Labour Inspectorate

Physical load on dock workers

Labour Inspectorate Physical load on dock workers Inspection of cargo transfer/transshipment in the Dutch sea harbours and their immediate periphery A project in the framework of the European campaign "Lighten the Load". Fall 2007

Table of contents Preface 1 2 2.1 2.2 2.3 3 3.1 3.2 3.2.1 3.2.2 3.2.3 3.2.4 3.3 4 Appendix: Summary Project setup and implementation Reason and objectives Implementation Communication Project results Total overview of the inspection results Results according to the nature of the load Mixed cargo Containers Bulk cargo Roll-on roll-off: lashing cargo Sticking points for employers Conclusions and recommendations NIOSH method 3 4 4 4 4 8 8 8 9 10 13 14 15 16 18 20

Preface "Lighten the Load" was the motto of the European campaign of Labour Inspectorates in the European member states in 2007. This inspection project, focused on reducing the physical load in the Dutch sea harbours was part of this. The project demonstrates that physical load is still a serious labour risk. The persistent conviction that a certain part of the work just happens to be physically hard and that nothing can be done about it, is deeply ingrained in many companies and employees in the harbours. The same is true for the attitude that the problem is primarily lodged somewhere else in the logistic chain, and that the fact that ships entering the Dutch harbours are jammed in an ergonomically irresponsible manner, is something that can not be changed. These kinds of convictions are precisely the ones that obstruct effective measures from being taken. An active and creative attitude is vital when one searches for solutions to reduce physical overloading: look at what is possible, not what is impossible. In order to inspire this attitude in you, we have also included examples of good practice in this report. Reducing physical load to acceptable proportions at the harbour companies not only requires adaptations inside the walls of the company itself. It is also important that international agreements are made with suppliers. Via the Harbour Surveillance Programme, the Labour Inspectorate will continue to scrupulously monitor whether employers and employees in the harbour companies are making every effort to substantially reduce the physical load. Both parties will profit from this, and, moreover, the process is mutual: healthy operational management implies healthy employees, and vice versa. The load will not be lightened for employees alone, but ultimately for employers as well.

Drs. A. van Dijk Deputy Director

Summary

This report presents the results of the inspections of physical load in the harbours, a project that was carried out during the months of September through December 2007. These inspections were part of the European "Lighten the Load" campaign, with the goal of reducing the physical load in the transport sector. In total, the Labour Inspectorate inspected 134 companies that transfer/transship cargo in the sea harbours (container transshipment, bulk cargo, mixed cargo transfer, fish transfer). Substantial physical overloading appeared to be involved in more than a third of the companies inspected (37.3%), and about half of the companies that manually transfer/transship cargo took no, or took insufficiently, effective measures to reduce the physical load. The Labour Inspectorate noted that employees frequently have a macho mentality, which stands in the way of denouncing physical load. Employers often have an incorrect image of the extent of the physical load and of the standards used for physical load. Furthermore, employers have the idea that only expensive or radical measures should be taken. The examples in this report show that simple solutions, as encountered at some companies, can also be effective. The Labour Inspectorate calls on employers and employees to proactively search out what solutions are available or can be developed to reduce physical load during transfer/transshipment of cargo in the harbours. Furthermore, the Labour Inspectorate calls on employees and their trade unions, as well as on sector organisations and employers, to bring this subject up for discussion at the company, and to actively engage employees in the search for suitable and practical measures to reduce the physical load. 2 2.1 Project setup and implementation Reason and objectives

Physical load still accounts for a considerable share of daily reality in the harbours of many employers that transfer/transship cargo from ocean ships, and so, unfortunately, does physical overloading. Physical overloading results in musculoskeletal system disorders, and could lead one to drop out of the workforce. In the Netherlands, the percentage of persons disabled as a consequence of physical load and musculoskeletal system disorders is about 28% (CBS StatLine 2007). Physical load is not only a Dutch phenomenon, but plays a role in the entire transport chain and in all harbours. For this reason, the European Labour Inspectorates carried out an inspection project in 2007 to reduce the physical load in this international sector. This also promotes levelling of the playing field for companies in the European member states. Objectives of this inspection project The Labour Inspectorate has set as goal for itself the reduction of the physical overloading during transfer/transshipment of cargo in the harbours by enforcement. Furthermore, the Inspectorate wants to stimulate employers and employees of companies in the harbour area to take measures against physical overloading themselves, and to devise creative solutions. To this end, the Inspectorate provides concrete sticking points and measures as examples. 2.2 Implementation

Assessment of the physical load: The NIOSH method Inspections of physical load from lifting are based on the so-called NIOSH method. The inspector uses this method to assess the extent of physical load by calculating the maximum acceptable weight that may be lifted. This calculation is made on the basis of the weight of the load to be lifted, the number of times this must be done, and any other possibly aggravating conditions (the position that must be used for lifting, the distance over which the cargo must be moved, the ambient temperature). Damage is inflicted to the health above the maximum acceptable lifting weight. Therefore, the maximum acceptable lifting weight is also called the medical threshold.

A different maximum acceptable lifting weight may thus apply to every work situation. Many employers assume that the maximum lifting weight is 23 kg for all situations. This is thus a misconception. Working above shoulder height is especially stressful. For this work, the Labour Inspectorate uses a maximum acceptable weight of 4 kg higher than 1.80 metres. Lifting 8 kg or more above this height is physical overloading. You can find more information on the NIOSH method in the appendix. Inspection system In its assessment of physical load, the Labour Inspectorate follows the course of action below: 1. If physical load is involved, but it remains below the medical threshold, the inspection is finished. 2. If the inspector assesses work that involves values above the medical threshold, but does not exceed it more than once, he will ask the employer for the more detailed risk inventory and evaluation (RIE) for physical load. The inspector then checks whether the company has assessed situations of physical load and whether appropriate measures have been taken, as described in the plan of approach in the RIE. In addition to this, the inspector verifies whether the employees have been informed as to the risks of physical load and are trained in limiting the physical load. If the RIE has not been implemented correctly, the inspector will issue a warning to the employer to still correct the RIE and of course take the appropriate measures. 3. If the inspector assesses work activities that result in exceeding the medical threshold more than twice, physical overloading is involved. This is an abuse and the inspector will impose a requirement on the employer to take immediate measures to reduce the physical load. Inspection of physical load due to transfer/transshipment work activities During the loading, unloading and transfer/transshipment situations of ships with bulk loads, mixed cargo, containers and roll-on roll-off vessels, inspectors focused on lifting, pushing and pulling, the position in which the work had to be carried out, the speed at which the work had to be done, the frequency of repeating work activities and any possibly aggravating conditions. The inspectors inspected the following work activities in the process: Shovelling: manually loosening and pushing together or sweeping loose cargo, often with long scrapers attached to a long (approximately 4 to 6 metres) steel or aluminium pole. Loosening dry cargo is generally no problem. The cargo drops when touched. However, this work is very hard when the cargo is moist and sticky. Hard because one has to keep the approximately 8 to 15 kg tool up high, and hard because of the force that must be used to scrape the cargo loose. When working with a scraper, unobstructed work space is required behind the employee in order to assume the correct posture. This free space must be 3.5 metres, at minimum, for poles from 3.5 to 7 metres long. If the poles are shorter, this space must be at least as long as the pole plus one metre.

Sweeping: sweeping/bringing together liquid (oil) cargo. Sweeping takes place in a tank of a vessel by means of a suction hose and squeegees. The cargo is heated and kept liquid by a heating element placed on the bottom. The liquid cargo is pulled together towards the suction hose. The temperature in the tank is high in order to keep the cargo liquid and the employee wears protective clothes.

Stacking: manually securing and loosening the automatic/semi-automatic twistlocks, the connectors to secure containers on top of each other. A twistlock weighs about 6.5 kg. The frequency and forced work position play a role in the extent of physical load.

Stuffing and stripping containers: loading and unloading a container can be particularly stressful if done manually. Pallets are often refused in order to load a container to the maximum capacity (since pallets take up space) and all holes and corners are stuffed. The risk in this action is lifting loads that are too heavy, lifting too high, assuming an unfavourable posture and applying too much force when pushing and pulling the goods to and from the container and inside the container itself. The employer can make agreements with its supplier about the way in which the container is loaded.

Lashing containers or cargo: using straps, rods and chains when securing cargo in or on the vessel. In combination with using heavy chains and rods, the work may be physically stressful in limited work space. Working in semi-enclosed spaces, where it may be oppressive as a consequence of high temperature, insufficient ventilation in combination with exhaust gases from the cars or lorries being unloaded, has aggravating consequences to the physical load. When lashing containers, they are secured and loosened manually with lashing rods on the deck of the container ship. These lashing rods weigh about 20 to 50 kg. Lashing is done in forced work positions, increasing the risk of health problems.

Monitor questions In addition to making inspections, the Labour Inspectorate has made an inventory of what sticking points employers are confronted with, and what solutions and measures they are currently using in practice to limit physical (over)loading. 2.3 Communication

Before the inspection project began, the Labour Inspectorate drew up a European brochure about physical load. This brochure was sent to sector associations and trade organisations in the middle of 2007. Furthermore, attention was focussed on the European campaign and this inspection project via the press. In conclusion, the Labour Inspectorate gave a presentation on physical load in the harbours to the Nationale Havenraad [National Harbour Council] in the fall of 2007. Website "Lighten the Load": http://www.handlingloads.eu/en/5.htm 3 Project results

The inspections were made at 134 companies in the period from September through December 2007. About two-thirds of the inspections were made at a loading and unloading site of the sea harbour. One third of the inspections were made on a loading, unloading and/or transfer/transhipment site in the immediate environs of the harbour premises. The results of the inspections and the monitor give a good indication of the occurrence of physical (over)loading in the various loading, unloading and transfer/transshipment situations in harbours and in the immediate periphery thereof. 3.1 Total overview of the inspection results

The inspector has imposed an enforcement instrument at 50 of the 134 companies. In the process, a total of 69 violations were found in the area of physical loading. This means that work activities involving physical overloading were found at more than one third of the companies (37.3%) (exceeding the medical threshold, according to the NIOSH method). The inspector did not impose any enforcement at 84 companies (62.7%). Incidentally, the latter does not mean that no physical loading takes place during work activities, but that no physical overloading was detected at the time of inspection.
Violation / no violation n = 134

37,3% 62,7%

violation no violation

The 69 violations resulted in the inspector issuing warnings, setting requirements and writing a fine report. A warning was issued in 38 cases, nearly in all cases to make a specific assessment of the work activities with physical load in the mandatory risk inventory and evaluation (RI&E), and to take effective measures based on this to prevent or limit physical load. Proper assessment of the extent and the type of physical load the employees are subjected to is often a first requirement for actually taking effective measures. For example, during the inspections it was regularly found that employers

do take some measures to reduce the physical load, but that these are insufficiently effective. It also appears that employers assume that no loads heavier loads than 23 kg may be lifted, as is customary in construction. However, the NIOSH method calculates the maximum acceptable lifting weight on the basis of the weight to be lifted, and also takes into consideration the frequency of lifting the weight, the position assumed when moving loads, or when loads must be lifted above shoulder height, as well as the room to manoeuvre. The Labour Inspectorate imposed specific requirements to have certain measures taken immediately in 30 cases in which physical overloading was clearly involved. Among others, these were the transfer of bales of cocoa. The employers working with cocoa have meanwhile started to take a joint initiative, prompted by these requirements, to develop a broad range of application-oriented solutions. A specialised ergonomics firm has been called in to assist in this matter. A fine report was drawn up immediately in one case, because the employer did not have a risk inventory & evaluation (RIE) available at all, and there was a serious case of physical overloading involved. Aggravating conditions were detected in about half of the situations found (63) during loading, unloading and/or transfer/transshipment. This chiefly concerned weather conditions (45) and ambient temperature: (freezing) cold in case of transferring frozen fish (21) and heat (4) when sweeping liquid cargo in the hold of a vessel. The lack of physical room to move (11) also results in aggravating conditions, often in situations of lashing containers and/or cargo, but also when working in the hold of a vessel. Finally, work pressure is involved (6). In the latter case, the factor that delay time in the harbour is expensive also plays a role, as does the fact that employees are often paid by the job, which means there is pressure to make good time. 3.2 Results according to the nature of the load

The table below presents an overview of the inspection results, itemized according to the nature of the load and the number of inspections dealing with manual work activities. The extent to which physically stressful work activities occur is indicated for each type of cargo, as well as how often violations of physical load/physical overloading were detected for each type of cargo. (Note: these data were created by means of monitor information. Since monitor information was not available for all 134 inspections, this concerns a somewhat smaller number of inspections). Type of cargo Number of inspections Inspections of physically stressful work activities 12 22 11 10 4 59 violations above the limit value (a) 10 16 5 4 1 36 %a Inspections in situations of physical overloading 9 16 8 1 2 36 violations 2x NIOSH (b) 9 13 5 1 1 29 %b

Mixed cargo Containers: stuffing/stripping Containers: lashing/stacking Bulk RoRo Total

28 34 16 27 5 110

83% 73% 46% 40% 25%

100% 81% 63% 100% 50%

The table shows that on average more than half of transfer/transhipment activities (59 of 110) still involve physically stressful work activities. Handling mixed cargo results in the most violations (83%), stuffing and stripping containers takes second place with 73% violations, and lashing and stacking of containers takes third place, with 46%. Columns (a) and (b) show that violations were not detected in all situations of physical (over) load. The reason for this is that in order for there to be enforcement, the inspector must actually have detected a situation of physical overloading in practice.

3.2.1

Mixed cargo

28 inspections were made on transfer of mixed cargo. This involved fish (7), metal (4), wood/paper (4), machine components (3), potatoes/fruit (3), cocoa (1) and other mixed cargo (6), such as salt, barrels of fruit juice, rocks, bags of flour and various cargo (including yachts). The mixed cargo was packaged in boxes or bags. Work activities taking place below the deck may especially be overly stressful for the body. 12 inspections involved work activities with a clear manual component, such as manual transfer on pallets (5 times), stacking goods (4), securing/loosening (4), pushing and dragging (2) and loading and unloading (2). Physical overloading was involved in nearly all these situations, with the exception of securing and loosening.

An inspector encountered a freezer trawler in the harbour of Scheveningen that was being unloaded. The fish caught had been immediately processed, frozen and packaged in cardboard boxes in the trawler while underway. The weight of the boxes was about 23 kilograms, on average. The boxes were stored on two levels in the freezer hold. The areas were stuffed to the maximum from bottom to ceiling and from starboard to port for economic reasons. Under orders from the stevedore an external company, with a crew of 8 to 10 strong young men, was put to work manually transferring the boxes from the freezer hold to pallets. They brought the boxes of fish from the hold to the deck via two 3 x 3 metre cargo hatches. This involved being paid by the piece and time pressure. The more pallets the crew filled, the more they were paid. Nearly 200 boxes per person were stacked manually per hour, on average, in bent over to stretched position, at a high frequency and in a stressful, freezing indoor climate.

Given the current state of the art, various technical and organisational options are available for reducing the physical load, such as lifting aids, task rotation and, for example, agreements to not stack any higher than 1.80 metres. In the harbour of Harlingen, an inspector encountered employees at the shrimp sieving machine who were stacking crates with a content of 20 kilograms on pallets higher than 180 centimetres. Plastic bags filled with shrimp, weight of a random sample 20.8 kg, were lifted from a crate into the tub of the shrimp sieving machine. Using the NIOSH method, it was found that the employees were exposed to excessive physical load and that there was a high risk of causing serious damage to their health. The frequency and the weight of the crates and plastic bags, as well as the height to which the crates with shrimp had to be lifted were taken into consideration in the process. In the Amsterdam harbour, an inspector observed a situation in which 50-kilo bags of flour were processed manually. A company spokesman stated that per person an average of 40 tonnes are stacked daily. Using the NIOSH method, it was found that the employees were exposed to excessive physical load and that there was a high risk of causing serious damage to their health.

The inspectors qualified the situations they found in the transfer of mixed cargo as alarmingly bad. It is striking that employers did make aids available in some situations, but that these were not used. For example, there was a company at which a vacuum lifting device was available, but this was not being used at the time the inspector made a visit. Instead, employees were performing their tasks manually. Examples of good practice In practice, companies apply the requisite measures to limit physical load. Measures applied were: task rotation (4), the use of pallets (3) so transfer was mechanised (wholly or in part) by means of forklift trucks, the use of lifting aids (2), lashing straps (2), the use of lifting platforms (1) and "big bags" instead of small bags (1) or packages.

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A company in the Amsterdam harbour works with a special container inverter. The container holding bags of cocoa is dumped on a conveyor belt by means of a special inverter machine. The conveyor belt then moves the bales of cocoa and drops them on a pallet set up below the belt. By mechanising the process this way, physical load is practically no longer involved. Before this was the case, and the process still consisted of manual unloading, about 50 tonnes were lifted per person per day (bales of about 65 kg). The management of a mixed cargo processor gave orders to its personnel that pallets are not to be loaded higher than 1.80 m (shoulder height) in order to prevent lifting being injurious to their health, and has issued written instructions to this end. Cargo ships deliver boxes of frozen fish (21 and 33 kg) on pallets. The pallets are moved by a Dutch company to an inverter by forklift truck, as a result of which the pallet ends up on top. The de-palletting machine subsequently removes the pallets, and the boxes of fish are then moved into the container by forklift truck with the help of a push-off mechanism. See the photo report.

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The first 2 photos show physical overloading during unloading cargo by the ships Russian crew, manually stacking boxes of cod and king crab on pallets in the hold of the Russian ship. A physically stressful work activity for the foreign crew. The second photo shows the full pallet being hoisted from the ship by means of a hoist, which does not involve any physical load. Employees of a Dutch company subsequently take over handling of the fish boxes, using aids such as a special forklift truck and inverter. See photos 3 through 6.

Photo 1: Manual stacking of boxes with cod and king crab.

Photo 2: Hoisting a full pallet from the hold of the ship onto the quay.

Photo 3: The pallet is taken along by a special forklift truck with 5 tines and then placed on an inverter.

Photo 4: The full pallet is placed on the inverter.

Photo 5: Full pallet turned 90 degrees so the cargo can be placed and the pallet can easily be removed

Photo 6: The pallet is taken off the stack, the boxes remain behind, properly stacked via a push-off mechanism, without any physical load.

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Fortunately, the very heavy physical work of handling frozen fish, specifically when unloading, occurs less and less frequently. About 70% of the vessels concerned are already suitable or have been made suitable for placing the boxes on pallets. For the other vessels the relevant employers will draw up a plan of approach. This plan of approach explores the opportunities for mechanisation, improvement of the work environment and reduction of exposures. A remarkable initiative hereby is that one employer is studying whether slipsheets may be a solution. Another employer at a fish auction has sent a letter to all its suppliers (shrimp cutter fishermen among them) with the announcement that they may not deliver any bags filled with shrimp that exceed 15 kilograms; should they do so anyway, the shrimp will not be processed! Fish auction personnel are authorised to refuse these bags. Employers handling cocoa have set up a joint trajectory to generate practical and economically feasible solutions for handling bags of cocoa that are effective in reducing physical load. 3.2.2 Containers

Lashing and stacking containers Manually securing and loosening containers on the deck of container ships with lashing rods is physically very stressful. Lashing rods weigh between 20 and 25 kg and usually must be secured and loosened on a work platform with limited space, in a stressful work position. Ashore, the automatic/semi-automatic twistlocks are secured and loosened. A twistlock weighs about 6.5 kg. These work activities may involve very uncomfortable work positions, possibly in combination with high frequency. Forklift truck and reach stacker drivers and crane operators may also be subject to physical load (static body position). 16 situations involving lashing and stacking were inspected. The 11 inspections involving employees securing and loosening lashing rods repeatedly showed that the threshold was exceeded, and situations of physical overloading were encountered in the majority of the cases. Loosening and securing twistlocks is also a manually performed task, but resulted in physical overloading in only half of the situations inspected. The verdict on these situations of physical overloading encountered during lashing and stacking varied from alarmingly bad (3x), bad (9x) to not bad but unsatisfactory (6x). Examples of good practice The following measures were applied to lashing and stacking, in order to prevent manual handling as much as possible: task rotation (7), scheduled breaks (5), plastic/aluminium lashing rods (2), platform on board (for lashing) (1), the use of a safety cage for twistlocks (1). When technical measures to reduce physical load during stacking and lashing are involved, a cradle or a platform can be used when working on the ship. When working in the hold of the ship, lighter lashing straps can be used instead of lashing chains. During stacking activities in particular, working from the quay and/or from a safety cage is better for the physical load, and as a rule also safer. There are certain types of vessels in the container trade where securing containers in preparation for departure no longer takes place by installing lashing rods, but is done entirely automatically by placing the containers between guide rails intended for this purpose (cellular container ships). Loading and unloading such ships no longer involves any manual component. Stuffing and stripping containers The degree of mechanisation for stuffing and stripping (packaging and unpackaging) of containers is often low. Because of this, the risk of overloading is high. 34 inspections dealt with the further investigation of stuffing and stripping a container. Physically stressful work activities were encountered in 22 inspections, such as stacking heavy boxes (13 times) and lifting operations (17 times). Situations of physical overloading were encountered during 16 inspections. The inspectors evaluated the situations of stacking and lifting when stuffing and stripping containers as bad to alarmingly bad.

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An inspector encountered an odd jobs company that regularly put its employees to work emptying containers for various clients. Among other things, bags of feed (25 kg) and bags of milk powder (20 kg) were unloaded manually. Boxes of wine were also regularly unloaded manually. The employer was unable to present a risk inventory & evaluation (RIE), nor had it assessed the clearly present risks of physical overloading. Although the employer had taken a few measures, these were absolutely insufficient to reduce the hazards of physical overloading.

In the harbour of Amsterdam, inspectors also encountered situations of physical overloading when a lorry was being loaded. The employees handled 18,000 to 20,000 packages per day, at an average weight of 10 kg. The maximum package weight was 31 kg. The weight is not printed on the packages, so employees cannot prepare themselves for it. Loads were also frequently lifted higher than 1.80 metres. The employer in question had not instructed its employees as to the risks of physical load related to this type of work, nor had it taken any measures.

Examples of good practice The inspectors encountered the following measures taken to limit manual operations as much as possible: task rotation (11), electrical aids (4), slipsheets (3), mini forklift truck (3), roller conveyors (2), scheduled breaks (1), roller forks (1), steps (1), container inverter (1) and palletisation (1). Other solutions for reducing physical load when stuffing and stripping containers include: the use of slipsheets, roller forks, lifting aids and mini forklift trucks for hard cargo (boxes, etc.) inversion, whether or not mechanic, of a container when unloading bags using steps and platforms if work must be done at a height above 1.8 m using ramps when floors are on different levels using electrically driven aids when moving cargo paying attention to the posture when lifting and moving loads (information and instruction about ergonomics and physical load). There are also employers who managed to arrange clever solutions via agreements with suppliers, which result in advantages to several parties in the overseas logistic chain. This applies, for example, to an employer (wine merchant) with an office at a container terminal. The merchant stated that he had made the agreement with his suppliers in South Africa and Chile to place the bottom wine boxes in the sea container on so-called slipsheets (plastic sheets). When unloading the container, the slipsheet can be grabbed via a grip on the fork set up of the forklift truck and pulled onto the forks. Not only does this prevent physical load on employees when unloading, but the container can transport additional cargo due to saving the space the pallets would have taken up. According to the employer the costs of using slipsheets were recovered within a few months. 3.2.3 Bulk cargo

27 situations where bulk cargo was handled were inspected, and physically stressful work activities were encountered in 10 situations. These chiefly involved shovelling and sweeping. When sweeping, employees manually sweep up liquid oils in tanks using large squeegees and heavy heating coils that must usually be moved manually. Shovelling involves scraping loose bulk cargo caked onto the vessel wall with long scrapers. 4 cases of physical load were detected here during the inspections, and one situation with physical overloading. The verdict of the inspectors on the situation during bulk transshipment was, in so far as physical load is concerned, "Not bad", but absolutely unsatisfactory. Examples of good practice The following measures were used in ships with bulk cargo, where shovelling or sweeping of cargo is involved, in order to prevent the necessity of manual operations as much as possible: task rotation (6), mechanic aids (5), scheduled breaks (2), permanent pipes (1).

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Heating coils are used to remove liquid cargo residues of edible oils, for example. These coils are heavy and must be moved and lifted. A company in the Rotterdam harbour manufactured its own simple lifting aid (a type of lever) to facilitate lifting and moving this coil. The costs of investment were practically nil (40 euros), the return, in terms of process speed and reduction of physical load were many times that! (See photo report 1 through 3.)

Photo 1: The "old" hook for manual lifting and moving the heating coil

Photo 2: The lever

Photo 3: Detail photo of the foot

Specific technical measures that reduce physical load when shovelling are, for instance, the use of lighter and/or shorter poles. Instead of manual operations for sweeping, chemical cleaning or the use of mechanical high pressure cleaning may be other options. 3.2.4 Roll-on roll-off: lashing cargo Lashing cargo involves securing cargo (mostly vehicles) on roll-onroll-off vessels using straps, rods and chains. The work is especially hard in limited work space and because of the fact work is done in the hold of the ship where it can be oppressive, for example as a result of higher temperature, insufficient ventilation in combination with exhaust gases/vapours of the cars or lorries being unloaded.

Note: As far as roll-on roll-off vessels are concerned, the aggravating effect on the physical load was primarily examined. During this project, 5 roll-on roll-off vessels were inspected, and clearly manual and physically stressful work activities took place in 4 cases. This involved securing and releasing cargo (cars, lorries, rolling equipment) in ocean vessels. Physical overloading was detected in 2 of these situations. Inspectors passed the verdict "bad" and "not bad, but unsatisfactory" in these cases.

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Examples of good practice During inspections on board roll-on roll-off vessels, the following measures to make the work less physically stressful were encountered: task rotation (2), the use of lashing straps instead of chains, since straps are lighter (1), the use of a pneumatic turnbuckle (1). The ratchet is also an aid for reducing physical load. See photo report 1 through 3:

Photo 1: Old-fashioned securing loads using chains and rods

Photo 2: Tightening chains and rods with a ratchet.

Photo 3: The ratchet (less stressful physically)

3.3

Sticking points for employers

Why do employers fail to apply measures? Using the state of the art, a broad range of solutions is available for reducing physical load during transfer/transshipment work activities in the harbours. Therefore, one could expect these solutions to be applied. However, inspectors encountered situations various times in which (standard) solutions could have been used, in their opinion. Why does this not happen? The employers indicate the following reasons or sticking points for this: employees are against this (6x) the employer is not familiar with the measure (4x) applying the solution wastes time (3x) the heavy work is contracted out (2x) there is no problem (2x) costs are too high (1x) equipment in use is obsolete (e.g. heavy lashing chains with which the ship is already equipped) (1x) Loading Employers encounter sticking points that have to do with the manner in which ships and containers have been loaded. They refer to other responsible parties in the logistic chain who do not take any measures for economic reasons, which leaves the situation that then confronts the transfer/transshipment of cargo in the Netherlands. For example, in the case of cocoa shipping, they immediately point out how cocoa is loaded into the ship in Africa. In the case of freezer trawlers, they point to the owners of the trawlers who stuff the holds with boxes of fish without putting them on pallets, or as far as outgoing loads are concerned, they point to the receiver who does not want any pallets because of the loss in volume in transport. For containers and roll-on roll-off vessels, they depend on the equipment on board the vessel. They have no influence on how the containers are lashed or on the lashing materials on these vessels.

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The opinion of the Labour Inspectorate is that employers must consider what is possible in these cases to a far greater extent. Parties receiving loads can make agreements with their suppliers in the exporting countries on the manner in which cargo is loaded. There are also possibilities to include working conditions aspects with respect to physical load in the regulations for loading and stowage, intended for the trim of the vessel and for keeping it in balance. This way, one would be working towards a more integrated approach to safety of the vessel on the one hand, and the health with respect to the physical load of the crew, or of those who handle transfer/transshipment of the cargo on the other. Protecting only one's own employees Some employers prevent the physical load for their own employees to as great an extent possible by having temporary workers do the hard work or by calling in the foreign crew of the vessel for this purpose. For example, a stevedore stated that he did not have his own employees stack containers, as he found this too dangerous. He made an agreement to have the crew of the vessel do this. A comparable situation was also encountered in the case of unloading frozen fish. The ships crew did the work manually, with the requisite physical overloading in combination with aggravating conditions of (freezing) cold and limited room to move in. The Dutch workers then took over, using forklift trucks and other mechanical aids. These are serious situations and in violation with agreements on social protection and labour standards that have been signed via the ILO treaties. However, not all countries have ratified these treaties, nor do all countries comply with these standards. Therefore, a lot of work still has to be done in regard to this issue, but the solutions are beyond the power of individual employees. In particular international parties (employer and employee organisations) and also international politics must make a move here. The recently signed ILO Decent Work Agenda, aimed at reinforcing dignified working conditions for all employees, is a new initiative to activate countries globally for better working conditions, taking the specific economic situation of a country into account. Situations as mentioned above must be brought up for discussion in this framework. The European labour inspectorates can also play an active role in this, by putting abuses encountered in their supervision practice on the international agenda. Misunderstanding about the lifting standard It has regularly been detected that employers have the idea that the standard" for physical load is 23 kg. Many employers think that if they comply with this standard, they are not exceeding the legal standard for physical loads. The medical threshold (the maximum acceptable lifting weight) may differ for each situation, depending on the weight to be lifted, the frequency with which this weight is lifted, the posture during lifting, and lifting above shoulder height. The Labour Inspectorate evaluates what the maximum acceptable lifting weight is by means of the NIOSH method. Company culture Attention to safety on the workfloor is reasonably established at a great number of companies in the harbours. After all, the Labour Inspectorate has been focusing attention on this for years. When attention to physical load is involved, it appears that employers and employees see this as a facet "that is just part of the trade". The hardest work is often still the most popular. For example, lashing containers is "more worthy" than stacking. Employees usually do not discuss their health with their employers. However, workers express something entirely different in one-on-one conversations with inspectors: on these occasions, employees recognise how hard the work is and think the Labour Inspectorate is doing a good thing by focusing on the issue. Level European playing field In interviews with the Labour Inspectorate, employers admit that, in addition to safety, more attention to health, and thus also to physical load, is no luxury in the harbours. They particularly point out the ever intensifying problems in finding good workers, as a result of a tight employment market. They comment that they are convinced of the importance of investments intended to reduce the physical load, but also point out the importance of equal inspection and enforcement in the European sea harbours, so they are not confronted with competitive disadvantage due to a non-level European playing field. This inspection project was initiated in part for this reason. It is part of a European initiative with the purpose of reinforcing enforcement of labour conditions among neighbouring countries and making them more uniform. Follow-up commitments on the exchange of inspection results in the sea harbours and on harmonising enforcement are made with the Labour Inspectorates in Belgium and Germany, where similar projects have been carried out.

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Conclusions and recommendations

This project showed that, in the harbours where manual handling of loads are involved, violations in the area of physical load were detected in more than one third (37.3%) of the companies inspected. It also showed that nearly half of the companies focus little or no attention on the problem of physical load, while this does involve companies where manual handling of loads is part of the daily work. The Labour Inspectorate emphasizes in this case that it exercises a great deal of restraint in taking action against physical overloading (only when the NIOSH standard has been exceeded twice), which does put the result of "only" a third of the companies with violations in a different light in this aspect.

Employers and employees themselves are primarily responsible, and must take concrete measures. The culture still prevails in the harbour companies that physical hard work "is just be part of the job" and that dock workers are "trained" for this. Both employers and employees often have an incorrect idea as to the legal standards for physical load. They think that a 23 kilogram maximum weight to be lifted, as is the standard in construction, is all they need to know. However, physical load and the indication of physical overloading are extremely work-type specific, and the weight to be lifted is only one of the factors that determine the maximum acceptable weight. Investing in solutions and measures to reduce physical load is not commonly found at the companies. If measures are taken, they are often the obvious ones, such as task rotation, or the use of available lifting aids and mechanisation. Companies must assume a more active attitude in order to develop creative solutions. The perception of employers is often quickly one of big and expensive investments, which they think will not be profitable. Examples of good practice in this report also show that very simple practical aids and solutions can be effective. Moreover, investments in preventing loss of employees, in view of the tight employment market and the continuing ageing of the work population that are already noticeable now, are also of great importance from a business economic point of view. The more "revolutionary" solutions, such as making agreements with suppliers, seem to be much more difficult to many. Several examples we showed demonstrate that they also can pay off. Even "farther away" solutions do not appear to come up for discussion at all. For example, there are certain types of vessels in the container trade in which containers are made ready to off-load by placing them entirely automatically between guide rails intended for this purpose (cellular container ships). No manual component is involved in loading and unloading such vessels. It seems advisable to investigate the advantages and disadvantages of this type of vessel in more detail, from a working conditions point of view, and to involve experts of insurers, engineering firms and ergonomic consultation firms in this.

The Labour Inspectorate is concerned that a macho mentality can still be perceived in employees in the harbours. This attitude makes it difficult to bring up physical load for discussion with the employers, and thus creates another threshold for the search for concrete solutions to reduce the physical load. The Labour Inspectorate finds it extremely distressing that protection of a company's own employees comes at the expense of physical overload of temporary personnel and/or foreign crew members, for example. There is still much ground to cover in this regard. Furthermore, it appeared that agreements with overseas merchants are a possibility, and have led to interesting win-win situations. All parties can still profit a great deal on this point. The Labour Inspectorate concludes that a "level playing field" has certainly not been established yet globally, while cargo transfer/transshipment in the harbours is of an extremely international nature. This is why various parties still have the requisite work to do, including employers, employee organisations, sector organisations, the EU and also various maritime organisations. As far as the Labour Inspectorate is concerned: it will focus attention on the problem of physical load in the harbours, and the results of this inspection project in particular, in international context with colleague inspection agencies and in its further international contacts such as the ILO. Attention to physical load will also continue to be an important subject in the framework of the harbour inspection programme. The Labour Inspectorate makes two recommendations to the employers and employees of transfer/transshipment companies in the harbours:

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Recommendation 1: More creative measures In addition to application of already existing and properly functioning measures, the Labour Inspectorate considers it important that companies search more actively for and invest in creative measures that prevent or limit physical load. The Labour Inspection calls on companies and sector organisations to allow themselves to be inspired by the examples of good practice within, but also outside their own sector. It is also worth the effort to not immediately push aside the "revolutionary" solutions, but to seriously examine them for effectiveness and feasibility.

Recommendation 2: Making physical load discussible The Labour Inspectorate considers it important that employees, employee organisations, sector organisations and individual employers make the physical load subject discussible. This requires the reigning culture and attitude among employees to be breached. Employees can be involved actively in searching for creative solutions for physical load they are subjected to. This will increase the support base for implementing measures.

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Appendix: NIOSH method

Evaluating lifting situations The American "National Institute of Occupational Safety and Health" (NIOSH) has developed an evaluation method for calculation of the Recommended Weight Limit (RWL). The following factors are taken into account here: H: horizontal distance from the load to the ankles V: vertical distance from the load to the ankles D: vertical distance the load is moved A: torso rotation, asymmetry factor F: lifting frequency C: contact with the load The NIOSH method can be used if one is free to choose the lifting position and can pick up the load with two hands. In optimum conditions, the recommended weight is 23 kg. This weight is multiplied by the 6 factors that vary between 0 and 1 (the optimum situation). The basic assumption of the NIOSH standard is that the majority of the population (99% of the men and 75% of the women) can carry out the lifting operation without any risk to their health. This limit would correspond with an energy consumption of 3.5 kcal/min or with a compressive force of 3400 N on intervertebral disc L5-S1. The NIOSH method results in excessively high thresholds for lifting situations that do not comply with the conditions for the method (e.g. one can not choose the lifting position or must pick up the load with one hand).

NIOSH formula: RWL = 23kg * Hf * Vf * Df * Af * Ff * Cf Hf = 25/H (minimum 25 cm to maximum 63 cm) Vf = 1 0.003 x |V-75| (maximum 175 cm) Df = 0.82 + 4.5/D (if moving distance < 25cm, then Df = 1) Af = 1 0.0032 A (in ) (rotation must be < 125 ) Ff = number of times per minute, from the table (0.2 minimum) Cf = from the table

[drawing, terms from left to right, top to bottom] Vertical Projection point view from the top Angle Horizontal position The midpoint between the ankles Vertical position Horizontal Midpoint between the ankles Horizontal position Projection point

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Example of pallet loading

Data: * Load 18 kg, box 45 x 45 x 30 cm. * Frequency: 5 boxes are placed on the pallet (10 cm high) per layer. This takes about 1 minute per layer. * The employee does this for about 1.5 hours per day. * He lifts the boxes from the bottom, so he can wrap his hands at a 90 degree angle around the load. * He can take steps to stand right in front of the load and keep the load close to his body.

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Evaluation according to NIOSH: Initial situation Parameters H (measuring or 20/25 + depth of the box) Vbeginning D F C A RWL End situation Parameters Hend Vend D F C A RWL 1st layer 35 2nd layer 35 4th layer 35 1st layer 0.71 2nd layer 0.71 4th layer 0.71

Factors Hf

50 40 5/min normal 0g 1st layer 40 10 40 5/min normal 0g

50 5 5/min normal 0g 2nd layer 35 55 5 5/min normal 0g

50 95 5/min normal 0g 4th layer 35 145 95 5/min normal 0g

Vf Df Ff Cf Af

0.93 0.94 0.6 0.95 1.00 8.1 1st layer 0.63 0.81 0.94 0.6 0.95 1.00 6.3

0.93 1.00 0.6 0.95 1.00 8.7 2nd layer 0.71 0.95 1.00 0.6 0.95 1.00 8.7

0.93 0.87 0.6 0.95 1.00 7.5 4th layer 0.71 0.81 0.87 0.6 1.00 1.00 6.6

Factors Hf Vf Df Ff Cf Af

Risk assessment: The lifting index (Li) is used for assessment of the risk. This index is the ratio between the weight that is effectively lifted and the recommended weight. This value is used as the risk indicator: < 1 : no problem 1-2 : attention required for adaptation > 2 : adapt immediately In this example: The load is 18 kg. RWl = 6.3 Lifting index is: 18/6.3 = 2.86. In this example, the NIOSH standard is substantially exceeded. Also the 5th layer cannot be assessed by using the NIOSH method. It is too high/heavy anyway. Maximum stacking height is 175 cm

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Colophon Project number: A851 Labour Inspectorate Project Manager Mrs J.G.M. van Vlerken Oudenoord 6 P.O. Box 820 3500 AV Utrecht Phone +31 (0)30 230 5600 Physical Load Specialist Mr A.G. Moss Janspoort 2 P.O. Box 9018 6800 DX Arnhem Phone +31 (0)26 355 7111 National Project Secretary Mr W.J. Legel Stadionweg 43C P.O. Box 9580 3007 AN Rotterdam Phone +31 (0)10 479 8376

The Labour Inspectorate is part of the Ministry for Social Affairs and Employment and is the supervisor and enforcer of the legislation in the field of labour protection, labour market fraud and working hours.