Wipes and gels still are not suitable for RCVs – unless an operator can prove otherwise
An “interim” enforcement position, introduced in 2012 (but not yet superseded), still maintains that soap and water hand washing sinks should be fitted to refuse collection vehicles (RCVs), according to the Health and Safety Executive (HSE).
The regulations were updated in response to a raft of employers and organisations beginning to rely increasingly on hand wipes, gloves and gels for operators of vehicles in their fleets, despite this being perceived by HSE as challenging existing guidance.
The Interim enforcement position: provision of hand wash basins on refuse collection vehicles (RCVs), although introduced as far back as 2012, still has Open Government Status of “Fully Open”.
It refers to guidance sheets Waste 04 and Waste 15:-
“These require wash basins to be fitted unless it can be demonstrated there is a minimal health risk.”
Applicable to a variety of industries
HSE’s position regarding hand washing basins for motor vehicles, which is describes as “consistent”, refers to a number of sectors, not just recycling and waste collection organisations. The entertainments industry and agriculture are two others that are specifically named.
The Executive is concerned that parallels are erroneously being drawn from other areas.
“It is based on the knowledge that while wipes and/or gels are used in the healthcare sector there is not necessarily any comparable evidence that would support their use in other sectors as the type, range and degree of contamination may be significantly different.”
Research was due to be commissioned in order for HSE to be able to provide updated guidance based on current scientific recommendations regarding specific industries. That, unfortunately does not yet seem to have yet materialised.
Guidance for inspectors
Under the “Action” section of the regulations, there are a number of guidelines for inspectors. These include:-
- Formal enforcement action due to a lack of hand washing sinks should not take place until new evidence is available says the HSE – but “current advice remains for provision of hand wash basins on RCVs as set out in Guidance notes Waste 04 and Waste 15.”
- “HSE’s view is that fitting a wash basin unit to an RCV is reasonably practicable and proportionate.”
- And that HSE is “unaware of any evidence” that verifies gels and wipes as being suitable to remove contaminants that are likely to be encountered in the aforementioned situations and sectors.
Interim enforcement position: provision of hand wash basins on refuse collection vehicles (RCVs) »
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