Malcolm Gunnyeon and Claire Campbell, Brodies LLP
The growth of wind energy in the UK has been significant, with wind farms playing a crucial role in the Energy Transition and the UK’s journey to Net Zero. However, with this growth comes a greater focus on the organisations with responsibility to ensure the health and safety of those working in and around these installations, both on and offshore.
The duty of wind farm operators
The Health and Safety at Work etc. Act 1974. places a duty on employers to ensure, so far as reasonably practicable, the health, safety, and welfare of employees and anyone who might be affected by their operations. For those who work with turbines, this means implementing robust safety measures to protect workers from the unique risks associated with these installations and, for onshore operators, additional measures to protect members of the public in the vicinity of turbines and other related infrastructure.
Key risks of working with turbines
Wind farms present several specific health and safety risks, including:
- Working at height: maintenance and inspection tasks often require workers to operate at significant heights, posing a risk of falls.
- Electrical hazards: the high voltage equipment used in wind turbines can present serious electrical hazards.
- Mechanical risks: moving parts of wind turbines can cause injuries if not properly guarded.
- Environmental conditions: workers are often exposed to harsh weather conditions, which can exacerbate other risks.
Fatal Accident Inquiry recommendations
A technician, Antonio Joao Da Silva Linares died on 15 March 2017, after falling at the top of a wind turbine at the Kilgallioch Wind Farm. A Fatal Accident Inquiry into his death found that by mistake he had not attached his harness to a fall arrest system, which would have prevented his death.
Following the Inquiry, the Court made three recommendations focussed on preventing a similar accident in the future:
- Joint health and safety drills involving all contractors and subcontractors should be conducted to ensure all personnel involved in rescue operations are properly prepared.
- Suitable stretchers to keep casualties horizontal and minimize chest pressure should be available on site. These will facilitate safer and more effective rescues in an emergency, reducing the risk of further injury during evacuation
- The industry should utilise technology to detect when a person disconnects from a fall arrest system, to ensure an immediate response to potential fall hazards.
Following publication of the Sheriff’s determination, the HSE emphasised the importance of these recommendations and urged the wind turbine industry to collaboratively consider technological improvements, including:
- Interlocks on Gates/Fall Arrest Systems to prevent accidental disconnection.
- Ergonomic improvements to assist safe transfer between systems and anchor points.
- Alarm systems to provide an immediate alert of disconnections.
The HSE encouraged stakeholder groups to coordinate industry actions in response to these recommendations.
Occupational health concerns
The HSE has also recently received reports from a wind farm operator about significant occupational health concerns related to wind turbines. In response to those reports the HSE issued two letters to the renewable energy sector, highlighting urgent concerns and making recommendations for how they should be addressed.
The notifications issued by the HSE highlighted that the presence of dust deposits containing hazardous substances, including metals and metal compounds such as lead, had been identified within the generator room and nacelle/hub of two wind turbine generators, giving rise to serious concerns about the potential health risks faced by technicians working in those areas.
To address the issue, the operator in question has implemented precautionary measures. Technicians are now equipped with powered respirators and sealed unit vacuum cleaners to ensure thorough cleaning prior to servicing. Additionally, targeted health surveillance programmes have been initiated, and information about the new risk has been promptly shared with the technicians. Further measures to prevent employee exposure to lead have also been put in place.
The HSE has confirmed that it will work closely with the relevant duty holders to gather more information and will ensure that any further findings are promptly shared with the industry. In the meantime, the HSE is urging all wind farm operators to take immediate action to address this newly identified risk.
Risk assessment and mitigation
Although the full extent of this issue is not yet known, it cannot be ignored. Duty holders must incorporate this information into their risk assessments and management processes. Good practice will include alerting maintenance teams to the issue, revisiting design risk assessments to identify potential sources of dust within wind turbines, assessing health risks associated with these dusts, and implementing appropriate control measures to protect the health and safety of employees. Any operator who ignores this information will find themselves in a very difficult position should an incident occur.
