Manufacturing & Engineering

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.

UK-wide
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UK-wide

Processing rubber and plastics — moulding, extrusion, calendering, curing, blow-moulding and finishing — is machinery- and chemical-intensive. The duties in this guide are not specific to one kind of product; they apply whether you make packaging, builders' ware, tyres, technical mouldings or film. Get this spine in place first, then layer the product-specific and packaging 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 plastics or rubber plant that means risk-assessing the machinery, hot surfaces, fume and material handling, providing safe systems of work, and training and supervising your people.

B. Control exposure to hazardous substances (COSHH)

The Control of Substances Hazardous to Health Regulations 2002 (COSHH) require you to assess, then prevent or adequately control, exposure to hazardous substances. In this sector that means polymer resins and powders, curing agents and accelerators, plasticisers, solvents, isocyanates in polyurethane work, and rubber fume and process dust. Provide engineering controls — local exhaust ventilation — and health surveillance where the regulations require it. Isocyanates in particular carry strict exposure controls and health surveillance.

C. Keep your work equipment safe (PUWER)

Your machinery — injection-moulding and blow-moulding machines, extruders, calenders, mills, presses and granulators — must be suitable, properly maintained, inspected and adequately safeguarded under the Provision and Use of Work Equipment Regulations 1998. Moulding-machine and calender guarding, and isolation for cleaning and unblocking, are recurring HSE enforcement themes. Lifting plant reads across to LOLER 1998.

D. Manage manual handling

Moving raw-material sacks and reels, moulds and tooling, and finished product is 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.

E. Manage fire safety

Polymers, solvents and combustible process dust give rubber and plastics processing an elevated fire load. The responsible person must carry out a fire risk assessment and maintain fire-safety arrangements. 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.

F. 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.

G. 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.

H. 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.

I. Meet your UK REACH duties on the substances you use

The substances and mixtures you use — monomers, plasticisers, stabilisers, colourants and curing chemistries — are subject to UK REACH. Depending on your role and tonnage you may need to register substances you manufacture or import, you must comply with Annex XVII restrictions (for example the restrictions on certain phthalate plasticisers and other substances of very high concern), and you must pass substance-of-very-high- concern information down the supply chain. UK REACH is a Great Britain regime enforced by HSE with the environmental regulators. If you place goods on the Northern Ireland market, check the position separately — Northern Ireland follows EU REACH under the Windsor Framework, so the duties there can differ.

  1. 1

    1. Write your health and safety risk assessments

    Assess moulding, extrusion, calendering, curing and finishing, and put safe systems of work, training and supervision in place under HASAWA 1974.

  2. 2

    2. Put COSHH controls in for your process chemistries

    Assess resins, curing agents, plasticisers, solvents, isocyanates and rubber fume; fit local exhaust ventilation and arrange health surveillance where COSHH requires it.

  3. 3

    3. Bring work equipment into a PUWER regime

    Make sure moulding machines, extruders, calenders and granulators are guarded, maintained, inspected and safely isolated for cleaning.

  4. 4

    4. Control manual handling and carry out your fire risk assessment

    Reduce hazardous handling of materials, moulds and product; assess fire risk from polymers, solvents and dust under the regime for your nation.

  5. 5

    5. 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.

  6. 6

    6. Map your substances against UK REACH

    Identify what you must register, check the Annex XVII restrictions that apply to your plasticisers and additives, and put supply-chain SVHC communication in place. Check the NI position separately if you supply there.

What to do next

This spine covers the duties every rubber and plastics manufacturer shares. On top of it, the rules depend on what you make:

Official sources

Authoritative health and safety, data-protection and chemicals guidance.

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