Health & Safety Policy
General statement of intent
LWC Engineering Ltd is committed to ensuring the safety of its employees, customers, members of the public and anyone else who are affected by our operations. The Company commits to operating in accordance with the Health and Safety at Work (etc) Act 1974, The Management of Health & Safety Regulations 1999 and all other applicable regulations and codes of practice, so far as is reasonably practicable. The management will ensure that significant risks are assessed and suitable and sufficient measures are adopted to allow each employee or subcontractor to carry out his/her duties safely and without risk to health. Suitable equipment will be provided and maintained in a safe condition and safe systems of work will be devised.
The Company shall strive to achieve continuous improvement in Health & Safety performance.
Each employee/subcontractor will be made aware of his/her responsibility for his or her own health and safety and that of others. All employees/subcontractors will be given the opportunity to consult with the management on matters relating to Health & Safety, or to appoint a representative to do so.
Where necessary the Company will arrange or provide suitable training for both management and operatives, in particular where new work practices or equipment are introduced.
The Company will seek external advice as necessary to keep its health & safety policy, working practices and equipment up to date and in accordance with current legislation.
Ultimate responsibility in all areas of safety rests with the Director. This duty is of no less importance than any of the responsibilities attached to that position.
Reviews of Health and Safety Policy will be made annually no later than 1 year after the date on this policy.
The monitoring of all issues relating to this policy is the responsibility of a Director.
Martin Davies, Director, LWC Engineering Ltd
LWC Engineering Ltd has identified Health & Safety legislation that applies to our organisation.
This list demonstrates our commitment to researching and complying with the appropriate legislation for our organisation
- Construction (Design & Management) Regulations 2015
- Control of Asbestos at Work Regulation 2012
- Control of Substances Hazardous to Health Regulations 2002
- Electrical Equipment (Safety) Regulations 1994
- Electricity at Work Regulations 1989
- Employers Liability (Compulsory Insurance) Regulations 1969
- Environmental Protection Act 1990
- Gas Safety (Installation and Use) Regulations 1998
- Environmental Permitting (England and Wales) Regulations 2010 – Groundwater Activities
- Health and Safety (Consultation with Employees) Regulations 1996
- Health and Safety (Display Screen Equipment) Regulations 1992
- Health and Safety (First Aid) Regulations 1981 (2013 update)
- Health and Safety (Information for Employees) Regulations 2009
- Health and Safety (Miscellaneous) Regulations 2013
- Lifting Operations and Lifting Equipment Regulations 1998
- Management of Health & Safety at Work Regulations 1999
- Manual Handling Operations Regulations 1992
- Noise at Work Regulations 2005
- Personal Protective Equipment (PPE) Regulations 1992
- Provision and Use of Work Equipment Regulations 1998
- Reporting of Injuries Diseases and Dangerous Occurrences Regulations 1995 (updated 2013)
- Safety Representatives and Safety Committees Regulations 1977
- The Health & Safety at Work etc Act 1974
- The IEE Wiring Regulations (18th Edition)
- The Work at Height Regulations 2005 (amended 2007)
- The Working Times Regulations 1998
- The Workplace (Health, Safety and Welfare) Regulations 1992
Organisation and managerial responsibilities
Martin Davies, the Director, is directly responsible for fulfilling Health and Safety legal obligations within LWC Engineering Ltd (the Company). The responsible person, the Director, will seek external assistance where necessary to ensure that the Company meets both its statutory obligations and the objectives laid down in this Health & Safety Policy.
The organisation of the workforce is the responsibility of the Director, Martin Davies. He is responsible for ensuring that the Company’s Health & Safety Policy and associated procedures are implemented by all site operatives.
Day to day management of the Company’s operations is the responsibility of the Director who may be supported by a nominated representative to be responsible for client site or premises. Depending on the size and nature of the site, the responsible person may be supported by one or more others responsible for the direct supervision of the Company operatives.
Each and every employee/subcontractor has a statutory duty to take reasonable care in relation to his/her own health & safety, and the health and safety of any other person who may be affected by his/her acts or omissions.
Therefore, it shall be the duty of all employees or subcontractors whilst at work:
- To take reasonable care for the Health & Safety of themselves and others, who may be affected by their acts or omissions at work
- To co-operate with the Director to ensure compliance with all the Company Health & Safety policies and procedures
- To refrain from intentional or reckless interference with equipment and systems provided in the interest of Health, Safety and the Environment
- To co-operate with management when required on such things as accident prevention and all procedures with regard to Health, Safety and the Environment as set out in the Health & Safety at Work Act 1974 and the Environmental Protection Act 1990 and all associated Regulations and ACOPs
- To maintain good standards of housekeeping in our premises and on client premises
- To report any accident or incident including near-misses (whether or not personal injury results) to the office
- To report any defects in equipment without delay to the Director or Site Supervisor and not to attempt repairs which they have not been authorised and specifically trained to undertake
- To ensure that no potentially hazardous item, substance or machine is brought on to site or used without the prior knowledge and authority of the Director or Site Supervisor
- To use and if applicable wear any item of Personal Protective Equipment
- To undergo any Health, Safety, Environmental and operational training deemed necessary by the Company and/or the Client
lf an employee or subcontractor becomes aware of any potential breaches of health & safety law, or unsafe working practices he or she must notify the Director or Site manager.
lf an employee or subcontractor feels that health & safety procedures may be improved, for example by use of alternative equipment; he or she will be encouraged to discuss any suggestions with the management.
This section defines our Company arrangements and policies for dealing with our activities.
The Company commits to operating to the very highest standards of Health Safety and Quality and will therefore carry out its operations in accordance with best practice as advised by the Health & Safety Executive and also various trade bodies and associations; this best practice will be reviewed on annual basis and adopted annually or when evidence that significant improvements can be made by adopting sooner. Guidance documents are kept at the office and are available to staff and other interested parties. The Health and Safety Law Poster is located on the Tea Room door.
Safety audits and monitoring
At monthly intervals the Director or his nominated representative will carry out a health & safety audit on one contract or job, selected at random. The audit will consider the effectiveness of the welfare facilities; emergency procedures, safe methods of work etc. identified at the outset, and will identify any corrective action required. Where the Director considers it necessary in order to maintain the desired level of health & safety, he may seek the assistance of an external Health & Safety Advisor in carrying out audits and identifying corrective actions.
All records will be kept by the Director, in written form indicated in the various appendices. Such records will include:
- Equipment Inspections
- COSHH Assessments
- Generic Risk Assessments
- Staff Training and Induction Records
In addition to the above general records, the following contract specific records will be maintained for each major contract.
- Client/Contract site information
- Specific Risk assessment
- Method Statements
Communication with workers
The Company uses a variety of methods to communicate information with employees and subcontractors. Informal meetings are held to discuss any issue, including safety.
Communication with employees whose first language is not English will be carried out using one or more of the following methods;
- Ensure adequate time to consult with employees where language and/or literacy may be issues so they can absorb the information and respond using clear and simple language
- Use an interpreter; this may be a trained work colleague
- Get information translated and check that this has been done clearly and accurately by testing it with native speakers
- Use pictorial information and internationally understood pictorial signs where appropriate
Health & safety training
The Company will provide as much training and re-training as is necessary to ensure, so far as is reasonably practicable, the health and safety of all staff on site and Company premises. During staff induction safety training will be provided to ensure that staff are trained in Health & Safety matters to a level appropriate to their responsibilities.
Every new employee will receive a safety induction on day one of his or her employment. The training will consist of fire safety, manual handling, and display screen equipment use (where necessary), environmental and general safety. New employees will also be given instruction and safety training on the equipment they will be required to use whilst discharging their duties. A training record will be kept and maintained. Copies of training records are available for clients upon request.
Method statements (Safe operating procedures)
Work Instructions (Risk Assessments and Method Statements) will be developed for all the Company’s operations. Information from the risk assessments will be used to formulate these documents which will be used in training and given to members of staff, the work instructions will be reviewed and updated either periodically or when something significant changes. Method statements are written and stored electronically and are available to customers upon request.
The Director or his nominated representative will prepare a generic risk assessment covering the common risks encountered in the Company’s normal business. lf necessary, external assistance will be sought to carry out the generic risk assessments. The significant findings of the risk assessments will be relayed to all staff. The Director or his nominated representative will carry out site specific risk assessment for any new site which the Company’s employees or subcontractors are obliged to work. Such assessments will consider the health and safety of employees, subcontractors and the public on site. In particular the Company is aware of the number of serious injuries from the incidence of slips, trips and falls and will therefore pay particular attention to eliminating these hazards from each site.
All Risk Assessments are made available to all clients upon request. Employees should have a copy of risk assessments for the work they carry out.
It is a requirement of law that any equipment supplied for safety must be used, and when not in use it is properly cleaned, stored and maintained. PPE will be provided by the Company, details of which will be made available to employees. No employee or subcontractor will be permitted to start work without the correct PPE, which must be worn at all times, and the necessary information, instruction and training to enable him to utilise the equipment correctly. It will be the responsibility of the Director or his nominated representative to monitor the wearing of PPE by employees.
Each employee or subcontractor must carry out a daily inspection of any equipment prior to its use, and must immediately report any defect, or suspected defect to the Director. The Manager will carry out 6-monthly inspections of all Company equipment, ladders, PPE, tools, etc, and will keep a record of such inspections. For the purposes of record keeping, each item of equipment shall have its own unique reference, which shall be clearly marked on it. Markings must be maintained so that they are clearly discernible at all times. Where an inspection reveals a defect, it will be the responsibility of the Director or Site Manager to ensure that the equipment is not used until such time as a suitable repair has been affected. If the equipment is beyond repair it must be discarded, whether or not a suitable replacement is available, and any work relying on the use of such equipment must be suspended until a suitable replacement is available.
All employees and subcontractors must report any near miss, accident or injury to the Office. Details of all accidents will be entered into the Company s accident record book. Any accident resulting in more than minor injuries or incident which might have resulted in serious injury will be investigated by the Director or his nominated representative. Depending upon the circumstances of the accident, the Director or his nominated representative may seek the assistance of an external Health & Safety Advisor, both in the investigation and the formulation of preventative procedures to avoid repetition.
The LWC accident book is located in the office.
It will be the responsibility of the Director or his nominated representative to notify the Health & Safety Executive in respect of any accident or occurrence for which notification is required by this regulation
The Director or his nominated representative will ensure that as a minimum the organisation has an appointed person for first aid. The appointed person will be responsible for maintaining the first aid kit and taking charge after an accident, this includes calling for a person qualified in first aid or ambulance if necessary. Where visits are carried out to other premises, the Director or nominated representative will ascertain the first aid procedures to be followed and include them in the applicable RAMS. Details will be provided to all employees and subcontractors required to work in or on such premises.
The First Aid box is located in the Tea Room.
In most cases Company employees or subcontractors will be able to use toilet and washing facilities within the client’s premises. It will be the responsibility of the Site Manager to ascertain if this is possible prior to commencement of a contract. Where it is not possible, it will be the responsibility of the Director/Site Manager to establish the location of suitable temporary or public facilities. Where work is carried out in people’s homes we will make a verbal request to use their washing facilities if required.
It is the responsibility of the Director or nominated representative to ensure that all fire safety procedures implemented in client buildings and on client sites are communicated to staff. Where staff are carrying out hot work, the operative must first obtain the appropriate hot work permit from the building manager/subcontractor and ensure the appropriate fire extinguisher is to hand, work area dampened, weld screen and/or fire blanket used. A 2 hour fire watch may be maintained after any hot work if deemed necessary and notified in the RAMS.
An annual Fire Audit for LWC premises will consider sources of ignition, sources of fuel and any extra sources of oxygen over and above what is present in the air. The assessment will evaluate the risk of a fire starting and the effect of the fire on employees, all site users and clients.
The assessment will indicate control measures to remove or reduce the risk of fire starting. The significant findings of the Audit will be recorded and the necessary actions taken.
Means of Escape
In the event of fire occurring, it is vital that staff and other persons are able to evacuate the premises. All existing doors through which a person may have to pass to get out of the premises or site must be capable of being easily and immediately opened from the inside. Employees will not block or otherwise obstruct exits provided for emergency evacuation. Access routes must always be maintained unobstructed and sufficient to allow easy access by the number of persons likely to use those routes, (750mm minimum) and employees must observe any line markers to indicate areas which must be kept clear.
In line with current legislation smoking is allowed in designated areas but not on client premises or Company vehicles.
Good housekeeping is most important. Waste or packing materials should not be allowed to accumulate in any building and disposed of in the appropriate bins on site or at the Yard/workshop. Combustible materials to be disposed of appropriately at the end of every day whether on site or in the yard/workshop.
All employees and subcontractors who are required to operate machinery will have the appropriate training and license to operate such machinery. It is Company policy to take severe disciplinary action against any person found to be operating machinery without the necessary competence.
All machines including power tools, jet wash equipment, saws, drills etc shall be subject to regular inspection by the Director or nominated representative, who will withdraw damaged or unsuitable equipment from service immediately. All machinery shall also be subject to maintenance and service as per the manufacturers instruction and maintenance schedule OR at least annually
All portable electrical appliances will be tested in accordance with the regulations, at the recommended intervals, ‘as may be necessary to prevent danger’. It will be the responsibility of the Director/employee/subcontractor or site manager to ensure that all equipment provided is suitable for the task, including any provided by a client.
Hand arm vibration syndrome (HAV)
Anyone who regularly and frequently is exposed to high levels of vibration can suffer permanent injury. The construction industry has the second highest incidence of vibration white finger (VWF) injury which is one of the more common forms of HAV. The Company will ensure that staff are not subjected to excessive vibration through power tools etc. The Company will endeavour to source low vibration tools and limit exposure to such tools. The Company will also provide adequate information instruction and training to its employees and subcontractors on the risks of HAV.
Transport & Company vehicle safety
It is the policy of the Company to only employ drivers who are competent. A person may only operate Company vehicles if he or she;
- Has held a full UK license for a minimum of 2 years
- Has not been disqualified from driving for drink and/or drug offences in the last 5 years nor has any prosecution pending
- Holds the correct license for the type of vehicle being operated
- Is over 25 years’ old
Drivers must inform the Company of any circumstances that may lead a driver to being unfit for driving duties. Drivers must inform the office immediately they become aware of any pending prosecution for any driving offence. All employees/subcontractors will be asked to present their licenses to the office; these will be photocopied and returned.
Where work is carried out on the client‘s premises, the Director or his nominated representative will ascertain the procedures to be followed as stated in the generic risk assessment, e.g. lone worker injury, welfare facilities etc. and details will be provided to all employees and subcontractors required to work in or on such premises.
Risk Assessments must be carried out in compliance with The Management of Health & Safety at Work Regulations 1999 and the Health & Safety (Young Persons) Regulations 1997/99. This includes any young people on job experience working within the Company.
Working with Display Screen Equipment is recognised as being a major cause of injury and ill health. The Company will carry out risk assessments and provide information instruction and training to its entire DSE user staff. Employees must carry out the recommendations of the risk assessment and must report instances of injury or ill health suspected of being caused by DSE work to the person responsible for Health & Safety at their earliest convenience
For all materials or substances utilised which may be hazardous to health, a formal COSHH Assessment will be carried out by the Director or his nominated representative. A register of hazardous substances shall be kept at the Office along with all relevant Manufacturers Safety Data Sheets. Significant findings of the assessments will be communicated to the relevant operatives, together with the necessary MSDS sheets and instructions for use.
Regular exposure to high noise can cause deafness and tinnitus. Noise assessments will be carried out whenever it is suspected that noise levels may be above 80db, hearing protection will be provided for all operatives. Where noise levels are at 85db or above the Company will take measures to reduce the exposure of noise to its employees by means other than hearing protection, the wearing of hearing protection shall also be enforced.
The Director or his nominated representative will carry out specific manual handling assessments for any necessary operation which has been highlighted as requiring a detailed assessment by the general risk assessment. Manual handling assessments will consider the load to be handled, e.g. tools, equipment etc, its size and weight, the individual, the task and the environment in which the task takes place. The assessment will also consider the possibility of utilising mechanical means to minimise the risks arising from manual handling.
It is the policy of the Company to comply with the Work at Height Regulations 2005 (amended 2007). Work at height will be avoided wherever possible and where not a risk assessment will be conducted with appropriate work equipment to access height provided. Only trained and competent staff will be allowed to work at height. Where the risk of a fall cannot be eliminated measures and equipment to minimise the distance and consequences of a fall will put in place should one occur.
Asbestos is recognised as being an extremely hazardous substance and as such must be treated with the utmost care. When working on site staff and subcontractors will assume any suspicious material is asbestos unless there is conclusive evidence to the contrary. No drilling, breaking or cutting shall be carried out to any material suspected of containing asbestos fibres. Any suspicious material shall be reported to the Director and site or building manager immediately. A type 2 survey will be carried out on all premises suspected of containing asbestos prior to starting work on site
Serious or imminent danger
These procedures are in line with Regulation 8 of the Management of Health & Safety at Work Regulations 1999.
It is a policy of the Company that no employee or subcontractor will be made to work in dangerous conditions without due regard to health and safety and that all employees should be aware that there are regulations and procedures regarding serious or imminent danger. All staff are reminded that they must not under any circumstances undertake work or instruct others to undertake work where there is a risk of imminent danger without the correct levels of training and safety procedures. The Company authorises any employee to remove him or herself to a relative place of safety when he or she has reason to believe he or she is at serious risk or in imminent danger. Work will not resume in that area until the problem has been neutralised. Some emergency events can occur and develop rapidly, thus requiring employees to act without waiting for further guidance, for example, in a fire. Employees must, on arrival at new sites, make themselves familiar with the emergency procedures, escape routes and location of firefighting equipment etc prior to starting work. Under no circumstances will work activities take priority over safety considerations.
It is categorically forbidden for employees to enter sites or places of work, to drive a vehicle, use or operate plant and equipment, to assist or supervise in the use of the aforementioned whether on or off Company business whilst under the influence of alcohol or illegal drugs or other substances, such as glue; or to be in possession of illegal drugs on Company, client property or in a Company vehicle. Employees taking medicines or prescribed drugs under the direction of their G.P, Dentist or Hospital Doctor that may affect their ability to carry out their work duties have a duty of care and must notify the Director or his nominated representative.