Pallet Racking in Ireland and HSA’s Role

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Pallet racking law in Ireland can be something of a mystery. To better understand it, it’s good to know what exactly HSA does.

HSA Ireland isn’t as clear as HSE when it comes to the safe use of pallet racking in Ireland, though there is a reason for this. While HSE simply covers health and safety law, HSA covers a broader range of issues. By understanding what HSA does, it’s easier to understand why its stance on pallet racking in Ireland is so vague.

Ireland Doesn’t Have an NHS

Ireland’s Health Act 2004 means that every Irish citizen is able to receive at least some basic healthcare. This act, however, did not set up a system as comprehensive as the UK’s National Health Service. Instead, the public healthcare of Irish citizens is handled by HSA and this means that the HSA is a much broader governmental body than HSE. So, as well as tackling issues such as myth busting and law making, HSA also does many things that HSE does not do, such as building wind farms and employing over 227,000 healthcare workers.

Not having an NHS means that Ireland has a huge HSA instead. It’s much more authoritative than HSE but, because it covers the health of Irish citizens in such a broad way, it does have a few blind spots.

Pallet Racking Ireland: The Body Which Doesn’t Exist

HSE is focused on just one thing: creating laws and guidance for workplace safety. Over time, its scope has had to expand to include other issues. From around 2010 to 2015, exploding pavements were a serious public health risk in London. This unique public health scare left authorities confused as to whose responsibility it was to solve the problem. In the end, it was left to HSE and this has set a precedent where we imagine HSE to be a body which keeps us safe in public spaces, not just workplaces.

However, aside from that, HSE’s role has remained the same. In other words, it has remained specific. As a result, despite huge funding cuts, it is still able to provide in-depth guidance on things like preventing slips and trips at work, minimum and maximum workplace temperatures, and pallet racking safety.

That last aspect of safety is something of a blind spot for HSA Ireland. While HSE works with SEMA (the Storage Equipment Manufacturers Association) to create laws and guidance on all aspects of pallet racking safety, there is no Irish equivalent. There is no “Pallet Racking Ireland” who helps HSA to create guidance and laws in the same way that SEMA helps HSE. As a result, many Irish storage equipment users and warehouse owners are left in the lurch trying to figure out the best practice for pallet racking safety in their country.

With no “Pallet Racking Ireland”, HSA’s advice on storage equipment safety is scarce at best, and towards the bottom of its page on the topic, it links outwards to Warehousing Ireland (a magazine which offers some advice) and HSE HSG76. This HSE guide mentions SEMA by name and recommends annual inspections from a SEMA approved racking inspector.

So should owners of pallet racking in Ireland follow this advice? Probably, but HSA doesn’t make it 100% clear that they should. One thing that is for certain is that having your warehouse inspected annually by an outside expert is an EU recommendation and that Ireland, as a member of the EU, should follow this advice.

Does HSA Need a “Pallet Racking Ireland”?

HSA needs to give out clearer advice on pallet racking safety, but that doesn’t necessarily mean it needs a “Pallet Racking Ireland” body just as HSE has SEMA. SEMA operates in countries all over the world (with SEMA approved racking inspectors working in Spain, Poland, China, Singapore, and the UAE). As a result, it’s perfectly reasonable for Irish storage equipment users to follow SEMA’s advice.

If HSA were to be more forthright, it could directly recommend SEMA services in the same way HSE does. As it stands, it doesn’t. However, it does recommend them indirectly by linking out to HSE HSG76, and having a SEMA approved racking inspection is also consistent with the EU’s advice. With HSA’s lack of input on the topic, this is likely the best advice to follow.

For a SEMA approved racking inspection, contact Storage Equipment Experts. We deliver racking safety inspections and racking inspection training from a SEMA approved racking inspector to any workplace in the UK or Ireland.

HSE CDM Regulations: Everything You Need to Know

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The HSE CDM Regulations have been in force since 2015, but some are still confused about what they mean.

Like most legislation, the idea of the HSE CDM (Construction, Design, and Management) regulations 2015 was to make things simpler. However, also like most legislation, it’s ended up making things more complicated. Or rather, as people learn to adjust to the new system, there’s an understandable amount of confusion. To clear things up, here’s everything you need to know about the HSE CDM Regulations.

What Are the HSE CDM Regulations For?

The best way to understand the new HSE CDM regulations is to understand why they were updated in the first place. The idea is to help “clients” (business owners, building owners, storage equipment users, heads of building sites, etc.) better know their role. Despite the “C” standing for “Construction”, Osborne Clarke calculated that about 85% of people affected by the HSE CDM regulations do not work in the construction industry.

This was largely the point of the HSE CDM regulations. By expanding the definition of “construction work”, the HSE CDM regulations aim to protect more people than the original 2007 regulations. “Construction work” now includes building, civil engineering, or engineering work as well as the building of temporary structures used for events, television, film, and entertainment productions.

So, according to the HSE CDM regulations, a television producer now works in the construction industry. This became particularly relevant in 2016 when a court heard that Harrison Ford “could have died” while filming Star Wars: The Force Awakens. Film sets can be dangerous places, and so this is why the CDM regulations expanded its definition of construction. To summarise, “construction work” is now a very broad umbrella and so, if you think you fall into this category, then you probably do.

The idea of this was to give legal protection to people working in industries which, until then, hadn’t been covered by very much health and safety legislation at all. By broadening the definition of “construction work”, it’s helped to simplify things. However, it’s also confused a lot of people, too.

The HSE CDM regulations also simplify other elements of health and safety in the construction industry. Namely, the notions of competence and client responsibility.

Competence & Client Responsibility Under the HSE CDM Regulations

Once again, to understand the HSE CDM regulations’ stance on competence and client responsibility, it’s good to understand why they were updated in the first place. In 2007, the HSE CDM regulations also placed emphasis on the importance of competence. People who worked in construction, according to the regulations, needed to be technically competent. This same idea is echoed in HSE HSG76.

But what do competence and technically competent mean? No-one could agree, and even Tony Mitchell from HSE conceded that the old HSE CDM regulations made things “too complicated”. What’s more, keen to capitalise on the confusion, over 300 “card schemes” emerged with so-called health and safety professionals claiming that paying for their card made you competent in the eyes of HSE and the law. Without a clear definition of competence, no-one could claim that these card schemes weren’t legitimate.

The 2015 regulations now mean that it is ultimately the client’s responsibility to decide who is and is not competent enough to perform a task in their workplace. The client responsibility itself is another important element of the HSE CDM regulations’ update and it has ramifications beyond deciding who is and is not competent enough to perform a task. Whereas before it was partly HSE’s responsibility to ensure that construction work was being done safely, now it is solely the responsibility of the client.

In short, the client decides who is and is not competent, what is and is not safe, and if something goes wrong then it is entirely the client’s responsibility. With these new regulations in place, it’s more important than ever to make sure that businesses, warehouses owners, and storage equipment users follow HSE’s advice. By following HSE guidelines, businesses will be able to defend their actions legally should the worst happen.

A perfect example of this is with regards to SEMA approved racking inspections and racking inspection training. HSE recommends racking inspections from an “expert” at least once a year. According to the HSE CDM Regulations, it is for the client to decide who would qualify as a competent enough expert to perform this task. However, HSE mentions SEMA approved racking inspectors as an example of exactly this kind of expert. With that in mind, a SEMA approved racking inspector would be the perfect person to perform this task.

HSE also recommends regular racking inspections from competent staff. The best way that a client could ensure that their staff are competent enough to perform these inspections would be through racking inspection training from a SEMA approved racking inspector — someone labelled as an “expert” by HSE.

To make sure that everyone in your workplace is “competent” enough to perform regular racking inspections, contact Storage Equipment Experts for racking inspection training from a SEMA approved racking inspector.

Simplifying the SEMA Racking Code of Practice: Technical Bulletin No. 1

Damaged racking equipment and unsafe use of racking are the causes of many headaches. In severe cases, it can even be the cause of fatality. While identifying damage is much easier when staff have undergone racking inspection training, choosing the right remedial action can be tricky. Many companies offer repairs that supposedly improve upon the structural integrity of racking equipment, but their methods are often at odds with the SEMA Racking Code of Practice.

For the convenience of all warehouse operators, we’ve created an infographic guide to the SEMA Technical Bulletin No. 1. In it, we take a look at what the organisation advises when it comes to types of racking repairs, some general rules of thumb and a handy traffic light system for classifying damaged racking.

SEMA Racking code of practice: technical bulletin #1 | Storage Equipment Experts

What SEMA Thinks of Different Repair Methods

The myriad of types of repair methods can lead to some confusion, so it’s helpful to see what the SEMA Racking Code of Practice advises in each case. Here’s what the SEMA Technical Bulletin No. 1 recommends:

  • Repairs involving welding are to be avoided in all cases. SEMA does not mince its words here. The sole guidance it provides in relation to welding is as follows: “Such repairs are not recommended.”
  • Repairs to secondary members, such as frame bracings, should be carried out in line with the manufacturer’s guidelines. They should also be covered by the repair company’s warranty and a quality assurance procedure must be put in place.
  • For repairs involving main structural members, specifically racking uprights, the information is much the same as in the previous point. However, this repair should not involve the bending of uprights back into shape. Damaged areas of upright should be cut out and new areas spliced in.

Repairs should also be highlighted during racking inspections. Whilst some warehouses may require more frequent inspections, HSE’s HSG76 recommends a racking inspection frequency of once per year as a bare minimum. These inspections should be interspersed with regular checks from employees who have undergone racking inspection training, in order to keep an eye on racking safety in between expert inspections.

SEMA Racking Code of Practice: The Rule of Thumb for Repairs

While you could spend years studying the various pieces of racking legislation, SEMA Technical Bulletin No. 1 provides a couple of quick rules of thumb. Firstly, it strongly recommends replacing damaged components “like-for-like”. Scrimping on replacement parts may not only void your product warranty, but it may also endanger warehouse staff.

SEMA’s Racking Code of Practice also generally advises against carrying out repairs of damaged components. This doesn’t mean you should replace an entire racking system if become damaged; affected components should be spliced and replaced, rather than being bent back into shape or welded. According to SEMA, any repair that involves the bending of damaged uprights should be avoided.

It’s also worth bearing in mind that SEMA’s advice on repair is backed up by the law. The Provision and Use of Work Equipment Regulations 1998 emphasises the importance of repairing and inspecting work equipment, such as racking, whenever damage is suspected.

The HSE Traffic Light System

To assist with the troubleshooting of damaged racking equipment, HSE recommends a traffic light classification system which can be used alongside the SEMA Racking Code of Practice. Damage is ranked green, amber, or red depending on its severity, and appropriate actions are suggested for each category.

Green represents damage which does not require remedial work, but which should be monitored at the next racking inspection.

Amber refers to damage which should be remedied, but which is not so severe as to require immediate offloading. However, once loads are removed from this racking, the equipment should not be reloaded until remedial works have taken place. Racking with amber risk category damage should be considered red risk if remedial work has not been carried out within four weeks of first noting the damage.

Red represents severe damage and racking should be immediately offloaded. The normal course of action in this case would be to replace the damaged components with like-for-like parts. Racking with red risk category damage should be isolated to prevent inadvertent use and further risk to warehouse staff.

At Storage Equipment Experts, we know the SEMA Racking Code of Practice inside out. For racking inspection training from SEMA approved racking inspectors, get in touch today.

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A Quick Guide to SEMA Safety

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SEMA safety is a big umbrella with lots of different elements of storage equipment safety beneath it.

The Storage Equipment Manufacturers Association (SEMA) is something of an authority when it comes to storage equipment safety. Though their advice is superseded by HSE (Health and Safety Executive), SEMA safety is vital because it is much more specific. SEMA safety doesn’t contradict HSE safety. Rather, it expands on the advice given in HSE HSG76 and then goes into much more detail.

In this quick guide to SEMA safety, you’ll learn about the most basic and important aspects of SEMA safety and how to follow them.

1) The SEMA Code of Practice

More or less every conceivable instance of storage equipment safety is covered in the SEMA Code of Practice. This code is not one document, but many different documents which you can purchase from SEMA at various prices. Not all documents are relevant to all storage equipment users or warehouse owners. Their “Guide to the Specification of Freestanding High Bay Racking and Clad Racks”, for example, is not needed for those warehouse owners who don’t use freestanding high bay racking or clad racks.

If you find HSE HSG76’s advice lacking with regards to your specific storage equipment safety query, these guides are a good place to start. However, if you want to know more about specific elements of racking safety, there are other options.

2) Racking Inspection Training from a SEMA Approved Racking Inspector

The SEMA approved racking inspector program is by far the most rigorous safety program SEMA runs. This is closely followed by the SEMA Cantilever Racking Inspection course. As a result, there are only 104 SEMA approved pallet racking inspectors in the world (with inspectors based in Spain, the UAE, Singapore, and even China) and only 35 SEMA approved cantilever racking inspectors in the world.

A warehouse owner or storage equipment user does not need to take either course. The program is designed for people who want a career as a SEMA approved racking inspector, rather than someone who just wants to know how to operate their racking safely.

For the latter person, we would recommend our racking inspection training course performed by a SEMA approved inspector. Our SEMA approved racking inspector is one of the few people to have passed both the SEMA pallet racking inspection course and the SEMA cantilever racking inspection course. For that reason, our racking inspection training course is one of the best in the UK (with rave reviews from Tate Modern, Hayden’s Bakery, Dunlop, White Stuff, and many others).

If you want to learn about some of the elements of SEMA safety specific to your racking system, but are a little intimidated by the scale of the SEMA Code of Practice, we’d highly recommend our racking inspection training course.

3) SEMA Technical Bulletins

The SEMA Code of Practice is often updated — or elements of it are clarified — with technical bulletins. It’s important to keep an eye out for these as they are often reactions to things happening in the industry. The SEMA Technical Bulletin No. 3 clarifies SEMA and HSE’s interpretation of the use of rack protectors (among other things) in response to people’s incorrect use of them.

These bulletins are a key part of SEMA safety and are great because they are often backed up with direct quotes from HSE HSG76. In other words, these bulletins help storage equipment users to understand HSE HSG76 in context.

4) SEMA Approved Racking Inspections & Staff Racking Inspections

As previously mentioned, SEMA runs different courses in order to train SEMA approved racking inspectors (SARIs). Both HSE and SEMA recommend racking inspections from SARIs at least once a year. HSE also recommend regular inspections from “competent” staff. At Storage Equipment Experts, we believe the best way to ensure that your staff are “competent” enough to perform the regular staff-led inspection HSE recommend is through our racking inspection training course: a course delivered by a SEMA approved racking inspector (SARI).

The importance of “competence” is also echoed in the CDM regulations 2015. As a result, this makes training doubly important.

5) Other Elements of SEMA Safety

SEMA safety also includes many other aspects, such as correct practice for storage equipment installation, storage equipment repair, and the dismantling of storage equipment. Each element of racking safety is covered somewhere in its Code of Practice. Most of the emphasis of HSE warehouse safety and SEMA safety is on the use of racking (as this is what warehouse owners and storage equipment users will spend the bulk of their time doing) but it’s important to pay close attention to the other elements of SEMA safety too. If the worst happens, your racking might need repair or dismantling. When it does, you’ll be glad that what to do is covered by SEMA safety.

For a greater understanding of SEMA safety, contact Storage Equipment Experts today for racking inspection training from a SEMA approved racking inspector.

What Is the SEMA Racking Code of Practice?

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The SEMA Racking Code of Practice forms the basis for all of the advice SEMA gives, but what is it exactly?

The SEMA Racking Code of Practice is not one article, or one document, but a series of documents which tackle different elements of storage equipment safety. All of them are available to download from the SEMA website for a range of different prices.

The advice issued by the SEMA Racking Code of Practice is consistent with HSE law. If it wasn’t, then there would be no point in following it. HSE’s HSG76 outlines some general principles about warehouse safety and it alludes to relevant laws, but the SEMA Racking Code of Practice is intended as a guide to racking safety specifically — with each separate document dedicated to a specific element of warehouse safety.

Combining SEMA’s knowledge of racking systems with a solid interpretation of the law, the SEMA Racking Code of Practice is as close as you can get to storage equipment safety gospel in the UK. In fact, during the SEMA Safety Seminar in June 2015, SEMA revealed that they had been talking with HSE about turning some of their SEMA Racking Code of Practice into law. As of May 2017, this hasn’t happened. However, the fact that HSE and SEMA’s relationship is so close shows how important the SEMA Racking Code of Practice is to storage equipment safety.

What Does the SEMA Racking Code of Practice Say?

It’s hard to summarise the advice, as it’s spread across several different documents and covers many different elements of racking safety, but there are technical bulletins which address some of the more common (and most important) elements of racking safety.

One technical bulletin, for example, addresses the use of rack protectors. Technical Bulletin No. 3, which acts as an update/clarification of the SEMA Racking Code of Practice, claims that rack protectors are often misused because clause 639 of HSE’s HSG76 gets misinterpreted. The clause states that “where racking is likely to be struck by lift trucks and other vehicles, it should be protected.”

Most end users of racking systems interpret this clause to mean that physical rack protectors are enough to protect a racking system and that vehicles bumping into the rack protectors is just part of the day-to-day workings of a warehouse. In short, many see rack protectors’ job as something which is designed to withstand regular bumps and scrapes from trucks and other machinery.

This is wrong. Rack protectors should be seen as the last resort rather than the only form of rack protection. Rack protection should be preventative and the physical protectors are only there in case they are absolutely needed. Like a motorcycle helmet, rack protectors are not there so you can act recklessly. They are a form of protection intended to save you from the worst possible outcome of an accident.

From this one technical bulletin, we can see how the SEMA Racking Code of Practice works. It is ancillary to — and works alongside — HSE HSG76, the law, and common sense. The SEMA Racking Code of Practice is vital for all users of storage equipment to understand, and users can download every part they need from the SEMA website.

The SEMA Racking Code of Practice & Racking Inspection Frequency

Some of the most important advice issued by both SEMA and HSE is with regards to racking inspections and racking inspection frequency. This is an integral part of the SEMA Racking Code of Practice, HSE HSG76, and storage equipment safety in general.

It’s recommended that all storage systems receive a SEMA approved racking inspection at least once a year and a more regular inspection from competent staff. In order to make sure your staff are competent enough to perform regular racking inspections, we would recommend racking inspection training from a SEMA approved racking inspector.

SEMA Approved Racking Inspectors have spent years studying the SEMA Racking Code of Practice as well as understanding all of its updates. So, for a rack safety inspection or rack safety inspection training from a SEMA approved racking inspector and expert on the SEMA Racking Code of Practice, contact Storage Equipment Experts today!