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The Journal for Employee Protection
The Journal for Employee Protection
by Scott Clark
Following The Health and Safety Executive (HSE)’s recent introduction of restrictions on hazardous welding fumes, businesses can expect greater scrutiny regarding the effectiveness of existing controls on welding activities. Here, Scott Clark, Principal Occupational Hygiene Consultant at Bureau Veritas, explains how firms can update their risk assessments to reflect the change in control measures.
In February 2019, the HSE released a
Safety Alert (STSU1 – 2019) targeted at any persons responsible for, or
undertaking, welding activities, including Mild Steel welding.
has reclassified the status of all welding fume as a Group 1 carcinogen – cancer-causing
to humans following new scientific evidence from the International Agency for
Research on Cancer linking exposure to lung cancer and potentially kidney
activities can generate various hazardous components including fume, gases,
vapours and ultraviolet (UV) radiation; all of which present health risks. As
well as welding fume being recognised as cancer-causing, other health effects
of exposure have long been known to include metal fume fever, serious lung
conditions and neurological effects linked to manganese, a chemical present in
mild steel welding fume.
tougher stance on welding activities follows the introduction last year of the EH40/2005 Workplace exposure
limits guidance by the HSE2, setting out new and revised
workplace exposure limits (WELs) for 31 chemical substances, including new
exposure limits for Manganese (Mn) in both inhalable and respirable fractions –
raising the significance of Mn as a component of welding fume.
The restrictions represent a significant
change for industries where welding forms an integral part of the manufacturing
process and where a company needs to maintain structure and asset integrity of
their plant or production lines. This will affect many businesses including
those operating in the automotive, engineering, chemical, construction, petrochemical
and pharmaceutical sectors.
safety alert was unambiguous in specifying that there will be a strengthening of
HSE’s enforcement expectation for all welding fume because current control
methods such as general ventilation on its own, will not be deemed acceptable
in achieving adequate control.
this reclassification there is now no known level of safe exposure to welding
fume and businesses can expect greater scrutiny regarding the effectiveness of
engineering controls. It also means that where controls are not adequate or not
present – for example when welding outside – that appropriate and effective respiratory
protective equipment (RPE) is provided and used. This will include training for
workers to ensure compliance.
now an expectation that due to the carcinogenic risk, that all indoor welding
activities will require Local Exhaust Ventilation (LEV). Where the LEV does not
adequately control exposure, it should be supplemented by adequate and suitable
RPE to protect against any residual fume not captured by the LEV.
It is worth noting that there should be
nothing new in this approach, certainly within the UK. Adequate control of
exposure requires employers to apply the eight principles of good practice outlined
in the Control of Substances Hazardous to Health (COSHH) Regulations Schedule
They must also ensure the WEL is not
exceeded and that exposure to substances that can cause occupational asthma;
cancer; or damage to genes that can be passed from one generation to another;
is reduced as low as is reasonably practicable.
In addition, welders may now require
medical screening prior to employment to identify any pre-existing conditions. Although
it is not a mandatory requirement, many reputable firms already have this in
place as a matter of best practice.
will also expect organisations to have up-to-date and adequate risk assessments
in place which reflect the increased risk posed by this update. All employers
are therefore advised to review their COSHH risk assessments for welding
activities and revise where necessary their control measures to protect those undertaking
include introducing workplace exposure monitoring to properly assess the risk. Non-compliance
will not only pose a significant safety hazard to workers but will mean that
businesses leave themselves open for severe repercussions from the HSE.
The requirement to follow good
occupational hygiene practice is explicitly referenced in the COSHH Regulations
2002, Schedule 2A, including;
all welding activities the following three control measures should be
considered for implementation:
practice, adequate control should be able to be demonstrated by using a
combination of all three. Dependent on individual circumstances and design, one
control measure alone will probably not be deemed adequate to demonstrate
effective control. It is therefore recommended that an approach adopting all
three control measures combined be considered. The successful combination of
these three components will contribute to reducing exposures to as low as
reasonably practicable (ALARP), however, the success of each will be dependent
on a range of factors.
As one of the most effective engineering
control measures, LEV is usually installed to capture the weld fume as close as
possible to the source and should be viewed as the primary control measure,
where it is feasible to introduce.
LEV systems suitable for welding can
either be fixed (e.g. in a workshop) or portable (mobile units). Both types of
system should be supplied with a large enough captor hood to aid the capture of
the weld plume, with a flexi/hard duct configuration to transport the captured
fume through to a motor/fan unit with a filtration unit to clean the air.
Ideally, the LEV extract fan and discharge
stack should be sited outside, and exhausted to atmosphere, to minimise the
recirculation of air back into the workplace and prevent the inadvertent re-introduction
of contaminated air, in the event of failure of the LEV performance. The captor
hood is to be placed as close to the weld fume source as possible and ideally
directly above it to promote effective capture (as weld plume naturally rises).
Whether a fixed or portable unit is used
also depends on the type of welding activity. For instance, dynamic processes
such as pipe fitting that involves welding will require a portable device that
can move locations along with the welder as works progress.
Many businesses will no doubt conduct
feasibility tests before installing LEV devices to determine the cost-effectiveness
and ease of installation. However, it’s also important to take into account how
it can address the risk of exposure.
There are several variants of portable
LEV units on the market, which provide a good, less expensive alternative to
fixed systems which invariably cost more. Some portable LEV units are fitted
with a fine dust filter, some are fitted with a High Efficiency Particulate Air
(HEPA) filter. Ideally a recirculating LEV device, such as a portable LEV unit
which exhausts air back into the working environment, should be fitted with a
HEPA filter (to capture particulate) and charcoal filters (to adsorb certain
gases/vapours). It should also be able to successfully meet the requirements of
a HEPA Filter Installation Leak Test (“DOP”) e.g. similar to a Type (Class) H
vacuum used in the asbestos industry.
The advantage of these type of devices
is that the HEPA filter, seal and carcass/body of the filter compartment will
be challenged during the test to ensure its integrity has not been compromised
and is thus a test which can be repeated to promote consistency during LEV assessments.
It is worth noting that in HSG258 Controlling
Airborne Contaminants at Work – A guide to local exhaust ventilation (LEV) that
where HEPA filters are fitted that “an
appropriate European or ISO standard is used to test such filter in situ”
e.g. ISO 14664-3. The disadvantage of an LEV system which doesn’t house or
accept a HEPA filter is it is not possible to perform a suitable repeatable
test on the device, and thus only a visual inspection can realistically be
As there is no known safe level of
exposure, it is deemed more beneficial to utilise systems whereby if air has to
be returned back to the workplace from the LEV system that it is fitted with a
HEPA filter. However, it is not yet known if the HSE will expect recirculating LEV
devices used to capture welding fume to meet such requirements.
to ensure the ongoing effectives of LEV systems, they must be assessed and
inspected every 14 months.
Where previously RPE wasn’t mandatory for mild steel
welding activities, the HSE’s recent restrictions have certainly made it so. Unless
all weld fume produced can be effectively controlled without the need for RPE,
RPE will still be deemed necessary. This is due to the likelihood that not all
the welding plume will be effectively captured at source, but this will be
dependent on the process. For instance, a fairly static, routine welding
operation will be more easily controlled in a permanent fixed location than a
welding operation being performed out on site.
The type of RPE to be used will be based
on suitability for the working environment, operator comfort and cost. As the
HSE alert states where adequate control cannot be relied upon by LEV, then RPE
will be required.
Positive pressured RPE is usually the
most effective option, with various designs to accommodate the requirements of
a welder. However, such equipment can often be more expensive and harder to
maintain, resulting in a reluctance to adopt them. It is important to note that
given the expected rise in the use of RPE devices, the user is required to be
clean shaven when wearing tight-fitting masks/respirators to ensure a
sufficient seal is created and the user must be face fit tested for the type of
mask in use. In addition, tight fitting masks can be uncomfortable to wear for
continuous periods leading to an increased chance of exposure if they are
adjusted in the working environment.
there is no known safe level of control, and dependent on exposure scenarios
and duration of exposure, it is deemed most likely that Powered Air Purifying
Respirators (PAPRs) will be used more and more. These usually come in the form
of a waist or backpack mounted unit, integrated with particulate and gas/vapour
filters that clean the air prior to entering the wearer’s welding hood.
The advantage of these type of devices
is that they provide greater protection against particulates, gases and vapours
than a tight-fitting face mask and are easier to wear. However, tight-fitting
masks/respirators may still be beneficial, and possibly preferred, where access
around the workspace is limited resulting in welders having to navigate and weld
in tight, restricted areas (e.g. when welding structural steel on site).
In light of the HSE’s recent
announcement, there’s now a greater onus for businesses conducting welding
activities to assess current control strategies. General ventilation can still
support good control when in combination with LEV and RPE.
First and foremost, it is important to
establish and quantify what general ventilation is already in place. Is it just
passive ventilation or are other forced mechanical systems in place?
General ventilation should be viewed as
the tertiary requirement, and although placed beneath LEV and RPE in
importance, it is still deemed necessary to incorporate the introduction of
fresh-air through a working environment where the work space is enclosed e.g.
workshop or temporary welding habitat (including habitats erected outside).
When performed outdoors, managing
welding fume exposure is certainly much harder to control as the plume is
difficult to effectively capture, particularly in restrictive spaces where it
can be hard to install an LEV device. Other safety aspects must also be
considered. For example, if the welding process is taking place in a high-risk
environment such as a chemical plant then care must be taken to ensure that sparks
generated are contained/controlled. In such cases, enclosing the welding
process and providing controlled general ventilation (dilution ventilation) may
be the best form of control of weld fume when combined with RPE. In the Oil and
Gas industries temporary habitats, with supply (fresh-air) and extraction
ventilation systems, are used to isolate the welding process from the immediate
area and create a positive pressure environment to reduce the migration of
hazardous gases/vapour into the welding area from outside.
The introduction of fresh-air
ventilation throughout a working environment will serve to dilute the
contaminated air which hasn’t been captured at source by the LEV, and thus
reduce the potential for exposure not only of the welding personnel, but also to
reduce inadvertent exposure of others. It will also serve to dilute air which
is being returned to the working environment via a recirculation LEV device and
further help to reduce exposure to fume, particulate, gases and vapours which
Indeed, grey areas may arise with regard
to dynamic processes where secondary exposure to welding fume can be difficult
to control. An example of this would be where a welder is tasked with fitting a
pipe in a facility which sees the welding activity move from one place to
another, further complicated by visitors entering and leaving the workspace. In
such instances, as there is now no safe level of exposure, businesses must assess
what is the risk to populations/exposure groups that aren’t directly involved
in the welding activity but may still be exposed. Therefore, effective general
ventilation cannot be overlooked. .
Amid the tighter WELs restrictions, it is
an appropriate time for industries that utilise welding to get much tougher on
minimising the dangers that welding fumes pose to employee health. At the heart
of this will be ensuring businesses have a robust occupational hygiene strategy
in place for controlling workplace exposure to harmful substances, which if
done correctly can not only prevent ill health but can also reduce the reliance
on uncomfortable respiratory protective equipment, thus improving working
a global health and safety and compliance expert, Bureau Veritas is ideally
placed to provide a holistic support service to organisations undertaking
welding activities. This includes assessment of welding qualifications, audit
and assessment of welding processes, thorough examination and test of local
exhaust ventilation (LEV) systems, measurement and monitoring of welding fume
exposure, review and update of COSHH risk assessments and provision of advice
on appropriate engineering controls.
For further information,
call 0345 600 1828 or visit www.bureauveritas.co.uk
Lyndsey Trengove /
email@example.com / firstname.lastname@example.org
0121 517 1007
About Bureau Veritas
Created in 1828, Bureau Veritas is a global leader in
Testing, Inspection and Certification (TIC), delivering high-quality services
to help clients meet the growing challenges of quality, safety, environmental
protection, and social responsibility. As a trusted partner, Bureau Veritas
offers innovative solutions that go beyond simple compliance with regulations
and standards, reducing risk, improving performance and promoting sustainable
development. Bureau Veritas is recognised and accredited by major national and
international organisations and works across a wide range of industries
worldwide. The UK business is headquartered in Birmingham, has 1,000 employees
and is based in office locations stretching the length and breadth of the
UK. In 2018, the group posted revenues
of €4.8 billion; the company has 75,000 employees worldwide, with more than
1,500 offices and laboratories, in 140 countries. Bureau Veritas is listed on
the Euronext Paris Stock Exchange (stock symbol: BVI).
Principal Occupational Hygiene Consultant at Bureau Veritas.
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