Control options

You must now decide how to

eliminate or reduce the risks identified by your assessments and legislative

and industry standards are likely to have a bearing on your selection of the

appropriate control measures. There are a number of ways to control risks but

legislation may, and often does, require you to adopt a hierarchical approach

when deciding which control option to use. In other words you must consider the

best (safest) option first and if that is not reasonably practicable you should

consider the next best - and so on. Once again, if other pig producers are

controlling specific risks by using control measures higher up the hierarchical

scale than you are, you should review your situation.

Some aspects of health and safety are governed by regulations that state precisely what controls measures must be applied. You must be aware of any that apply to you (see step 2) and must obviously comply.

For other aspects of health and safety several regulations may apply which have their own specific hierarchy of control measures to be considered. It is not possible to list all of the variations here but the general principles are explained below. Control measures are divided into two categories: physical controls, which are directed against the hazard itself, and personal controls, which apply to the people at risk of exposure to the hazard.

Physical Controls
These are usually the most effective and should be considered first. In order of priority they are:

• Remove.
• Replace.
• Restrict.
• Reduce.

Remove the hazard completely by eliminating the task or making design or organisational changes. This is the most effective control measure. For example:

• Mechanise an activity to eliminate manual handling.
• Re-design a loading bay to avoid having to reverse vehicles.
• Repair floors to eliminate the trip hazard.
• Replace a flammable solvent based paint with a non-flammable water based paint.
• Replace an electric pressure washer with a diesel powered one to eliminate the risk of electric shock.
• Replace a diesel powered pressure washer with an electric one to eliminate hazardous exhaust fumes.

This last example is to illustrate the point that eliminating one hazard may mean that a different one will have to be assessed.

Replace the hazard with one that is less hazardous. This is different from removal (and less effective) as the same type of hazard is still present but the likelihood of an event or its consequences are reduced. For example:

• Replace a disinfectant that is highly caustic to skin and eyes with one that is only a mild irritant.
• Replace a highly flammable solvent based paint with one that is less flammable.
• Replace an aggressive sow with one that is docile.

Restrict access to the hazard by physical means. For example:

• Put guards on dangerous parts of machinery.
• Put barriers around hazards such as machinery and slurry pit openings.
• Put guard rails on raised gantries.
• Fit an automatic lock out so that the auger cannot be accessed until it has stopped rotating.

Reduce the level of the hazard or the duration of exposure to it by physical means. For example:

• Use dust extracted straw for bedding to reduce dust levels.
• Fit a residual current device to electrical equipment.
• Store sacks of feed closer to the points of use to reduce the amount of carrying involved.
• Fit baffles or box-in noisy machinery (feed milling and bagging plant) to reduce the level of noise.

Personal controls
These will be required in all cases in addition to the physical controls. Such personal controls may include:

• Training.
• Instructions.
• Information.
• Supervision.
• Permits to work.
• Protective devices.
• Personal protective equipment.

Training, instructions and information - must be provided for all employees by law in most countries but many employers are unsure of the distinction between the three terms.

Training can be considered to have been sufficient once a person is judged to be competent to perform a task safely without supervision.

Instructions may be written or verbal and usually consists of a list of the steps to take to complete a task (i.e. work instructions) or a statement that a specific control must be implemented (e.g. switch off the power before opening the cover of the auger).

Information must be given regarding the hazards and risks that the employees may be exposed to in an area of the pig farm or when performing particular tasks. For example the nature of any hazardous chemicals involved (caustic, irritant, toxic, etc.), how the chemicals can cause harm (by ingestion, inhalation, skin contact, etc.), what level of risk is associated with the chemicals in particular areas or situations, how to prevent or minimise exposure to them and what to do in the event of accidental exposure.

Employees must also be provided with information regarding accident, first aid, fire and emergency procedures.

When assessing risks and evaluating control measures the existing standards of employee training, instruction and information must be considered.

Supervision - of all new employees and of existing employees undertaking new tasks must be carried out and must be sufficient for the employer to determine whether the procedures are always performed safely, or whether additional training, instructions, information and supervision is needed.

Permits to work - are documents that must be obtained by an employee or contractor before certain works can be carried out. The permit must state that the necessary controls have been implemented and that it is safe to proceed with the work. In many countries it is a legal obligation to operate a permit to work system for certain activities. You must check how your regulations apply to you.

Even if it is not a legal requirement it is sensible to operate your own permit to work systems for high risk activities. These need not necessarily be written documents but could include, for example, a stipulation in the work instructions that the employee must obtain permission before starting a given job so that somebody is aware that the activity is about to take place and can implement the appropriate controls or simply be standing by e.g. fumigation using formalin. Other situations where such a permit system may be required are high voltage electrical work and entry into confined spaces e.g. slurry pits and feed silos.

Protective devices - can be used by a person to reduce the likelihood of a harmful event. An example is the use of a pig board.

Personal protective equipment (PPE) - includes such items as ear defenders, hard hats, dust masks, respirators, eye shields, gloves, boots, coveralls, waterproof aprons and washing facilities.

Coveralls, boots and gloves are obviously essential items for pig farmers and should be used routinely which they generally are. Other items of PPE are often used inappropriately, incorrectly or insufficiently.

Each situation needs to be carefully assessed. The important points to consider are:

• Legislation usually demands that PPE must be the last control option and should only be used if exposure to hazards cannot be controlled by any other reasonably practicable means.
• PPE can itself be a hazard. Dust masks for example make breathing laboured and can put unnecessary strain on the heart and lungs. Ear plugs may mean that audible safety warnings such as fire alarms are less effective.
• The item of PPE used must be appropriate for the level and type of hazard. Nuisance dust masks afford little protection. A mask that is adequate for general piggery dust is unlikely to be adequate for dust that could contain antibiotics (medicated feed). Different types of mask will be required for aqueous mists (e.g. from pressure washers), slurry gases and welding fumes - all common hazards. Ear plugs and ear defenders come in grades appropriate for the level and type of noise.
• PPE can be used as a stop gap to reduce a known risk until it is reasonably practicable to implement a more effective control.
• Only use PPE that has official approval (all PPE in Europe must be CE marked).
• PPE can lead to a false sense of security. Employees must be instructed to continue to take due care.
• PPE is ineffective and possibly hazardous if badly fitted. Dust masks and ear plugs must be close fitting.
• Oversize gloves can result in clumsy handling of hazards. Oversize boots are a potential trip hazard.
• PPE is ineffective and possibly hazardous if damaged, dirty or worn out. Employees must be instructed in the use and care of PPE.

Once you have considered the control options you can complete the last two columns on your assessment record sheets i.e.:

11. What measures will be implemented to control the risk?
Specify the physical and personal controls you think are appropriate.

12. What management procedures are needed to ensure the controls are maintained?
This section should specify, what if anything, is needed in terms of a staff training programme, spot checks. machinery, service contracts, health surveillance schemes, assigning responsibilities, safety audit and review systems, etc.