Manufacturing & Engineering UK-wide

Basic metal manufacturer: compliance checklist

Use this checklist to confirm your basic-metal manufacturing business (SIC division 24) meets its obligations before a production campaign. Work through the universal high-hazard items every producer shares — including the environmental, major-accident and, where it applies, nuclear gateways — then the section for placing products on the market. If you answer no to any item, follow the linked guide before you proceed.

Guide summary

Use this checklist before starting a production campaign. Answer yes or no to each item. If you answer no, follow the linked guidance. You must complete high-hazard risk assessments, control metal fume and silica exposure, zone hazardous areas, inspect equipment, and hold an environmental permit.

  • Write high-hazard risk assessments for molten metal, hot work, plant, and gases
  • Assess and control metal fume and silica exposure
  • Zone hazardous areas under DSEAR and use compliant equipment
  • Inspect work equipment under PUWER, PSSR, and LOLER
  • Assess and reduce manual handling risks for billets, ingots, coils
  • Carry out a fire risk assessment for your site
  • Hold employers' liability insurance of at least £5 million
  • Hold an environmental permit from your nation's regulator
  • Permit radioactive sources and monitor incoming scrap
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Related guides in Health & Safety

Use this checklist to confirm your basic-metal manufacturing business meets its obligations before a production campaign. Work through each item and answer yes or no. If you answer no, follow the linked guide before you proceed.

Workplace health and safety is enforced by the Health and Safety Executive in Great Britain and by HSENI in Northern Ireland. Environmental permitting and major-accident control name the body for your nation. Product conformity is a Great Britain market regime — UKCA is the GB mark and CE marking also continues to be accepted on the GB market. If you supply Northern Ireland, check the position separately, because NI follows EU product rules under the Windsor Framework. Each section names the body that applies.

Section 1 — Every basic-metal producer

These high-hazard workplace, environmental and registration duties apply to every producer, whatever you melt, cast, roll or refine. Confirm each one before you start production.

  1. 1

    Have you written your high-hazard risk assessments and put safe systems of work in place?

    Your general duty under the Health and Safety at Work etc. Act 1974 is to ensure, so far as is reasonably practicable, the health, safety and welfare of your people. Risk-assess molten-metal handling, hot work, heavy plant and process gases, and put safe systems of work, training and supervision in place. If not, follow "Set up and run a safe metal production plant".

  2. 2

    Have you assessed and controlled exposure to metal fume and silica?

    COSHH requires local exhaust ventilation, RPE, exposure monitoring and health surveillance for metal fume (manganese, hexavalent chromium, nickel, lead), respirable crystalline silica from foundry sand and acid mists. If not, follow "Set up and run a safe metal production plant".

  3. 3

    Have you carried out your DSEAR assessment and zoned hazardous areas?

    Molten-metal/water explosions, flammable process gases (blast-furnace and coke-oven gas, hydrogen, acetylene) and combustible metal dusts must be assessed, with hazardous areas classified into zones and compliant equipment selected.

  4. 4

    Is your work equipment safe, maintained and inspected under PUWER?

    Furnaces, ladles, rolling mills, presses, cranes and casting plant must be guarded and maintained, with pressure plant under PSSR 2000 and lifting equipment under LOLER 1998.

  5. 5

    Have you assessed and controlled manual handling?

    Billets, ingots, coils, castings and moulds must be handled with the risk eliminated or reduced so far as reasonably practicable, with lifting aids where needed.

  6. 6

    Have you carried out your fire risk assessment?

    Hot processes, flammable gases and combustible metal dusts make fire a serious risk. Assess it under the fire-safety regime for your nation and maintain your precautions.

  7. 7

    Do you hold employers' liability insurance and meet your equality and data duties?

    Hold at least £5 million of cover once you employ anyone. Do not discriminate under the Equality Act 2010 (or separate NI equality law enforced by the ECNI). Comply with the UK GDPR and Data Protection Act 2018, registering with the ICO unless exempt.

  8. 8

    Do you hold the environmental permit your installation needs?

    Integrated works, furnaces and foundries above the thresholds need a Part A or Part B permit from your environmental regulator (Environment Agency, NRW, SEPA or NIEA), covering emissions to air, water and land.

  9. 9

    Have you permitted radioactive sources and contaminated-scrap monitoring?

    Sealed sources in nucleonic gauges and monitoring of incoming scrap for radioactive contamination generally need a radioactive-substances permit from your environmental regulator.

  10. 10

    Have you assessed your COMAH tier and put the controls in place?

    If your holdings of process gases or other named dangerous substances exceed the thresholds, notify the Competent Authority and put your major-accident prevention policy and (upper-tier) safety report and emergency plan in place.

  11. 11

    If you process nuclear fuel, do you hold an ONR nuclear site licence?

    Enrichment, fuel fabrication or reprocessing cannot begin until the Office for Nuclear Regulation has granted a nuclear site licence under the Nuclear Installations Act 1965, with its 36 standard licence conditions.

Section 2 — Placing products on the market

If you place metal products on the market, confirm the conformity regime for each product. These are Great Britain market regimes. Check Northern Ireland separately if you supply there.

  1. 1

    Do structural and reinforcing steel carry the right conformity marking?

    Load-bearing metal components to a designated standard (for example BS EN 1090) need a declaration of performance, execution-class factory production control and conformity marking (UKCA, or CE which is still accepted on the GB market) before the GB market. If not, follow "Place basic metal products on the GB market".

  2. 2

    Do other products meet the general product safety duty?

    Semi-finished or finished metal goods outside a specific regime, where placed on the market for or likely to be used by consumers, must still be safe under the General Product Safety Regulations 2005, enforced by OPSS and Trading Standards.

If you answered no to anything

Work through the guide linked in that item before your production campaign. The two task guides — the safe production-plant spine and placing products on the GB market — set out what to do. Start from the router if you are not sure which apply to you.

Official sources

Authoritative health and safety, major-accident and product-conformity guidance.