Good Practice Guide Ch 2 Health and Safety

CHAPTER 2 HEALTH & SAFETY

Table of contents

INTRODUCTION

Section I:

Roles & Responsibilities

Section II:

Law & Regulations

Section III:

Types of Operations

Section IV:

Port Area Hazards & Controls

Section V:

X-ray Scanners

Section VI:

Examining Containers

Section VII:

Clothing & Equipment

Section VIII:

Risk Assessment

Section X:

Forms/procedures

Annex

EUROPEAN COMMISSION GOOD PRACTICE GUIDE

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CHAPTER 2- HEALTH &SAFETY

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INTRODUCTION

Health and Safety are very important issues in the daily work. Knowing the possible risks and taking the appropriate action to reduce them should take a place within the daily work. This chapter will cover health & safety in all areas including dockside, quays, container parks and examination sheds where you as custom officer are likely to be working within the Port. Container parks and examination sheds outside of the port area are also covered in this chapter. The rules and regulations referring to health & safety differ per country. That is the reason that there are now specific rules are mentioned in this chapter. Please go to your own health & safety officers for specific information.


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Section I Roles & responsibilities Responsibilities for Health & Safety can be divided into individual, operator and managerial. These are laid down in law and failure to meet meet these responsibilities may leave an individual liable to criminal prosecution and/or civil action.

Individual As an individual you have a legal responsibility for your own and others safety at work. In general you can satisfy these legal requirements by adhering to laid down procedures, such procedures include: ◊

co-operating with any instruction given by the Department with regard to health and safety

◊

Departmental Good Practice Guides

◊

manufacturers’ instructions (for tools and equipment)

◊

safe working practices

◊

proper use, care and maintenance of Personal Protective Equipment (PPE), and to wear any provided

Operator Any person using or operating any tool or item of equipment must have received all of the relevant training and must adhere to manufacturer’ and departmental operating instructions. It is the individual’s responsibility to ensure that tools and equipment are inspected before use, are used properly, that faulty tools are not used and that any faults are reported as soon as possible.


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Managerial Managerial responsibilities are additional to those of the individual and operator, legally these additional responsibilities apply to anyone who has a managerial role and in general apply to the following areas: ◊

planning for safe working practice particularly when new working practices or equipment is introduced

◊

identifying hazards and assessing the risk

◊

identifying and implementing appropriate controls

◊

monitoring and reviewing the controls

◊

ensuring that staff have sufficient training, information and supervision to carry out their work safely

Managers also have a departmental responsibility to ensure that all accidents and dangerous occurrences are properly reported, to carry out investigations into such incidents, and to take steps to avoid any recurrence.

Duties and Responsibilities Team Member It is an Individuals responsibility to work safely - do not place yourself or others at risk by any act or omission. Do not undertake any task if you have not undergone appropriate training. Advise your team leader of any training needs. Do follow any Health & Safety instructions you are given. Do follow Good Practice Guides. Do use proper tools and equipment in any task. Do not use any tools or equipment other than properly approved and supplied. Do not use any equipment that you have not been trained to use. EUROPEAN COMMISSION GOOD PRACTICE GUIDE

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Do make sure you are trained to use any equipment properly Do ensure that Personal Protective Equipment (PPE) issued to you is appropriate. If it is supplied for a particular purpose you MUST use it. Keep PPE clean and well maintained and replace as necessary. Dirty gloves, overalls, High Visibility clothing etc. are hazards, do not use them. Do report accidents and dangerous occurrences and near misses. Make sure that you know the procedures for doing this. Do study the District Risk Assessment, and be aware of any controls. Do make sure that you know the duties and responsibilities of your managers. Do raise any new potential risks with your manager or colleagues Remember that a container port area is a very dangerous place and you should ensure that you never work alone.

Team Leaders Do carry out H&S assessments of all tasks, or ensure that a competent person does this. Seek advice if you are not sure. Do ensure that any task you undertake or direct has been assessed for Health & Safety risks. Do ensure that any staff working under your direction are properly equipped and trained for the task. Do ensure that safe working practices/Good Practice Guides are adhered to. Do make sure that tools and equipment are ALWAYS inspected before use Do ensure that any faulty tools or equipment are not used, and that faults are reported. Do arrange for proper PPE, tools, and equipment to be provided for staff and ensure that they receive the appropriate training before using them. Do arrange maintenance, replacements, repairs and re-training as required. EUROPEAN COMMISSION GOOD PRACTICE GUIDE

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Do ensure that all accidents, dangerous occurrences and near misses are properly reported. Carry out preliminary investigations, take appropriate action and recommend further action not in your control. Do liase with outside bodies (Dock Company, shipping companies etc.) on Health and Safety matters. Do ensure that Safe Systems of Work are adhered to in all tasks and in the use of any tools and equipment. Do co-operate with safety reps. Do observe your team to ensure they are following safe systems of work. Remember that a container port area is a very dangerous place and you should ensure that you never ask your staff to work alone. Functional Manager Do ensure proper training and equipment is provided for district tasks, and maintenance is carried out as required. Do ensure District Risk Assessments are monitored, reviewed and evaluated. Do provide assurance on health and safety systems Do ensure that there is adequate training and deployment of qualified First Aiders. Do encourage Health and Safety awareness among staff. Do liase with other departmental staff on H&S matters. Do ensure maintenance of adequate and relevant records i.e. assessments, training, incidents etc. Remember that a container port area is a very dangerous place and you should ensure that you never ask your staff to work alone.


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Resources Available for Help and Advice EXTERNAL Park/Quay Controller or Shed Foreman: Transit Sheds are not necessarily located within the Dock, they can also be found at remote locations i.e. industrial estates.

Custom officers should make initial contact with the controller requesting the sight of a container, the request is based on risk information or a tip-off etc. The Controller will then contact Custom when the container is ready for examination. The controller should be approached on arrival to ensure that they know you are there for evacuation purposes or to ensure that forklift drivers are aware of your presence. Custom officers should prepare the contents of the container for examination, but sometimes Custom officers checks the seals on the container first Port Emergency Services: The Port Emergency Services should only be notified if the cargo is suspicious or dangerous, i.e. it is leaking when you open it, or if there is a harmful substance around an area which needs to be handled during a search i.e. Caustic Soda packed around cigarettes.

INTERNAL Health and Safety Advisers (NB: each country will have its own system) Health and Safety Advisers is a group of advisers who can be contacted for Health & Safety advice. Your Health & Safety matters are resolved locally, but if you need further advice you can call, if available, a helpline.

During a physical check it is possible that you encounter certain goods that can be a danger for Health & Safety. A few examples: Firearms and Explosives. If a firearm or parts of a firearm, explosives etc. are detected, you should preserve the scene and seek advice. You must always consider your Health & Safety and that of anyone else first, whilst at the same time preserving forensic integrity if this is possible.


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CITES. If live plants and/or animals are discovered you should act promptly as there may be a high mortality rate for any species taken from its natural habitat and the stress of travel can be an added factor. You should always should always think about your own and your your colleagues Health and Safety. There may may be the danger of disease or the risk of sustaining a venomous bite or sting, even the container used to house the creature/plant that you are examining may pose a Health and Safety risk! Environmentally dangerous goods. These goods are sometimes hard to recognise. If you find any goods that smell bad, are labelled as dangerous etc., barrels etc. witch are not declared and no labels, can be very dangerous. You should preserve the scene and seek advice of a specialist. You must always consider your Health & Safety and that of anyone else first. Radiation. If there is any sign of radiation, you should preserve the scene and seek advice of a specialist. You must always consider your Health & Safety and that of anyone else first.


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Resources Available for Help and Advice Useful Contacts

Name

Telephone No.

Address

Park/Quay Controller or Shed Foreman Report to above regarding any duties to be undertaken.

Port Emergency Services Control Office local numbers - Fire, Ambulance, Dangerous Goods, Police etc.

Health & Safety Adviser

Firearms and Explosives officers CITES Liaison Officer

Radiation Protection Officer and Supervisors Port Health

H&S Executive

Other Contacts


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Section II Law & regulations You will need to be aware of the departmental guidance that you will be working to on a daily basis. You should familiarise familiarise yourself with the good practice guide Health & Safety. If there is further departmental guidance available should you require it, you should discuss where to find further information with your trainer/teamleader/mentor.

Section III Types of operations As part of training you should be taken on a tour to your local port, this will give you an idea about the type of areas that you will need to be aware of in your daily duties at the Port. Before you embark embark on your tour please read the following guide to the general operations that are carried out on a Port. You should be aware that there are many different health and safety issues around each area and the various types types of cargo. You should also note that whilst you are on the tour you MUST remain with your trainer/mentor and adhere to all Health & Safety instructions.

Quays

Various types of bulk cargo including containers and pallets, are discharged and moved to and from ships. Some Ports have Quays, which deal with loose cargo such as scrap metal metal or grain. The grain is pumped from the ship directly into silo’s permanently located on the Quayside, where scrap metal is being moved there is a danger of loose particles falling from the ‘grabber’.


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Parks

Operations involved in the parks include the storage and movement of; containers which are; pending clearance (import and export), waiting to be loaded onto a ship, waiting to be produced for exam or waiting for devanning. Other operations include the storage and movement of trailers, some ports have parks, which deal with the storage and movement of timber. Sheds

Operations carried out in the sheds include the examination and devanning of containers, some Ports have cold store facilities for examining frozen or fresh foodstuffs. Pallets are also examined and used in the devanning procedures. Examinations carried out in the sheds may also involve the movement of various types of equipment. Your trainer or mentor should provide you with a map which shows the Quays, Parks and Shed areas highlighted, you will need to take your copy of the map with you to familiarise yourself with the layout of your local Port/Dock.


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Section IV Port area hazards & controls Throughout this module the terms ‘hazard’ and ‘risk’ will be used, the definition for each of these terms are as follows: Hazard

anything with the potential to cause harm or damage

Risk

the potential for a hazard to cause you harm if it is ignored or inadequate precautions are taken

On returning from the tour you good mark the map, with highlighter pens, showing where each of the hazards from the following list are located. You should discuss the tour and map with your trainer/mentor, to find out if any hazards have been missed. You should note that this list is not exhaustive, depending on your own Port/Dock, there may be other hazards not listed here.

Quayside Gantry Cranes ◊

the drivers visibility may be poor or restricted

◊

there may be a lot of movement around these cranes

◊

drop areas for the containers being off loaded

◊

temporarily stored on quayside, may be unlit and unmarked

Hatches


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All Access Points and Blind Spots ◊

fast moving traffic across path

◊

poor or restricted visibility

◊

noisy

Container Stacks and Lines ◊

to be avoided if possible only go under supervision

◊

restricted visibility

◊

lots of moving traffic

◊

operators restricted visibility

Straddle Carriers ◊


◊

speed and size

◊

noisy

◊

lots of traffic

Rail Lines


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Turning Points ◊

rubber tyre gantry very restricted visibility

Turning Areas ◊

speed

◊

not necessarily done in specified areas - watch out for this in all areas of the port

◊

fast moving traffic

◊

noisy

◊

drivers restricted visibility

All Vehicles

Dangerous Goods Areas ◊

should be clearly marked hazardous cargo

◊

should be restricted access

◊

fast moving traffic

◊


◊

noisy and busy

Exit Points

Examining Bays ◊

reversing traffic

◊

straddle movements

◊

container examination

◊

forklifts


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Lorry Lines ◊

moving traffic

◊

reversing

◊


Maffi and Skeleton Parks ◊

busy moving traffic

◊


◊

fast

◊

carrying loads so restricted visibility

◊

can be quiet (electric)

◊

insecure cargo - danger of falling

Forklifts

Straddle Parking Areas ◊

busy

◊

noisy

◊


◊

drivers finishing their shift (not normal areas to go into)

◊

can be very slippery

General Hazards ◊

uneven surfaces

◊

wet / slippery surfaces

◊

trailing ropes

◊

obstructions EUROPEAN COMMISSION GOOD PRACTICE GUIDE

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Controls

Following on from the previous part of this section, where you were asked to highlight the hazards and risks, you will now be asked to supply the controls which you can use to minimise the risks to each of the following hazards: ◊

moving traffic

◊

poor or restricted visibility

◊

noise.

List the controls that you think might be appropriate to each of the hazards on the following page. Write your your answers in the space provided.

Hazards

Control

Moving traffic ◊

adhere to approved routes and parking areas.

◊

keep to safe walkways

◊

adhere to all normal driving laws and follow port procedures.

◊

always report your presence if appropriate.

◊

use safe walkways wherever possible

◊

observe and use proper sight and sound signals e.g. flashing lights and bells.

◊

awareness of limitations of vehicle types (speed, visibility, manoeuvring).

◊

be alert at all times.


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Poor or restricted visibility ◊

all of the above controls for moving traffic.

◊

always wear hi-visibility clothing.

◊

be aware of specific hazards in all of the following conditions - night, fog, rain, snow and take all necessary precautions make sure you know the area and route that you will be taking.

◊

Noise ◊

make sure you wear the appropriate ear protection

◊

make sure that you learn important sound signals e.g. a crane moving


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Section V X-Ray scanners The use of X-ray scanners is getting more coming. Because health & safety instruction various per type of X-ray scanner type, it is necessary to check with your local management for specific instruction.

Section VI Examining containers & trailers On the following pages you will find some pictures of the containers and trailers that you may may come into daily contact with. Each picture includes a brief description of its structure, design and intended purpose. You should should take general precautions with any type of container, however as well as general hazards there are some specific hazards associated with some containers and trailers. Fumigated containers Before you enter a container! Some containers are fumigated with a toxic gas. This is no part of the cargo but is added to exterminate bugs etc. Containers under fumigation should carry a hazard warning sign but this is not always the case. If there is a hazard warning label on the container you should ask for a statement that the container is free of gas. If you discover any sign that a container is or has been under fumigation. Do not touch or remove any fumigation chemicals and keep well away from containers when fumigation operations are being carried out.


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The most used gases are: Sulphuric Fluoride Methyl bromide Phosphorous Hydroxide Formaldehyde This is a notice you may find danger.

SO2F2 CH3BR PH3 H2CO in a container, if you find it, you could be in


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CONTAINER /TRAILER TYPES

SPECIAL HAZARDS / RISKS

BULK CONTAINER Especially for dry bulk cargoes, e.g. malt Three manholes for filling in the roof of each container.

If loaded by top hatches, hatches, DO NOT OPEN THE DOORS

•

•

Risk of falling cargo

•

Oxygen depletion from cargo

•

Risk of collapse if it is not secured

•


•


FLAT CONTAINER Especially for heavy loads and over-width cargo. Strong bottom construction with fixed endwalls (which allow bracing, lashing and stacking).

HARDTOP CONTAINER Especially for heavy loads, overheight cargo, loading from above, e.g. by crane. The hardtop steel roof can be easily moved by handling gear.

HIGH CUBE CONTAINER Especially for light, voluminous cargo and overheight cargo

Manual Handling risk is increased by it’s height volume

•


•


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INSULATED CONTAINER Especially for cargo, which needs constant temperatures above or below freezing point. Temperature is controlled by ship’s/terminal’s cooling or clip-on-unit.

OPEN TOP CONTAINER Especially for: overheight cargo, loading from above, e.g. by crane loading from door side, e.g. with cargo hanging from overhead overhead tackle

PLATFORM Especially for heavy loads and over-sized cargo. Strong base construction.

REFRIGERATED CONTAINER Especially for cargo, which needs constant temperatures above or below freezing point

•

cold, wet slippery floor

•


•

roof not fixed

•

often bulk loaded cargo (grain etc.)

•

risk of falling cargo

•


•

Moving machinery parts, inside and out Cold wet and slippery surface Interior fittings hooks, racks Cold cargo Heavy doors Exhaust and other fumes Electricity hook up cables, points Diesel tank

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• • • • • • •



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TANK CONTAINER Especially for liquid chemicals for portable liquids (e.g. spirits). See Good Practice Guide for Dangerous Goods labels

hazardous cargo

•

previous cargo may have been hazardous

•

toxic fumes

•

VENTILATED CONTAINERS Especially for Cargo which needs ventilation. Natural ventilation is ensured by openings in the top and bottom longitudinal rails. rails. The labyrinth construction of these ventilation openings

•

cold, wet slippery floor

•


•

TRAILER Especially for transporting cargo. The sides of the trailer are not rigid.


-

The fact that ventilation is required may indicate that the cargo is hazardous

•

cold, wet, slippery floor

•

risk of falling cargo

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Controls

Now that you have identified some of the hazards, you should now consider what procedures or controls you should take in order to minimise the risks. Please write in the space provided, what you think the control are to the hazards listed on the following page. You should compare your answers with the answers provided after this task and discuss them with your trainer. You should also note that the list given is not exhaustive.


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Your answer should include the following, however you should be aware that this list is not exhaustive. Special hazards

Controls

Manual Handling ◊

proper assessment - task, load, working environment, individual capability

◊

minimise need for manual handling

◊

mechanical aids

◊

safe systems of work - planning, layout, etc.

◊

sufficient time/resources for task

◊

use of dock/operator labour where applicable

◊

training (Back Pack etc., Enhanced training as available)

◊

proper techniques

◊

PPE

◊

minimise distance and load (planning)

Door opening/closing ◊

use of Dock staff to open/close where applicable

◊

use of door checkstraps

◊

PPE

◊

extension bar for door handle if appropriate

Slippery and unclean floors or surfaces ◊

establish and maintain cleanliness routine

◊

report all spillage, hazards

◊

avoid the area if possible


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Specific Hazards

Controls

Poor Stowage ◊

checkstraps for door opening

◊

special assessment/safe system of work

◊

PPE

Adequate heating, lighting and ventilation ◊

maintenance regime, report deficiencies

◊

use of auxiliaries (lights, heaters, fans)

◊

PPE / thermal clothing if appropriate

Physical exam of crates, packages ◊

manual handling - proper techniques

◊

safe surface, proper height/ suitable environment

◊

PPE especially gloves, eye protection

◊

proper use of tools (knives, bars, etc.)

◊

always use the proper tool for the job

◊

only use officially provided tools

◊

familiarity with and understanding of equipment its uses and limitations

◊

follow manufacturer/supplier instructions

◊

always inspect before use

◊

never use faulty or damaged tools - report and obtain replacements

◊

proper planning

Use of tools


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Specific Hazards

Controls

Working Platforms and Raised Bays ◊

approved access points only

◊

ensure locked/stable

◊

NEVER work underneath

◊

authorised operators only

◊

PPE

◊

be aware of risk of trips/falls

◊

use dock labour if possible

◊

guard against moving traffic/collisions

Fork Lift Movements ◊

know and stick to safe system of work

◊

proper planning

◊

sight & sound signals

◊

warning signs

◊

communication

Space restrictions ◊

proper planning, safe systems of work

◊

remove possible obstructions

◊

PPE


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The following is a list of procedures or controls that you should take to minimise the risk to any of the general hazards that may be involved the physical examination of containers or trailers (including underside & top). ◊

DO NOT be tempted to examine a container outside of an approved site

◊

DO NOT walk or climb on the top (unless it is a Tanktainer and a secure walkway is provided)

◊

Use mobile ladders that are provided

◊

Ensure that fixed or overhead facilities are in a safe condition

◊

Beware of loose objects, debris or dust on the top of the container or it’s cargo, use PPE including eye protection

◊

Remember to use PPE!!

◊

Exterior fittings on reefer units etc. are to be used by trained personnel only

◊

Beware of moving parts and electricity e.g. fans

◊

Remember the proper use of tools

◊

Never work underneath a container unless it is secured on a frame specifically provided for the purpose

◊

Never walk or work under container suspended by a straddle carrier or fork lift

◊

Be aware of various types of fixture and fittings, especially in reefers e.g. fans, ducts, hooks

◊

Be aware of slippery floors and the cold, check the flooring for security and safety

◊

Be aware of any residues, even in empty containers

◊

Be aware of sharp, s harp, raised, abrasive objects and surfaces

◊

Ensure there is adequate light and ventilation

◊

Carry out as much research as possible to identify the cargo and take the necessary precautions EUROPEAN COMMISSION GOOD PRACTICE GUIDE

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H&S Foodstuffs Examination

Be aware that there are particular hazards and concerns in examining any raw or processed foodstuffs. Many raw farm products imported to the EU will come from Third World countries, where the hygiene and safety regimes are not the same as those applied in the EU. Processed, packaged goods, ready for retail sale, should be treated as a final product, and any packages opened for examination should be properly destroyed. Raw, unprocessed goods such as grains and pulses are likely or possibly to have been treated with insecticides or other chemicals prior to shipment. They may be infested by insects such as weevils or mites, especially if they have not been treated, or they may be affected by rot which could induce fungal growth. You may also come across bulk importations (tanks, containers etc) of products destined for the human or animal animal food industry. These tanks are likely to be sealed, and breakage of the seal may render the product “condemned” or commercially worthless. In such circumstances the Department may be liable for substantial compensation claims. You should ALWAYS consider examination of unprocessed foodstuffs as potentially hazardous, for the reasons laid out below; ◊

some may be allergens or respiratory sensitisors

◊

some may be intrinsically poisonous

◊

Some may be infested by; insects, reptiles, crop diseases, such as weevils, mites or Colorado Beetle, snakes, sometimes found in esparto grass, bananas or ergot (damp grain or pulses)

◊

“ethnic foods” may be encountered, particularly from some African, Indian or Caribbean areas. BE AWARE AWARE that these are likely to be loaded in recycled boxes and crates, and lacking uniformity, may be unstable within the container

This list is not exhaustive, and you should enquire about local traffic and trends. EUROPEAN COMMISSION GOOD PRACTICE GUIDE

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Custom officers should also be aware that we have a duty to the general public, the trade and to our employer. When foodstuffs are selected for examination, care should be taken to avoid any contamination, or cross-contamination. If necessary, disposable outer clothing should be available. If there is any doubt, err on the side of caution. Seek advice from experienced colleagues, Port Health etc. before proceeding with examination.


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Section VII Clothing and equipment Reducing risks by adhering to health and safety procedures also involves wearing and maintaining all protective clothing and equipment which is provided, you should ensure that you use only those items of clothing, tools and equipment provided by Customs & Excise. You must also make sure that you comply with the law and regulations involved in using PPE by: ◊

following the instructions given with each item

◊

keeping each item clean and well maintained, using recommended cleaning advice

◊

if the use by date has expired, do not use

◊

only using the item as recommended by the manufacturer

◊

using only the items provided, do not use personal items

◊

ensuring the equipment fits you properly

A few examples of special clothing you could use.


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Some examples of tool you could use

The correct equipment makes your job easier to carry out.


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Section VIII Risk assessment Prior to each examination a local risk assessment should be undertaken to decide how the examination should be conducted, or whether the examination should take place at all. However, It is not the aim of this section to show you how to complete a risk assessment form. It gives you an example of a risk assessment. For example, an empty tank container may have previously contained a hazardous substance. Before attempting attempting to conduct an examination any risks should be identified by researching it’s history to find out what cargo was previously contained within it. If research is not possible extra caution, using all possible controls, should be taken prior to the examination. On the following page you will find an example of a risk assessment form, however you should be aware that these forms are subject to local variations. You should ask your health & Safety officer for the, in your area used, specific risk assessment form and procedure.

Section IX Health and safety forms As well as understanding how to identify risks, using controls and safe systems of working to minimise the risks, you also need to be aware of the procedures you should use in the unlikely event of an accident or near miss occurring. The Line Manager/team leader and the individual each have responsibilities for completing the forms and sending them to the appropriate department. Ask you own Health & Safety officer or your team leader how the proper procedure works.


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RISK ASSESSMENT FORM Date of record creation Vessel Container No.

(page 1)

Case Officer Goods

Origin

Comments/ Reasons for interest

Health & Safety Assessment Assessment Officer: Team

Safety Assessments

External

Is area around Container/Trailer

FREE OF TRAFFIC ADEQUATELY LIT FREE FROM OVERHEAD HAZARD ANY HAZARD LABELS

YES / NO YES / NO YES / NO

SECURE STABLE ADEQUATELY VENTILATED Type

YES / NO

Safety Assessment:

YES / NO YES / NO YES / NO

Internal

Cargo Description: ……………………………………………………………………………… ……………………………………………………………………………………………………

Cargo Hazard Assessment BAGS SACKS DRUMS

CARTONS BARRELS CRATES

PALLETISED MACHINERY LOOSE LOADED

OTHER Hazards

Glass Dirty Infested Bulky

IS LOAD STABLE (UNLIKELY TO MOVE) YES / NO if no, reason: Chemicals Chemical s FRAGILE Flammable Heavy Slippery Wet Unwieldy Sharp Corners/ edges

Other

(Page 2) EUROPEAN COMMISSION GOOD PRACTICE GUIDE

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IS ALL REQUIRED SAFETY EQUIPMENT/CLOTHING ISSUED OR AVAILABLE YES / NO IF NO, REASON:

Handling equipment required / desirable / used:

X-ray Van Forklift Truck Other Other Comments / Conclusions:


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Good Practice Guide Ch 2 Health and Safety

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