Manufacturing & Engineering

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.

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UK-wide

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); and 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 (e.g. 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.

Set up and run a safe metal production plant

Producing basic metals — smelting, casting, rolling, refining and founding iron, steel, aluminium and other non-ferrous metals — is among the highest- hazard things a manufacturer does. Whatever you produce, this is the universal spine. It takes you through your core workplace health and safety duties, control of metal fume and silica, explosive-atmosphere and work-equipment safety, fire, insurance, equality and data protection, the environmental permits your installation needs, the COMAH major-accident controls at threshold, and — for the few nuclear-fuel sites — the ONR nuclear site licence.

Set up and run a safe oil refinery or coke works

Refining crude oil and making coke is among the highest-hazard manufacturing there is — large quantities of flammable and toxic substances, high temperatures and pressures, and major-accident potential. This is the universal spine. It takes you through your core workplace health and safety duties, explosive-atmosphere controls, work equipment, manual handling, fire safety, the COMAH major-accident regime and your environmental permit, the UK Emissions Trading Scheme, insurance, equality and data protection.

Fabricated metal manufacturer: compliance checklist

Use this checklist to confirm your fabricated metal manufacturing business (SIC division 25) meets its obligations before a production run. Work through the universal items every fabricator shares, then the sections for placing products on the market and for firearms, ammunition and explosives. If you answer no to any item, follow the linked guide before you proceed.

Set up and run a safe metal fabrication workshop

Metal fabrication is machinery- and exposure-intensive: cutting, welding, grinding, pressing and surface finishing. Whatever you make, this is the universal spine. It takes you through your core workplace health and safety duties — including the controls now required for welding fume — work equipment safety, manual handling, fire safety, employers' liability insurance, equality, data protection, and the environmental permit you need if you treat metal surfaces.

Set up and run a safe rubber or plastics factory

Rubber and plastics processing is machinery- and chemical-intensive: moulding, extrusion, calendering, curing and finishing. Whatever you make, this is the universal spine. It takes you through your core workplace health and safety duties, control of hazardous substances, work equipment safety, manual handling, fire safety, employers' liability insurance, equality, data protection, and your UK REACH duties on the monomers, plasticisers and additives you use.