What to expect before your inspection with the HSE on Wood Dust

Working with wood dust can lead to serious and often irreversible health issues, including sinus and nasal cavity cancer, asthma, and dermatitis. Employers in the woodworking industry are legally obligated to prevent or effectively manage employee exposure to wood dust within the workplace.

An Urgent Call for Woodworking Businesses

The HSE conducted over 1,000 inspections of woodworking operations and discovered that 78% of businesses did not comply with safeguarding their employees against respiratory sensitisers. This resulted in over 400 enforcement actions by the HSE. This situation has prompted the HSE to initiate inspections of woodworking businesses throughout 2023/24, aiming to reduce cases of work-related illnesses and combat the severe impact of occupational lung diseases on workers.

Insights from a recent HSE visit

We spoke to Ed Kirk from the TRA’s health and safety committee about his recent visit from the HSE regarding wood dust.

“We had an HSE inspector visit our facility earlier this year. During the inspection, the HSE representative conducted a comprehensive review of the factory and areas where our employees work.

The inspector asked to see training records and various reports related to air quality, Local Exhaust Ventilation (LEV) testing, and the implementation of health surveillance protocols. The inspector also posed several inquiries, covering topics such as training programs, service intervals, and the frequency of site inspections.

Expect them to engage with shop floor personnel to assess their training and use of personal protective equipment. Depending on the circumstances, these visits can range from several hours to half a day, so I would highly recommend revisiting any guidance you may have previously given workers.

If the HSE hasn’t yet visited you, it is important to ensure your housekeeping practices are consistently maintained at a high standard.”

What if you haven’t been visited by the HSE yet?

For TRA members who are yet to have a visit from the HSE, it is important to keep on top of your housekeeping. The HSE has identified four areas of concern which TRA members should be especially aware of:

• Dry sweeping:
  Members should refrain from dry sweeping and using compressed air when cleaning, as these practices can create dust clouds and redistribute the dust. Use vacuum equipment that meets at least the dust class M (medium hazard) classification or a suction hose attached to the LEV system.
• Local Exhaust Ventilation (LEV): The primary means of controling wood dust at the source to prevent its spread within the workplace is by using a fixed LEV system. These systems must be designed and regularly tested to prove dust levels are always below the WELs (Workplace Exposure Limits) 5mg m3 where only Softwood is processed or 3mg m3 where Hardwoods or mixtures of Hardwood and Softwood are processed. Further guidance on LEV design and management can be found on the HSE’s website.
• ALARP “as low as reasonably practical” principle: Being below the workplace exposure limit WEL is the minimum legal requirement. HSE inspectors expect companies to also apply the ALARP principle through additional practical measures further reducing workers exposure to wood dust. For some machines this means in addition to effective LEV workers also being required to use RPE (Respiratory Protective Equipment) for some or all tasks.
• Face fit testing: A face ‘fit test’,  is needed to ensure any tight-fitting RPE  is effective for the individual worker. Facial hair or glasses tend to lift the respirator off the face and permit inward leakage of contaminated air. Inspectors will want to see records that face fit testing is regularly carried out.
• Health Surveillance: Employers in the woodworking industry must fulfil their legal duty to provide health surveillance as several health concerns are associated with wood dust.

It is also important to provide ongoing training for your staff regarding cleaning, maintenance, proper fitting of personal protective equipment, health surveillance, and testing.

We often see ‘as low as reasonably practicable’ (ALARP) in official guidance, which signifies that you can demonstrate you have made every effort to manage the risk. It must also be demonstrated that the cost of further risk reduction would greatly outweigh the benefits gained. It’s a best practice judgment of risk and workforce benefit balance. For employees requiring custom-fitted face masks, it is particularly important to stress the significance of proper fitting and use to all your employees.

The TRA Health and Safety Committee is available to offer assistance and address any queries TRA members may have regarding health and safety concerns.

TRA members can access the Wood Safety Group’s guide on wood dust.