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Get ready – an inspector may call

John Dyne

A Health and Safety Executive (HSE) campaign targeting the waste and recycling sector started on 1 October. There will be a series of unannounced inspections during the next three months, repeating a campaign previously run in 2017.

It will focus on the management of workplace transport and machinery safety through suitable control measures put in place by the operators, but other areas of concern will also be audited.

Coinciding with this campaign, two waste operators were recently convicted and sentenced for offences under health and safety legislation, so it’s not the most auspicious of starts.

workplace accident

workplace accident

Operators visited last year should not assume they will not be revisited. The HSE is aware that previously targeted companies that did not attract enforcement action last time may have become complacent, and it will be keen to ensure that standards have not slipped.

The industry has had a bad health and safety press of late and, according to the HSE, is statistically one of the most dangerous industries in the UK, with a fatality rate 15 times higher than the average rate across all other industries.

As well as machinery and transport, inspectors will be on the lookout for risks associated with fire and explosion, working in confined spaces and structural safety, asbestos identification, risk assessment for bioaerosols and provision of respiratory protective equipment.

Should inspectors identify that there is (or is likely to be) a risk of serious injury, then they are expressly directed to consider issuing a prohibition notice. The workplan for the campaign identifies what are termed ‘initial enforcement expectations’ for a variety of non-compliant situations.

Based on performance data from the previous campaign – when nearly 50% of sites inspected were non-compliant – it is anticipated that a significant number of waste operators will be on the receiving end of contravention notices and improvement notices.

They will then liable to pay the HSE a fee based on the amount of time taken by inspectors on the case.

Company bosses must prepare for the campaign. You can do this by downloading the HSE’s workplan, identifying how the specific areas relate to your operation and ensure the risks are being appropriately managed.

John Dyne is managing director at Dyne Solicitors

What the HSE is looking for

As a foretaste of the audit strategy, MRFs can, for example, expect inspections covering the following:


Safe site: separation of vehicles and pedestrians, minimisation of reversing, safe refuges

Safe vehicles: maintenance, fitness for purpose, reversing alarms and beacons, working lights, mirrors, horns, lifting gear inspections

Safe drivers: driver training, competency, monitoring and supervision (including visiting drivers)


Access and guard protection


Clean-down and blockage removal

Machine isolation

Operator training

Musculoskeletal risks

Manual handling: risk assessment, training, alternative mechanical aids, assessment of sorting and picking line ergonomics



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