OHSA – Malta Safety Lens

Safety Glasses

September 7, 2022September 7, 2022 Franklin Grima2 Comments

“In-Nuccalijiet”

The human eye is one of the most vulnerable and exposed organs in our body. Most of the other organs are protected behind the human skeleton, however, the eye only has the eyelids and the eyelashes as natural protection. In conjunction with our natural reflex to blink our eyelids protect our eyes from dust, wind, intense light and small flying objects such as insects.

However, this protection is natural and only protects against natural sources of harm. At the workplace, we have several industrial processes which bypass such natural protection due to their excessive speed, forces, radiation and/or light. It is often observed that grinding, rock breaking, metal work, polishing, lathework and other work processes which may create flying particles or intensive radiation/light (such as welding) are carried out without the required collective protection.

Usually, the first thing that comes to mind as protection for the eyes is safety glasses. However, as per the hierarchy of controls in health and safety, these are the last item to consider when implementing control measures. Safety glasses offer only individual protection and should they fail, they do not fail to safety, meaning the individual will be harmed. Other collective protective measures should be considered prior to the provision of safety glasses.

We’ll be using a pipe-cutting machine as an example to outline what some of these measures are.

Elimination: Is it possible to remove the process of using the pipe-cutting machine? For example by purchasing pipes of the correct length?
Substitution: Is it possible to change your equipment or process to use lesser hazardous equipment? Will a hand operated pipe cutter do the required work?
Engineering Control: Does the machine has the required guards to make sure that in case of failure the hazard does not reach the user? Can the machine be completely isolated from the worker by enclosing it?
Administration controls: Is the pipe cutting machine subject to a periodic maintenance regime? Have the personnel been trained on the use of this equipment? Are safety signs posted and rules implemented?

After considering the above, PPE is to always be implemented when using industrial high-risk equipment. All the above-mentioned measures reduce the risk significantly, but some residual risk will always remain as we can never be completely safe and this is mitigated by PPE, more specifically safety glasses in this case.

Different types of eye protection are available depending on the hazard one needs to protect against. Amongst others, these include safety glasses, safety goggles, hood and face shields.

The type of eye protection made available to the employees should be based on a risk assessment, based on manufacturer guidelines and certification.

The main types of certification for safety glasses are EN166 (European standard) and ANSI Z87.1 (American standard). Such certification would be outlined on the safety glasses frame and also on the lenses.

_{Quality & certification | Bollé Safety (bolle-safety.com)}

For employees who wear prescriptive glasses, there are two options, either safety over-glasses or prescriptive safety glasses. Over glasses, as the name implies, are safety glasses which are designed to be worn over normal prescriptive glasses. Prescriptive safety glasses are specifically designed safety glasses which have integrated certified prescriptive lenses.

Regardless of the type of safety glasses chosen, it should always be ensured that these are manufactured to the previously mentioned standards. I have come across situations where suppliers provide frames which are certified but fitted with normal non-certified prescriptive lenses. Personally, I do not accept or recommend these types of glasses within my workplace and practice the rule “no certification means not allowed”.

For any equipment to be certified, this has to be manufactured according to a standard, as such the only local shops which provided these prescriptive safety glasses are PPE importers who order the glasses directly from the PPE manufacturer.

When a grinder wheel is spinning up to 2000 RPM, all safety features fail and it detaches, you want to be sure that the personal protective equipment provided to the employees is certified as safety equipment. PPE is always the last line of defence.

_{(Picture by Gillian S: Safety Glasses Save Lives (bulksafety.com))}

Have a look at the safety glasses used by yourself or at the workplace, are these adequate and certified? Are the employees who use prescriptive glasses offered the same level of protection as all other employees? Are you making use of safety glasses to reduce the level of residual risk?

Management of Change

June 26, 2022July 24, 2022 Franklin GrimaLeave a comment

“L-Immaniġjar tal-Bidla”

Articles, blogs, entrepreneurs and business leaders all state that change is required for a company to grow and maintain a competitive edge against its competitors. Changes may occur in the product being provided, the company’s branding, management of people and technological changes. Such changes can promote the company’s profits, increase employee engagement and growth, and lead to a safer workplace. However, they can also lead to uncertainty, additional financial costs, reduced performance and the introduction of new hazards and risks.

The effectiveness of a change depends entirely on the management of the said change.

Management of change is a process by which the changes are systematically analysed to identify inherent environmental, health, safety and business risks which may be introduced in the process of implementation. It is so important in health and safety that it is an identified clause required to be implemented for ISO45001 Occupational Health and Safety Management Systems certification. Furthermore, although not mentioned directly in legislation, the General Provisions for Health and Safety (S.L. 424.18), places an obligation on the employer to evaluate the risks arising from equipment, chemicals, work processes and the workplace. As such, it can also be said that a procedure for the management of change helps the employers stay compliant.

Management of the change process would usually involve the following steps:

A request for a change
An evaluation of risks and hazards related to the change
An evaluation of compatibility with current work equipment, infrastructure, chemicals and work processes.
Identification of any changes required
Training on the change and
Implementation

A concept which goes hand in hand with “Management of Change” is “Safety by Design”. Which, as defined by Worksafe is “the process of managing health and safety risks throughout the lifecycle of structures, plant, substance or other products”, perfectly illustrated in the picture below.

Should a change not be managed correctly, and safety not be given importance at the designed stage, the costs to remedy the risks introduced and the possibility of harm increase significantly.

When considering environmental, health and safety, quality and business requirements, change is not a matter of procuring and implementing equipment. It requires time, careful planning and proper evaluation. The personnel leading the change must make sure that the following pitfalls are avoided:

Lack of communication and consultation with the stakeholders who may be affected by the change
Tackling a big or several small changes all at once without the adequate resources
Think that the change will affect only its immediate surroundings, without giving due consideration to secondary equipment, processes, legislative and standard requirements.
Beliving that the change has been fully implemented, without proper long-term monitoring of its effectiveness.

In today’s fast-paced industry, change is no longer optional to stay ahead within your sector but is most often imposed by legislative changes, technology advancements and stakeholder requirements. As such, having a robust system to manage such changes is as important as any other day-to-day procedure required to keep the company afloat.

The Scaffolding

May 3, 2022July 24, 2022 Franklin GrimaLeave a comment

“L-Armar għall-Bini”

On the 2nd of May 2022, a video was posted online by a passerby of a scaffolding swaying with the wind, on the verge of falling onto the street causing damage to cars and possibly injuries to personnel.

Scaffolding is one of the most commonly used structures at construction sites. It is highly recommended to provide a safe working platform and avoid the usage of ladders and rope access techniques. But, it is only safe when it is built correctly.

An article published by the Times of Malta (timesofmalta.com) explains that the construction works on this historical building had conflicts with the law from the start, whereby works had commenced without approval from the planning authority. The planning commission fined the contractor 50 euros a day. Is that fine adequate to stop a contractor from carrying out illegal works?

Guidance and legislation are readily available, both locally, within the EU and from the Health and Safety Executive in the UK.

Legislation regulating the minimum requirement at construction sites (LEGISLATION MALTA) is extremely straightforward where scaffolding is concerned. The regulation states:

“All scaffolding must be properly designed, constructed and maintained to ensure that it does not collapse or move accidentally“

It is also stated that the scaffolding must be inspected and certified as safe for use, prior to being put into service, at periodic intervals and after any modification or exposure to bad weather.

The guidance from the OHSA (L-Armar għall-Bini (gov.mt)) goes one step further and determines the periodicity that the scaffolding is to be inspected and certified i.e. every week that it is in use.

Guidelines state that every scaffolding is to be secured to avoid any swaying. While, both the legislation and guidance provide information on ladders, gangways, guardrails and toe-boards that are to be installed with the scaffolding to ensure safe access and prevent falling tools.

In the United Kingdom, scaffolding is regulated by the implementation of The Construction (Design and Management) Regulations 2015. Fines related to breaches in these regulations issued by the HSE range between 15,000 and 27,000 pounds. In Malta, the penalty for setting up inadequate scaffolding is only 250 euros as stipulated in the Occupational Health and Safety (Payment of Penalties) Regulations.

Since this video went viral, comments on social media read “unbelievable, health and safety doesn’t exist“, “Never ending story” yet again we only see public complaints when things are about to go south.

The posts that reach the attention of the mainstream media are mainly reactive to accidents and not proactive to ongoing health and safety concerns.

However, how many instances like this do we need to witness for the competent authorities to have allocated the adequate human resources to properly regulate the ever-growing construction industry?
Are the current fines adequate to promote a preventive culture rather than a corrective one and isn’t the preservation of human life more of an incentive than any fine imposed?

I write these posts not to point fingers, as it is never the objective of a health and safety practitioner to ascertain blame but to possibly provide insight into health and safety legislation and good practice.

The Unsung Heroes

November 10, 2021July 24, 2022 Franklin Grima1 Comment

“L-Eroj Mhux Imsemmija”

On the 13^th of September, Deputy Prime Minister Dr Chris Fearne presented the Occupational Health and Safety Authority (OHSA) CEO with the commemorative coin “Heros of the pandemic”. This coin is being awarded to all health care workers and OHSA employees in recognition of their work during the Covid-19 Pandemic. Everyone is aware of the excellent work carried out by the health care professionals and the OHSA however very little information can be found on the work implemented by local Occupational Health and Safety Practitioners working independently or employed by companies to ensure the health, safety and business continuity at the workplace.

I made contact with a few of my peers to write this blog post about the roles and responsibilities of the health and safety practitioners during the covid-19 pandemic. As such I would like to thank amongst others, Daniel Cassar and Antoine Cutajar for their input and insights.

In multinational companies, work started way before the Covid-19 pandemic started in Malta. The health and safety departments of different countries started meeting beforehand to discuss how covid-19 is impacting the business and health and safety of the companies where the pandemic had already started. By doing so the companies which were in countries where the pandemic had not yet emerged could prepare and implement measures in anticipation of the coming issues. Such measures included a review of the current risk assessments, review of the cleaning regime, increasing the stock of PPE (both for the pandemic and usual business), segregation of shifts to ensure business continuity and the implementation of a Covid-19 Emergency Plan which included all the relevant measures. As guidance and legislation were still missing at this time, all decisions were based on risk assessments and research carried out on international guidance and legislation, by the same practitioners.

Online tools such as NextStrain are helping to track the spread of coronavirus in real time. Image credit - nextstrain.org — *Image credit – nextstrain.org*

Communication was key throughout all the stages of the pandemic. Practitioners in the industry worked with both management and the workforce to ensure that proper information was disseminated throughout the company. This was carried out by implementing training programs, online meetings, information bulletins and distribution of surveys. As a result of these communication campaigns, it was possible to answer questions and doubts from the workforce and prevent mass hysteria arising from false information popping up all over the internet.

Mental health and psychosocial risks were always being considered during the implementation of the emergency plan and the publishing of communication. The practitioners were aware that the way the information may be interpreted may give rise to occupational stress. Furthermore, although it was made sure that the companies were compliant with legislation and guidelines, suggestions put forward by other people which were “holier than the Pope” and other “measures” being implemented by third parties, not in line with research and guidelines, were not put forward to management or implemented. The reasoning for not implementing these suggestions was not always easy to explain, however, if the non-factual measures were implemented, the same may have had unnecessary business implications or negative effects on employees as the pandemic progressed.

File:Quarantine staff screening passengers in Shenzhen 2.jpg - Wikimedia Commons

As part of travelling risk assessments, the measures of different countries where people from multi-national companies were travelling to had to be reviewed. The health and safety practitioner made sure that only necessary travel was allowed, the risk to the country of destination was acceptable and that the travelling employee faced no surprises such as an unexpected quarantine and missed flights.

Later into the pandemic, when the governments started to ease off on restrictions, the health and safety practitioners needed to revise their risk assessments to ensure that such relaxation of measures are implemented accordingly. It was and still is, a top priority for the health and safety practitioners to ensure that the measures ranking high in the hierarchy of controls, such as social distancing, provision of barriers and cleaning, are not taken lightly and are still practised at the workplace.

The work of the health and safety practitioners served as an intermediary between the government who implemented guidelines and legislation, the management and the workforce. Legislation and guidelines were translated into layman’s terms and into different formats so that they can be understood by all the workforce and management.

The health and safety practitioner is not always the person seen in a high visibility vest and a white helmet at construction sites, in bigger companies they are usually the ones working in the background, preparing and implementing policies, drawing up risk assessments, carrying out research and preparing proposals and providing suggestions to the management so that adequate and wise decisions can be taken.

The Guard Rails

August 29, 2021July 24, 2022 Franklin GrimaLeave a comment

“L-Ilqugħ”

On your balcony, you fix railings that are permanent and made of solid materials. These railings are normally manufactured to fit your needs and dimensions. Once fixed you would not have to worry about anyone falling down from your residence. However, a fixed railing is not possible during the construction of a building and temporary measures must be put in place to protect workers.

Edge protection is what this temporary measure is called and if you keep an eye out for construction sites in Malta you notice a lot of different measures put in place as edge protection.

Thin timber connected with screws and nails (picture 1), timber guardrails with intermediate guardrails and horizontal timber posts (picture 2), timber guardrails with metal clamp horizontal posts (picture 3) and timber guardrails fixed to the adjacent wall (roof picture 4).

Which of these are adequate? which ones do actually provide protection? and which ones are legally compliant and follow standards and/or good practice?

Edge protection is mentioned in the Maltese legislation in S.L. 424.36 which outline the minimum requirements for construction sites. There is one article in this legislation which states that edge protection must be installed in areas where a person may be liable for a fall and that edge protection must be suitable for its intended use, strong and of adequate height.

Further guidance is provided in a document published by the OHSA called “OHSA Guidance L-Armar għall-Bini”. In this document, it is stated that there should be a guard rail set at 115cm from the ground up and an intermediate guard rail set at 90cm. Furthermore, toeboards are to be implemented if works are ongoing to prevent falling tools which are to be a minimum of 15cm.

A BS EN Standard categories edge protection under three different classes depending on the degree of the slope of the floor. As most Maltese buildings have a flat rooftop, the majority of Maltese buildings would require class A edge protection. The standard states that such edge protection shall withstand a horizontal force of 0.3kN and a vertical force of 1.25Kn. These systems may be supported by clamps, anchors and friction posts. The standard also states that the principal guard rail is to be continuous.

To put the above in perspective, a person of 60Kg who falls for a distance of just 1m will have an impact of approximately 0.8kN.

These standards show that edge protection should not only be there to warn a person of the upcoming drop but to actually arrest the person should he stumble against the same edge protection.

Edge protection from picture 1 has a principal guardrail which is made up of different pieces of timber.
This edge protection is not in compliance with local law and does not follow any guidance. The principal guard rail is not continuous, it is missing an intermediate guardrail. It is unlikely that this system will stop a person from falling down.

Edge protection from pictures 2,3 and 4 all have a principal guard rail and intermediate guards as per local guidelines. They also look structurally sound, either screwed directly to the wall, fixed to metal beams or using horizontal clamps.

Three out of four buildings observed, follow the local guidelines. However how many employers go that extra step and test the guardrails as per the BS EN standard? Do you ever see construction sites and ask yourself “will that actually save my life?”

The Heat

June 25, 2021July 24, 2022 Franklin GrimaLeave a comment

‘Is-Sħana’

Following one of Malta’s hottest days when temperatures reached 40.2°C ⁽¹⁾, I felt that this month’s post has to be about heat exposure. How hot is too hot, what do the guidelines and legislation say and how to protect yourself against heat and sun exposure?

The OHSA aimed to answer the latter by publishing guidelines on work carried out in warm weather and in the sun⁽²⁾.

The publication starts off by stating that a comfortable temperature should be in the range of 20°C to 25°C. This range is also cited in the Compliance code – Workplace amenities and work environment issued by WorkSafe Victoria⁽³⁾. However, it is common knowledge that it may be impossible to achieve such temperature for outdoor workspaces in the summer. Working in high temperatures for prolonged periods of time can lead to a lack of alertness, tiredness and other heat-related illnesses such as heat stroke and heat cramps.

The OHSA document goes on to explain good practise which is to be followed by the employers and employees such as the provision of adequate ventilation, an increase of breaks, access to potable water, job rotation, and provision of adequate clothing and training. However, these are only guidelines and it is up to the employer to carry out a risk assessment to determine what is required to be implemented. Furthermore, the guidelines are somewhat vague…what is adequate clothing? The Skin Cancer Foundation states that clothing should cover as much skin as possible, and be loose and dark/bright coloured(4). However, due to lack of information, it is common to see construction workers wearing vests or no shirt at all.

What are other countries doing to combat this risk?

When it comes to temperature, it is very difficult to obtain guidelines and/or legislation from European countries. The biggest problem for EU countries is cold weather. In an approved code of practice published by the Health and Safety Executive a workplace minimum temperature of 16 °C can be found, however since hot weather is not common in the UK, the maximum temperature is not mentioned⁽⁵⁾.

In a document titled “Health and safety – time for change” published by The Trades Union Congress based in the UK, it is stated that 14% of workers’ safety representatives remarked high temperatures as a major concern. One would only imagine what this percentage would be if such a survey is carried out in Malta. In this same document, the TUC is calling for a maximum limit of 30°C to be set for workplaces⁽⁶⁾.

However, more fruitful information can be found if one looks at guidance and legislation published by countries with warmer climates.

The American Conference of Governmental Industrial Hygienists (ACGIH) set the threshold limit value between 25 °C and 34 °C depending on the activity being carried out at the workplace and other environmental conditions such as airflow and humidity⁽⁷⁾.

On March 26th, in the United States of America, the Asuncion Valdivia Heat Illness and Fatality Prevention Act of 2021 was introduced which aims to push forward the development of a safety standard for the prevention of exposure to excessive heat. The aim is to publish this standard within 2 years and is to include, amongst others, action limit values, medical surveillance, paid breaks and exposure monitoring⁽⁸⁾.

A country at the forefront of implementing legislation protecting workers from heat is the United Arab Emirates. A law banning outside work and working in the sun from 12:30 to 15:00 is enforced from June to September. The law is backed up by hefty fines and other administrative penalties for those found to be in breach⁽⁹⁾. In Malta, a ban on construction work is implemented in certain localities to protect tourism. What about protecting the workers from the sun?

In a country where public health warnings targeting high temperatures are common, where heat stress and long sun exposure are acknowledged as a serious problem by the chief of OHSA⁽¹⁰⁾ and where heat exposure was identified as a workers’ main concern in 2002 by the HSE in a report called ‘Perceptions of health and safety in Malta’⁽¹¹⁾ …. shouldn’t specific legislation regulating heat be published? shouldn’t we be at the European forefront in the implementation of innovative arrangements against exposure to heat and sun?

Resources

The Dust – Silicosis

April 24, 2021July 24, 2022 Franklin GrimaLeave a comment

‘It-Trab’

The screaming noise of a blade going through stone followed by a white cloud of dust:

This is a sight one expects to see on any construction site regardless of the size of the project. One wouldn’t believe anyone who claims to be a builder if the person wasn’t covered in white dust arising out of the Maltese Limestone. Why is everyone complacent to the dust generated by such works? Should be people be concerned?

Limestone is naturally occurring and contain varies amounts of quartz (crystalline silica). This mineral is not dangerous in its bulk form and is safe to use. However, when the material is processed, cut or broken down it may create dust which contains respirable crystalline silica. As such, any quarry, mining and most building activities involve crystalline silica (https://www.eula.eu/crystalline-silica/).

Lamiot, CC BY-SA 4.0 https://creativecommons.org/licenses/by-sa/4.0, via Wikimedia Commons

If inhaled, respirable crystalline silica may settle in the lungs which is then attacked by the immune system. This may cause swelling which may lead to scarred tissue (fibrosis). As a result, a person may develop a persistent cough, shortness of breath and a feeling of tiredness. These are the symptoms of silicosis which also increases the risk of a person getting other serious conditions such as chest infections, lung cancer and arthritis Silicosis – NHS (www.nhs.uk).

Respirable crystalline silica is regulated in Malta by S.L.424.35 Protection of Workers from the Risks related to Exposure to Carcinogens or Mutagens at Work Regulations . Amongst others the employer has a duty to carry out the following; assessments, reduction of exposure, implementation of technical measures and making arrangements for health surveillance.

The law is quite technical and somewhat difficult to interpret. However, if we look at guidelines issued by the Health and Safety Executive (HSE) we better understand what is required to protect oneself from silica exposure.

To put us in perspective of how important the following measures are, the HSE published this image which shows the amount of inhaled silica, not be exceeded per day.

In certain circumstances, dust can be avoided altogether by purchasing the correct size of material or using direct fastening systems. Having said that, the generation of dust may be inevitable, as such tool extraction and respiratory protective equipment is to be used to reduce and protect against exposure to dust (Construction dust CIS36 (hse.gov.uk)). In Malta we sometimes see construction site workers using water damping devices however this is not a common sight to see.

Dust exposure is so serious that the HSE has been running a campaign called ‘Dust Buster’ whereby HSE inspectors check on construction sites to ensure that the above controls are implemented and that workers are aware of the risks involved (“Health and Safety Executive cracks down on dust – HSE Media Centre”, 2020).

In 2001 there were 485 cases of silicosis in the European Union (Karjalainen & Niederlaender, 2004). These exclude other respiratory problems which arise out of dust and have not been diagnosed a Silicosis. Such as, lung cancer, chronic obstructive pulmonary disease (COPD) and asthma.

So how come we still expect builders to be covered in dust? How come dust bothering neighbours of construction sites, is still considered a nuisance and nothing else? How come workers still refuse to wear appropriate PPE? Aren’t we all tired of seeing dust-covered cars, dust-covered roads, dust-covered buildings and dust-covered people?