Producing basic metals — melting, casting, rolling, refining and founding — is high-hazard heavy industry. The duties in this guide are not specific to one product; they apply whether you run an integrated steelworks, an electric-arc furnace, an aluminium smelter, a non-ferrous refinery or an iron or steel foundry. Get this spine in place first, then layer the product-specific and site-specific rules on top.
Health and safety law here is largely devolved. The Health and Safety Executive (HSE) is the regulator in Great Britain and the Health and Safety Executive for Northern Ireland (HSENI) in Northern Ireland; the underlying duties are equivalent across the UK. Work through the sections below in order.
A. Meet your general health and safety duty
The Health and Safety at Work etc. Act 1974 is the foundation. You must ensure, so far as is reasonably practicable, the health, safety and welfare of your employees and of anyone else affected by your work. In a metal production plant that means risk-assessing molten-metal handling, hot work, heavy plant and process gases, providing safe systems of work, and training and supervising your people.
B. Control exposure to hazardous substances (metal fume and silica)
The Control of Substances Hazardous to Health Regulations 2002 (COSHH) require you to assess, then prevent or adequately control, exposure to hazardous substances. This bites hard in basic-metal production. Metal fume from melting and casting can carry manganese, hexavalent chromium, nickel, cadmium and lead; pickling lines generate acid mists; and foundry sand is a major source of respirable crystalline silica. You need effective engineering controls — local exhaust ventilation — suitable respiratory protective equipment, exposure monitoring and health surveillance where COSHH requires it.
C. Control explosive atmospheres and flammable process gases (DSEAR)
The Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) require you to assess and control fire, explosion and energetic- event risks. In metal production the dominant hazards are molten-metal and water steam explosions, flammable process gases such as blast-furnace gas, coke-oven gas, hydrogen and acetylene, and combustible metal dusts from aluminium and magnesium fines. Classify hazardous areas into zones and select equipment suitable for those zones.
D. Keep your work equipment safe (PUWER)
Your plant — furnaces, ladles, rolling mills, presses, conveyors, cranes and casting lines — must be suitable, properly maintained, inspected and adequately safeguarded under the Provision and Use of Work Equipment Regulations 1998. Steam, compressed-gas and hydraulic plant reads across to the Pressure Systems Safety Regulations 2000, and lifting equipment handling hot metal to LOLER 1998.
E. Manage manual handling
Billets, ingots, coils, castings, moulds and heavy tooling are routine, so the Manual Handling Operations Regulations 1992 apply. Avoid hazardous manual handling so far as is reasonably practicable; where you cannot, assess the risk and reduce it — through lifting equipment, better layout, and safe systems of work.
F. Manage fire safety
Hot processes, flammable process gases and combustible metal dusts make fire a serious risk. The responsible person must carry out a fire risk assessment and maintain fire-safety arrangements (read alongside DSEAR). The duty is devolved: the Regulatory Reform (Fire Safety) Order 2005 in England and Wales; the Fire (Scotland) Act 2005 and Fire Safety (Scotland) Regulations 2006 in Scotland; and the Fire and Rescue Services (Northern Ireland) Order 2006 in Northern Ireland.
G. Hold employers' liability insurance
As soon as you employ anyone, you must hold employers' liability compulsory insurance — normally at least £5 million of cover — and display or make available the certificate. This is a legal requirement across Great Britain, with an equivalent duty in Northern Ireland.
H. Meet your equality duties
As an employer you must not discriminate against, harass or victimise people because of a protected characteristic. In Great Britain this is governed by the Equality Act 2010; in Northern Ireland separate equality legislation applies, enforced by the Equality Commission for Northern Ireland.
I. Handle personal data lawfully
If you process personal data — about staff, customers or suppliers — you must comply with the UK GDPR and the Data Protection Act 2018, and in most cases pay the data protection fee to the Information Commissioner's Office (ICO). This applies UK-wide.
J. Get the environmental permit your installation needs
Integrated iron and steel works, sinter plants, coke ovens, blast furnaces, electric-arc furnaces, ferro-alloy production and non-ferrous smelters above the Part A(1) capacity thresholds need an environmental permit covering emissions to air, water and land. Larger ferrous foundries need a Part A permit; smaller foundries typically need a Part B local- authority air-emissions permit for furnace and knock-out emissions. The regulator is the Environment Agency in England, Natural Resources Wales in Wales, the Scottish Environment Protection Agency in Scotland and the Northern Ireland Environment Agency in Northern Ireland.
K. Permit any radioactive sources and contaminated scrap
If you keep or use radioactive material — for example sealed sources in nucleonic level and thickness gauges — or accumulate and dispose of radioactive waste, including where you monitor incoming scrap for radioactive contamination, you generally need a radioactive-substances activity permit. This is a routine concern for steelworks and foundries handling bought-in scrap, not just for nuclear sites. The regulator is the Environment Agency (NRW in Wales); Scotland runs the equivalent radioactive-substances authorisation through SEPA and Northern Ireland through the NIEA.
L. Assess your COMAH tier and put major-accident controls in place
An integrated steelworks holding bulk flammable or toxic process gases — blast-furnace gas, coke-oven gas — and other named dangerous substances above the qualifying inventory is a lower- or upper-tier establishment under the Control of Major Accident Hazards Regulations 2015. You must have a major-accident prevention policy, notify the Competent Authority, and — at upper tier — produce a safety report and an on-site emergency plan. COMAH is enforced jointly by HSE and the Environment Agency as the Competent Authority (SEPA in Scotland); in Northern Ireland the COMAH Regulations (Northern Ireland) 2015 apply. It is strictly threshold-driven — only establishments holding qualifying quantities are caught.
M. If you process nuclear fuel (SIC 24.46)
This section applies only to the small number of sites that enrich, fabricate or reprocess nuclear fuel. No site may be used for processing nuclear fuel unless the Office for Nuclear Regulation (ONR) has granted a nuclear site licence under the Nuclear Installations Act 1965. The licence carries 36 standard licence conditions — covering the safety case, training, emergency arrangements, operating rules, the accumulation of radioactive waste and decommissioning — and is held for the life of the installation. ONR also regulates nuclear security and safeguards. The nuclear site licence is a UK-wide regime administered by ONR. Radioactive discharges are separately permitted by the environmental regulator under section K above. If this is you, treat the ONR licence as the operating gateway that comes before everything else.
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1. Write your high-hazard health and safety risk assessments
Assess molten-metal handling, hot work, heavy plant and process gases. Put safe systems of work, training and supervision in place under HASAWA 1974.
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2. Put metal-fume, silica and COSHH controls in
Fit local exhaust ventilation, provide RPE, and arrange exposure monitoring and health surveillance for metal fume, respirable crystalline silica and acid mists.
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3. Carry out your DSEAR assessment and zone hazardous areas
Assess molten-metal/water explosions, flammable process gases and combustible metal dusts; classify zones and select compliant equipment.
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4. Bring work equipment into a PUWER regime
Make sure furnaces, mills, presses, cranes and casting plant are guarded, maintained and inspected, with pressure and lifting plant covered by PSSR and LOLER.
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5. Control manual handling and carry out your fire risk assessment
Reduce hazardous lifting of billets, coils and castings; assess fire risk from hot work, gases and combustible dusts under the regime for your nation.
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6. Take out employers' liability insurance and register with the ICO
Arrange at least £5 million of cover before anyone starts work, and pay the data protection fee unless you are exempt.
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7. Apply for your environmental permit and radioactive-substances permit
Identify the Part A or Part B permit your installation needs from your environmental regulator, and a radioactive-substances permit for sources, gauges and contaminated-scrap monitoring.
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8. Assess your COMAH tier and, for nuclear fuel, secure the ONR licence first
Notify the Competent Authority and put major-accident controls in place at threshold; if you process nuclear fuel, the ONR nuclear site licence must be in place before operations begin.
What to do next
This spine covers the duties every basic-metal producer shares, plus the environmental, major-accident and nuclear gateways for larger and higher-hazard plants. On top of it:
- If you place structural steel or other metal products on the market, follow Place basic metal products on the GB market.
- Confirm you have covered everything with the basic metal manufacturer compliance checklist.
Official sources
Authoritative health and safety, environmental, major-accident and nuclear guidance.