Risk assessment that gets used, not just filed

In many factories the risk assessment is a thick file, produced by an external prevention and protection service, signed and put in a cabinet until the next ITM (Labour Inspectorate) visit. The press operator does not know what it says about his press, and the shift leader has never opened it. When a line is moved or a tool is changed, the file stays as it was.

The law does not ask for a thick file. It asks for an assessment that describes the real risks and leads to measures. And if you used an external service, the responsibility is still yours: Law 319/2006, art. 6(2), says an employer using external services “is not exempted from its responsibilities”.

What the law requires, in short

Art. 12(1)(a) of Law 319/2006 obliges the employer “to carry out and hold a risk assessment”. The methodological norms in Government Decision (HG) 1425/2006 (art. 15(1), point 1) set the level: identification of hazards and assessment of risks for each component of the work system, meaning the person doing the work, the task, the equipment and the working environment, by workplace and workstation.

On the basis of the assessment, measures are set for each workplace or workstation and the prevention and protection plan is drawn up (art. 46 of the same norms). The plan is submitted to workers or their representatives for review. The required level is therefore the workstation, not the factory, and the assessment has to connect to concrete measures.

At the workstation, with the people who do the job

The person who knows best what happens at a workstation is the operator who has worked there for two years, not the consultant who walked through the hall once. Do the assessment at the workstation, with the operator, the shift leader and someone from maintenance.

An order that works:

1. Break the work at the workstation into tasks, as they are really done, not as the job description says.
2. For each task, ask what can injure someone, how, and how often the person is exposed.
3. Look at the measures that already exist and whether they are used. A guard taken off and leaned against the wall is not a measure.
4. Write down the new measures, with an owner and a deadline.
5. Show the result to the operators on all shifts, not only the one who took part.

The scoring method (matrix, points, another grid) matters less than getting the task list right. A risk scored wrongly gets corrected at the next revision. A task missing from the list never does.

The tasks that are not in the job description

Most assessments describe normal production well and skip everything else: maintenance, cleaning, changeover, adjustments, clearing a jam, trial runs after repair. That is exactly where guards are open, the machine runs in setup mode, and people enter zones they never enter during production. EU-OSHA data for several European countries show that in 2006 around 10-15% of fatal accidents were linked to maintenance operations.

The question that brings out the real risk is simple: “What do you do when it jams?” The honest answer often differs from the instruction. If a jam is cleared by hand, with the machine only stopped from the control panel and not locked out and tagged out, that has to appear in the assessment, even if it is unpleasant to write down.

For each piece of equipment, check whether the assessment covers:

• daily cleaning and end-of-week cleaning;
• format or tool changeover;
• clearing jams, including the frequent ones that operators deal with on their own;
• maintenance work and lockout/tagout of energy sources (electrical, pneumatic, hydraulic, residual energy);
• work by external contractors on the equipment.

The order of measures

Art. 7(3) of Law 319/2006 sets out the general principles of prevention, among them avoiding risks, combating them at source, replacing what is dangerous, and giving “priority” to collective protective measures over individual ones. In practice the order is: eliminate the hazard, replace it with something less dangerous, separate the person from the hazard by technical means, organise the work, and only at the end issue personal protective equipment (PPE).

One reliable sign of an assessment written at a desk: the measures column says “training” and “wear PPE” almost everywhere. Take a packing machine, as an example, that jams several times per shift while the operator reaches in behind the film. Gloves solve nothing. The real measures are removing the cause of the infeed jams, a clearing access that does not require entering the danger zone, an interlocked guard, and a short lockout procedure that the operator can apply alone.

Link to instructions and training

An assessment that does not reach the instructions and the training stays on paper. The norms (art. 15(1), point 3) require the employer’s own instructions to be drawn up, and Law 319/2006 (art. 20) requires training on hiring, on change of workplace, when equipment is introduced or modified, and when a new technology or procedure is introduced.

Link them explicitly. Every “procedure” measure in the assessment points to the specific instruction, by its code. Every work instruction states which risk it covers. Workplace training starts from the risks of the workstation, not from a general presentation on occupational health and safety (SSM).

When to revise it

The norms in HG 1425/2006 (art. 15(3)) require the assessment to be revised at least when technology, equipment, substances or workstation layout change, after an event occurs, when omitted or new risks are found, when the workstation is used by a worker from a group sensitive to specific risks, and when special work is carried out.

To make it actually happen, build the revision into processes that already exist. The form for a technical change or a machine relocation has a box “risk assessment updated”, ticked before start-up. Every near miss reported by an operator is compared with the workstation assessment. If the situation does not appear there, you have an omitted risk, which is itself a reason to revise.

At the workstation, on one page

The full file stays for inspections and revisions. At the workstation, put up one page: the main risks of the workstation, the measures the operator applies, what is forbidden, the lockout points and the protective equipment needed. Write it in the words used on the floor, with a photo of the machine if that helps.

Verification is done on the shop floor. Ask an operator what risks the workstation has and what to do at a jam. If the answer matches the page, the assessment is being used.

What to measure

• percentage of workstations where the assessment was redone with the operators;
• how many measures are open and how many are past their deadline;
• share of measures that are only “training” or “PPE”;
• how many near misses led to a revision;
• how many technical changes started without an updated assessment.

If you have a workstation sheet that is really used at your plant, bring it to the WhatsApp group “HSE (Health, Safety & Environment)”.