Following the death of a UK laundry operative in a tunnel washer in 2003, and the resulting prosecution, the Health and Safety Executive (HSE) began to raise concerns about the safe operation of tunnel washers.

In particular the HSE wanted to reverse the industry’s traditional acceptance of automatic entry in the event of a blockage.

It was clear the HSE had been considering a total ban on entry, except perhaps by specially trained and equipped “unblock” teams set up by, for example, machine suppliers.

In response the Textile Services Association undertook on behalf of the industry to produce a code of practice for safe working.

The code would seek to replace the practice of automatic entry with a hierarchy of risk management, principally aimed at avoiding blockage and supported by education and training.

Moreover, operators must implement the practice through hazard and risk assessments and the development of operational Safe Systems of Work (SSoWs).

To develop the code, the TSA’s technical and standards committee, which has a remit for health and safety issues, set up a working group of processors and machinery suppliers.

The working group considered that while the idea of special “unblock teams” might be a necessary option for some small or independent workers with limited resources, limiting entry to these teams as a general principle would be too restrictive a solution, since the logistics of the situation could lead to an unacceptable loss of productivity.

Members of the group prepared a working draft. At the same time, the committee chairman, Richard Newton of Initial, led discussions with the HSE’s Steve Kay.

The HSE insisted that the code must address its chief concerns (see box on page xx).

However, the HSE agreed to consider (and advise on) a draft code of practice in preparation to decide whether its concerns could be satisfactorily met.

The bottom line would be demonstrable implementation by the industry and a measurable reduction in incidents and accidents.

Meanwhile the working group agreed that the first draft contained the necessary information, or raised situations requiring innovative solutions. Using the HSE’s list of requirements work then began on restructuring and reorganisation of the working draft.

This started by defining what would constitute entry and this is shown in the title picture.

After some small, but important changes in emphasis, the document gained the approval of the HSE.

The key elements detailing the code’s approach are:

• education and training in tunnel washer operation and particularly in avoidance and early detection of blockages

• education and training in hazard/risk assessment and the development of safe systems of work (SSoWs)

• development of a SSoW for unblocking WITHOUT entry

• development of a SSoW for unblocking WITH entry, and

•annexes with blank forms for records and procedures.

The code makes particular distinction between training and education and recognises that operators and managers must not only know how equipment is intended to function, but vitally in hazardous situations and emergencies to understand why, so that correct decisions can be made in unforeseen circumstances.

After carrying out hazard and risk analysis for each machine and the specific conditions on each site, the processor must consider the available local resources, such as personnel, equipment or money, and decide what activities may be safely implemented and carried out (see diagram).

If the decision is made to contract out the “entry” or “non-entry” activities the processor must remember that the company is still responsible for contractors working on site and must ensure that they have safe systems of work in place.

A copy of the code has been sent to TSA members and to UK’s Society of Hospital Linen Service and Laundry Managers. It is also available on the TSA’s website.

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HSE requirements

1 Removal of the traditional culture of automatic entry
2 Emphasis on avoidance of blockages as the best practice
3 Incorporation of a hierarchy of hazard/risk assessment
4 Provision of information for the development of Safe Systems of Work (SSoWs)
5 Removal of any notion of ‘entry as a last resort’
6 Objective evidence that the procedural hierarchy(2, 3 & 4) has been followed
7 Review of fitness/competence of trained staff to make entry
8 Evidence that the code has resulted in much lower frequency of entry

Tunnel washer entry Title pic
DEFINITION Diagram showing how entry into a tunnel washer is defined.

Choices for the processor
CHOICES: The diagram shows what the laundry must do and the options for contracting out part of the necessary activity