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Are
your LEV systems up to the job of protecting users
adequately?
The
COSHH Regulations1 require employers to
prevent or control exposure to hazardous substances by
their employees and people affected by their activities.
Since inhalation is the most significant route of
exposure to hazardous substances, it follows that Local
Exhaust Ventilation (LEV) becomes a useful measure to
control and capture these substances as they are
released into the atmosphere within the workplace.
Main
LEV Components
LEV
is a ventilation system that takes dusts, mists, gases,
vapour or fumes out of the air so that the workers or
anyone in the workplace cannot breathe them in.
An LEV system typically consists of the following
components (see figure 1):
|
|
| Hood(s) |
to
collect airborne contaminants at, or
near, where they are created. |
|
|
| Ducts |
to
carry airborne contaminants away from
the process. |
|
|
| Air
Cleaner |
to
filter and clean the extracted air |
|
|
| Fan |
which
is of the correct size and type to
provide sufficient extraction. |
|
|
| Discharge |
the
safe release of cleaned and extracted
air into the atmosphere. |
For
an LEV system to work effectively, each of these
components has to be selected and designed carefully,
taking into consideration the work process it is
intended to control.
What
is the Problem?
LEV
systems have been used in industry for a number of years
and they come in various shapes and sizes.
So what is the problem?
LEV
can be a very effective way of controlling exposure by
removing contaminants from the workplace air, but the
HSE says that much of the equipment in use doesn’t
work. The
main problems are:
| 1. |
Employers
often don’t appreciate the extent of
exposure risk from their process. |
| 2. |
Employers
and employees are often over-optimistic
about LEV capabilities and performance. |
| 3. |
There
has been no guidance on LEV buying and
employers are often mislead and mis-sold. |
| 4. |
As
regards the LEV design, often the LEV
hood is not matched to the process and
sources causing exposure. |
| 5. |
The
LEV system is neither installed nor
commissioned thoroughly. |
| 6. |
The
regular checking and maintenance of the
LEV systems is often neglected. |
| 7. |
The
thorough examination and test as
required under COSHH regulations is
often not done or incomplete (it is not
“thorough”). |
Recent
statistics from the HSE2 show that
occupational disease and exposure affect many workers.
Thousands of people in the
UK
die of lung disease or get asthma because of airborne
contaminants they have breathed in at work.
The cost to industry for occupational asthma is
£96-135 million and it is on the increase each year.
Health risks need to be better controlled and a
disease reduction programme is being promoted by the
HSE.
What is
the Solution?
The
HSE has recently published revised guidance on LEV,
including booklets for employers, designers, installers
and examiners and pocket cards for workers.
Following a major re-write, new and improved LEV
guidance is now available (see http://www.hse.gov.uk/lev/index.htm)
The changes are so significant that the HSE felt
the need to provide additional training for their
Inspectors and over 400 have been trained and issued
with simple test equipment.
As
part of a campaign to raise standards, the HSE launched
Trainer, Advisor Briefing Days last year.
ESL consultants were invited to the first
briefing day on 24th October 2008 at the
Health & Safety Laboratory in Buxton.
The new LEV course training material
(presentations, video clips, etc) was given to those
attending the briefing, free of charge, subject to terms
and conditions. The
HSE is doing this because
they are looking for a step change in the understanding
and application of LEV systems.
In
addition to the above, the HSE has published documents3,4
which should provide employers, managers and health and
safety officers with assistance in meeting their legal
duties under the Management of Health & Safety at
Work and COSHH Regulations5.
Specialist
Help
Unless
you have a fairly simple process to control, you
probably need to get specialist help when it comes to
purchasing a new LEV system.
There are some third party consultants who will
act as advisers but most people will be dealing directly
with an LEV supplier.
It is therefore important you select and vet any
potential suppliers carefully.
The following questions might prove useful:
| 1. |
What
experience do they have in designing and
providing LEV? |
|
|
| 2. |
What
are their professional qualifications,
experience and affiliations? |
|
|
| 3. |
Have
they successfully applied LEV to similar
processes or activities in your
industry? |
|
|
| 4. |
Can
they provide references or examples
showing successful installation of LEV
systems? |
|
|
| 5. |
Are
they tied to a particular range of LEV
products? |
|
|
| 6. |
How
will they show that the LEV provides
adequate control? |
It
is important that you give the supplier a specification
of the work that you want to have done and what the
proposed system should achieve.
One of the areas where specialist help might be
needed is the annual examination and test of the LEV
systems. What
are the requirements of the HSE’s revised guidance?
LEV
Thorough Examination and Test (HSG 258)
Most
LEV systems need a thorough examination and test once
each year although COSHH specifies that you are allowed
14 months between tests.
This is a legal requirement to ensure that the
LEV works well and continues to protect users.
Some LEV systems need more frequent thorough
examination and testing, e.g. systems that are used to
control critical or high hazard processes.
Someone
who is “independent” of the maintenance of the
system should undertake the thorough examination and
test. In
practice, this normally means hiring in an outside
contractor. Whatever
the case, the following summarises what is required in
order to carry out thorough examination and test under
the new HSG 258:
LEV Examiner
| 1.
The
examiner must be competent |
|
2.
The
examiner must be provided with:
| · |
Commissioning
report |
| · |
User
Manual which should
cover details of any
thorough examination and
testing work |
| · |
Log
Book recording checks
and maintenance
activities |
| · |
Full
access to the systems
and the co-operation of
relevant staff |
|
|
|
| 3. |
If
no commissioning report or
manual is available, the
system will need to be
retrospectively
commissioned. |
|
|
 |
Thorough
examination and testing of LEV system involves three stages:
| Step
1: |
A
thorough visual examination to verify
“….in efficient working order, in good
repair and in a clean condition” – COSHH
Regulation 9(1). |
|
|
| Step
2: |
Measuring
and examining the technical performance to
check conformity with commissioning data |
|
|
| Step
3: |
Assessment
to check the adequate control of worker
exposure |
LEV
system examiners need equipment such as Pitot tubes, smoke
generator, dust lamp, anemometer and sometimes air sampling
kit.
LEV
Hood Label
This
is a new requirement under the HSG 258 that the examiner
should attach a test label to each hood when tested and when
the LEV requires remedy or repair, the examiner should
instead attach a red “FAIL” label to the hood (see
figure 2). Employees
who use the LEV system and their supervisors need this
testing information. All
hoods (including fume cupboards) should carry a simple test
label.
Figure
2: Test label
Test
Reports
The
HSE has highlighted some issues for employers with current
reports and these are:
| 1. |
Report
goes to engineering function and join the
long queue |
| 2. |
Report
filed and forgotten |
| 3. |
No
action taken |
The
HSE would like to see the directors and senior managers
taking the lead in treating the report as an ‘audit’ on
previous years’ checking, maintenance and actions on test
results.
A
suitable test record should contain the following:
| 1. |
Prioritised
remedial actions (including any red labels) |
| 2. |
The
process and substance(s) controlled |
| 3. |
LEV
diagram showing location and test points |
| 4. |
LEV
system condition (including photos, serial
numbers, etc) |
| 5. |
Qualitative
and quantitative test methods used |
| 6. |
Qualitative
and quantitative test assessment records |
| 7. |
Required
and assessed LEV system performance compared |
| 8. |
Comments
on operator methods of working |
| 9. |
Comments
on system wear and tear |
| 10. |
Date
of next examination and test |
| 11. |
Signature |
|
|
LEV
Instrumentation
Quite
often, it is difficult to tell whether an LEV system is
working properly or not.
Hazardous substances are not always visible to the
naked eye and nor do they always have an odour.
Users
of LEV systems, particularly the operators at LEV hoods,
should be able to tell that the hood airflow continues to be
adequate to control exposure.
Good practice requires the periodic monitoring of
performance for all hoods.
Generally speaking, new and modern fume cupboards are
designed with a complex device to activate an alert if the
airflow drops below pre-set trigger levels6.
The
HSG 258 encourages employers to install an airflow indicator
at every hood because the operator needs some simple
indication that the hood is working properly.
It becomes critical when the operator has to adjust a
damper to get adequate airflow.
The airflow indicator must indicate simply and
clearly when the airflow is adequate.
A simple manometer can be used and there are other
indicators available on the market (see figure 3)
Fig 3. Airflow
Indicator
Conclusions
| · |
The
new HSG 258 published by the HSE is part of
a campaign to raise standards and the HSE
will also be taking a tougher line on
inspection of LEV systems.
Further information on the new
publications is available from the HSE
website at: www.hse.gov.uk/lev |
|
|
| · |
If
LEV is properly selected, installed,
maintained and used, it can be an effective
control measure, which reduces personal
exposure to hazardous substances. |
|
|
| · |
The
Employer has a legal duty for arranging the
thorough examination and test of LEV systems
on an annual basis by a competent person. |
|
|
| · |
The
Examiner should issue a simple label for
every hood examined and tested. |
|
|
| · |
The
users of LEV systems need to see that the
system is working properly and thereby
controlling exposure.
This can be demonstrated by using a
simple airflow indicator on every hood. |
References.
| 1: |
Control
of substances hazardous to health (5th
edition).
The Control of Substances Hazardous
to Health Regulations 2002 (as amended).
Approved Code of Practice and
Guidance L5 (5th edition) HSE
Books 2005 ISBN 978 0 7176 2981 7 |
| 2: |
Health
and safety statistics 2007/08, A
National Statistics publication.
Also http://www.hse.gov.uk/statistics/overpic.htm |
| 3: |
Time
to clear the air! A workers’ pocket guide
to local exhaust ventilation (LEV) Pocket
card INDG409 HSE Books 2008 ISBN 978 0 7176
6300 2 |
| 4: |
Controlling
airborne contaminants at work: A guide to
local exhaust ventilation (LEV) HSG 258 HSE
Books 2008 ISBN 978 0 7176 6298 2 |
| 5: |
Management
of health & safety at work, MHSW
Regulations 1999.
Approved Code of Practice and
Guidance L21 (2nd edition) HSE
Books 2000 ISBN 978 0 7176 2488 1 |
| 6: |
Fume
Cupboards Safety and Performance
Requirements.
British Standards Institution, BS EN
14175-2:2003 |
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