Planning the controls for a new high-care line
Calder Valley Foods runs a ready-meal factory with 380 employees on two shifts and is commissioning a new high-care assembly line in ten weeks. The line adds 60 staff, a new wash-down regime and a chilled-water plant, and no risk assessment exists for it yet.
Existing hazards include four filling lines running at 92 dB(A), 20 kg ingredient sacks unloaded manually at up to 90 sacks per hour, hand-knife preparation (three laceration first-aid cases last quarter), flour dust, an ammonia refrigeration plant with a 400 kg charge, and lone cleaning on the night shift. The site's risk assessments were produced in one week by line managers using a 5x5 matrix copied from a sister site, and the standard control entry for most hazards reads 'PPE mandatory, training provided'. Noise monitoring dates from 2019. The legal register was last updated in 2021 and does not reflect recent changes in noise exposure limits or ammonia safety requirements. The only OH&S objective is 'reduce accidents by 10%'. There is no formal process for responding to change.
1. Critique the site's hazard identification against ISO 45001 clause 6.1.2 and propose a method that would fix it.
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The current approach fails 6.1.2 in method, coverage and ownership. A 5x5 matrix copied from another site imports someone else's assumptions; line managers completing the whole site in a week are producing paperwork, not identifying hazards. The uniform entry of 'PPE and training' shows no hazard-specific thinking.
What 6.1.2 requires is a proactive, systematic process covering routine and non-routine activities, emergency situations, human factors, changes in work organisation, and the people affected - contractors, visitors, the public, and workers at all shifts. Missing at Calder Valley:
- Non-routine and infrequent work: wash-down, ammonia plant maintenance, night-shift lone cleaning, unblocking jammed fillers.
- Emergency situations: ammonia release, fire in a high-care area, casualty evacuation with restricted access.
- Human factors: workload and pace at 90 sacks per hour, monotony, fatigue on nights, language and literacy among agency staff.
- Health hazards: noise exposure with no current data, flour dust, manual handling cumulative damage, knife lacerations.
- Change: the new line, new chemicals, new layout, new staffing.
- Interfaces: contractors, delivery drivers, maintenance during production.
A workable method: task-based hazard identification by trained teams including the workers who do the job, walking each area and each shift; separate health-hazard surveys using measurement (noise, dust, manual handling); scenario reviews for emergencies; and a formal trigger so any change re-enters the process under 8.1.3. Outputs should feed a single prioritised risk register with named owners.
2. For the noise, the 20 kg sacks and the ammonia plant, recommend controls consistent with the hierarchy in 8.1.2 and explain why the current PPE-first approach is inadequate.
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Clause 8.1.2 sets a mandatory order: eliminate the hazard; substitute with less hazardous processes, operations, materials or equipment; use engineering controls and reorganisation of work; use administrative controls including training; and only then adequate PPE. PPE sits last because it protects one wearer, depends on fit and behaviour, and fails silently.
- Noise at 92 dB(A). Elimination is unrealistic, so substitute and engineer: specify low-noise fillers at replacement, enclose or lag the noisiest units, fit silencers on air exhausts, and segregate noisy plant into a separate room. Then administrative controls: rotate exposure, mark hearing-protection zones, and use hearing protection as the last layer. Crucially, the 2019 data is unusable for compliance decisions; measurement must be repeated and calibrated.
- 20 kg sacks at 90 per hour. Actual elimination means buying in bulk or in smaller unit weights - a substitution at the procurement stage (8.1.4). Engineer: vacuum lift assist, roller conveyors, adjustable-height tables, decanting hoppers. Reorganise: job rotation and two-person handling for the heaviest items. Training and technique alone do not remove the load.
- 400 kg ammonia charge. Engineer out the risk: leak detection interlocked to alarms and ventilation, automatic isolation, remote shut-off outside the plant room, permitted-access maintenance with a competent contractor, and a tested emergency plan under 8.2 including evacuation and medical response.
PPE-first is inadequate because it leaves the hazard in place, transfers the burden to the worker, and provides no evidence that exposure is controlled. It also fails 6.1.4, which requires actions to be planned, integrated into the system and evaluated for effectiveness.
3. Evaluate the single objective and the state of the legal register, and propose how 6.1.3, 6.2 and 9.1.2 should work together at this site.
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'Reduce accidents by 10%' fails most of 6.2.1. It is not clear what is being counted, over what baseline, by whom, or with what resources; it targets one lagging outcome; it is unconnected to the significant risks; and it can be met by under-reporting. It also gives nothing to monitor at line level.
Better objectives, each with a baseline, target, owner, resource, deadline and measurement method:
- Reduce filling-line noise exposure to below 85 dB(A) at all operator positions by quarter three, through enclosure and silencer retrofit.
- Eliminate manual lifting of 20 kg sacks on the sauce line by installing a vacuum lift and decanting hopper by the end of quarter two.
- Achieve zero hand-knife lacerations on preparation by introducing cut-resistant gloves for high-risk tasks plus fixed-blade alternatives, measured monthly.
- Complete ammonia emergency drills involving the local fire service twice a year, with all actions closed within 30 days.
The legal register (6.1.3) is stale, which is a direct planning failure: if the organisation does not know its current obligations on noise and ammonia, its controls and its objectives cannot be correct. It needs an owner, a defined update trigger (regulatory change, new process, new substance, new site), and a link to the risk register.
9.1.2 then closes the loop: evaluate compliance at planned intervals against that register, record the results and the evidence, and feed the findings into 9.3 and 10.2. Objectives under 6.2.2 are monitored under 9.1.1; compliance is evaluated separately under 9.1.2. The three must reference the same obligations and the same significant risks.