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BS 4163:2021+A1:2022 ‘Health and safety for design and technology in educational and similar establishments – Code of practice states that:
‘In England and Wales, there should be a maximum of 20 learners with one competent, qualified teacher in any one work area’.
‘In Scotland and Northern Ireland, there should be a maximum of 20 pupils for all classes in practical subjects’.
It goes on to provide a helpful framework to use when assessing group sizes:
‘Risk assessments should be carried out to determine the appropriate number of students in the work area. The risk assessment should take the following factors into account:
1. the size and layout of the work area;
2. the size and number of items of furniture and equipment in the work area;
3. the type of activities carried out in the work area;
4. the age and abilities of the students;
5. the competence and experience of the teacher;
6. the extent of technician or other appropriate support;
7. whether learners with special needs are present;
8. whether there are students whose first language is not English;
9. the behaviour of the students.’
More detailed advice regarding student numbers in D&T is set out in our publication: ‘Risk Assessment in Secondary Schools and Colleges D&T Teaching Environments’, available from the D&TA resource shop.
Clearly, the number of learners in any one work area should be carefully considered to ensure safe working and effective supervision and the D&T Association publication does not attempt to set a maximum group size for design and technology lessons. The D&T Association believes that only through risk assessments by professional staff can a valid judgement be made about class sizes. There are occasions when group sizes of 12 to 14 should be a maximum because of the behaviour patterns of the learners or the work being undertaken. Thus the publication sets out an approach for schools to use to make assessments based upon local conditions. Sound professional advice from a head of department on site and/or from an LA Health and Safety or D&T Adviser is the best criterion to use.
Clearly too, some of the risks will not be known when senior managers are allocating learners to groups in design and technology. In such cases the D&T Association’s advice for groups engaged in designing and making is that under normal circumstances at Key Stage 3, groups up to 20 should be manageable and enable good learning experiences to take place safely. At Key Stage 4, groups of approximately 18 should be manageable and enable good learning experiences to take place safely. At post-16 level, group sizes of 16 should be manageable, the major challenge here being the complex project work and personal use that learners may make of dangerous equipment.
Employees are required by law to work safely. Whenever teachers are given responsibility for learners and a workplace this also includes a duty to provide and maintain a safe and healthy work place. The most common complaint from design and technology teachers is the size of the working groups they are expected to teach. They often explain that senior management who sort out notional class groups are generally unaware of the needs and demands of practical design-based work planned to suit the special situations of each work area. What may for example be an acceptable class size for a classroom based subject can create a source of danger to learners operating in a D&T work area and cause additional stress for the teacher. A safe teaching and learning environment can be achieved where teachers are able to closely supervise hazardous activities and respond quickly to emergencies that might occur. This can best be achieved where classes are of reasonable size.
Determining class sizes will therefore require a professional judgement on the part of the headteacher in consultation with the head of design and technology, based on risk assessment. It must be remembered that anybody who identifies or observes a hazard and does nothing about it may be contributing to the possibility of an accident. It is important to plan ahead so as to avoid risk. One must never assume that a group of any size can be taught safely in design and technology areas. Decisions have to be thought through carefully and thoroughly. For instance, precautions should be observed in the case of learners who lack knowledge, experience or maturity or who have disabilities or behavioural disorders, especially when determining the appropriate level and nature of the activity. For example, learners with special needs may have poor co-ordination, lack of spatial perception, slow reaction times, variable levels of concentration, all of which affect performance and require close teacher support and guidance. Some learners may have limited knowledge of English and may not understand instructions. In these situations it would be unreasonable to ask a teacher to take charge of groups that contained the maximum number of 20 learners. An individual workshop ‘license’ which relates to the above criteria and specifies the maximum number of learners allowed to attend and work on design and technology projects within individual rooms could then be agreed. This would help to ensure a safe working environment and allow the teacher to closely monitor and supervise the practical activities and respond to emergencies.
Where a solution cannot be identified, then those involved should, through discussion, make every effort to agree to consult external agencies, which may include the LA Safety Adviser and/or the Education Adviser for information and guidance. It should then be possible to reach a solution in order to avoid unsafe practice and hazards or lack of opportunity to the National Curriculum D&T entitlement through inappropriate group sizes. The CLEAPSS document PS68 D&T Class Sizes, Room sizes and Possible Effects on Safety can provide further advice on this issue.
‘Advice’, ‘non-mandatory’ - there is often an assumption that because an issue is described as ‘advice’ or ‘not mandatory’ that employers and employees can regard them as ‘optional’ or indeed ignore them. Where a formal, written risk assessment has been carried out in accordance with HSE and other professional requirements, proper regard and action needs to be taken as appropriate to the level of risk identified. Should an employer or employee fail to do what is reasonably practicable and an accident or incident occur which may be found to be partially or wholly contributory to any injury sustained, they may be found culpable.
Safe working practice in D&T requires sufficient overall space so that students can move safely around the furniture, equipment and machinery that is required today in a modern D&T workshop or studio. The key information required in relation to this question is contained in 2 documents: the DfE Building Bulletin 81 and BS 4163:2021 ‘Health and safety for design and technology in educational and similar establishments – Code of practice.
Building Bulletin 81 provides a wealth of relevant information, for example on the number of square metres required per learner and space allocation diagrams relating to the working areas required for floor and bench mounted machines. Technically, Building Bulletin 81 has been archived by the DfE, but at the present time it still provides the most detailed information available on this topic available. A quick search on the net will bring up a number of websites where the document is still available and can be downloaded.
For each piece of equipment and machinery the document notes the clear working space required on either side and in front. Where machines are situated next to one another these dimensions can be overlapped. In addition, a 200mm space is recommended at the back of each machine for maintenance and cleaning purposes. In preparation areas it is assumed that the space dimensions required can also overlap, as only one machine would normally be in use at any one time and there is much less likelihood of misuse by the operator than in the workshop.
Just as an example, it recommends that a pillar drill requires 750mm clearance on either side and 1000mm clearance in front, in addition to the 200mm of clearance at the back.
The latest British Standard Code of Practice, BS4163:2021 contains some of this information, in particular that relating to the size of rooms required for different D&T activities based around the size of the group with a single teacher.
It uses the equation: H + (F x G), where H is the space for fixed equipment (m2), F is the area per learner (m2) and G is the number of learners .
It then attributed different zones for various activities, i.e.
| General teaching area | Zone A |
| Electronics and control systems | Zone B |
| Graphic activities | Zone B |
| Textiles activities | Zone B |
| Food activities | Zone C |
| Resistant material activities | Zone D |
| Engineering | Zone D |
In Zone D as an example, for 20 learners the area range would need to be:
Minimum: 27 + (4 x 20) = 107 m2 and a Maximum: 31 + (4.4 x 20) = 119 m2
See BS4163:2021 Section 3 ‘Planning and Services’ for further information.
We would always advise schools to follow the guidance provided in ‘BS4163:2021 Health and safety for design and technology in educational and similar establishments – Code of practice’ and any further guidance provided by your employer.
The British Standard Code of Practice states that:
‘The school or similar establishment should decide which machine is suitable for use by each group of learners. The decision should be based on student maturity and competence, the level of supervision, and local authority/employer and national guidelines’
‘Learners should only work in a high-risk area where it is fully under the control of a person competent to work in the area (i.e. a person with demonstrated competency through the D&T Association training scheme) and, where appropriate, risk assessments have been carried out taking into account the learners’ capabilities’.
‘For specific higher risk activities training and assessment of individual students is necessary and training records should be kept’.
‘Risk assessments should be carried out on the requirements of learners, in particular those with special needs, learning or behavioural difficulties, or those who do not have English as their first language’.
The decision therefore as to the appropriate age at which individual students should be allowed to use individual pieces of machinery and equipment should follow this guidance and must take into account both learners and staff capability as well as local authority/employer and national guidelines. The decision should of course be recorded in the department’s risk assessment on each piece of machinery and equipment, so that all members of the department are clear as to the decision that has been taken.
The D&T Association H&S Training Standards establish the professional view of what should constitute the minimum H&S training requirements for ITT students in D&T. It is assumed that students in training will be undertaking this H&S training throughout the year and as a result it is not anticipated that their Registered D&T H&S Consultant (RDTHSC) would normally register them on-line for accreditation until all of their training has been completed.
For example, to complete the Core Standards, trainees will need time to collate their portfolio of evidence over a period of several months, collecting the evidence required from each of their placement schools, and it is not anticipated that RDTHSCs would register trainees on-line for this Core level accreditation until the portfolio has been completed and signed off.
In addition, it is anticipated that students may be working over the year towards accreditation at one or more of the Specialist levels and possibly one or more of the Specialist Extension Levels. Clearly, it is in the trainees’ interest to be accredited for as many of the Standards as possible before they are registered.
So, it is anticipated that students would not be registered by their RDTHSC until the latter stages of their course. The invoice to cover the cost of accreditation will hopefully be paid by the training institution itself, but it may need to be paid by the student directly or even the school of the student’s first teaching post may be willing to pay it.
Much media attention has been drawn towards MDF and the hazards associated with its use in schools, although there is no evidence that calls for it to be removed entirely from use in schools, it’s use does raise serious concerns.
Hardwood dust is classified in COSHH as carcinogenic, and softwood is now a suspect carcinogen, although not defined as such in COSHH. Thus under risk assessment procedures substitution by natural wood may not eliminate the problem.
Serious concern has been raised over the dust created when machining and sanding this material. HSE, CLEAPSS and NAAIDT have all provided information on this subject in the past. The Control of Substances Hazardous to Health Regulations 2002 require a risk assessment to be carried out on wood dust to determine the control measures required. A combination of control measures might be required. Regular users of timber materials (especially if sanding is regularly carried out) are at increased risk of cumulative hazards to their nasal and upper respiratory passages. The degree of risk depends on the dust concentration and the length of exposure. All timber based dusts are assigned with an HSE maximum workplace exposure limit (WEL) of 5mg per cu m and control measures should be put in place to reduce exposure to the lowest reasonably practicable level.
Dust from hardwood and composite materials, including MDF has a WEL of 3mg per cu m. It is essential that sufficient general ventilation is provided. A risk assessment should be carried out, and local exhaust ventilation provided if required. Respiratory protective equipment should also be provided if required. For both hardwood, composite and softwood dusts, the COSHH Regulations require employers to ensure that exposure by inhalation is reduced as far as reasonably practicable and in any case to below the WEL.
It is essential that sufficient general ventilation is provided. A risk assessment should be carried out, and local exhaust ventilation provided if required. Respiratory protective equipment should also be provided if required.
The following information on wood dust may be useful, taken from the HSE website:
Wood dust causes asthma. Carpenters and joiners for example are 4 times more likely to get asthma compared with the UK working population.
Hardwood dust can cause cancer – particularly of the nose.
Both hardwood and softwood dusts have a Workplace Exposure Limit (WEL) of 5mg/m3 which must not be exceeded. WELs are limits on concentrations of dust in the air, averaged over 8 hours. But because wood dust is an asthmagen, exposure must be reduced as low as is reasonably practicable.
Key controls for wood dust:
Provide dust extraction (also known as local exhaust ventilation or LEV) at woodworking machines to remove dust before it can get breathed in.
Keep the extraction and collection system maintained to make sure it continues to work efficiently.
It is a legal requirement to have dust extraction equipment examined by a competent person at least every 14 months.
Use a vacuum system to clear up wood dust – either a free standing vacuum cleaner or preferably a vacuum pipe attached to your extraction system. Vacuum cleaners should be suitable and have a HEPA filter.
For particularly dusty tasks such as sanding use RPE as well as LEV.
Don’t use airlines or dry sweeping to clear dust away:
Using airlines and dry sweeping of wood dust can cause high peaks of dust exposure and simply spread the dust around.
Carry out health checks:
Because wood dust causes asthma, you need to make sure that any health affects are picked up early. This can be done using health surveillance.
For most woods, a low level of health surveillance is sufficient. This consists of a questionnaire administered before anyone starts work where they are exposed to wood dust, and then repeated annually. These questionnaires also provide information on what to do if you think someone has been affected.
A higher level of health surveillance, including lung function testing, is needed for exposures to western red cedar which is a known asthmagen. Further information can be found in the Woodworking Information Sheet ‘COSHH and the woodworking industries’, at http://www.hse.gov.uk/pubns/wis6.pdf, and in the CLEAPSS document ‘PS33, Medium Density Fibreboard (MDF)’.
You will recognise then that the decision as to whether, or the extent to which, MDF is used in a school is very much up to the school to decide. This should be based on their knowledge and understanding of the material, its’ suitability for the curriculum and the provision of appropriate LEV that will ensure that the risks associated with dust are kept to an absolute minimum.
In summary, the D&T Association's advice to schools re the use of MDF is as follows:
A high level of cleaning of the teaching environment must take place to reduce to a minimum the dust in the environment.
All machining of MDF, and other timbers, should have good quality and effective dust extraction.
Rooms should be well ventilated when working MDF by hand tools. Rotary sanding discs or machine sanders with no dust extraction must not be used in schools.
In relation to the use of other specific timbers, CLEAPSS reported on the use of iroko in school workshops in their Spring 2009 Bulletin to schools. This provides the following information: ‘Sometimes when school science departments are refurbished the old iroko bench tops are discarded. Design and technology departments are often reluctant to see wood going to waste so may wish to claim the old timber for re-use in some way, for either benching or pupils’ woodwork. We are not aware of any legal restrictions on the use of iroko but some local authorities do not permit its use. The timber is also commonly used for garden furniture. Research reveals a fairly clear link between iroko dust raised when relatively unseasoned timber is used by woodworkers and asthma / allergic skin reactions, though most reports are from industrial situations where exposure will be at a high level for much longer periods than those expected in schools. CLEAPSS Model risk assessments for technology sheet 1.058 mentions iroko as being potentially poisonous/allergic. We are reluctant to preclude the use in school technology of a potentially valuable resource such as discarded iroko bench surfaces but handling this wood requires certain precautions. However, unless users can be sure that nobody will accidentally use some of it, either now or in the future, without realising its hazards - it may be better not to accept it.
A specific risk assessment should be carried out for any activity involving iroko, to include the following points:
Pieces of iroko should be stored in such a way that people who are unaware of its hazards cannot accidentally use it.
Individuals with known allergies or asthma should not be present when iroko is being worked on.
Dust masks offering protection against fine dusts (e.g. to FFP 2S) should be worn by all people present in the room when work is carried out on iroko.
Dust masks should be used once only, for reasons of hygiene.
Iroko should not be sanded by pupils, even by hand.
Iroko should be cut or shaped only with sharp hand tools e.g. saws or chisels. Although sawing will produce dust, this will not be as fine as that produced by sanding.
Finishing by pupils should be confined to removal of sharp edges. Staff preparing wood for use by children may carry out other activities for which additional precautions include:
LEV should be used when iroko is being worked on. Dust masks (either disposable or respirators to FFP 2S) should be worn in addition.
Any sanding should be kept to the absolute minimum e.g. by first removing sharp edges.
It is better to confine hand finishing to the removal of sharp edges.
Note also that the cost of providing disposable face masks for class use may outweigh any cost savings on using second-hand timber.’ In addition we would recommend that you then look at the HSE Information Sheet, Woodworking Sheet No 30 on Toxic Woods, available on the HSE website at http://www.hse.gov.uk/pubns/wis30.pdf. This sheet is one of a series produced by HSE’s Woodworking National Interest Group. Its purpose is to provide information on the reported adverse health effects associated with all of the more common woods used in commercial quantities within the UK, e.g. mahogany, oak, pine, teak etc.’
You will recognise then that the decision as to whether, or the extent to which, individual timbers are used in a school is very much up to the school to decide. This should be based on their knowledge and understanding of the material, its’ suitability for the curriculum and the provision of appropriate LEV that will ensure that the risks associated with dust are kept to an absolute minimum.
The HSE guidance leaflet, Getting to grips with manual handling – a short guide, available on the HSE website here will be a useful reference for you and should help to resolve any difficulties. Manual handling comes under the Manual Handling Operations Regulations 1992, as amended in 2002, and apply to a wide range of manual handling activities, including lifting, lowering, pushing, pulling or carrying.
More than a third of all over-three-day injuries reported each year to HSE and local authorities are caused by manual handling - the transporting or supporting of loads by hand or by bodily force.
The Regulations require employers to:
avoid the need for hazardous manual handling, so far as is reasonably practicable; assess the risk of injury from any hazardous manual handling that can’t be avoided; and reduce the risk of injury from hazardous manual handling, so far as is reasonably practicable.
Employees have duties too. They should:
follow appropriate systems of work laid down for their safety; make proper use of equipment provided for their safety; co-operate with their employer on health and safety matters; inform the employer if they identify hazardous handling activities; take care to ensure that their activities do not put others at risk.
Wherever possible then it is recommended that employees should avoid manual handling – so is it necessary to move for example sewing machines from a cupboard onto the work-surface, or can they be safely left out in the classroom? If manual handling is unavoidable, then a risk assessment must be completed. Undertaking risk assessment is the employer’s responsibility, but you as the subject experts will be able to do the assessment on your employer’s behalf and identify ways to make the activity easier and less risky, i.e. less physically demanding. The HSE leaflet and the risk assessment should hopefully help to resolve this problem.
The HSE guidance leaflet ‘PUWER 98: Retrofitting of braking to woodworking machines’, available on the HSE website, hse.gov.uk, clarifies the ruling on braking to certain classes of woodworking machinery, and was introduced following the updating of the Provision and Use of Work Equipment Regulations (PUWER) in 1998.
For new woodworking machinery, the provision of an automatic brake is an essential safety requirement of the Supply of Machinery (Safety) Regulations 1992. The Regulations require that the machinery must be equipped with an automatic brake that stops the tool in a sufficiently short time (defined in CEN standards as 10 seconds or less) if there is a risk of contact with the tool while it runs down. Because of the safety benefits that braking provides, it is also felt appropriate that the same standard is now applied to existing machines as well as new machines.
The main ways of providing braking are to:
replace the existing unbraked motor with a braked motor;
fit a direct current (DC) injection braking device to the existing unbraked motor;
fit a power-operated mechanical brake;
fit a manual or foot-operated brake.
If braking is required, when must it have been completed? The relevant Approved Code of Practice laid down a timetable for certain specified classes of machine. For circular saw benches, dimension saws, powered and hand-fed cross-cut saws, single-end and double end tenoning machines and combined machines incorporating a circular saw and/or a tenoning attachment, the work had to be completed no later than 5 December 2003, i.e. 5 years after PUWER 98 came into force. For narrow bandsaws, re-saws, vertical spindle moulding machines (unless fitted with a manual or foot operated brake), hand-fed routing machines, thicknessing machines, planing/thicknessing machines and surface planing machines, the work had to be completed no later than 5 December 2005, i.e. 7 years after PUWER 98 came into force. For any other machine not specified above but for which the risk assessment shows braking to be necessary, the deadline was 5 December 2008, i.e. 10years after PUWER 98 came into force.
BS4163:2021 Health and safety for design and technology in educational and similar establishments – Code of practice notes these requirements in the context of planing and thicknessing machines and all sawing machines. Within Section 4: Teaching areas, equipment, tools and processes it notes that emergency switching systems should be provided in each separate student work area. Preparation areas for staff use only need not have any emergency switching system and should not be affected by the emergency stop system of any other area. Critical circuits specifically installed to remove hazards should not be controlled by the emergency stop system. The emergency stop system installed in a workshop should not negate any other safety systems fitted to machines, e.g. braking systems on hand fed wood cutting machines.
This is the dilemma. Clearly if braking is fitted to these machines in workshop areas using the same circuit, the brake will not work if the power is interrupted, e.g. by an emergency stop button. Within preparation areas, this has been solved by removing the necessity for an emergency switching system. Within workshops, the braking on machines would need to be fitted therefore via a separate circuit.
In practice many schools have found the cost of installing braking too prohibitive to older machines and schools have found it more cost effective to replace the machines with new models that meet the stopping requirements from manufacture.
The D&T Association H&S guidelines for Primary colleagues provides guidance on the use of low-melt glue guns and their safe use in primary schools.
We would recommend that you must have in place a written risk assessment covering the use of this piece of equipment in your school. This should demonstrate that you know and understand the main hazards that their use will involve and it should record the control measures that you intend to implement to ensure that these hazards can be suitably dealt with.
For example, you will need to consider:
What training you are going to provide for other colleagues in the school.
Where you plan to position the glue guns in your classrooms.
What specific measures you plan to take to minimise the risk of burns happening.
What personal protective equipment you plan to provide for pupils. The current guidance is that protective goggles should be used.
What level of supervision the use of glue guns will require, e.g. one to one supervision, in view of the hazard of burns.
In our experience, it is highly likely that in doing your risk assessment you will conclude that their use should be restricted to pupils in KS2 under one to one supervision by an adult, and if this is your judgement, this should be clearly recorded in your written risk assessment.
Further advice on health and safety relating to D&T in Primary schools can be obtained by attending training on the Primary D&T H&S Training Standards. Contact the D&T Association for further advice or training by sending an enquiry to info@designtechnology.org.uk
Let us know if you are interested in hosting a course at your school and we will send you the details.
We are not aware of any age restrictions on the use of a sewing machine and many younger children find them relatively easy to use.
We would advise a risk assessment is always done. This might include ensuring children don't put their hands near the needle and any other moving parts. It's also important to make sure that a child’s seating positions is correct and that they sit face on to the machine with no other children crowding around them. In addition it’s important machines are switched off and unplugged when not in use. Appropriate demonstrations to the children before they use it are also important. Other issues such as trailing flexes, broken needles etc. should be considered as should basic procedures for using a machine e.g. putting the presser foot down before sewing and developing speed control. The machine should also be serviced regularly (usually annually) to check it is working correctly and is safe.
You might find it useful to refer to CLEAPSS documents for risk assessment. This is a paid for service and if your school isn’t a member it may well be that a local secondary school might be able to help you out with this information as they are likely to be members (try both D&T and Science).
We would advise that with such young children they are supervised on a one to one basis all of the time when on the machine and that they are never left alone. It might be suitable for an adult to help guide the student’s hands, or for them to operate part of the machine. I would however generally advise against this in most cases as it is better if there is one person in full control of the machine. Certainly another child should never touch the machine while a child is operating it.
The type of sewing machine used can help reduce the likelihood of any problems. Many newer sewing machines are designed to be very simple to use
e.g. one with a switch that allows the speed to be changed and automated machines where the correct stitch set up is done automatically. Many newer machines also remove the needle from the fabric when stitching is complete and some will put down the presser foot when the machine is operated and all of these are a big help with younger children.
The space-allocation diagram indicates the recommended distances around sewing machines on a side bench
The diagram shows a corner bench but the principles can be applied to other situations, such as freestanding tables. The shaded area shows an overlap of 500mm, which is applicable if benching is back to back (for example, in a peninsular arrangement). The 800mm dimension shows the recommended distance from the centre of a sewing machine placed at the end of a run of benching to the end of the bench. Click the picture to view it
*distance between last sewing machine and end of run of benching.
ADDITIONAL GUIDANCE for the use of BORAX BASED FLUXES in Schools and Colleges.
Many of you will have picked up on the changes to the WeldabilitySIF COSHH Material Safety Data Sheet for their Borax based fluxes and for most of us via the 2016 SIFBronze flux data sheet. This rang alarm bells for many in schools as if we applied this on the basis of the work exposure hazard headlines, we would be thinking seriously whether young women or girls should be engaging in this key part of design and technology / engineering practice. The Design & Technology Association have been in discussion with the manufacturer WeldabilitySIF and have produced this additional guidance to take account of the much more limited use of these materials by schools, students and staff. With a few basic precautions, outlined in the additional guidance, these fluxes are safe to continue to use in our workshops as long as exposure is limited for any individual. Good hygiene and effective LEV remain important here.
Please note that when you review any COSHH material safety data sheet, you do need to take account of the exposure level, but please do not just assume that the risk is lower on reduced contact, do ensure you take advice from the manufacturer.
Remember, it is important that Health and safety training and accreditation, for all staff using workshop equipment, is up to date to ensure you remain compliant. Refresher training is easily accessible from the D&T Association. See Training and Events section on the D&T Association website or call 01789 470007