The case for Bring Site Monitoring – Proactive, reactive or not at all?

From the state of the nation’s bring sites, it appears that the UK had a VERY merry Christmas and a very Happy New Year! With alcohol sales up 150% over the festive period, it’s no surprise that an estimated 13,350 tonnes of glass is recycled during December and January.

With the increase in recyclable material generally, much of this material is disposed of via our network of Bring Sites. It appears that we don’t give as much consideration for Health and Safety at these sites as perhaps we should do!? In the event of an accident at a Bring Site, who would be responsible?

Section 3 of the Health & Safety at Work Act 1974 places a duty on an employer to ensure as far as is reasonably practicable, that non-employees (Visitors, contractors, the public etc) are not exposed to risk of their health and safety.

The definition of ‘So Far as is reasonably practicable’ means the duty holder must assess the degree of risk against the sacrifice involved in introducing control measures to eliminate or control risk. This sacrifice can be measured in terms of financial cost, time and effort. Therefore, the Local Authority could be liable if they are servicing a Bring Site directly or via a contractor.

The non-exhaustive list below shows some of the more common health and safety risks associated with Bring Sites:

  • -Wear and tear of containers and their overall integrity over time
  • -Poorly-maintained sites attract further antisocial behaviour/criminal activity
  • -Sleeping in containers
  • -Unsecured containers
  • -Verbal abuse towards operational staff
  • -Manual handling of loose/hazardous/unknown/heavy waste types
  • -Broken glass
  • -Isolated environments in some remote areas
  • -Poor lighting conditions
  • -Trip hazards from loose material
  • -Rodent activity and associated disease

Each Bring Site could have additional risks, which is why it is important to assess these risks on a site by site basis. All Bring Site container operators will provide Risk Assessments and copies of Public Liability and Employee Liability Insurance certificates on request, which I would urge you to collate if you have not already done so.

The HSE have suggested that their HSG65 Model of Plan, Do, Check and Act is not being followed in its entirety as evidence from enforcement activity shows the ‘Check and Act’ elements are not being documented. These cover Supervision and Monitoring, which are both high on the HSE RADAR, so it makes sense to have an active monitoring regime in place for Bring Site inspections, which would be grounds for working towards that golden phrase, ‘ reasonably practicable’.