Introduction

Assessing the health, safety and environmental risks posed by a particular plant or production process is not as easy as it might seem. Despite society's immense technical and scientific knowledge, it is still difficult to link certain health effects or environmental damage with a particular factory - for example, illnesses may take a long time to develop after exposure, causation is often clouded by inclusion of life-style factors (such as smoking or diet), and GPs are rarely alert to, or even particularly competent in, linking illness to work. So it is not so easy to point to a particular plant and say that it is dangerous.
We often have to piece together existing, if fragmented evidence, in order to make an overall assessment of the risks being faced by workers and local residents. We need to ask questions such as:
· what are the known and likely hazards associated with a particular production process?
· what evidence is there of these becoming manifest?
· are there any regulations relating to these production processes, and if so how robust are these?
· what are the enforcement records of relevant agencies such as Environmental Health Departments (EHDs) and inspectors at the Health and Safety Executive (HSE)?
· what do we know about the general standards of management of the plant?
We address some of these questions here in relation to the Sonae UK Ltd site, Knowsley Industrial Park, in order to assess the possible dangers posed to workers and local residents.

Workplace Health Effects

We know a great deal about the possible health effects involved in producing chipboard. Wood based boards - laminated boards, particle boards or fibre boards - are used almost everywhere. They are produced by gluing or bonding together laminates or wood particles, using formaldehyde resins. Most boards will be glued by urea formaldehyde but exterior, "WBP", or marine quality boards will be glued by stronger glues, normally phenol formaldehyde or possibly resorcinol formaldehyde. Boards which need to be water resistant may have melamine mixed with the glue.
Even at low levels of exposure, formaldehyde resins irritate the eyes, mucous membranes, nose and throat. They can sensitise skin (dermatitis) and the respiratory system (asthma and rhinitis). Exposure increases risk of cancer. There is some documented evidence that exposure is linked with reproductive hazards and possible damage to a foetus. Even after it has hardened, Formaldehyde resin continues to emit vapour. Melamine is a known eye, skin and mucous membrane irritant, causes dermatitis, and is an 'experimental carcinogen'.
These are not the only health risks associated with the production of wood based boards. Dusts are a more visible hazard. Hardwood dust can cause nasal cancer, with a small number of woods being directly implicated (beech, oak, redwood). Inhaled soft wood dust, although not recognised as having the same potential hazard as hardwood, should be treated with caution. Respirable dust of any kind can irritate the respiratory system or interfere with mucociliary action. A number of woods are irritants of the skin (Iroko, Keruing, Afromosia), the respiratory tract (Beech, Iroko, Maple) or the eyes (Yew, Teak, Satinwood). Some, such as Western Red Cedar, Iroko and Mahogany, cause allergic asthma. There are also other safety risks: some woods are poisonous, such as Yew and Oleander that can cause nausea and malaise and affect the heart. Large quantities of airborne wood dust in an enclosed space can cause an explosion; some wood dusts will spontaneously combust on contact with certain oils or chemicals. Timber may be sprayed with a pesticide when it is logged to prevent mould growth, or at any point on its journey from the forest to the workplace or home. Some boards may contain wood treated with pesticides but it will be difficult to check this. Moulds such as neurospora - that grow on wood and board products - can irritate the respiratory system and cause asthma. When machined, PVC veneers can give off fumes of vinyl chloride monomer (VCM), a very potent cancer agent.
There are various regulations that need to be followed if these hazards are to be managed effectively. But we should note, though, that even if these regulations are carefully followed, this does not remove risks to safety. For one thing, there is debate about the exposure levels that have been set by the law: these levels are set in laboratories, and are usually based on experiments on animals; they also tend to be conservative. A second problem is that all these limits relate to exposure to one substance - even though workers are exposed to a combination of these substances in the real world. The combined effects of wood dust, formaldehyde or other substances, and any other hazards are not known. It is safe to assume that the effects of combined exposure will probably be greater than the sum of the parts, especially if dust has disabled the body's defence mechanisms.

Health and Environmental Effects

Does chipboard production cause damage to the environment? The question of environmental damage - where effects can be very diffuse and become manifest over long periods - is often even more difficult than linking exposure to an identifiable group of workers. But we have some indications that chipboard production does have identifiable environmental effects.
The major emission from any chipboard factory is formaldehyde. It has an unpleasant smell and causes streaming eyes, runny noses, and sore throats. It makes respiratory conditions - such as asthma - worse. It is a carcinogen.
Since the Sonae plant opened at Knowsley, local people have complained about the smell coming from the plant, and the white dust that covers the area. Their major complaint is of the increase in respiratory problems, which they think are associated with the plant. Most of these people live in Kirkby, a large residential area on the outskirts of Liverpool.
They say that a 'blue haze' - probably containing formaldehyde - is being emitted from the factory from time to time.
They have repeatedly reported problems to the Environmental Health Department at Knowsley, But both the Council and the Company deny that deterioration in health is linked to emissions from the factory.
One investigation did reveal the emission of some toxic chemicals, including dioxin and mercury. The Environmental Health department suggested a few alterations to the plant's chimney to make the plume disperse further. Emissions, they say, are within limits.
Kronospan, an Austrian company, set up their chipboard plant nearly twenty years ago, outside a town called Chirk, famous for its castle. Once a thriving tourist trap, the town itself has virtually closed down because tourists won't brave the fumes. The company has been prosecuted for releasing formaldehyde (a carcinogen) into the atmosphere. Twenty years on and the wood dust from the plant still settles nearby. Chronic asthma and respiratory diseases along with the cancers are the result. There have also been two deaths at the plant because of lax health and safety.

Workplace Safety

The Health and Safety Executive maintains a database that records details of contact between its inspectors and companies they regulate. The database - known as FOCUS - is relatively new, and does not include records of all contacts with companies. But even if it is an incomplete record of standards of safety at particular companies, it is a useful resource for checking the safety records at companies and making an assessment of the general state of safety management. The FOCUS records for Sonae are therefore worrying. These indicate that: in the construction and commissioning of the plant, HSE have consistently identified serious problems with the management of the plant, and a "worrying trend of major and minor accidents" ; HSE enforcement has been remarkably lax - there is only one improvement notice recorded for a plant that Inspectors consistently identify as persistently failing to comply with their duty of care.
The database has much more detail in relation to the construction and commissioning of Sonae woodchip/particle board plant in Kirkby. This information casts serious doubt on Sonae's credibility, and questions their ability to run this plant safely.
In March 2000, an HSE inspector received a call from J Baxter, Principle EHO, Pollution Unit, Knowsley Borough Council. A senior ex-employee of Sonae UK has made serious allegations to the council: "i.e. claims that there is a danger of a dust explosion (in the furnace and drying ovens), fires in the plant, the log yard is not stacked properly, no first aid facility, a serious drug abuse problem and 'punishment' beatings are carried out against consultants who disagree with the company" HSE told Baxter that "unless HSE can record and investigate properly then we cannot deal with unsubstantiated rumours. Whole project is politically sensitive." HSE "offered" a joint investigation (this seems to mean that HSE proposed to conduct a joint investigation with J Baxter).
In April 2000, the HSE investigated an incident of a Sonae employee (Ian Fairclough) who became trapped in the clamping mechanism of a Dieffenbacher hydraulic press. Ian Fairclough suffered serious crush injuries to his arm and chest when "trapped in the Synchron-Quick drive of the KT machine on Melamineline no 2. He had entered the line to release a trapped board and became trapped when the line activating the board was released. Dieffenbacher are supposed to commission the line, teach Sonae employees the basic training and then leave them to run the line. The machinery was "still being commissioned by the manufacturers". The investigation revealed that "an interlock had been defeated allowing access to the press line which was being controlled by a PLC." The report notes that the investigation is continuing.
Later in April 2000, a HSE Inspector visited the site at the request of the company safety officer, J Forbes. He reported "the situation is serious, with continuing complaints about safety standards. I discussed the situation and made it plain that I was unhappy with the current sate of affairs. (4 reported accidents, 2 major, defeated interlocks, and an almost complete lack of communication between Sonae and Dieffenbacher, the commissioning company). Spoke to the assembled mangers (sic) and outlined the situation for them. Hopefully things might improve from a management point of view."
In September 2000, Shaun Lambert, Electrical Supervisor suffered electric shock and burns to his hands, right arm and face working on an electrical panel at 4pm - although it was not deemed by the company to be life threatening, he required immediate treatment at the burns unit. He had attempted to attach a new fuse switch onto a metal clad 415volt switchboard while it was still energised. After 5pm, HSE took a call asking for permission to start working on the switchboard again. When the inspector phoned back at 5.40pm, he was told that they were already working on the switchboard. "Said I was not impressed by this." Also the inspector notes that remedial work had begun on the switchboard despite HSE warning to preserve evidence and not to touch anything pending an investigation. Subsequent investigations noted that keys were readily available for the lock off padlocks and that the company had blamed the permit to work procedure and told the HSE the procedure was under review. A complaint 6 months later by a Sonae employee working in the woodyard (27.4.01) revealed that electrical safety switches were shorted out as a matter of routine. One supervisor "was oblivious to safety conditions and didn't appear answerable to anyone, eg. he used to bridge out safety circuits re-starting conveyor belts without warning, shorts across 'Pilz relays' [safety relays]. One company withdrew from the site as he had hacksawed an isolation lock off." This report also noted "It is a relatively new plant. There are only a few start up alarms on conveyors … This complaint highlights just one aspect of a serious problem under consideration."
In April 2001, Michael McNamara broke a leg after he was caught between the level roller and conveyor of fuel feed in the fuel plant room. HSE report notes: "No safe system of work appears to have been in place ... the worrying trend of major and minor accidents continue and it was emphasised to management as being totally unacceptable."
In July 2001, employees complained during an inspection. Men cleaning down furnace were trapped inside after a hatchway had been partially blocked, described by HSE as "very worrying events." Investigation report also notes that "Issues re entry into confined spaces, employees being trapped and lack of safe systems of work were discussed and the company left in no uncertain terms that this was totally unacceptable."
The accident profile of the plant reflects the seriousness of the problem: 6 over 3-day injuries and 7 major injuries reported to HSE over a 6 month period between October 2000 and April 2001.

Summary

We can now with confidence provide answers to the questions set out above.

What are the known and likely hazards associated with a particular production process?
There is a range of hazards associated with the production of wood-based boards, about which we know a great deal.

What evidence is there of these becoming manifest?
Local residents have documented classic symptoms of exposure to some of these risks.

Are there any regulations relating to these production processes, and of so how robust are these?
Some regulations exist, though often these are inadequate - for example, in relation to exposure levels - and have been set in the laboratory rather than in the real world, where workers and residents are exposed to a combination of chemicals rather than one at a time.

What are the enforcement records of relevant agencies such as Environmental Health Departments (EHDs) and inspectors at the Health and Safety Executive (HSE)?
In general, these agencies seem to be slow to take action and have adopted a lax approach to enforcement - typical of how these agencies operate across the country.

What do we know about the general standards of management of the plant?
The details entered on the HSE's FOCUS database - particularly those in relation to the Sonae plant in Kirkby cast serious doubt Sonae's credibility, and questions their ability to run this plant safely.

None of the above should give great confidence to local residents in Knowsley. Neither the Environmental Health Department nor the Health and Safety Executive seem particularly willing or able to intervene in the running of a plant - supported by £5 million of development money - by a large multinational (Sonae is a Portuguese based company and the world's largest manufacturer of wood panels). Moreover, if residents' fears about the health and environmental effects inside and outside the plant are difficult to 'prove', Sonae does not seem to have the most competent or diligent management when it comes to workplace risks. We have documented this in some detail, since it is important evidence - poor safety is much easier to identify than poor standards of health and environmental management, while we should assume that a company managing the safety of its workers poorly is likely to do even more poorly in managing the invisible hazards to health and the environment.

Dave Whyte
Steve Tombs
For the Merseyside Hazards and Environmental Centre
July 2001