With figures from Europe suggesting 20% of all accidents are related to maintenance activities, the need to undertake a suitable and sufficient risk assessment for maintenance work is clear. Mike Sopp reports.
According to the Health and Safety Executive (HSE), maintenance is about ensuring the workplace, its structures, and associated assets operate safely and that their condition does not decline, thereby preventing potential unexpected failures with their associated consequences.
However, as EU-OSHA states “while maintenance is absolutely essential to ensure safe and healthy working conditions and prevent harm, the maintenance work itself involves exposure to several hazards for the maintenance worker”.
Maintenance activities, be they planned or reactive, can include many functions including testing, repair or servicing of building elements or its associated plant and equipment.
Work activities can range from minor repairs to major overhauls. They take place in almost all work environments and can involve tasks being undertaken by employees as part of their everyday duties as well as by specialist contractors.
Poorly planned or managed maintenance activities and procedures raise the risk of workplace accidents and ill health including fatal accidents. As well as the 20% of all accidents, EU-OSHA estimates that in Europe, between 10–15% of all fatal accidents at work can be attributed to maintenance operations.
Literature issued by EU-OSHA highlights that maintenance workers are much more likely than other employees to be exposed to a wide variety of hazards including:
physical hazards such as falls from height, crushing by machinery, musculoskeletal disorders, exposure to noise, vibration, UV radiation and inclement weather
chemical hazards such as exposure to substances hazardous to health and exposure to asbestos containing materials
biological hazards including the potential exposure to agents such as the Legionella bacteria
psychological hazards may include stress, for example due to tight deadlines and working unsocial hours/shift work, etc.
Apart from hazards to those directly undertaking the maintenance activities, poor procedures can potentially put other building users/occupiers at risk.
Maintenance activities are often outsourced. This can increase risk factors, for example, due to:
little or no routine for the maintenance activities (eg a one-off operation)
an unknown/unfamiliar working environment
contractual time pressures
lack of communication between parties
subcontracting of operations by the main contractor.
In terms of the latter, again referring to EU-OSHA literature, a study conducted in France found that subcontracted maintenance workers had the second highest rate of accidents after subcontracted construction workers.
As the case of R v Swan Hunter Shipbuilders Ltd tested, if a work activity such as maintenance work is outsourced, this does not necessarily mean the client is absolved of its duties under health and safety legislation.
Risk assessing is a fundamental element in controlling the risks from all work activities and is obviously a legal requirement. Risk assessing maintenance activities is no different.
It is worth noting that BS 8210 Guide to Facilities Maintenance Management notes that the management of health and safety “should be viewed as an integral component of facilities maintenance management” and that an organisation should “implement risk control, as an integral part of its risk management”. To achieve this, a suitable and sufficient risk assessment should be completed.
However, as EU-OSHA identifies, “assessment of risk for maintenance operations is an especially difficult task because of the various uncertainties of such work processes, such as being called unexpectedly to repair broken down machines or discovering unforeseen causes of breakdown”.
This can be further complicated by maintenance operations being carried out across multiple sites, often in an outsourced environment.
Planning the risk assessment process is therefore essential. The scope of the assessment, as it relates to the type of maintenance activity (or activities) should be determined and from this an “inclusive” approach should be taken to ensure the views of in-house persons and/or contractors undertaking the activity are fully considered.
As with any risk assessment, the hazards need to be identified using the normal sources of data including the knowledge of those undertaking the maintenance activity, good practice guidance, previous experience and legal requirements, etc.
As already noted above, poor safety in maintenance activities can expose not just those undertaking the work activities to risk but others including occupiers, visitors, passers-by, etc. This should be identified in the risk assessment.
When analysing/evaluating the risk, the simplest approach to take is to benchmark current risk control methods against those contained in best practice guidance. As an example, for lift maintenance, risk control requirements can be benchmarked against the requirements of BS 7255 Code of Practice for Safe Working on Lifts.
Typical factors that will need to be considered include the skills and number of staff required (including roles and responsibilities), the tools required to undertake the work, personal protective equipment required, access and egress requirements, the competency deemed necessary to both manage and undertake the tasks.
From this, the necessary risk control and safe working practices can be adopted that reduce the risks to as low as reasonably practicable.
As noted above, maintenance work activities can be dynamic in nature due to the uncertainties that may be present, particularly for reactive maintenance activities.
A key aspect of any risk control system for maintenance work is therefore ensuring that those undertaking the work are competent to do so and that good communication between relevant parties takes place from planning to completion of the work activities.
Due to the dynamic nature of maintenance work, a key aspect of controlling risks may have to include operatives/supervisors recognising when the assessment and subsequent safe working practices will not suffice, that work should be stopped, and that a revised risk assessment needs to be completed.
Indeed, EU-OSHA emphasises that “employers need to ensure that workers have the skills that they need to carry out the necessary tasks, are informed about safe work procedures, and know what to do when a situation exceeds their competence”.
In terms of practicalities and safe working, the outcomes of the risk assessment in terms of risk control can be transposed into a Method Statement that describes the actual safe working practices.
The HSE website notes that a Method Statement “describes in a logical sequence exactly how a job is to be carried out in a safe manner and without risks to health. It includes all the risks identified in the risk assessment and the measures needed to control those risks. This allows the job to be properly planned and resourced”. The Method Statement would cover the safe working requirements and will describe:
how the working environment will be made safe including power shut off, securing moving parts, establishing restricted zones of working, etc
the use of appropriate tools and equipment to undertake the work as well as the use of personal protective equipment
the safe working practices to be adopted including safe systems of work, permit-to-work procedures and the use of hazardous substances, etc
the monitoring and supervision of the work, particularly where contractors are undertaking the work
the procedures for deviating from the Method Statement and emergency situations
the procedures for undertaking final checks to ensure the area/equipment is safe and that all tools, equipment and waste materials are removed.
Both routine (planned) and reactive maintenance can create hazards not only to operatives undertaking the work but third parties as well.
With high levels of accidents and fatalities involving maintenance work the need to plan and control such activities is essential.
The starting point for this is a suitable and sufficient risk assessment that involves all parties undertaking the work, including any contractors.
As with any risk assessment, thought needs to be given to the process of risk assessing. Rather than being a tick-box exercise, the risk assessment should identify the risk control measures required, leading to the development of safe working practices.
These safe working practices can be communicated through the use of a Method Statement that all parties are aware of and agree to.
Last reviewed 3 December 2018