Manufacturing & Engineering

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.

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UK-wide

Use this checklist to confirm your fabricated metal manufacturing business meets its obligations before a production run. 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. 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. Firearms and explosives are controlled under Great Britain regimes, with separate legislation in Northern Ireland. Each section names the body that applies.

Section 1 — Every metal fabricator

These workplace and registration duties apply to every fabricator, whatever you make. Confirm each one before you start production.

  1. 1

    Have you assessed and controlled exposure to welding fume and other hazardous substances?

    COSHH requires local exhaust ventilation and RPE for all welding, plus control of metalworking-fluid mists, isocyanate paints and plating chemistries, with health surveillance where required. If not, follow "Set up and run a safe metal fabrication workshop".

  2. 2

    Is your machinery safeguarded, maintained and inspected under PUWER?

    Power presses, guillotines, press brakes, lathes and grinders must be guarded and maintained, with thorough examination of power presses and their guards under PUWER regulations 32 to 35.

  3. 3

    Have you assessed and controlled manual handling?

    Heavy plate, sections, coils and fabrications must be handled with the risk eliminated or reduced so far as reasonably practicable, with lifting aids where needed.

  4. 4

    Have you carried out your fire risk assessment?

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

  5. 5

    Do you hold employers' liability insurance?

    You must hold at least £5 million of cover once you employ anyone, with the certificate available.

  6. 6

    Have you met your equality duties as an employer?

    Do not discriminate against, harass or victimise people because of a protected characteristic, under the Equality Act 2010 (or separate NI equality law enforced by the ECNI).

  7. 7

    Have you met your data protection duties?

    Comply with the UK GDPR and Data Protection Act 2018, and register with the ICO and pay the data protection fee unless you are exempt.

  8. 8

    Do you need an environmental permit for surface treatment?

    If you electroplate or surface-treat metals above the thresholds, you need a permit from your environmental regulator (Environment Agency, NRW, SEPA or NIEA) and a trade-effluent consent.

Section 2 — Placing products on the market

If you make metal products to sell, 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 steel and construction products 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 fabricated metal products on the market".

  2. 2

    Is your pressure equipment conformity-assessed and marked?

    Boilers and pressure vessels above the thresholds must meet the essential safety requirements, undergo the right conformity-assessment module (approved body for higher categories) and carry conformity marking (UKCA or CE).

  3. 3

    Do other products meet the general product safety duty?

    Metal goods outside a specific regime must still be safe under the General Product Safety Regulations 2005, enforced by OPSS and Trading Standards.

Section 3 — Firearms, ammunition and explosives (SIC 25.40)

Only complete this section if you manufacture weapons, ammunition, propellants or explosives. These controls must be in place before any manufacture begins.

  1. 1

    Are you a registered firearms dealer, with section 5 authority if needed?

    Manufacturing firearms or ammunition by way of trade requires registration with police firearms licensing (Firearms (NI) Order 2004 / PSNI in Northern Ireland), plus section 5 authority for prohibited weapons. If not, follow "Manufacture weapons and ammunition".

  2. 2

    Do you hold an explosives manufacture and storage licence?

    Making ammunition, propellants or explosives needs a licence under the Explosives Regulations 2014 from HSE or the local authority/police, with a separate regime in Northern Ireland.

  3. 3

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

    If your explosives or propellant holdings exceed the thresholds, notify the Competent Authority and put your major-accident prevention policy and (upper-tier) safety report and emergency plan in place.

If you answered no to anything

Work through the guide linked in that item before your production run. The three task guides — the safe workshop spine, placing products on the market, and manufacturing weapons and ammunition — set out what to do. Start from the router if you are not sure which apply to you.

Official sources

Authoritative health and safety and product-conformity guidance.

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 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.

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.

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.

Set up and run a safe tobacco factory

Tobacco processing is machinery- and dust-intensive: conditioning, cutting, drying, blending, rolling and packing, using casing and flavouring chemicals. Whatever you make, this is the universal spine. It takes you through your core workplace health and safety duties, control of hazardous substances and tobacco dust, work equipment safety, manual handling, fire safety, employers' liability insurance, equality and data protection.