Wind power, solar, tidal, biomass, and heat pumps are a among a few technological comprise the renewable energy industry. These technologies may be implemented by small, medium and large companies and projects and instillation may vary on scale and terms of their environment. The uptake of Renewables is increasing and as such needs to be regulated to the same health and safety standards throughout Guernsey, the same as any other industry.
The issue
- As the renewable technology industry grows so does the likelihood of hazards. Furthermore, with new technologies come new hazards that will supplement existing hazards in the industry. These hazards will occur in both the construction, and decommissioning stages but also in the operating stages of energy production. They will also extend into new environments.
- The Health and Safety Executive (HSE) will not promote any renewable technology over another and will only act as a regulatory safeguarding body. As such, the HSE will draw on its experience regulating workplace health and safety and apply this to emerging renewable industries. The HSE is equipped to do this by its experience in all sectors of industry and as an authoritative body is able to do so. However, the degree of health and safety achieved in the renewable technologies sector will be determined by duty holders, and how well these duty holders manage the risks in line with their legal responsibilities. The HSE regulates all stages of the renewables industry from development of these technologies, installation, operation, and decommissioning.
- A major factor in these technologies is addressing health and safety in the initial stages and using a 'built in' approach. This is generally more cost effective and easier to manage than applying health and safety design in a retrospective manner. Therefore, it is imperative to consider health and safety in the design stage to give a higher standard and health and safety in the operational stages of renewable technologies. If all the risks and hazards are considered early on, it will enable Guernsey to move towards a safer future regarding renewable technologies.
Understanding the associated hazards
- Emerging technologies are very much new and previous data on their safety is limited. Therefore, identifying hazards proves difficult due to their novel nature. For example, solar, hydrogen and wind and tidal turbines are relatively new compared to other industries. Therefore, identifying hazards is difficult and risk assessments are hard to produce as there is limited data compared to the older industries. Therefore, understanding the risks associated with renewables should be pursued carefully. Again, this needs to be considered at all scales from small business to commercial developments.
- However, there are typical health and safety hazards that may be exacerbated in regard to the expansion of renewable technologies and industry in Guernsey. These are, but not limited to:
- The growth of this industry will create more job roles, therefore, work volumes will be higher in tern leading to increasing health and safety incidents unless managed by the duty holder adequately
- A lack of experience and training to fill demand for high-skilled tasks on all scale of projects. Consequently, unsuitably skilled workers could be exposed to emerging technologies they are not acquainted with
- Companies wishing to exploit this rapidly emerging industry may struggle to achieve and maintain certain standards of health and safety
- On-site power projects could increase the risks to the day to day running operations. This may affect all areas of society from schools and hospitals to agriculture
- Unexpected pressures or financial constraints may increase maintenance related risks. This may also be exacerbated by retrofitting technologies which is typically more expensive
- Time constraints during installation and maintenance of these unfamiliar technologies could lead to compromising safe working practices and compliance with certain standards
- Lack of communication between contractors during the construction stages could lead to greater potential for accidents to occur. This would be especially true for large scale projects that comprise of smaller sub projects
- The process of identifying, managing and controlling hazards should not be regarded as a barrier of deployment of emerging energy technologies. On the contrary, it is a process specifically designed to prevent and eliminate problems that might otherwise hinder the transition to a new energy system for Guernsey. In fact, failure to tackle health and safety issues regarding renewables could compromise efforts to develop sustainable, secure and affordable energy supplies for islanders in the future.
Risk specifics: occupational hazards
- In addition to major hazards which could impact on workforces developing, installing, operating and maintaining emerging energy technologies, a range of lower-level occupational hazards also pose a potential threat to health and safety in the Guernsey workplaces:
- Occupational health presents significant challenges that must be addressed effectively if workers are to enjoy appropriate protection from short-term and long-term health impacts
- Workforces in Guernsey need to be safeguarded from a diverse range of on-site safety hazards, some of which could result in a risk of death or major injury. Many of these occupational health and safety hazards are familiar ones that will now be replicated in new and emerging unfamiliar environments; others have never been encountered on a meaningful scale before in the Bailiwick
Risk specifics: hazards to the public
- Emerging energy technologies pose an mixture of health and safety risks to islanders living or working in close proximity to them. While some of these can be defined as major hazards others are more localised in their possible effects, although could still be of extreme seriousness for individuals. Many of these hazards are rooted in the fundamental nature of the energy generation technologies concerned. Some, though, are primarily attributable to the fact that many emerging energy technologies will be harnessed in comparatively innovative, more decentralised ways, with a large number of small-scale projects 'embedded' into communities and a substantial increase in the number of property owners involved in energy generation for their own use.
The right response
- The States of Guernsey HSE aims to promote sensible, proportionate management and control of hazards and risks. Fundamentally, this means seeking to regulate the technologies to the same standards as existing industries with comparable hazard and risk profiles and avoiding the imposition of unnecessary burdens. Indeed, the starting point is a presumption that further regulation will not be required unless it becomes obvious that current regulation is insufficient in which case UK legislation will be looked to under the concept of precedent.
Specific legislation
- The Health and Safety at Work (General) (Guernsey) Ordinance, 1987 places the onus for controlling risk on those who create it. Employers in Guernsey are therefore obliged to ensure, so far as is reasonably practicable, the health and safety not just of their workforces but also of anyone else who may be affected by their work activities. In accordance with the provisions of the Renewable Energy (Guernsey) Law, 2010, section 5(1), with effect from 30th May, 2012 and subject to subsection (3) of that section, this Ordinance shall apply to and in relation to persons at work (within the meaning of the Health and Safety at Work etc. (Guernsey) Law, 1979) within the territorial waters of Guernsey where such work is carried on in connection with the activities as set out in the said section 5.
What are the HSE's responsibilities in respect of renewable energy technologies in the Guernsey?
- The HSE is responsible for enforcing general health and safety at work legislation:-
- During construction
- During maintenance
- Where technology is used as part of a work undertaking
- Regulating product safety issues where machines are designed/supplied for use at work
- Commenting as a statutory consultee at the land use planning stage if appropriate
- The HSE is not responsible for:-
- Contributing at the land use planning stage (except in special circumstances)
- Setting separation distances between wind turbines and buildings, roads or similar
- Product safety legislation for small/micro technology for non-work purposes
