Manual packing line: is the risk assessment suitable and sufficient?
A 140-person bakery supplies supermarkets from one site. A new manual packing line was commissioned six weeks ago. Operatives lift 12 kg trays from a conveyor about nine times a minute over eight-hour shifts, and the line runs at 87 dB(A). The workforce includes 14 people over 55 and three with diagnosed back problems. The line supervisor completed the risk assessment using a generic five-page template from another site, scoring lifting as 'medium' and noise as 'low' because 'ear defenders are available'. No measurements were taken. The assessment has not been reviewed since commissioning, although output targets have risen twice and conveyor speed was increased. Two operatives now report numbness in their fingers. Production managers say stopping the line to make changes would breach customer orders. There is no health surveillance for noise or hand-arm vibration, and no manual handling training specific to the new trays.
1. Critically evaluate whether the risk assessment is suitable and sufficient. Identify the most significant failings and explain the consequence of each.
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Assessment against the standard for suitability and sufficiency
A suitable and sufficient assessment must identify the hazards, evaluate the risk in the actual circumstances, and be proportionate to the risk. This assessment fails on several counts.
- It is generic, not site-specific. A template from another site cannot reflect this line's conveyor speed, tray weight, layout or workforce. The scores therefore have no evidential basis.
- The ratings contradict the facts given. Noise is scored 'low' despite a stated 87 dB(A), which is above the upper exposure action value where hearing protection zones and mandatory protection are required. Lifting is scored 'medium' despite nine lifts a minute of 12 kg over eight hours. 'Ear defenders are available' is a statement about a control, not an evaluation of exposure or residual risk.
- Vulnerable workers are not considered. Fourteen operatives over 55 and three with back problems materially change the risk profile; the assessment does not address them.
- Ill-health signals are ignored. Numbness in fingers is a reason to review exposure and consider health surveillance, not to leave the assessment unchanged.
- There is no review trigger. Output targets and conveyor speed changed after assessment, which is precisely when a review is required.
- Competence and consultation are unclear. The supervisor may not be competent to assess noise and musculoskeletal risk, and there is no evidence that operatives or representatives were consulted.
The consequence is that controls are mis-prioritised, exposure continues, and the document cannot support a defensible decision to keep the line running.
2. Using the hierarchy of control, propose a prioritised set of controls for the lifting and noise risks. Explain why relying on PPE and training alone would be inadequate.
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Apply the hierarchy in order, not as a menu
Lifting risk
- Eliminate or mechanise the lift: vacuum lift assist, roller conveyor, scissor table, or palletising aid so the 12 kg tray is not manually transferred at nine lifts a minute. This removes the frequency and weight problem at source.
- Reduce the tray weight or the lift height and reach; redesign the workstation so the operative does not twist or reach across the conveyor.
- Organise work to limit continuous exposure: job rotation, planned micro-breaks, and a slower line speed consistent with safe handling.
- Train and supervise in the specific technique for these trays, not generic manual handling.
- Health surveillance and early reporting for the three workers with back problems and the two reporting numbness.
Noise risk
- Reduce at source: enclosure of the noisy section, dampers, maintenance of bearings, quieter conveyor components, or relocation of the noisy drive.
- Isolate noisy equipment from occupied areas or separate the task in time and space.
- Administrative controls: exposure time limits, rotation, signage, and hearing protection zones at 85 dB(A) and above.
- Hearing protection as a last resort, with fit testing and training, because protection depends on correct use all day.
PPE and training alone would be inadequate because they do not reduce the hazard at source, depend on individual behaviour, and leave the underlying exposure unchanged. The hierarchy requires the more effective controls first, with PPE supplementing them where residual risk remains.
3. The operations director asks whether the line can keep running while controls are introduced. Advise, with reference to ALARP and temporary measures.
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Decide on evidence, not on order-book pressure
The line need not be stopped automatically, but it cannot simply continue unchanged. The decision should be risk-based and recorded.
Immediate stop triggers. If there is an imminent risk of serious injury, or if the numbness reports suggest a rapidly worsening condition, the affected tasks should stop or be restricted until assessed. Numbness is not a diagnosis; it should trigger an occupational health review and a review of exposure.
Interim measures while permanent controls are engineered. These could include reducing conveyor speed, introducing rotation and breaks, providing lift assists for the heaviest trays, creating a hearing protection zone with mandatory protection and signage, and prioritising noise enclosure of the noisiest section. Each measure should have an owner and a deadline.
ALARP reasoning. The director should be advised that 'breaching customer orders' is a commercial consequence, not a safety justification. The test is whether risk has been reduced so far as is reasonably practicable. If a reasonably practicable measure exists, cost may be considered but must be weighed against the risk; it does not automatically justify inaction. The temporary controls must not become permanent by default.
Record and communicate. Document the interim risk level, the measures, the review date, and the residual risk accepted. Inform the workforce and consult representatives. Set a date for re-measurement and a further review.