Appendix 6:

Example EMM1 Form, Sections 1-4 only

Mandatory recording of enforcement decisions on the Enforcement Assessment Record Form (EMM1) is required for:

  • Fatal accidents
  • Major incidents
  • Prosecutions
  • Investigations (Recorded on COIN as an investigation)

Other circumstances as required by line management.

The following is an example scenario where RPE is commonly used as a control measure in combination with on-tool extraction; the intention is to use this example to illustrate the completion of the relevant sections of the EMM1 form.

Scenario

4.5 hours fitting softwood doors with dust bag attachment fitted to powered sander.

Significant long-term exposure to wood dust has been measured to be 6.02mg/m3 8-hour TWA. The WEL for softwood dust is 5mg/m3 8-hour TWA with a Sen notation.

It is the opinion of the inspector that on-tool extraction attached to the sander would be a possible control measure to capture the dust. However, due to the different positions and angles at which the sander is used on the door frames, the on-tool extraction used at this site does not capture all of the dust generated. RPE would also be required to reduce exposure to ALARP.

Enforcement Assessment Record (EMM1)

EMM1 (04.12)

Section 1 / Directorate: / FOD / HID / ONR
Duty holder / Customer No
Site/Premises / Site No / Case No
Brief description of circumstances, including the specific issue considered and the associated risk/failing.
Exposure to softwood dust whilst fitting door frames. Investigation has shown that exposure to the soft wood dust is likely to be above the WEL.
Section 2
Risk of serious personal injury - HSWA Section 22 Prohibition notice / Yes / No / x
Article / substance is cause of Imminent danger of serious personal injury - HSWA Section 25 powers / Yes / No / x

EMM1 (04.12)

Section 3 – Benchmark & Risk gap: see GRIP for further benchmark information

EMM1 (04.12)

Specify the appropriate standard to be achieved. (Describe relevant requirements e.g. of Acts, Regulations or ACoPs; industry CoPs or standards etc.)

COSHH Regulation 7
The 8-Hour TWA WEL is 5mg/m3 with a Sen notation.

EMM1 (04.12)

Risk Gap - (From Table 1, Table 2.1 and Table 2.2 )

EMM1 (04.12)

Actual risk

/ Consequence / Serious / x / Significant / Minor
Likelihood / Probable/significant / x / Possible / Remote / Nil / negligible

Benchmark

/ Consequence / Serious / X / Significant / Minor
Likelihood / Probable/significant / Possible / Remote / Nil / negligible / x
Risk gap (and table used) /

Single/low casualties(Table 2.1)

/ Extreme / x / Substantial / Moderate / Nominal

Multiple casualties(Table 2.2)

/ Extreme / Substantial / Moderate / Nominal
No breach of law OR no risk gap

EMM1 (04.12)

Section 4 – Initial Enforcement Expectation (Tables 5.1, 5.2 or 5.3

EMM1 (04.12)

Standard(Table 3) / Defined / / Established / X / Interpretative

Compliance / admin descriptor(Table 4)

/ Absent / / Inadequate / Minor Deficiencies

Compliance with permissioning document

/ Contravention / Irregularities / Compliance
Initial Enforcement Expectation / Prosecution / Crown Censure / x / IN / Direction / Specification / x / Letter / Verbal warning / No enforcement action
Permissioning document impact (table 5.3 only) / Revocation / Refusal / Direction / Amendment / Refusal / Variation / Amendment / Letter / Letter / verbal warning / Nil

EMM1 (04.12)