Transcript of a HSE letter to various airlines and airport operators following inspections at Heathrow, Gatwick and Stansted - Dec 2010
Dear Sirs
HEALTH AND SAFETY AT WORK ETC ACT 1974
This letter Is to provide you with feedback about the recent inspection initiative by HSE inspectors at Stansted, Gatwick and Heathrow. Issues are discussed generally, rather than identifying individual companies, who have received separate letters. First we would like to thank all those who provided representatives to escort our teams as this helped us to make the most effective use of our time. Their assistance was much appreciated.
TURNROUND PLANS
Turnround plans were requested before our inspection. There seemed some confusion about what we were asking for. By turnround plans I mean the plan/systems of work ensuring the safe and effective management of all companies working on the ramp involved in getting an aircraft disembarked and then ready for take off. HSE produced HSG 209 ‘Aircraft turnround' some time ago as guidance for the industry to help airlines comply with their legal duties to ensure co-operation and co-ordination of persons working on the ramp. This is as required by regulation 11 of the Management of Health and Safety at Work Regulations 1999.
Only about half of the airlines requested produced turnround plans. Even where they were provided there was no evidence on the ramp of effective co-operation and co-ordination (even where turn round co-ordinators had nominally been appointed).
One airline suggested that the notion of turnround plans had been discredited. We would not wish to argue about terminology but the requirement for effective co-operation and co-ordination remains a legal requirement. The main responsibility falls on individual airlines and the contractors they use for ground handling to work together to ensure aircraft turnround is carried out both safely and effectively This is not a responsibility that airlines can delegate down to ground handlers
Out of gauge/super out of gauge
There had been no proper consideration of the risks of moving out of gauge and super out of gauge luggage. This has been followed up with individual companies
Use of flat bed trailers
Examples were seen of flat bed trailers that had no edge protection to prevent anyone falling from them. This has been dealt with by means of an Improvement Notice. There were several examples seen of aircraft being off-loaded direct from hold to flatbed This results in unacceptable postures - in one case a ground handler was kneeling to receive the bags from the hold Companies have been told this practice must cease.
Training
While the majority of ground handlers spoken to had received manual handling training there was anecdotal evidence that some of this was classroom based and not always relevant to working conditions. To be effective manual handling training must reflect real life conditions and also needs reinforcement once training has been comp'eted. There were examples of training that included these elements that had a very positive impact in reducing manual handling injury.
Heavy loose cargo
Several examples were seen of heavy components such as aircraft wheels, brake parts etc had to be manually moved down the aircraft hold, loaded onto the belt loader and then unloaded at the bottom We were told that lead lined coffins are also a significant problem. There seems to have been little thought given to resolving these issue& The industry needs to liaise with overseas airports to ensure that as far as possible heavy items are put into holds with magic carpets', Where these are not available heavy items should be loaded so as to minimise the amount of handling. The industry also needs to consider whether specialised equipment could make unloading of heavy loose cargo safer. An example of this was seen at Stansted for loading and unloading aircraft wheels.
Extending belt loaders (ERLs)
Inspectors came across one example where EBL.s were in use but some concerns were raised that they were not as reliable as conventional belt loaders. We accept that there is more to go wrong on EBLs but there is now enough research that clearly demonstrates that this technology is the way forward to really tackle manual handling injuries in ground handlers and we strongly support their introduction when equipment is being replaced. The holds of narrow bodied aircraft are not designed for people to safely handle goods in.
This initiative suggests the air transport industry still has some way to go before it can be said to be adequately managing health and safety on the ground. We recognise that competition for business is fierce and profit margins small. This is not sufficient reason to continue tolerating the degree of manual handling injuries in particular that are current in the industry. HSE believes a positive way forward would beforairlines and handlers to agree set standards for the safe handling of luggage could remove any pressure to cut corners by existing ground handlers or new entrants to the industry. Airports airlines and ground handlers can all contribute to achieve this end
This general letter has gone to all companies involved in the recent initiative and is supported by follow up to specific companies by the three HSE offices involved. We would recommend that the more general issues raised in this letter are taken forward by the CM Ground Handling Operations Safety Team (GHOST). in the first instance, perhaps with a view to setting up working groups to develop recommended best practice.
HSE inspectors visiting airports will be looking in future to see improvements in the areas indicated in the future
Yours faithfully
HM Inspector of Health and Safety