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Risk Assessment Guide:

Industrial-emission monitoring
The first publication of this document was created by the STA Health and Safety task
group in 1997, it has since been recognised by the Environment Agency and
implemented into the MCERTS scheme. It has also been adopted by a number of
countries in Europe and around the world. However, the document is based on the
requirements of UK health and safety legislation.
 Contents

1. INTRODUCTION .......................................................... 4
2. THE BASICS OF RISK ASSESSMENT ...................... 7
3. GENERAL SITE HAZARDS ...................................... 15
4. PHYSICAL HAZARDS AT THE STACK ................... 18
5. CHEMICAL HAZARDS AT THE STACK .................. 41
6. CHEMICAL HAZARDS IN THE LABORATORY ...... 48
7. WEATHER, ENVIRONMENT AND WELFARE ......... 48
APPENDIX 1 .................................................................. 56
APPENDIX 2 - Useful Links ......................................... 60
Table of figures
Figure 1: Example of a monorail system ........................................ 56
Figure 2: Monorail end view ........................................................... 57
Figure 3: Standard 125mm Sample port ........................................ 58
Figure 4: Lifting point ...................................................................... 59

Version 14 – August 2017

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 Record of amendments
Version Amendment Date
7 Section 2: Clarification of when a risk assessment is to be carried out inserted February 04
on page 6.
7 Section 4.1; page 13, reference to HSGN 017 platform inspection added. February 04
7 Section 4.1; page 14, Space/ size requirements for platforms brought in line
with EA guidance.
7 Section 4.1: box text on page 15 modified to included new STA guidance February 04
document HSGN0017
7 Section 4.2; page 17, Falling objects during lifting/ lowering guidance note February 04
number changed
7 Section 4.3; page 19, text box updated and addition of STA guidance note February 04
HSGN015.
7 Section 4.7; page 23, Control Measures STA guidance note updated February 04
7 Section 4.8; page 24, New section added on noise February 04
7 Section 7.4; page 37, Wind chill factor updated to include positive February 04
temperatures and limited to 30 MPH
7 Section 7; page 39, text box updated to include STA guidance note HSGN018 February 04
7 Appendix – All drawings updated to take into account recommendations for February 04
platform size, monorail attachments and sample ports.
8 Book revised to take into account Work at Heights Regulations April 2005
9 Various minor adjustments to take into account revised STA guidance. October 2006
10 Chapter 3. Page 9 and 10. Remove confined space as a site hazard and March 2008
replace in Chapter 5 on Chemical Hazards at the Stack
10 All Chapters. Update and amend Further Information sections March 2008

10 Chapter 4 Section 4.1 Page 11. Update statistics on fatalities March 2008

10 Chapter 4 Section 4.8 Page 27 Update Noise Exposure Limits March 2008

10 Chapter 5 Section 5.1 Page 29 Change references to occupational exposure March 2008
limits to Workplace Exposure Limits
10 Chapter 5 Insert text on confined space March 2008

10 Chapter 7 Section 7.7 Page 41 Amend working day recommended maxima to March 2008
12 hours and include reference to Working Time Regulations, specifying a
recommended maximum 48 hour week.
11 Various minor adjustments to take into account revised STA and EA August 2009
guidance.
11 Appendix 2 added “Useful links.” August 2009

12 Section 1 – Introduction bolstered to include legal perspective and glossary of June 2012
terms and definitions.
12 Section 2 - expanded to include more detail on risk assessment and June 2012
application of control measures.
12 Section 2 - expanded to include more detail on emergency planning June 2012

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12 Section 3 – General site hazards expanded to include extra examples of June 2012
hazards, reference to DSEAR, RIDDOR and coverage of safe systems of
work.
12 Section 4.1 – Further guidance on use of platform inspection records, prior- June 2012
to-use checks and a reference to BS EN 15259:2007.
12 Section 5.2 – expanded to include reference to Material Safety Data Sheets June 2012
(MSDS) and Registration, Evaluation, Authorisation and restriction of
Chemicals (REACH).
13 Section 1 – updated with new accident data and extended to include ‘six-pack’ October 2015
regulations.
13 Section 3 – extended to include more coverage of DSEAR including October 2015
description of dangerous substances.
13 Section 4.1 – references to BS EN 15259:2007 included in main text. October 2015

13 Section 4.1 - significant extra guidance on plans for emergency and rescue October 2015
added.
13 Section 4.7 – significant extra guidance on use of compressed gas cylinders October 2015
added.
13 Section 5.2 – extra information on REACH regulations added. October 2015

13 References to all STA guidance notes amended to reflect the new system October 2015
document classification which was introduced by the STA in 2013.
14 Section 4 – Amended to reflect the clarification received from the HSE about May 2017
their classification of permanent platforms with respect to the Work at Height
Regulations and Health and Safety at Work Act. Sundry other minor
amendments also made throughout the document at this time.

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1. INTRODUCTION
Legal Perspective
Each year in the UK, approximately 150 people are killed at work and
several hundred thousand more are injured or suffer ill-health as a
result of workplace activities. In the year 2013/14, it is estimated that
28.2 million workings days were lost due to work-related illness and
workplace injury which cost the UK economy over £14 billion. In the
UK, it is the job of the Health and Safety Executive (HSE) to prevent
people being killed, injured or made ill by work. A key piece of
legislation in the UK is the Health and Safety at Work etc. Act (HSW
Act) 1974. This is an Enabling Act which means that further laws
(known as Regulations) can be made without the need to pass
another Act of Parliament. There are now many Regulations which
support the HSW Act. A group of six regulations was introduced on 1
January 1993, popularly known as ‘the six pack’. These are:
 The Management of Health and Safety at Work Regulations
 The Display Screen Equipment Regulations
 The Manual Handling Operations Regulations
 The Personal Protective Equipment at Work Regulations
 The Provision and Use of Work Equipment Regulations
 The Workplace Health, Safety and Welfare Regulations
These regulations implement various European Directives on health
and safety and also clarify how employers must comply with their
duties under the Health and Safety at Work Act 1974.
The HSE has produced Approved Codes of Practice (ACOPs) for
many of these Regulations which give more details on the
requirements of the Regulations. The HSE also publishes a range of
further legal and best practice guidance which is available online.
The HSW Act places many duties on employers and employees but
essentially you have to ensure the health and safety of yourself and
others who may be affected by what you do or do not do. It applies
to all work activities and premises and everyone at work has
responsibilities under it. In general, the HSW Act requires people to
do what is ‘reasonably practicable’ to ensure health and safety.

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One example of more recent regulation is the Management of Health
and Safety Regulations 1999. These also apply to every work place
and, among other things, require all risks to be assessed and
controlled. Failure to provide evidence of risk assessment can result
in regulatory action.
Some requirements of HSW Act 1974 are set out below:
Employers’ Duties
 Provide safe plant and systems of work.
 Provide safe use, handling, transport and storage.
 Provision of information, instruction, training and
supervision.
 Provide safe place of work, access and egress.
 Provide safe working environment; adequate welfare.
 Produce written safety policy (>5 employees).
 Arrange for consultation with safety representatives.
Employees’ Duties
 Take reasonable care for the H&S of themselves and
others.
 Co-operate with the employer and others to enable them
to fulfil their obligations.
Some requirements of Management of Health and Safety at Work
Regulations 1999 Act 1974 are set out below:
Employers’ Duties
 Produce suitable and sufficient written risk assessment.
 Ensure proper planning, organisation, control, monitoring
and review of H&S measures.
 Ensure competent persons are employed.
 Prepare emergency procedures.
 Provide adequate information, instruction, training and
supervision.
 Consider risks to young persons and new/expectant
mothers.
Employees’ Duties

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  Use equipment or substances in accordance with training
or as instructed.
 Report any serious or imminent danger.
 Report any shortcomings in H&S arrangements.
Some terms and definitions
Health - protection from illness in workplace.
Safety - protection from physical injury.
Welfare - facilities to maintain health and well-being.
Occupational ill-health - Caused or triggered by workplace
activities.
Accident - unplanned event that results in injury or ill health of
people or damage or loss to property, plant, materials or the
environment (HSE).
Near miss - incident that could have resulted in an accident.
Dangerous occurrence - near miss which could have resulted in
serious injury or loss of life.
Hazard - potential of a substance, person, activity or process to
cause harm.
Risk - likelihood of a substance, person, activity or process to
cause harm.
Control measure - actions taken to reduce risk.
Residual risk - risk remaining once controls have been adopted.
PPE – Personal Protective Equipment.

Stack-emissions monitoring is an inherently hazardous occupation.

There are many hazards associated with carrying out a stack-
emissions test in process industry. The basic principles of good
health and safety practice must be applied. In particular, a risk
assessment must be carried out before starting work. Keep the
risk assessment in your job file – in the unfortunate event of an
accident or other event, it will be needed.
Note: The Environment Agency Mcerts scheme stipulates that a risk assessment shall be
carried out at the ‘site review’ stage (ie well in advance of the monitoring work being carried
out). This is to allow sufficient time for any changes in sampling facilities to be made if
necessary.

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This guidance booklet describes each of the most prominent hazards
in turn. The factors that affect the risk of an accident from each
hazard are listed and control measures are suggested which may be
used to reduce the risk to an acceptable level.
Note: The HSE has produced a guidance book Essentials of Health and Safety at Work.
(ISBN 978 0 7176 6179 4). This publication is available to download from www.hse.gov.uk
and is recommended as a useful reference source to augment this STA guidance booklet.
The STA recommends that, as a minimum, the routine hazards
described in this booklet should be included in your risk assessment.
But remember: this is not an all-encompassing list and there may be
other hazards. Every site is different.
2. THE BASICS OF RISK ASSESSMENT
The Risk Assessment Process
The fundamental stages can be summarised as:

Decide who Evaluate the Record your Review your

Identify the might be risks and findings and assessment
hazards harmed and decide on implement and update if
how precautions them necessary

The risk assessment is the basic foundation of safe working on

stacks. It’s very important to understand what we mean by hazard
and risk:

Hazard The substance’s or physical situation’s inherent

potential to cause harm.
Risk An estimation of the likelihood of that potential
being realised, within a specified period or in
specified circumstances, and the consequence.

Using a very simple example to illustrate this, sunshine poses a

health hazard (sunburn). But the corresponding risk of harm would
be very low if the work was carried out in winter. Another example is
working at height which is always hazardous; however, the risk can
be reduced to an acceptable level by the implementation of
appropriate control measures.
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So, the risk assessment must start out by identifying the hazards you
will face, who will be affected and then make a judgement on what
the risk will be (i.e. the likelihood of an accident) in light of all the
relevant factors. If the risk is not acceptable, then additional control
measures must be put in place to reduce the risk to an acceptable
level. Only then should you start work.
Control measures can be:
 Collective - such as engineering measures (e.g. a self-
closing gate to reduce the risk of falls from the platform)
and procedural measures (e.g. permit-to-work systems;
safety induction training provided by the operator); or
 Personal – using personal protective equipment (PPE)
(e.g. safety goggles to reduce the risk of eye injury when
opening access ports).
For many hazards there will be a choice of control measures that
could be implemented. The first consideration should always be
to investigate the possibility of removing the hazard altogether
(for example by elimination or substitution). If that is not possible,
collective control measures should always be considered
before personal control measures. Some of the reasons for this
are that collective control measures are usually easier to use,
require less training and maintenance and protect all users.
Conversely, personal control measures often require more
training and maintenance; they require the worker to use them
(and use them properly) and, even then, only protect the user.
Personal measures should be used to reduce the risk further only
when collective control measures fail to reduce the risk as low as
reasonably practicable. PPE shall not be the control measure of
first choice.
The Form of the Risk Assessment
Risk assessments are made mandatory by the Management of
Health and Safety at Work Regulations 1999 and also other
regulations (e.g. COSHH, Work at Height Regulations). These
regulations state that the risk assessment should be suitable and
sufficient. A risk assessment may be considered suitable and
sufficient if it includes the following:

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 Identifies significant hazards and risks.
 Identifies who is at risk
 Identifies measures to comply with any statutory provisions.
 Is appropriate to the nature of work.
 Remains valid over a reasonable period of time.
 Identifies the risks arising from the work.
 Includes a level of detail proportionate to risk.
 Is recorded.
Generic-type risk assessments are not usually suitable for stack-
emission monitoring work as the hazards will vary from site to
site and over time. A separate risk assessment must be carried
out at every location on each site. It is important that all relevant
aspects are included and that all necessary information is
obtained. Accordingly, a structured approach can be useful to
help ensure that the wide variety of hazards is covered; as such,
the use of pro-forma risk assessment sheets can be beneficial.
The STA example of a risk assessment summary form is
available on the Source Testing Association website at www.S-
T-A.org. It should be emphasised that this is an example only,
and will not cover all hazards at all sites and will not be
appropriate in every case. Organisations should use a risk
assessment format that is suitable for their specific needs.
In general, a qualitative risk assessment approach is used* by
stack-emission monitoring organisations, whereby the severity of
the hazard is considered together with the likelihood of
occurrence to obtain an estimate of the risk of injury. The risk can
be described in several ways: some assessors classify the risks
as “high”, “medium” or “low”. However the STA prefers the
classification of risks as either “negligible”, “as low as reasonably
practicable” (ALARP), or “unacceptably high”. The logic here is
that if it is reasonably practicable to reduce the risk further, it

* The quantitative risk assessment approach is not the most common approach for stack-emission
monitoring health and safety risk assessments; although it is recognised that some organisations favour
this type of method.

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 should be done. Not to reduce the risk further when it is
reasonably practicable to do so, is unacceptable.
It is important to remember that the assessment should be of the
risks as they are at the time that the risk assessment is performed
- not as you think they will be after any necessary control
measures are put in place. The risk assessment should be
repeated or revised once the control measures have been
implemented. It is important to ensure that the risk assessment
is reviewed at regular intervals and at least every day, before
work commences or in the case of a change in work location.
These are often referred to as ‘tool-box’ checks and focus on the
aspects of the risk assessment which are most likely to have
changed since the previous risk assessment – for example,
weather, personnel, process conditions etc. This ‘dynamic’
approach to risk assessment is necessary to take account of
hazards which may be variable with time.

Who Does What?

The Management of Health and Safety at Work Regulations 1999
place a duty on employers to have a safety policy and to carry
out risk assessments. So both the stack-emissions organisation
and the client (usually the operator) have a responsibility to carry
out a risk assessment. If work is being carried out directly for a
regulator; the organisation, the operator and the regulator all
have responsibilities* in this regard. In practice, if you are an
MCERTS certified person, you will be best placed to assess the
risks to you and others during the monitoring work you do on site
– don’t be tempted to leave the workplace risk assessment to
someone else. For example, as part of being certified as
competent under the MCERTS scheme, you will have

*The HSE has advised the STA that for the purposes of the Health & Safety at Work Act, the monitoring
organisation has a direct duty of care towards its own staff conducting the monitoring, and the process
operator has a duty of care towards all persons working on the site, including the monitoring
organisation.

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 successfully completed an appropriate safety and risk
assessment training course.
Note: The MCERTS scheme for manual stack-emission monitoring makes it
mandatory for risk assessments to be approved by someone qualified to MCERTS
Level 2.
The risk assessment should not be confused with the platform
inspection. The latter should be carried out by the employer (i.e.
the site operator) using a competent person. These platform
inspections are not carried out by the monitoring team. However,
it is necessary to see a platform inspection report (or other
evidence that the platform is acceptable for use) to be able to
properly conduct the risk assessment. Your risk assessment will
not be suitable and sufficient if you have not considered this
issue.
However, the person using a platform should also perform their
own check ‘prior-to-use’ check. This is not a formal inspection but
should take account of factors such as:
 Ladders: are they secure, with no bolts missing, and free
from corrosion and grease?
 Handrails: Are they secure, with no bolts missing and free
from corrosion?
 Floor plates: are they fixed securely with no bolts missing
and free from corrosion?
 Access hatches: are they closed when not in use?
…and When?
For a new client, a site visit will be necessary to properly assess
the risks. This gives the site operator time to implement any
control measures that you find are necessary.
Note: The Environment Agency Mcerts scheme stipulates that a risk assessment shall
be carried out at the ‘site review’ stage (ie well in advance of the monitoring work being
carried out). This is to allow sufficient time for any changes in sampling facilities to be
made if necessary.
For sites with which you are familiar, a separate reconnaissance
visit may not be necessary but you must still carry out a risk
assessment before you start work. It is important that this risk
assessment is carried out at the start of every monitoring
campaign at the site, even if you have visited the site frequently

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 before. This is a good discipline because it focuses the team’s
attention on safety as the first issue to address on site, and it
reduces the possibility of the staff becoming complacent after
several visits because they feel they know all the issues.
The risk assessment must be carried out at the start of each
campaign and should be reviewed at least daily or following a
change in location and before starting work. However, it is
important to note that there are some hazards, such as weather
conditions, which can change rapidly and, therefore, risks might
need to be re-assessed at more frequent intervals.
Monitoring work shall only commence when the risk assessment
has been completed and the control measures have been
implemented to the satisfaction of the competent person carrying
out the risk assessment (normally the monitoring Team Leader,
MCERTS Level 2). The risk assessment shall be communicated
by the Team Leader to, and signed by, other members of the
monitoring team before work commences and whenever the risk
assessment is revised.
Getting the Operator Involved
On arrival at the site, you should ask the site operator to
demonstrate that the platform and access/egress are acceptable
– for example by producing a platform inspection report for the
stack(s) you will be working on. Check that the platform
inspection report has been carried out within the time period
specified and check that it states that the platform is safe to work
on. Take the evidence into account when making your risk
assessment or your insurance cover could be invalidated. If no
evidence such as a platform inspection report is available for
work at height, do not proceed with the work.
The STA recommends that when you have completed your risk
assessment you should brief the operator’s representative on the
findings. This will give the operator the opportunity to raise any
additional issues of concern or site activities that may affect you,
and to comment on the findings of the assessment and the
control measures you have decided will be necessary. If the
operator has any comments, you will wish to consider these and
assess whether they can be incorporated into the assessment
12
 and its findings: they may reduce the risk further (which is fine),
or hinder the reduction of risk (which is not).
Some of the control measures you require may need to be put in
place by the operator. Get the operator’s confirmation that these
have been completed, before you start work.
When you have finished the site work, make any relevant
comments on the risk assessment based on any lessons learned.
This will be useful for the next visit.

The Layout of this Booklet

The following sections describe each of the most prominent
hazards in turn, grouped together in five main categories:
 general site hazards.
 physical hazards at the stack.
 chemical hazards at the stack.
 chemical hazards in the laboratory.
 weather, environment and welfare.
Important factors affecting the risk are highlighted, together with
some control measures that may be used to reduce the risk to an
acceptable level.
It is recommended that this guidance, together with other
relevant guidance, is consulted as part of the risk assessment
process. However, safety management is a fast-evolving subject
and new or revised guidance and legislation appears frequently.
All parties involved in stack-emission monitoring should ensure
they take account of the most recent developments.

13
 Figure 1 Some prominent hazards associated with stack-emission monitoring

Wind, rain, lightning, Site traffic

snow and ice
Mechanical operations

Sunburn
Chemical operations
Weather, General site
environment and hazards
Lone working welfare Confined spaces

Tiredness
Lifting
RISK TO
HEALTH & Falling
SAFETY

Burns
Physical hazards at
Chemical hazards in the stack
the lab Electricity

Chemical hazards at Compressed gases

the stack
Exposure to Radiation
substances used in
analysis and cleaning

Exposure to Exposure to
substances used in substances from
monitoring tests the flue gas

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3. GENERAL SITE HAZARDS
Each site has its own specific set of hazards. These might
include:
Site traffic hazards
The movement of vehicles around site is a hazard. The sampling
team may be in unfamiliar surroundings and they may be working
on a temporary access platform, the existence of which is not
known to the site drivers.
Mechanical operations hazards
The mechanical aspects of the process can be hazardous. For
example, the sampling workplace or access route may be in, or
near, large moving machinery (eg presses or cranes).
Chemical operations hazards
Chemical processes are often hazardous. This includes the
product stream and waste streams (e.g. stack gas releases,
fugitive emissions, liquid discharges).
Infection hazards
Some processes can give rise to biological hazards such as;
 Medical waste – hepatitis
 Sewage treatment processes – Leptospirosis/Weil’s
disease
 Cooling Towers/Air-conditioning systems – Legionnaires
disease
Climatic conditions
The climatic conditions on site can be hazards in themselves
(e.g. temperature extremes) but can also increase the risk from
other hazards (e.g. high wind increases the risk of a fall, cold/wet
weather increases the risk of dropping equipment). Weather and
the environment are covered in more detail in Section 7.
Fire and explosion hazards
At many sites, particularly in the organics and petrochemicals
industry sectors, there are fire and explosion hazards. These are
covered by The Dangerous Substances and Explosive

15
 Atmospheres Regulations 2002 (DSEAR). Dangerous
substances are any substances used or present at work that
could, if not properly controlled, cause harm to people as a result
of a fire or explosion or corrosion of metal. They can be found in
many workplaces and include such things as solvents, paints,
varnishes, flammable gases such as liquid petroleum gas (LPG),
dusts from machining and sanding operations, dusts from
foodstuffs, pressurised gases and substances corrosive to metal.
DSEAR includes a requirement to undertake a risk assessment
relating to explosive atmospheres and to employ suitable safety
management systems to ensure that an adequate level of
explosion safety is maintained. There is also a requirement to
conduct area classification (zone 0, 1 or 2) and to define locations
of hazardous areas in the workplace.
Note: The definition of a hazardous area is ‘any place in which an explosive
atmosphere may occur in sufficient quantities to require special precautions to protect
the health and safety of the workers concerned is deemed to be hazardous’.
Control Measures
The importance of induction training and permit-to-work systems
cannot be over-emphasised. Procedures for first-aid on site and
emergency evacuation procedures must be generated. These
will vary greatly between sites. It is essential that you fully
understand the permit-to-work system, procedures for first-aid,
and emergency evacuation procedures for the site in question.
If you are unsure of any of these aspects, they must be clarified
before starting work.
You must comply with any control measures that the site operator
puts in place, e.g. site speed limits, use of PAT-tested or ATEX-
rated equipment.
Work must only start work at the monitoring position if weather and
environmental conditions are safe and stable.
Most accidents are multi-causal and, as such, an integrated
approach to risk management is needed. Mistakes cannot always be
eliminated entirely, therefore it is important that the workplace is
made safe even if a mistake is made. Making the workplace safe
includes providing instructions, procedures, training and supervision
to encourage people to work safely, as well as taking account of the
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nature of the task, timing issues (eg weekend or night work) and
providing appropriate PPE. A permit-to-work might be thought of as
a specialised type of safe system of work.
The HSW Act requires ‘safe systems of work’ but does not go into
detail. Guidance on what this means in practice has been produced
by the HSE in their publication Essentials of Health and Safety at
Work. The reader is encouraged to consult this document for further
information. The reader’s attention is also drawn to the requirements
of the Reporting of Injuries, Diseases and Dangerous Occurrences
Regulations 1995 (RIDDOR). These regulations place duties on
employers, the self-employed and people in control of work premises
(the ‘Responsible Person’) to report serious workplace accidents,
occupational diseases and specified dangerous occurrences and
near misses. See links below for more information.

STA guidance
STA HGO-005 Safety Passports
STA HS 1057-00 Example Risk Assessment
Further information
Management of Health and Safety at Work Regulations 1999.
Workplace (Health, Safety and Welfare) Regulations 1992
and accompanying Code of Practice.
Essentials of Health and Safety at Work. HSE ISBN 978 0
7176 6179 4indg 370 dsear (HSE)
www.hse.gov.uk/riddor/

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4. PHYSICAL HAZARDS AT THE STACK
4.1 Hazard: working at height
This is a major hazard in stack testing. A large proportion of fatal
injuries to workers are caused by falls from heights, and there
have been examples of fatalities resulting from falls during stack
emission monitoring. The risks of injury from falling from height
are so serious that a high standard of protection is required to
reduce the risk of falling to as low as reasonably practicable.
The employer must ensure that the workplace and access meet
all current legislative requirements, are maintained to a safe
standard and have been inspected by a competent person.
Under the Workplace Regulations and Health and Safety at Work
Act, a safe place of work must be provided by the process
operator, but under the Work at Height (WAH) Regulations there
are some specific duties that fall on employers when they engage
people in activities which requires work at heights.
Sampling from any elevated workplaces, whether platforms,
roofs or the tops of arrestment equipment, vessels and other
ducts is unacceptable unless they have been inspected and
assessed as being suitable. Further information concerning the
requirements for platforms is available in the WAH Regulations,
EA Technical Guidance Note M1, BS EN 15259 and STA
Guidance Note: Inspection of Permanent Elevated Work
Platforms WAH 001.
Mobile elevated work platforms are usually inappropriate for the
majority of stack emissions monitoring work. Sampling from
ladders is always unacceptable. Further guidance on these
issues is available in EA Technical Guidance Note M1.
Factors affecting the risk
 To some extent, the height at which the stack monitoring is to
be carried out is a risk factor. The Work at Height Regulations
apply to work in any place, including a place above or below
ground level, where, if measures required by those regulations
were not taken, a person could fall a distance liable to cause
personal injury ie there is no minimum height.

18
  The type of surface, objects or substances onto or into which
a person could fall.
 The structural stability, strength, integrity and condition of the
sampling platform.
 The size of the sampling platform.
 Provision of suitable safeguards to prevent falls, e.g. railings,
self-closing gates.
 Environmental conditions (e.g. wind, rain, ice) at the work
location.
 The adequacy and suitability of the means of access/egress to
the sampling location.
 The means by which equipment will be lifted to the platform.
Unless suitable control measures are taken, the risk of injury or
death will be unacceptably high. The risks must be reduced to as
low as is reasonably practicable through the identification and
application of appropriate control measures.
Hierarchy of Control Measures
The WAH Regulations require the employer to avoid carrying
out work at height where reasonably practicable. However, if it
has to be carried out, then he must take appropriate measures
to prevent falls by:
i. firstly, taking the appropriate measures to prevent falls,
preferably by working from an “existing place of work” (best
thought of as anywhere where you do not need to use any
extra work equipment to prevent a fall, i.e. a safe and fully
protected place); or if this is not possible
ii. using work systems comprising the most suitable work
equipment, instructions and training.
‘Work equipment’ can include relevant machinery, tools,
appliances, apparatus, installations, guard rails, barriers,
working platforms, collective fall arrestment devices (e.g. net or
airbag), and personal fall protection systems (e.g. ropes,
harnesses, lanyards, fall arrestors). Collective control measures
must be given priority over personal protection measures.

19
 Where work equipment is to be used as the safety measure(s),
the hierarchy is:
a) use work equipment to prevent a fall (e.g. guard rails, or work
restraint); then,
b) use work equipment to minimise the distance of the fall and its
consequences (e.g. erection of nets, fall-arrest PPE); then,
c) use work equipment to minimise the consequences of a fall (e.g.
an airbag, or wear a lifejacket if working at height over water – it
is not just the fall impact that needs to be considered); then,
d) use work equipment that does none of the above (e.g. ladders,
hop-ups, etc.) but minimise the risk of any fall occurring through
appropriate measures (e.g. supervision and training, etc.).
finally, an emergency rescue plan must be established – that
does not rely on the emergency services.
Further Guidance on Collective “Work Equipment”
 Platform stability, strength, integrity, condition and
inspection
Platform design and construction – All platforms, whether
temporary or permanent must be fit for purpose* and in
particular must be of suitable dimensions and capable of
supporting the required load.
Temporary platforms – the WAH Regulations (Schedule 3)
place specific requirements on strength and stability
calculations for scaffold, assembly, use, dismantling and
marking/labelling. Compliance with these requirements is
mandatory.
Temporary platforms must be tied or supported to a permanent
structure to prevent collapse or overturning. They must meet
the requirements stated in the monitoring standard (if present)
and must be of suitable dimensions and capable of supporting
the load required to fulfil the measurement objective (ref: BS
EN 15259, s6.2.3.1).

*A number of CEN standards (eg EN 15259) have been published which give guidance on access and
platforms and a British Standard exists covering permanent access.

20
 Temporary platforms must be inspected and assessed by a
competent person as required by the Work at Height
Regulations. Monitoring teams should ask to see evidence of
the inspection and assessment. A properly completed and
dated “Scafftag” is one means of demonstrating and recording
this inspection. Double-check yourself that the inspection tag
covers the load category suitable for your work – this would
normally be ‘heavy duty’, but could be a lower rating depending
on requirements of a particular job.
Permanent platforms
Note: During the summer of 2016, lengthy correspondence
took place between the Health and Safety Executive, the
Environment Agency and the Source Testing Association
concerning the issue of platform inspections. During the
course of this process, it became clear that the HSE regards
permanent platforms (erected for the purpose of conducting
stack-emission monitoring) as being classed as ‘existing
places of work’ because they form part of the fabric of the
building or structure. As such, they would not be considered
to be pieces of ‘work equipment’ as defined by the Work at
Height Regulations (2005) and, therefore, the regulation of
these platforms would be covered primarily under the Health
and Safety at Work etc. Act (1974, Section 4). However, the
HSE would still expect duty holders to instigate and
maintain an inspection regime which is both reasonable and
proportionate.
The STA considers that the general guidance contained
within this document concerning the conduct and frequency
of inspections for permanent platforms remains valid.
It is important to understand that stack-emissions monitoring
may require platforms that can support up to six people and up
to 300 kg of equipment.
The structural integrity and condition of permanently installed
platforms (and any supports and attachments) must be
inspected and assessed by a competent person.

21
 For post-1995 permanent platforms, an initial design
assessment may have been carried out under the Construction
(Design and Management) Regulations 1994, (now 2007)
which should address whether the platform is fit for purpose. If
not, the operator should arrange for a survey to be carried out
by a competent person to establish its current integrity and
condition. This ‘baseline’ survey will then recommend the
extent and frequency of subsequent periodic, routine
inspections that will also include the effects of weathering,
corrosion and damage. The frequency of inspection and the
comprehensiveness of the inspection shall be commensurate
with the risk of failure and the risk of serious injury. For
example, a steel platform at great height and in a corrosive
atmosphere may require a more frequent and thorough
inspection than a platform in a benign atmosphere.
Monitoring teams should ask to see evidence of the inspection
and assessment before they ascend to the work area. They
should record the fact that an appropriate inspection record is
available as part of their own risk assessment procedure. The
STA also recommends that stack testers perform their own
prior-to-use check. This might include a visual observation of
ladders, gantries and platforms to check for signs of damage
or corrosion, presence of grease on ladder rungs etc. (see
section 2).
 Required features for all platforms
Platform safety features - schematics of platform
requirements are given in Environment Agency Technical
Guidance Note M1 Sampling requirements for stack emissions
monitoring. These diagrams should be referred to in
conjunction with the following requirements.

Note: Environment Agency Technical Guidance Note M1 contains many references

to BS EN 15259:2007 ‘Measurement of Stationary Source Emissions - Requirements
for the measurement sections and sites and for the measurement objective, plan and
report’. The reader is strongly advised to have access to both documents.

22
 The platform shall be provided with guard-rails and toe-boards
meeting the requirements of Schedule 2 of the WAH
Regulations. The top guard rail shall be at least 950 mm* above
the edge and an intermediate guard rail shall be positioned so
that the gap does not exceed 470 mm. STA guidance is that
toe-boards (also called kickboards) should be approximately
0.25 m high.
There is also a practical requirement that the tops of handrails
should be far enough below the centre line of the access ports
so that they do not interfere with the insertion and removal of
the sampling apparatus. Though the 125mm minimum quoted
in standards is adequate for Pitots and simple sample probes,
a clearance of 500mm is required to allow access with more
complex sampling trains having back-end sample collection.
Where the selected sample plane is located in a horizontal
section of a large rectangular duct, and where some of the
sample points are positioned above a convenient and safe
working height (nominally 1.75 m maximum for sample probe
handling), it will be necessary to provide a dual level sampling
platform of adequate design or facilities to suspend sampling
equipment from a monorail system so that sampling staff can
carry out the full range of sampling requirements in a safe and
satisfactory manner. Removable chains, trap doors or self-
closing gates shall be used at the platform to prevent workers
falling through access hatches or ladder wells.
The platform shall have suitable weather protection for
personnel and equipment. The platform shall not accumulate
free-standing water: if necessary, drainage is to be provided.
Space/size requirements for platforms - these are given in
Environment Agency Technical Guidance Note M1 Sampling
Requirements for stack emissions monitoring. For example,
the minimum platform depth in front of the access port shall be
internal diameter of the duct (plus wall thickness) plus 1.5m.
Where the details of sampling equipment are not known, or

*For existing guard-rails, the requirement is at least 910 mm. Previous STA guidance required for a top
railing height of 1000 mm and so should meet this requirement.

23
 may change, the general rules given in M1 should be adhered
to.
It is very important that equipment must be kept within the
confines of the platform at all times i.e. not extending over or
outside of the handrails.
Further Guidance on Personal ‘Work Equipment’
The WAH Regulations (Schedule 5) place strict limitations on
when personal fall protection systems can be used, and by
whom. Specific requirements are given for fall arrest systems,
work restraint systems, work positioning systems and rope
access and positioning techniques.
Personal fall protection systems should only be used when a risk
assessment has demonstrated that work can be carried out
safely and that the risk of falling cannot be reduced to as low as
reasonably practicable by collective work equipment. A personal
fall protection system must be suitable and sufficient (and
regularly inspected to show this), and the user must have
received adequate training.
There are two types of harness: an arrestment harness designed
to catch you, and a restraint harness designed to stop you falling
in the first place. The HSE has advised us that the type suitable
for use when carrying out lifting-up of equipment, etc. is a
restraint harness. The STA is of the view that if the sampling
location is so risky that a harness needs to be worn during
actual sampling, or that an arrestment harness needs to be
worn, then the risk of injury to our members outweighs the
potential environmental benefits of the monitoring data and
therefore the work should not proceed. However, it is
acknowledged that undertaking an emergency recovery of an
individual who is wearing a harness can be easier as this will
often provide an attachment point for the rescue team. STA
Guidance Note HGE-002 gives some further information on PPE.
Other Issues Concerning Work Platforms
Planning, supervision and competence
The WAH Regulations require the employer to ensure that work
performed at height is properly planned, appropriately
24
supervised and carried out in a way that is, as far as is reasonably
practicable, safe. This includes selection of equipment,
procedures for emergencies and rescue, and due consideration
of adverse weather conditions. The WAH Regulations also
require the employer to ensure that competent persons carry out
all activities (including organisation, planning, supervision and
inspection).
Essential services and facilities at the workplace
 The sampling position shall have artificial lighting (if
needed) and shall be well ventilated. Single phase, 110
volt (preferably centre-tapped) electrical power of a
suitable current shall be provided by means of a suitable
number of outdoor waterproof sockets at the platform.
Water, drainage and compressed air shall be supplied if
requested by the sampling team.
 Lifting equipment is required for the raising and lowering of
apparatus where access to the sampling platform is by
vertical or steeply inclined ladders or stairs. In all such
cases, the lifting equipment (e.g. hoists) and attachments
must be installed, inspected and maintained by the site
operator (see Appendix, Figure 4). Inspections of lifting
equipment should be undertaken at least once every
twelve months and records should be kept for two years.
 If a US EPA Method 5 type sampling train is to be used,
the platform may need to be fitted with suspension points
to enable the use of a sampling monorail (see Appendix,
Figure 1 & 2). The STA recommends this approach to
reduce risks associated with manual handling.
 The platform or workplace shall be, as far as possible, free
from obstructions that would hamper the sampling effort.
 Protection from the elements will usually be required for
an outdoor sampling position.
 An additional access port or hole to vent sample air back
into the duct may be necessary if the flue gas presents an
exposure hazard.

25
Planning for Emergencies and Rescue
The Work at Height Regulations requires that there is a workable
plan in place for emergencies and rescue. This plan should take
account of, and be proportionate to, the attendant risks at each
specific location where work at height is carried out.

The HSE Work at Height Brief Guide stipulates that; ‘you must plan
for emergencies and rescue, e.g. agree a set procedure for
evacuation. Think about foreseeable situations and make sure
employees know the emergency procedures. Don’t just rely
entirely on the emergency services for rescue in your plan’.

The plan should be a joint effort between the site and also the
teams or personnel working at height. Procedures will vary
between sites depending on a variety of parameters, such as
height of work, means of access, duration of task and the type of
site. Each site should have an emergency plan which is based on
the actual risks specific to that site.
So, companies cannot simply rely on the Emergency Services
without having any other plan. It may be that the Emergency
Services could cope with a rescue from height from a site in some
cases; however this should be discussed with them to ensure that
this is the case. Fire & Rescue services have local liaison officers
who can be contacted to discuss these issues. The outcome of
these discussions could influence what action needs to go into the
site plan.
For example, a major industrial site might have a well-developed
Site Emergency Response Plan, which details site evacuation and
assembly procedures, contact procedures for the emergency
services and lists responsibilities and contact numbers of key
personnel, such as qualified first-aiders. The plan might also
contain instructions covering the set-up of control rooms and
include contact details for utility suppliers. Other items might
include a chemical inventory, isolation procedures, spillage and
other environmental procedures, as well as check lists and forms
to be completed as required.

26
However, whilst it is acknowledged that the above scenario might
be appropriate for a major industrial site it may be exceed that
which is required for smaller sites. Accordingly, it is vital that the
plan is produced as part of the site-specific risk assessment
procedure.
When considering the personnel working at height, such as the
sampling team, it is vital that they discuss the plan before
commencing work to make sure they are comfortable with it and
also to make the site aware of their work activities and locations.
This is important as the site may have overlooked these activities
as part of their plan, focusing on the everyday tasks of their own
employees. The sampling team may also consider the use of
harnesses. As well as being used for fall prevention these can be
used to lower casualties with designed kits by trained staff. It is
easier to rescue an individual with a harness on as this will often
provide an attachment point.
Consideration should be given to the circumstances in which the
casualty should be stabilised in-situ (normally the preferred option)
and those circumstances where rescue or evacuation would be
necessary. For example, a worker who has fainted on a sample
platform should be attended to in-situ because any attempts to
move the casualty might increase the risks of further injury.
However, a worker who falls and is suspended above ground
would need to be rescued rapidly. The guidance published by the
Work at Height Safety Association (Technical Guidance Note №
5) is a useful source of further information. A distinction is made
between the terms ‘rescue’ and ‘evacuation’. Rescue typically
involves the recovery of a casualty by a third party (either remotely
or directly) whereas evacuation is typically effected by the
stranded user to escape from a remote location.
Of particular importance is the need to ensure reliable
communication such that help can be made available promptly. It
is also noted that the provision and availability of First-Aid should
be considered with specific reference to the particular
requirements necessary when working at height.

27
The means of access/egress must be safe at all times. All workers
need to be made aware of the arrangements for emergency
evacuation.
In summary it is important that the following are considered when
devising an emergency plan:
 Risk assessment to consider what could happen, could people
be trapped at heights, for example. This could vary depending
on the nature of the site.
 Plan could depend on size of site
 May be appropriate to rely on emergency services – but must
liaise with them first – do not just assume that you can rely on
them alone.
 Fire & Rescue have local liaison officers who are happy to
attend site for discussions.
 The emergency services might include ‘High Line Rescue
Teams’ and ‘Ambulance Service Heart Teams’ but they could
be located some distance away.
 If there is no immediate risk to life – leave alone and call
Emergency Services.
 It can be easier to rescue people who are wearing a harness.
It is important to note that the issues outlined above must be
considered by the site, and staff going on to site, as part of a risk
assessment. This is because, if there is an incident and the
emergency services are called, it would be reported to the HSE.
If it is found that they were not considered, or that if no plan was
in place, then prosecutions could follow.

28
STA guidance
STA HGO-008 Platform Inspection Questionnaire
STA HGE-008 Suitability of MEWPs relating to stack-emission
monitoring

Further information
Environment Agency Technical Guidance Note M1 Sampling
requirements for stack emissions monitoring
BS EN 15259:2007 Measurement of Stationary Source
Emissions - Requirements for the measurement sections and
sites and for the measurement objective, plan and report.
Work at Height Regulations 2005
Work at Height Regulations 2005 (as amended) – a brief
guide HSE (indg401, rev2, Jan 2014)
BS 4211:2005 Specification for permanently fixed ladders
The Work at Height Safety Association, Technical Guidance
Note № 5. Guidance on rescue during work at height.
Work at Height Awareness Syllabus, Advisory Committee on
Work at Height Training (ACWAHT).
BS 8454 - Code of Practice for delivery of training and education
for work at height and rescue.

29
4.2 Hazard: Falling Objects and Danger Areas
This hazard occurs because of objects potentially falling from the
platform itself and also during lifting and lowering of equipment.
The risks of injury from falling objects can be serious. Many
fatalities are caused each year in the UK workplace by falling
objects.
Factors affecting the risk
 Falling objects from platforms – the risk of falling objects is
increased when working on grid floors.
 Falling objects from platforms - temporary working platforms
can have gaps between scaffold planks.
 Falling objects from platforms – the risk is increased if the
platform does not conform to the requirements for kickboards/
toe boards.
 Falling objects during lifting/lowering - there can be a large
amount of unwieldy equipment to lift into awkward positions.
The weight of the equipment and the height it needs to be lifted
affect the risk of injury.
 Falling objects during lifting/lowering - the effects of cold, wind
and rain increase the risk.
 Falling objects during lifting/lowering - the risk of falling objects
is increased if there is lack of adequate provision for lifting
equipment or space that leads to snagging and objects falling.
Unless suitable control measures are put in place, the risk of
injury may be unacceptably high. The risks must be reduced to
as low as is reasonably practicable through the identification and
application of appropriate control measures. Examples are listed
below.
Control Measures
The WAH Regulations contain specific provisions relating to
falling objects and the resulting danger areas. Amongst these are
requirements for the employer, as far as is reasonably
practicable, to:
i. firstly, prevent the fall of objects; then

30
 ii. prevent a person being struck by a falling object.
Danger areas (exclusion zones) must be clearly indicated and,
where reasonably practicable, equipped with devices preventing
unauthorised entry.
The Lifting Operations and Lifting Equipment Regulations 1998
(LOLER) apply. These cover, amongst other things, periodic
checking of equipment, record keeping and visual checks before
use. You should ensure that staff are suitably trained and
competent in lifting and lowering operations. Consult STA Health
Safety Guidance Note HGE-004 and HGE-005 for further
guidance.
Some recommended control measures are:
 Falling objects from platforms – elevated platforms must have
toe boards.
 Falling objects from platforms – Any gaps in the floor should
be filled in (e.g. with mesh) where equipment or tools could fall
and endanger people below.
 Falling objects from platforms – The area below the access
and working platform should be designated a hazardous area.
Restrict access to appropriate personnel. Use Danger Working
Overhead signs and a physical barrier if possible. It is
advisable that the exclusion zone extends beyond the
‘footprint’ of the platform because if an object is dropped it
might strike obstructions as it falls and ricochet in
unpredictable ways.
 Falling objects during lifting/lowering - all elevated working
platforms must have a secure lifting point (see Appendix,
Figure 4). Ensure any temporary platform cannot topple over
when equipment is hoisted up.
 Falling objects during lifting/lowering - use a safe lifting system
of work. Two people should be used in all lifts. Ensure no one
is directly underneath the lifting point during a lift.
 Falling objects during lifting/lowering - ensure that the loads do
not exceed the safe working load (SWL) of the hoist or support.
Ensure the lifting equipment is in serviceable condition. STA

31
 guidance HGE-005 gives an example of an inspection report
record.
 Falling objects during lifting/lowering - PPE: Hard hats and
protective footwear should be used. STA Guidance Note HGE-
002 gives some further information on PPE.

STA guidance
STA guidance HGE-004, LOLER Regulations
STA guidance HGE-005, LOLER Inspection Reports
Further information
The Lifting Operations and Lifting Equipment Regulations
1998 (LOLER)

4.3 Hazard: Manual handling

The preparation and demobilisation for stack-emissions testing
usually requires a considerable degree of manual handling of
sometimes heavy equipment such as gas cylinders, control
boxes, etc. Such activities are subject to the Manual Handling
Regulations 1992. An outline of the requirements is given in STA
Health & Safety Bulletin, No.3, July 2001. It should be noted that
there is a specific legal requirement to carry out a manual-
handling risk assessment for tasks that cannot be eliminated or
avoided and could result in injury.
Factors affecting the risk
Guidance on the Manual Handling Regulations issued in 1998,
includes comprehensive advice on the assessment of manual-
handling risks. Reference should be made to that document.
However, major factors affecting the risk of injury are:
 The weight of the object.
 The shape and size of the object.
 The distance to be moved through.

32
  The physical capability of the employee to handle the load.
 The extent of manual-handling training the employee has
received.
Control Measures
Examples of control measures that may be employed for stack
monitoring are:
Engineering controls – consider if it is possible to mechanise
the task, e.g. using hoists for lifting.
Procedural controls – ergonomic design is important, e.g.
storage of equipment at a height that eliminates it being lifted
from, or to, floor height. Training in safe-lifting procedures is
essential. Management should ensure that staff employed to
carry out such work are physically capable of carrying it out
without injury.
Personal Protective Equipment (PPE) – safety shoes/ boots
should always be worn. Protective gloves may be needed for
sharp or rough objects. Back supports are sometimes used as
PPE for lifting: however, these are not a substitute for
controlling the risk at source and they may encourage lifting
beyond a person’s normal safe limits.
Guideline limits for lifting have been set at 25kg for a man and
16kg for a woman.

STA guidance
STA Guidance HGE-007, Manual handling
Further information
HSE INDG143 Rev 2 Getting to grips with Manual Handling
HSE INDG383 Manual Handling assessment charts
Manual Handling Operations Regulations 1992

4.4 Hazard: electricity

A considerable amount of electrical equipment is used during
stack-emission monitoring – sometimes in quite adverse
33
 environments, e.g. rain, dust or surrounded by lots of bare metal.
The risks of injury from personnel receiving an electric shock,
especially on a high platform, can be serious.
Factors affecting the risk
 Portable electrical equipment may be used in cramped spaces
with a lot of bare metal.
 The design of probe-heating elements can increase the risk.
 Rain or water ingress can increase the risk.
 The site power supplies can be unreliable in terms of both stability
of supply and type and suitability of socket.
 Some site plant may itself pose an electric-shock hazard, e.g.
electrostatic precipitators.
Unless suitable control measures are taken the risk of injury can
be HIGH. The risks must be reduced to as low as reasonably
practicable, using appropriate control measures.
Control measures
The Electricity at Work Regulations 1989 apply to electrical
equipment and instruments used for stack monitoring. The
Regulations cover, amongst other things, equipment inspections
(e.g. portable appliance ‘PAT’ testing) and visual checks before
use. You should consult STA Health Safety Guidance Note HGE-
003 for further guidance on electrical supplies. Some other
control measures are:
 The site operator must ensure the provision of a power supply
that is stable and safe with a suitable number of outdoor,
waterproof sockets at the sampling location (platform or other
workplace).
 The voltage on the equipment should be 110V, via an isolating
centre earth transformer. Do not use 240V equipment on
sampling platforms.
 Have your electrical equipment regularly inspected and PAT-
tested by a competent person.
 Regularly check electrical equipment yourself between PAT-
tests. For example, visually check casings, leads, cables and
plugs.
34
  Protection devices such as Residual Current Devices (RCDs)
should be used at the point of power.
 Trailing leads should be highly visible and should be protected
from process operations.
 Take extreme care when manoeuvring probes, Pitot tubes, etc.
in the vicinity of live power lines which may be overhead. For
example, do not sample too close to electrostatic precipitators or
power supplies for overhead cranes.
 Hot gases can conduct electricity quite well and can lead to
shocks downstream if sampling too close. When sampling after
ESPs ensure that the equipment is suitably earthed using
earthing straps.

STA guidance
STA Guidance HGE-003, Understanding Electrical Supplies
Further information
HSG107, Maintaining portable and transportable electrical
equipment (2004)
HSE INDG231 Electrical Safety and you 2005

4.5 Hazard: High temperatures

Hot flue gases and hot duct work and equipment can cause
serious burns.
Factors affecting the risk
 The temperature of the flue gas.
 Flue gas under high positive pressure.
 Whether the hot surfaces are lagged or guarded.
 Manipulating unwieldy equipment.
 The amount of space available on the working platform.

35
Control measures
 Find out the temperature and pressure of the flue gas before the
visit.
 Use PPE appropriate for the risk, e.g. protective gloves and
covered forearms. Eye protection should always be worn.
 Loosen ports slowly.
 Sufficient staff should be available to safely handle the
equipment.
 The platform should be large enough to safely accommodate the
equipment.
4.6 Hazard: ionising radiation
There is potential for exposure to ionising radiation whilst working
on stacks at some specific types of site. This applies only to a
small number of specialised processes. These are specifically
authorised to emit radioactive substances to air and generally
have their own radiological protection supervisor. In the event
that an STA member organisation is invited to carry out stack-
emission monitoring from these plant, it is recommended that the
risks from radiation and necessary control measures are
assessed in close co-operation with the site operator and under
the guidance of the radiological protection supervisor.
4.7 Hazard: compressed gases
It is very common to use compressed gases in stack-emission
monitoring. The hazards and risks can be explosion, fire, rapid
acceleration, manual handling and toxicity. Here we deal only
with explosion, fire and manual handling. The toxicity is a
chemical hazard and will be dealt with in the next section.
Factors affecting the risk
 How the gas cylinders are transported
 How the gas cylinders are secured/stored
 Staff training (including manual handling)
 Regulators, valves, valve outlets and pressure lines can be very
vulnerable (especially if damaged)

36
Control measures
Some of the control measures used when using/transporting gas
cylinders are:
 Store in an area which avoids extremes of temperature.
 Stow cylinders securely, normally in the vertical position, to
prevent them moving or falling.
 Disconnect regulators and pressure lines from cylinders
whenever reasonably practicable.
 If necessary, fit suitable protective valve caps and covers to
cylinders before transporting.
 Ensure the cylinders are clearly marked to show their contents
and hazards.
 Transport properly (see below)
 Move properly (use cylinder trolley)
 Check for leaks (especially if flammable eg hydrogen)
 Do not use thread tape or jointing compounds
 Do not open valves fully (moderate torque)
 Turn off after use (moderate torque)
 Position outside buildings if possible
 Ensure good ventilation (especially when changing)
 Cover gauge glass when opening valve
Regulators on compressed gas cylinders require specific
considerations for example:-
 Maintenance/functional checks (annually)
 Consider safe working life (usually 5 years)
 Ensure correct thread type
 Perform prior-to-use checks such as:
 Regulator - inspected, not overdue for replacement, suitable
for inlet/outlet pressure, check for damage, leaks etc.
 Correct type (eg flame arrestor required?)
 Inlet clean and undamaged

37
  Gauge eg glass in good condition, reads zero
 Remember regulators control pressure not flow
 Never use thread adaptors
Some of the control measures used in manual handling of gas
cylinders are:
 Wear appropriate gloves, footwear, eye protection
 Do not use valves and caps for lifting cylinders unless they have
been designed and manufactured for this purpose.
 Use suitable cradles, slings, clamps, etc. when lifting cylinders
with a hoist or crane. Do not lift using the forks of a fork-lift truck
unless adequate precautions are taken to prevent them from
falling.
 Use correct hand-holds eg valve guard or gripping point
 Use correct PPE (check Safety Data Sheet, SDS)
 Use a suitable cylinder trolley (size, restraints)
 Check the route eg:-
 Stairways
 Lifts (do not travel with gas unless breathable air)
 Physical capability (bend knees, hold close to body)
 Never roll or drop
 Never unscrew, loosen or remove main valve
 Do not move with regulators attached (close main valve)
 ‘Churn’ only small distances
Some of the control measures for using gas cylinders at the
monitoring position are:
 Use in vertical position unless specifically designed to be used
otherwise.
 Securely restrain cylinders to prevent them falling.
 Close cylinder valve and replace dust cap (where provided) when
not in use.

38
  Before connecting the cylinder to pipework/equipment, make
sure the regulator and pipework are suitable for the type and
pressure of gas being used and are in good condition.
Transport of compressed gases
STA Health Safety Guidance Note HGA-002 describes regulations
applying to transport of chemicals. Considerations include:
 Compliance with Carriage of Dangerous Goods/ADR Regs if
appropriate.
 Minimum requirements
 Training in hazards, safe handling, emergency procedures
 Open vehicles or well ventilated (do not transport toxic
gases in closed vehicles)
 Carry fire extinguisher
 Ensure valves are closed and cylinders are properly restrained
 Labels legible
 Documentary details may be useful eg Transport
Emergency (TREM) cards.
 Specific provisions may be required if Threshold Quantity
is exceeded (check)
 BCGA Leaflet L1 (Rev5, 2015) contains more information.

STA guidance
STA HGA-002 The application of carriage of dangerous goods
regulations relating to stack testing operations
STA HGE-001 Transportation and handling of gas cylinders

4.8 Hazard: Noise

Significant noise exposure can occur during stack-emission
monitoring. Impact noises such as rapping mechanisms on
electrostatic precipitators and bag filtration plant are particular
examples of noises that may significantly exceed the 87dB
exposure limit level or the Peak Sound Pressure of 140 dB. The
lower action level of 80dB can be exceeded by continual
39
 exposure to the equipment a stack-emissions monitoring team
might take to site. Equipment such as US EPA Method 5 type
pumps and heated head pumps are examples of equipment that
can become noisy and to which personnel might be exposed for
extended periods of time.
Control Measures
 Identify the workers at risk from hearing damage (so you
can prepare an action plan to control noise exposure).
 Determine the daily noise exposure (Lep,d) of workers.
 Identify additional information to comply with legislation e.g.
whether noise control measures or hearing protection are
needed, and, if so, where and what type. In cases where
employees are likely to be exposed to the second or peak
action level or above, it is required that, as far as reasonably
practicable, exposure must be reduced in ways other than
by providing hearing protection. It should be noted that
wearing hearing protection can make verbal communication
difficult and also increases the risk of not hearing alarms or
site traffic. Noise reduction measures should always be
preferred to the wearing of hearing protection.

STA guidance
STA guidance HGE-006 Protection against noise during stack-
emission monitoring.
Further Information
HSE INDG362 Guidance for employers on the control of noise
at work Regulations 2005
HSE IND 363 Protect your hearing or lose it! (2007)

40
5. CHEMICAL HAZARDS AT THE STACK
5.1 Hazard: flue gases
This is a major hazard in stack-emission monitoring. Unless the
process operator has made you aware of the nature of the stack
gas, the specific hazard will be unknown. There is no way to
assess the risk of an unknown hazard so such stacks should be
regarded as a high risk and appropriate control measures taken
to reduce the risk.
The hazards may arise from the chemical nature of the flue gas
or from the fact that its oxygen level is depleted. There may also
be rapid changes in the nature of the flue gas which affect these
factors and its toxicity. The temperature or pressure of the flue
gas can also be a hazard. Process or waste gas from other
sources can wash over the platform area. The consequences of
personnel being overcome by fumes from flue gas, especially on
a high platform, are very serious.
Factors affecting the risk
 There may be little or no information available on the nature of
the flue gas.
 The concentrations of hazardous chemicals in the flue gas can
be orders of magnitude higher than any workplace exposure limit
(WEL).
 Flue gas may be under high positive pressure, which increases
the risk of exposure.
 The temperature of the flue gas might increase the risk of
secondary chemical reactions.
 Sampling requires that access is gained to the chimney stack,
duct or flue. This may be at two or three points around the stack.
 The sample ports may be a wide variety of shapes and sizes.
Good seals may be difficult.
 Extractive sampling equipment may exhaust toxic vapours into
the workplace, increasing the risk of exposure.
 Ventilation efficiency at the workplace will have an important
effect on exposure risk. On certain sites, the monitoring location
may be in areas that can be classified as confined spaces, as
41
 defined by the Confined Space Regulations 1997. This may
include mobile laboratories and vehicles in which the monitoring
equipment may be placed when sampling.
 The sampling location may have a very restricted escape route,
which may prolong exposure in an emergency.
Unless suitable control measures are taken, the risk of injury will
be unacceptably high. It is advisable to treat all unknown flue
gases as high risk. The risks must be reduced to as low as is
reasonably practicable by appropriate control measures.
Control measures
There is a specific legal requirement under the COSHH
Regulations for the ‘employer’ to make an assessment of the
risks to health from hazardous substances and implement
measures to control exposure to them. You should consult STA
Health Safety Guidance Note HGA-001 for further guidance on
chemical exposure risks. Some other control measures are:
 Obtain information on the physical and chemical nature of the flue
gas before sampling. The STA has a data-collection sheet
Exposure to Hazardous Stack Gases During Sampling which can
be sent to operators to complete. This sheet is available on the
STA website. Once you have this information you should next
assess the risk of exposure.
 Check whether there has been any process change from the last
visit that could alter the expected stack gas concentrations.
 Ensure that the operator has provided adequate ventilation for
the sampling location. This is a specific requirement contained in
Environment Agency Technical Guidance Note M1. The STA
generally recommends that no sampling is carried out in confined
spaces. The HSE has produced guidance on work in confined
spaces. The relevance to stack-emission monitoring has been
discussed in STA Health & Safety Bulletin, Issue 2, February
2001. The STA recommends that, generally, members should not
carry out work in confined spaces, unless they have been
specifically trained in such working and have suitable control
measures in place to reduce the risk to an acceptable level.
 Sample ports should be closed firmly when not in use.
42
 The probe used should be a good fit with the dimensions and
design of sample port.
 If the flue gas is hazardous, warning signs should be placed on
or near the sample ports.
 Where the exhaust from the sampling equipment creates an
unacceptable risk of exposure, vent it remotely or back into the
stack via another port.
 If necessary, monitor the exposure of the sampling team and use
alarm devices, e.g. personal SO2 alarms and CO alarms.
 There should be a good system of liaison between the sampling
team and the process operator. If there are any variations
expected in the flue gas due to process changes then the
sampling team must be kept informed.
 There may need to be a system for emergency communication
between the samplers and other personnel.
 Personal Protective Equipment (PPE) – the following hierarchy of
exposure prevention should be applied: exposure prevention>
engineering control measures> procedural control measures>
PPE. This hierarchy of control measures must be applied on the
basis of minimising risk, not cost, i.e. if exposure can be
prevented or minimised by moving the sampling position or
installing ventilation, then this should be done in preference to
using breathing apparatus (BA) or other respiratory protection
equipment (RPE) even if it costs more. The STA does not
endorse carrying out any stack monitoring work where it is
necessary to use BA. In such situations, the risk of personal injury
outweighs the environmental benefit that may be gained from
sampling. Some kinds of breathing apparatus may be appropriate
as an escape precaution, but as with all PPE, personnel must be
trained in their use. STA Guidance Note HGE-002 gives some
further information. Rigorous maintenance and inspection of the
equipment and refresher training for its use is also necessary.
 Health surveillance may be necessary for some monitoring
organisations. For example, the monitoring organisation should
assess whether it is appropriate to give blood tests if its staff could
experience significant exposure on lead sites.

43
5.2 Hazard: Chemical substances used during stack
monitoring
Whereas it is sometimes difficult to get information on the
hazardous nature of the stack gas, all STA members should have
a detailed knowledge of the hazards posed by any substances
(e.g. chemical reagents and gases) utilised in the apparatus
which is used in stack-emission monitoring work. The hazards
are not just confined to substances that are toxic by inhalation;
substances that are corrosive can be a hazard to the skin and
eyes too.
Factors affecting the risk
 The toxicity/corrosive nature of the substances used.
 Whether the substance is contained or used in the open.
 The actual work activity you are performing, e.g. pouring an acid.
 Frequency and duration of the work.
 Ventilation efficiency.
 Personal protection used.
Control measures

The COSHH Regulations require the employer to make an

assessment of the risks to health from hazardous substances
and implement measures to control exposure to them. For work
as complex and high-risk as stack monitoring, this assessment
should be documented. An ideal place for this is in a safety
section in the organisation’s written technical procedure for the
test. Safety data sheets (SDS) have been a well-accepted and
effective method for the provision to downstream users of
information on chemical substances and mixtures in the EU.
Most buyers (either importers or distributors or downstream
users) in EU will request a copy of SDS when they buy chemicals.
Other countries such as USA have used Material Safety Data
Sheets (MSDS), which are very similar to SDS in terms of format
and contents.

Suppliers of chemical reagents have to produce (Material) Safety

Data Sheets (MSDS or SDS). These documents help provide

44
information such as handling and storage arrangements as well
as any mandatory PPE requirements. This information is
necessary in order to produce a thorough COSHH assessment.

Another, more recent, piece of relevant regulation is ‘REACH’

which is a European Union regulation concerning the
Registration, Evaluation, Authorisation and restriction of
Chemicals. It came into force on 1 June 2007 and replaced a
number of European Directives and Regulations with a single
system. When it is finally implemented fully (June 2018) REACH
will apply to substances manufactured or imported into the EU in
quantities of 1 tonne or more per year. Amongst other things,
REACH aims to provide a high level of protection to human
health and the environment making the people who place
chemicals on the market (e.g. manufacturers and
importers)responsible for understanding and managing the risks
associated with their use. In the UK, REACH operates alongside
COSHH.

The REACH regulations state that for substances that are sold in
quantities of more than 10 tonnes per year and are classified as
dangerous, exposure scenarios describing how a substance can
be safely handled to control exposures to both human health and
the environment shall be added to the SDS, forming extended
safety data sheets (eSDS). This new SDS/eSDS is known as
‘REACH SDS’.

‘Exposure Scenario’ means the set of conditions, including

operational conditions and risk management measures, that
describe how the substance is manufactured or used during its
life-cycle and how the manufacturer or importer controls, or
recommends downstream users to control, exposures of humans
and the environment.

There is a wealth of information covering REACH available on-

line (including the HSE website).
You should consult STA Health Safety Guidance Note HGA-001
for further guidance on chemical exposure risks.

45
 Some control measures are:
 Substitute hazardous substances in the test for less-hazardous
substances where this is practicable. For example, substitute
hazardous blue silica gel for less-harmful orange indicating gel.
 Reduce the amount of contact with the substances so far as is
practicable.
 Carry out the test according to your work procedure, using the
control measures specified.
 Ensure adequate ventilation.
 PPE: if other control measures cannot reduce exposure to an
acceptable level, PPE may be required, e.g. protective gloves,
goggles, respiratory protective equipment (RPE) suitable for the
substances should be used. Personnel must be trained in the use
of their PPE. STA Guidance Note HGE-002 gives some further
information on PPE. Note that the SDS/eSDS may contain
mandatory PPE requirements.

46
STA guidance
STA HGA-001 Chemical Exposure Risks During Stack Testing
Operations
STA HGE-002 Personal Protective Equipment
STA HGO-004 Confined space regulations
STA HGO-006 Stack-gas exposure information sheet
STA HS 1058-00 Example COSHH Assessment
Further information
Personal Protective Equipment at Work Regulations 1992.
HSE INDG136 Rev 3 COSHH A brief guide to the regulations
2005
Confined Space Regulations 1997
HSE INDG258: Safe Work in Confined Spaces (1997)
HSE indg353 safety data sheets
HSE What is REACH?
http://www.hse.gov.uk/reach/whatisreach.htm

47
6. CHEMICAL HAZARDS IN THE LABORATORY
6.1 Hazard: substances used during cleaning and analysis
The risks associated with cleaning and analysis carried out in
the laboratory are beyond the scope of this booklet, which
focuses on site activity alone. There is a wealth of existing
guidance on applying COSHH and other aspects of health and
safety to laboratory work, and this should be referred to. In
practice, much of the guidance given in the preceding Section
5.2 will apply.

Further information
COSHH in Laboratories, Version 4. Royal Society of
Chemistry, 2008.

7. WEATHER, ENVIRONMENT AND WELFARE

7.1 Hazard: temperature extremes
The Workplace (Health, Safety and Welfare) Regulations 1992
and accompanying Approved Code of Practice (ACOP), provide
a general set of minimum standards for thermal comfort in the
workplace. However, these are not designed to cover those
working in extremes of temperature outdoors or around
processes. The risk assessment made under the Management
of Health and Safety at Work Regulations 1999, should include
the effects of heat, cold and humidity where appropriate. Note
also that for elevated workplaces, the WAH Regulations specify
that work should only be carried out where weather conditions do
not jeopardise safety.
The hazards due to extreme cold include frostbite and
hypothermia. Cold hands also make manual handing more
hazardous and increase the risk of dropping equipment.
The hazards associated with hot environments are dehydration,
heat exhaustion and fainting. In addition, metal surfaces and
tools can become very hot to touch leading to the risk of skin
burns. If radiant heat is present, e.g. in furnaces, rolling mills and
glass manufacture, the eyes and skin may be affected.

48
Factors affecting the risk
 Time of year.
 The ambient temperature.
 Duration of the work.
 How exposed the working platform is, e.g. provision of shelter or
refuge.
 Wind chill factor (see Section 7.4).
 The height of the working platform.
 Location: e.g. sampling positions are often located in the roof
spaces above processes, where elevated temperatures may be
encountered.
 Process: there are some processes, e.g. incineration, cremation
and steel production, where the ambient temperature in the work
space above the processes can reach as high as 40-50C.
 Personal protection used
 The risk assessment must consider both the environment and the
individual when calculating the risks involved, e.g. pregnant
women tolerate heat less well and may more readily faint and be
more liable to heat stress. It may be necessary to use medical
screening to exclude high-risk individuals from working in very
hot or very cold environments, for example employees whose
physical capabilities might be impaired due to issues associated
with :
 Age.
 Bodyweight.
 Skin conditions (eg in the case of radiant heat).
 Cardiovascular or renal disease.
 Peripheral vascular disease (Raynaud`s disease or ‘white
finger’).
Control measures
Ideally, thermal comfort should be through building design and
the incorporation of thermal insulation. However, this is often an
impracticable solution for stack-emission monitoring work.
Additional workplace controls may include:
49
  Controlling the source of heat/cold, e.g. by insulation.
 Separating the source from the person, e.g. by erecting barriers.
 Controlling the task, e.g. limiting workloads.
 Controlling ventilation in the workplace, e.g. through the use of
fans or air conditioning.
If temperatures providing reasonable comfort in the working
environment cannot be achieved, suitable protective clothing
(e.g. warm clothing) and rest facilities should be provided. For
extremes of cold, periods of exposure should be followed by
adequate spells of rest in warm, well-ventilated rest areas. When
working in hot environments, frequent rest periods should be
taken in cool areas (particularly if strenuous work is involved) and
cool drinks should be taken regularly. Rehydration fluids or even
salt tablets may be considered necessary in extreme cases.
If radiant heat is present, tinted protective glasses may be
needed.
The risk assessment should take all these factors into account to
decide on a safe maximum working time for exposure to heat or
cold.
7.2 Hazard: snow and ice
Snow and ice greatly increase the hazards of falls from height,
and make manual handling more risky.
Factors affecting the risk
 The ambient temperature.
 The height of the working platform.
 How exposed the working platform is.
 Provision of shelter.
 Duration of the work.
Control measures
All the control measures applying to hazards that are worsened
by cold, snow and ice (e.g. falls, manual handing) should be
reassessed. More stringent control measures may be required
than in the absence of cold, snow and ice. The most basic
additional control measures are:
50
  Request shelter to be provided at the sampling location. Seek
advice before lashing tarpaulins or sheeting to platforms as these
can destabilise the structure on windy days.
 Do not work on platforms outside if there is snow or ice present.
 If possible, avoid starting work outside in conditions which make
the onset of snow and ice likely.
 At low temperatures, where there is no snow or ice, use
appropriate PPE, e.g. thermal workwear and gloves.
7.3 Hazard: sunburn
When working outside, the ultraviolet radiation in strong sunlight
can lead to sunburn and sunstroke. The most serious long-term
effect is an increased chance of skin cancer later in life.
Workplace factors affecting the risk
 Time of year of the work
 Duration of the work
 Location of the work
 The risk of sunburn is increased when the working area is
surrounded by reflective surfaces, e.g. metal roofs.
Personal factors affecting the risk
Some people are more susceptible to burns and/or skin cancer
than others. The HSE recommends you take particular care if you
have:
 White skin - fair or freckled skin that doesn’t tan easily is most at
risk.
 Red or fair hair and light-coloured eyes.
 A large number of moles: over 100 in young people or over 50 in
older people.
Control Measures
 Determine a safe maximum working time for exposure to heat or
sunlight.
 Work in the shade if possible.
 Avoid working outside in the 3 or 4 hours around mid-day in
summer when the sunlight is most intense.
51
  Wear clothing covering exposed skin.
 Use sunblock: this will give some protection – use an SPF rating
of at least 15.
 Health surveillance: regularly check for skin abnormalities.
7.4 Hazard: winds
The risks due to wind include causing workers to lose their
balance, causing objects to be blown from the work platform and
causing ropes, cables and sheeting to whip about. Wind also
makes verbal communication difficult even over short distances.
Thus many of the hazards identified previously (e.g. falls from
height, falling objects) are worsened by wind. Wind can therefore
pose a serious risk of injury and a high standard of protection is
often required to reduce the risk to as low as reasonably
practicable.
Factors affecting the risk
 The strength of the wind
 The height of the working platform
 How exposed the working platform is
 Provision of shelter
 Personal protection used
Control measures
You must decide what a safe upper limit of wind speed is suitable
for the sampling location, taking into account the height you are
working and how exposed you are. The following are guideline
criteria that have been found suitable in some general situations:
 Do not go up the stack if the ground wind speed exceeds 30 mph.
 If the wind speed up the stack exceeds 30 mph during sampling,
stop work and come down if it is safe to do so.
 If it is not safe to come down, stay where you are and use a safety
harness.
The wind speed can be measured using a hand-held
anemometer or estimated from the Beaufort scale (e.g. trees
bending). At 30 mph, light equipment will sway significantly when
being hoisted.
52
 The wind chill factor, see table below, must also be taken into
account

Temperature oC

10 4 -1

5 9 3 -3
Wind Speed (MPH)

10 4 -2 -9

15 2 -6 -13

20 0 -8 -16

25 -1 -9 -18

30 -2 -11 -19

7.5 Hazard: rain

The hazard due to rain is that it increases the risk of many of the
hazards identified previously (e.g. falls from height, electric
shock).
Factors affecting the risk
 The strength of the rain
 The height of the working platform
 The presence of electrical equipment
 How exposed the working platform is
 Mud/dirt on the platform
 Provision of shelter

53
Control measures
All the control measures applying to the hazards worsened by
the rain (e.g. falls, electric shock) should be reassessed if it
begins to rain. More stringent control measures may be required
than in dry conditions. The most basic additional control
measures are:
 Request shelter to be provided at the sampling location but seek
advice before lashing tarpaulins or sheeting to platforms as these
can destabilise the structure on windy days.
 Do not work on platforms where dust can turn to mud. This is
common at minerals sites.
7.6 Hazard: lightning
The hazards associated with lightning are burns, possibly fatal,
from lightning strikes.
Control measures
 All outside work should be stopped during lightning storms. The
team should come down from the stack if it is safe to do so.
Sampling teams should keep abreast of weather forecasts and
remain vigilant of changing weather conditions which might
signify the potential for electrical storms.
7.7 Hazard: tiredness
The hazard associated with tiredness is that it increases the risk
from many of the previously described hazards. In addition,
driving whilst tired poses a serious risk.
Factors affecting the risk
 Duration of the work on site.
 Duration of the journey to/ from site.
 Amount of physical exertion.
 Other factors, e.g. heat exhaustion.
 Check presence of airbags for drivers and passengers in
commercial vehicles and cars.

54
Control Measures
 Determine a safe maximum daily working time, to include site
work and travelling. An example would be a normal maximum of
10 hours per day with occasional maxima of 12 hours.
 Take rest breaks
 Do not drive if you are unfit to do so. Some employers stipulate a
maximum distance that can be driven in a day if a full day’s work
is also to be carried out. Rest breaks of at least one-quarter of an
hour should be taken every 2 hours during a drive. Rotate drivers
if possible.
 Design and cost the job to allow for the above.
 The requirements of the Working Time Regulations should be
adhered to. Site teams should not work more than 48 hours per
week.
7.8 Hazard: lone working
It is most unlikely that a risk assessment of stack-emission
monitoring on a complex industrial process would conclude that
lone working is safe. However, there may be occasions on less-
complex, less-hazardous processes when undertaking straight-
forward tasks where lone working is acceptable. It is also
acknowledged that some types of worker (eg service engineers)
might carry out site operations alone. The STA has issued
separate guidance on the hazards, risks and safety control
measures for lone working, HGO-002.

STA guidance
STA HGO-002 Lone Working
STA HGO-003 Working hours on site relating to stack-
emission monitoring.
STA guidance HGO-007 Lightning strikes
Further information
HSE INDG 337, Sun Protection Advice for Employers of
Outdoor Workers 2001
HSE INDG147Rev 1 Keep Your Top On – Health Risks from
Working in the Sun 1998
55
 APPENDIX 1
Figure 1: Example of a monorail system

2 1 2

7
3
4

5 6

1. Monorail Unistrut P1001

2. L brackets Unistrut P2484
3. Unistrut H frame, refer figure 2
4. Standard 125 mm sample port, refer figure 3
5. Sampling platform, refer Environment Agency Guidance Note
M1
6. Platform hand rail
7. Example of sample train

56
 Figure 2: Monorail end view

1000

1 1
3 2
2200

4 5
1. Bracket Unistrut P1358
2. Unistrut P1000
3. Standard sample port, refer figure 3
4. Sampling platform, refer Environment Agency Guidance Note
M1
5. Platform hand rail

57
 Figure 3: Standard 125mm Sample port

2
STACK WALL

129.30

1. Flange BS10 –125mm (5”)

2. Pipe stub 125mm schedule 40
3. Pipe stub length should be a minimum of 75mm from the stack
wall (recommended is 100mm)
4. Recommendation that 1000mm of Unistrut P1000 is fitted
vertically on the centre line of the sample port for positioning of
the monorail

58
 Figure 4: Lifting point

4
3

1
1. Sampling platform, refer Environment Agency Guidance Note M1
2. The lifting point must be able to withstand a resultant force of at least
100kg.
3. The construction design of the lifting point is at the discretion of the
engineer involved but should be able to conform to the specifications on
this diagram.
4. Loop (minimum internal dimension - 20mm x 15mm) to which a karabiner
with a rope and pulley system will be attached prior to sampling
apparatus being hoisted and removed after sampling has taken place
and all equipment has been lowered from the platform. It should therefore
be easily accessible from the platform without having to reach over the
edge of the handrail to such an extent that there is a risk of falling. The
boom would ideally rotate.
5. Height of loop above the platform.

59
 APPENDIX 2 - Useful Links
STA Health and Safety Guidance Note Download from

HGA-002 The Application of the Carriage of Dangerous www.s-t-a.org

members area - guidance note – Health and Safety
Goods Regulations Relating to Stack Testing
Operations

HGA-001 Chemical Exposure Risks During Stack Testing www.s-t-a.org

members area - guidance note – Health and Safety
Operations

HGE-001 Transportation and Handling of Gas Cylinders www.s-t-a.org

members area - guidance note – Health and Safety

HGE-002 Personal Protective Equipment www.s-t-a.org

members area - guidance note – Health and Safety

HGO-002 Lone Working www.s-t-a.org

members area - guidance note – Health and Safety

HGE-003 Understanding Electrical Supplies www.s-t-a.org

members area - guidance note – Health and Safety

HGO-003 Working hours on Site Relating to Stack- www.s-t-a.org

members area - guidance note – Health and Safety
Emission Monitoring

HGE-004 LOLER Regulations www.s-t-a.org

members area - guidance note – Health and Safety

HGE-005 LOLER Regulations - Inspection Report www.s-t-a.org

members area - guidance note – Health and Safety

HGO-004 Confined Space Regulations www.s-t-a.org

members area - guidance note – Health and Safety

HGO-005 Safety Passport Scheme www.s-t-a.org

members area - guidance note – Health and Safety

HGO-006 Stack-gas exposure information sheet www.s-t-a.org

members area - guidance note – Health and Safety

HGE-006 Protection against noise during stack-emission www.s-t-a.org

members area - guidance note – Health and Safety
monitoring

HGE-007 Manual Handling www.s-t-a.org

members area - guidance note – Health and Safety

HGO-007 Lightning strikes www.s-t-a.org

members area - guidance note – Health and Safety

HGE-008 Suitability of MEWPS relating to stack-emission www.s-t-a.org

members area - guidance note – Health and Safety
monitoring

HGO-009 Guidance on Risk Assessment Forms www.s-t-a.org

members area - guidance note – Health and Safety

HGO-008 Platform Inspection Questionnaire www.s-t-a.org

members area - guidance note – Health and Safety

HS 1057-00 Example Risk Assessment www.s-t-a.org

members area - guidance note – Health and Safety

HS 1058-00 Example COSHH Assessment www.s-t-a.org

members area - guidance note – Health and Safety

60
Further information Download from
HSG107, Maintaining portable and transportable electrical www.hsebooks.com/Books/product/product.a
equipment (2004) sp?catalog_name=HSEBooks&category_na
me=&product_id=2858&cookie%5Ftest=1

HSE INDG136 Rev 3 COSHH A brief guide to the www.hse.gov.uk/pubns/indg136.pdf

regulations 2005

HSE INDG143 Rev 2 Getting to grips with Manual www.hse.gov.uk/pubns/indg143.pdf

Handling
HSE INDG147Rev 1 Keep Your Top On – Health Risks www.hse.gov.uk/pubns/indg147.pdf
from Working in the Sun 1998

HSE INDG231 Electrical Safety and you 2005 www.hse.gov.uk/pubns/indg231.pdf

HSE INDG258: Safe Work in Confined Spaces (1997) www.hse.gov.uk/pubns/indg258.pdf

HSE INDG 337, Sun Protection Advice for Employers of www.hse.gov.uk/pubns/indg337.pdf

Outdoor Workers 2001
HSE INDG362 Guidance for employers on the control of www.hse.gov.uk/pubns/indg362.pdf
noise at work Regulations 2005

HSE IND 363 Protect your hearing or lose it! (2007) www.hse.gov.uk/pubns/indg363.pdf

HSE INDG383 Manual Handling assessment charts www.hse.gov.uk/pubns/indg383.pdf

Personal Protective Equipment at Work Regulations 1992 www.hse.gov.uk/pubns/indg174.pdf
Workplace (Health, Safety and Welfare) Regulations 1992 www.hse.gov.uk/pubns/indg244.pdf
and accompanying Code of Practice.
Management of Health and Safety at Work Regulations www.hse.gov.uk/pubns/hsc13.pdf
1999.
BS 4211:2005 Specification for permanently fixed ladders www.bsigroup.com/en/Shop/Publication-
Detail/?pid=000000000030172432
Work at Height Regulations 2005 www.hse.gov.uk/pubns/indg401.pdf

Work at Height Regulations 2005 – operational circular www.hse.gov.uk/foi/internalops/fod/oc/200-

OC 200/31 299/200_31.pdf

Environment Agency Technical Guidance Note M1 publications.environment-

Sampling requirements for stack- emissions monitoring agency.gov.uk/pdf/GEHO1105BJXX-e-
(2006) e.pdf?lang=_e

Manual Handling Operations Regulations 1992 www.opsi.gov.uk/SI/si1992/Uksi_19922793_

en_1.htm
The Lifting Operations and Lifting Equipment Regulations www.loler.org.uk/
1998 (LOLER)
Confined Space Regulations 1997 www.opsi.gov.uk/si/si1997/19971713.htm

Reporting of Injuries, Diseases and Dangerous www.hse.gov.uk/riddor/

Occurrences Regulations 1995 (RIDDOR)
COSHH in Laboratories, Version 3. Royal Society of www.rsc.org/pdf/ehsc/coshhlabs.pdf
Chemistry, 2003

61
Notes

62
Notes

63
 Web Site: www.s-t-a.org

About us
The STA exists to advance the science and practice of emissions
monitoring and to promote safe working and high a quality of
service to customers.
How you will benefit from membership
Whether you are a process operator, a regulator, a monitoring
organisation, an instrument supplier, or a laboratory, you will
benefit from joining the STA. We give you:

o a voice in monitoring matters at national (e.g. BS,

MCERTS) and international (e.g. ISO, CEN) levels

o personal and professional development including training

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such as our Proficiency Testing (PT) scheme

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