Quality Assurance for the Memorial Industry
The Health and Safety Executive (HSE) has recently updated its business plan. The updated plan includes the HSE’s priorities for 2025/26, with 14,000 business inspections planned during this period to ensure and enforce regulatory compliance.
The HSE aims to reduce and prevent occupational lung disease, with a particular focus on silicosis related to exposure to respirable crystalline silica. The Local Authority Circular (LAC 67/2), which expands upon the HSE’s business plan, details the sector focus for inspections. Businesses that cut and shape stone are listed, with a particular mention of gravestone masonry.
NAMM asked Synergy Environmental Solutions, who specialise in workplace air quality assessments, to offer their expertise and guidance to members to ensure compliance and the safety of all involved in memorial masonry. Matt Hayes, Managing Director at Synergy has contributed this article to help you navigate HSE regulations and the likely impact of inspections.
The health risks linked to exposure to respirable crystalline silica (RCS) are well established. When inhaled, RCS particles can reach deep into the lungs and pose significant health dangers. The main concern is silicosis, a serious and irreversible lung condition marked by inflammation and scarring of lung tissue. Prolonged exposure to silica dust can result in severe forms of silicosis, which can be life-threatening. In addition, RCS exposure is associated with a heightened risk of lung cancer and other respiratory illnesses.
RCS falls under the Control of Substances Hazardous to Health (COSHH) 2002 Regulations. Sole traders to multi-national organisations are required by law to protect themselves and employees from hazardous substances in the air. RCS is part of COSHH and a priority for the HSE in 2025/26. Hazardous substances, such as RCS, have workplace exposure limits (WELs) that are detailed in the HSE’s EH40 2005 document.
Before setting out RCS exposure limits, it is important to emphasise that these figures represent the legal maximum and staying below them does not necessarily mean employees are fully protected. Synergy advises employers to aim for levels below 10% of the workplace exposure limit (WEL), in line with the guidance provided in BS EN 689:2018.
WELs are the average concentrations of hazardous substances over a set period, known as the time-weighted average (TWA). Most WELs have short-term (15 minutes) and long-term (8 hours) limits. The RCS WELs below are given in milligrams per cubic metre
As RCS is a carcinogen, employers must reduce exposure to as low as reasonably practicable. Even if levels are below legal limits, further controls must be used where possible, as there is no safe level of exposure to carcinogens.
As you can imagine, reading the COSHH regulations can be quite a dry task. To ease this task, Synergy has a concise overview of regulations important to COSHH compliance. The key points include:
To avoid falling foul of regulations and preparing for a surprise HSE inspection the following steps, following the COSHH regulations outlined above, should be followed:
It is important to note that if you do have an inspection, inspectors will be watching and listening, so it is vital that safety measures and practices are carried out by each and every employee. Having all the documentation and procedures in place can be undone if an inspector sees a worker acting unsafely or finds dusty surfaces.
One final tip that helps to ensure the safety of employees is to adopt the Hierarchy of Control. This is a framework that prioritises the effectiveness of controls from most effective to least effective:
Navigating the complexities of COSHH compliance can be a daunting task. Regulatory knowledge and the complexities of monitoring hazards, laboratory results, and conducting health surveillance require specialist knowledge. COSHH regulations require risk assessments and monitoring to be carried out by a competent individual or organisation, and ideally, when RCS is involved, this should be an annual process. Calling upon an accredited Occupational Hygiene Consultancy can ease the risk assessment process and ensure the well-being of employees.