Managing a small manufacturing site
The checklists below cover some things to consider when managing a small manufacturing site. These are relevant under the Health and Safety at Work Act 2015 (HSW Act), which came into force on 4 April 2016 and impose duties on the ‘PCBU’.
What is a PCBU?
The HSW Act defines ‘PCBU’. It is essentially a person conducting a business or undertaking, whether alone or with others and whether for profit or gain or not. The PCBU is in the best position to control risks to work health and safety. This is why the PCBU will have the primary duty to ensure health and safety as of 4 April 2016.
Despite its name, a PCBU can be a business entity, such as a company, as well as an individual person. An individual person will generally be a PCBU if they are a sole trader or a self-employed person.
Examples of a PCBU include:
- a manufacturing business
- an import business
- an owner-driver of their own courier business
- a self-employed person operating their own business
- a partnership
- a building company, whether a principal contractors or a sub-contractors
- a not-for-profit organisation that employs admin staff.
PCBUs have a number of duties under the Health and Safety at Work Act. PCBUs with overlapping duties must work together to achieve health and safety at work.
Keep this in mind when reading the checklists. Many of the things covered in this booklet will help PCBUs to meet their duties under the Act.
Do you make sure workers:
- are trained, competent and fit to do the job safely and without putting their own or others’ health and safety at risk?
- are properly supervised and given clear instructions?
- have access to washing and toilet facilities?
- have the right tools, equipment, plant and protective clothing?
- are involved in discussions about health and safety issues?
- are given opportunities to participate in improving health and safety?
When to notify worksafe
In an emergency: call the emergency services by dialling 111.
A PCBU must notify WorkSafe as soon as possible if any of the following ‘notifable events’ occur:
- the death of a person
- a notifiable injury or illness
- notifiable incident
Call the WorkSafe Response Team on freephone 0800 030 040 (24 hours) and choose option 1.
Some types of work also require you to notify WorkSafe. These include where a worker could fall 5 m or more, a substance escaping, spilling, or leaking, explosion or fire.
Under the Health and Safety at Work Act 2015 (HSWA) you must notify us when related events occur.
Use our Notifiable Event tool to help you with understanding which events are notifiable, what you need to do and when, and how to notify us.
Don’t disturb the scene.
You must not interfere with an accident scene until authorised by a health and safety inspector. Exceptions include certain situations, such as when people or property are at risk. If you require scene clearance or other immediate assistance from a health and safety inspector, call WorkSafe on 0800 030 040.
- Do you provide adequate facilities e.g. kitchen, dining, toilet and washing facilities?
- Is the site clean and tidy?
- Are materials and product safely stored and stacked?
- Do you provide the necessary ventilation?
- Are tools and equipment checked by users, visually examined on site and regularly inspected by a competent person?
- Are cables and leads protected from damage?
- Are RCD’s regularly tested?
- Do you ensure only appropriately licensed or registered electricians carry out electrical work?
- Do you get electrical equipment that is used in ‘hostile environments’ regularly tested by a competent person?
(A hostile environment is one where electrical equipment is exposed to operating conditions that are likely to result in damage to the equipment or a reduction in its expected lifespan)
- Do you have a noisy working environment (e.g. is it difficult to hold a conversation with a person one metre away from you)?
- Have you identified the source of the noise?
- Can you control the noise at source using engineering, process or isolation controls?
- Are hearing protectors required?
- Do you have systems in place for workers to be trained and educated in the use and, cleaning and maintenance of hearing protectors?
Personal protective equipment
- Is suitable equipment provided to the head, eyes, hands and feet where appropriate?
- Do workers wear their protective equipment and do they wear it according to the manufacturer’s instructions?
- Have workers been trained in the safe use, care and storage of the protective equipment.
- What substances are in the fume and the risks associated with them? Detailed information can be found on the Safety Data Sheet.
- How concentrated is the fume?
- What are the relevant workplace exposure standards Workplace Exposure Standards (WES)?
- What welding process are used (arc, flame, resistance)?
- Are welding surfaces coated or painted?
- Which processes create fumes?
- Where will the welding be done (inside, outside or confined space)?
- Who is exposed to the fume and for how long?
- Do you ensure exposure monitoring (including assessing air quality) is completed by a competent person?
- Can you modify the process to eliminate or reduce the amount of hot work or fume?
- Do you use effective local exhaust ventilation to extract fumes?
- What type of RPE will protect against the hazardous substance?
- Is the RPE suitable for the form of the contaminant e.g. is it a mist, a gas or solid?
- Is the RPE suitable for the type of work being done (light or heavy work, short or long duration, confined space, ventilation)?
- The requirements for each of your employees e.g. is the Respiratory Protective Equipment (RPE) the right size?
- Is it compatible with other Personal Protective Equipment (PPE) that your employees need to wear?
- What control measures are recommended on the Safety Data Sheet (SDS)?
- Do you train your workers how to use and maintain their RPE properly?
- Do you provide health monitoring for your workers exposed to solvents, fumes, dusts, radiation, noise, vibration and hazardous substances that can harm them?
Working in extreme temperatures
- Are your workers exposed to extreme temperatures at work?
- When assessing whether your workers are exposed to extreme temperatures do you take into account air temperature, humidity, radiant heat, air movement, physical activity and clothing?
- Do you take into account personal factors such as weight, health, level of fitness, age, use of prescribed substances and use of non- prescribed substances?
- Do you adequately train people who work in a hot or cold environment or who supervise the work, how to avoid heat or cold strain associated conditions?
- Do you take adequate measures manage the risk of working in cold or hot environments for example, work environment, equipment design, PPE, safe work practices?
- Do you plan for work carried out in cold or hot environments?
- Have you identified all harmful substances and materials, such as asbestos, lead, solvents, paints, heavy metals and silica dust (eg from silica board, glass making etc)?
- Is protective clothing and respiratory equipment provided?
- Do you need a location test certificate and if so is it current?
- If required does your site need a person to hold a current approved handler certificate?
- Have you identified and put into place precautions to prevent or control exposure to hazardous substances, by:
- doing the work in a different way,to remove the risk entirely?
- using a less hazardous material?
- using tools fitted with dust extraction?
- installing warning signs to show where work involving hazardous substances is taking place?
- Have workers had information and training so they know what the risks are from the hazardous substances used and produced on site, and what they need to do to avoid those risks? For example holding an approved handler certificate.
- Have you arranged health surveillance for employees exposed to hazardous substances (eg lead, silica, solvents, and sensitisers such as epoxy resins, isocyanates)?
- Are the right tools or machinery being used for the job?
- Are guards secured and in good repair?
- Are tools and machinery maintained in good repair and are all safety devices operating correctly?
- Are all operators trained and competent?
- Is machinery reviewed against AS/NZS 4024 or machine specific standards for that piece of machinery? (i.e. this includes all newly purchased/imported machinery, old machinery or retrofitted machinery)
- Does the design and layout of the machinery protect the safety of workers?
- Have you identified operational hazards of machinery use (e.g. normal use, cleaning, clearing, unblocking and maintenance)?
- Do you have in place a machinery lock-out procedure for cleaning and maintenance?
- Are mechanical hazards identified and managed (e.g. trapping, entanglements and projectile hazards)?
- Have you considered electrical hazards such as fuse, shock, laser burn, earthing, lightening electromagnetic or EMF radiation
- Do you identify and monitor occupational health hazards, (i.e. noise, dust, fumes radiation, extreme temperatures, vibration, biological and fibres etc)?
- Do you consider worker wellbeing (i.e. fatigue, shift work, workload) when planning work?
Choosing the right guard
- Is access required by operators and maintenance staff or cleaners?
- Does opening the guard cause the hazard to stop before access?
- Is constant access required?
- Can presence sensing systems be used appropriately?
- Has a competent person verified that the machinery can’t be guarded?
Safe systems of work
- Have you identified hazards that may occur by using a safe system of work?
- Do you ensure the correct use of tools and plant (e.g. safe operating procedures, job safety analysis and effective and safe maintenance and cleaning)?
- Have you provided a good work environment (e.g. safe layout, lighting, ventilation, and noise and fumes managed)?
- Do you have procedures, information, equipment and trained staff to manage emergencies?
- Do you keep vehicles and pedestrians separate (eg barriers, markings)?
- Do you manage the speed vehicles travel on your site (eg signage, speed bumps, on way systems)?
- Do you have safe loading and unloading procedures (eg spotters designated safe area for drivers whilst loading and unloading)?
- Is it the right vehicle for the job?
- Is the vehicle maintained according to the manufacturers specifications?
- Do you do have procedures in place for pre-start checks, regular maintenance inspections and do you monitor and audit these?
- Are your drivers trained and competent to operate the vehicle safely (provide initial training, refresher courses and feedback from observations)?
- Do you regularly ensure drivers are medically fit to operate vehicles?
- Do you have drug and alcohol polices in place?
- Are your forklift drivers certified, and approved by you to drive; and is their certification renewed every three years?
- Do you ensure the operator does daily pre start checks and records them in the log book?
- Do you ensure weekly checks are carried out by a suitably trained person authorised for the job?
- Are forklifts fitted with operator restraint interlocks?
- Do you check floors for damage, wetness, greasy or oily surfaces or obstructions in aisles?
- Are forkhoists maintained, repaired, rebuilt or adjusted according to the manufacturers design criteria?
- Are areas where forklifts operate well ventilated?
- Are areas where forklifts operate well lit.
- Do you comply with the guidance for front loading, order pickers, side loaders, and straddle trucks?
Loading and unloading goods
- Have you checked that the load has not moved or destabilised during the journey to site?
- Is there an exclusion zone around the loading/unloading area to keep people who are not involved away from the work?
- Have you planned your method of unloading?
- Does your lifting equipment have a current annual certificate?
- Do you have to access the back of the truck at all, or can the preparation work be done from ground level? If not:
- do you have a safe way of getting up and down from the back of the vehicle?
- what do you have in place to prevent workers from falling off the back of the vehicle?
- are your employees provided with sensible safety footwear with a good grip?
- Choose the right tool for the job – can you buy or hire some alternative equipment that would provide a safer means of access?
- Are they in good condition?
- Do ladders rest against a solid surface and not on fragile or insecure materials?
- Are ladders secured at the top and bottom to prevent them slipping sideways and outwards?
- Do ladders rise at least a metre above the landing place? If not, are there other handholds available?
- Are the ladders positioned so that users don’t have to overstretch?
- Do you have to use the top three rungs of a stepladder? If so your stepladder is too short.
- Is the user competent? Those using ladders should be trained to use the equipment safely.
- Can users maintain three points of contact at all times?
- Are materials being transported safely, i.e. not carried up a ladder? Carrying materials up a ladder increases the risk of falling.
Temporary work platforms
- Does the temporary working platform have guardrails?
- Are workers trained and have suitable experience with the type being used?
Elevated work platforms
- Have you identified hazards and put controls in place?
- Before starting work have you put a safety plan in place?
- Is the Mobile Elevated Work Platform (MEWP) designed using sound and accepted engineering practices and manufactured using best practices?
- Do you keep an up to date log book and register?
- Does a competent person complete the manufacturers prescribed maintenance schedule?
- Is the operator adequately trained by a competent person and can they demonstrate their competency before using the equipment?
Slips and trips
- Are walkways in the right place, are they being used, are they available for use?
- Are walkways being clear?
- Is the floor suitable for the environment, fitted correctly and properly maintained?
- Are walkways wide enough?
- Are stairs suitable; are risers consistent and nosings highlighted where necessary; are usable handrails available?
- Is the lighting good enough for workers to see the hazards?
- Are there heavy materials such as drums, pallets or bagged products that could cause injury if they have to be moved by hand?
- If so, can you:
- choose lighter materials?
- use trolleys,hoists,gantry cranes,lift trucks,vacuum lifters, tilters, and other plant or equipment so that manual lifting of heavy objects is kept to a minimum?
- order materials such as bags of granules in units that are a manageable weight (e.g. 25 kg bags)?
- Have people been instructed and trained how to use lifting aids and other handling equipment safely?
- Have people been trained how to lift safely?
- Are all frequently used components within easy reach?
- Has the gantry crane been certified by a chartered professional engineer with respect to design, construction and non-destructive testing, as relevant?
Stacking and storage
- Do you have a safe system of work that integrates people, materials and machinery?
- Have you checked the safety load of the floor and supporting surfaces?
- Are the shelves, bins, hoppers and other structures for storage of materials adequately designed to support and contain materials for which they are used?
- Are the stacks of articles placed a safe distance from walls and rail tracks?
- Does the stacking size and shape of the stack take into account the bulk weight, rigidity or fragility of the articles stored?
- Are fire instruction notices prominently displayed in all storage areas?
- Are your workers trained to operate firefighting equipment and trained to deal with small fires?
- Has a risk assessment been undertaken by a competent person before the work begins?
- Do you ensure that a stand by person is posted at the entrance of the confined space to make sure that communication is constantly maintained?
- Do you have an effective communication system for workers in the confined space, eg voice, tugging, tapping or especially designed battery operated communication system for working in confined spaces?
- Have you put in robust retrieval system for both workers and equipment, (eg) heavy duty lifeline, tripod or personnel winch?
- Have you provided training for supervisors, stand by person, worker in the confined space and rescue personal?
Stress and fatigue
- Do workers take regular, quality rest breaks in their working day?
- Are working hours reasonable and not too long? If longer working days are required, are start and finish times staggered, and/or are longer rest breaks and periods off work allowed?
- Are tasks scheduled suitably throughout a work period (e.g. critical jobs are avoided during the low body clock period of 3pm to 5pm)?
- Is work scheduled to allow enough time for completion?
- Are monitoring and limitations in place for overtime worked, consecutive night shifts, shift swapping and on-call duties?
- Are jobs rotated to minimise exposure to extreme temperature and excessive mental or physical demands?
- Are fit-for-purpose plant, machinery and equipment used?
- Are workloads practical and manageable, with consideration given to any work flow changes? (e.g. machinery breakdowns or unplanned absences)
Alcohol and drugs
- Is there a policy and procedure in place to constructively manage alcohol- and other drug-related hazards?
- Are workers monitored for signs of alcohol and drug use? (e.g. dizziness, slurred speech, drowsiness, sudden aggressive or violent behaviour, lack of or impaired coordination/reflexes.)
Alcohol and Drug Helpline 0800 787 797
Pasifika Helpline 0800 787 799
- Are there emergency procedures, e.g. for evacuating the site in case of fire?
- Do people on site know what the procedures are and where the nearest emergency centre is?
- Is there a means of raising the alarm, and does it work?
- Is there a way to contact the emergency services from site?
- Are there enough suitable escape routes and are these kept clear?
- Are first aid arrangements good enough for the site, and is there someone available who can administer first aid if needed?
- Is the quantity of flammable materials, liquids and gases kept to a minimum?
- Are they properly stored, e.g. isocyanates
- Are flammable gas cylinders returned to a ventilated store at the end of the shift?
- Are smoking and other ignition sources banned in areas where gases or flammable liquids are stored or used?
- Are gas cylinders, associated hoses and equipment properly maintained and in good condition?
- When gas cylinders are not in use,are the valves fully closed?
- Is flammable and combustible waste removed regularly and stored in suitable bins or skips?
- Are suitable fire extinguishers provided?