before in this column. This means that engineering controls need to be in place to protect the workforce. In practice, this means:

  • Suitable and effective LEV (local exhaust ventilation) in place, with kit being maintained, examined and tested as necessary and, most importantly, being used every day.
  • Risk assessments for occupational health conditions must be in place, up to date, suitable and sufficient.
  • Training the workforce on the hazards as well as good cleaning and hygiene practices. Good practice and protocols need to be in place for eating and drinking in areas where the hazard exists.
  • Where RPE (respiratory protective equipment) has to be used, it needs to be the right sort, with face-fit testing undertaken for tight fitting face piece masks. Also, there needs to be adequate storage of kit in work areas so employees can leave their RPE in clean conditions – so no storing masks and clothing on dusty dirty surfaces.
  • Training on the use and maintenance of RPE has to be given to all employees who will wear it.

    Working practices such as dry sweeping or the casual use of airlines for cleaning everything down has to cease.

    Management has a duty of care to ensure all this is in place and is being actively followed on a daily basis, for as long as the processes generating RCS and exposures are in operation.

    The hazard of RCS, and the problems and deaths it can cause, has been known for hundreds of years. Now the biggest change in its classification is happening, it will contribute significantly towards helping keep our workforce healthy.

    The HSE has already issued improvement notices to several foundries in the past twelve months for not addressing RCS well and, in a few instances, not addressing the issue at all. This will continue for at least the next three years as part of the current strategy.

    If we want to stay in business today, keeping our current employees healthy, and work to change the perception of this traditional base industry to be able to attract and retain the next generation of employees, action is a necessity, not a luxury.

    Contact: Richard Heath at the Cast Metals Federation, Tel: +44 (0) 121 601 6392, email: richardheath@cmfed.co.uk