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06

Health and safety management

6.1. Development, engineering and procurement - Site assessment

Risk assessment – health and occupational

A. Health, safety, security, and environment

Health, safety, security, and environment are key priorities for any solar PV project. This chapter will investigate specific areas of HSSE policy and coordination that relate to EPC service providers. For a general overview of the fundamentals of HSSE coordination, please refer to SolarPower Europe’s Lifecycle Quality Guidelines V 1.0.

To fully understand site hazards, mitigate them through inherently safe design, and manage any residual safety and operational risks during construction, the following best practices should be carried out across the full lifecycle of a project, and always be underpinned by strong HSSE leadership and personal ownership.

Establishing Leadership, Culture, Communication and Accountabilities

It is important that the EPC service provider (Principal Contractor) has a Health & Safety (H&S) policy statement that summarises its commitment to H&S throughout all levels of the organisation. The EPC service provider’s organisational structure, with defined roles and accountability for leadership and service provider’s personnel, related to the delivery of safe compliant and reliable operations, further demonstrates this commitment. 

Pre-Construction and Design

Pre-construction & Design relates to activities taken to improve asset design that removes construction and operational risk and as such is Inherently Safe, one of the most effective risk mitigations.

Thorough subcontractor selection process (pre-qualification) and final selection informed by historical HSSE performance

Operational HSSE performance requires everyone on site to be equally focussed and committed to understanding day-to-day risks where they work, the preventions that have been put in place to minimise the chances of those risks materialising, and the mitigations that have been put in place to keep any impact as low as possible. In industry, when working with partners, contractors that share the same goals tend to develop a safety culture that delivers high HSSE performance.

Prior to selecting a contractor, a thorough review of their commitment to HSSE, HSSE performance and systems should be conducted.

Health and Safety Plan/File

The Health and Safety Plan/File is the EPC service provider’s working document which sets out in detail how they will manage HSSE on the project and will include answers to any safety issues raised during Pre-Construction design. The purpose of a Health and Safety Plan on a project is to make everyone aware of the scope of the project, how the HSSE of the project affects them, and how the Health and Safety Plan affects others, including non-project related personnel.

The Plan/File details the following:

·       Project description

·       Residual hazards

·       Structural/electrical design information

·       Hazardous materials

·       Safe O&M

·       Location of services

·       As-built drawings

·       How to decommission the plant

·       Waste management

Identifying and aligning on Environment, Health & Safety legal requirements

The Health & Safety Plan/File and the subsequent implementation needs to comply with local codes and regulations as well as all applicable international standards such as ISO 45001 and ISO 14001.

It is important that, to meet legal compliance to local law, the EPC service provider maintain a register of compliance obligations and be able to provide details demonstrating their compliance to partners, operators and for external and internal audits.

Safety in design: The industry continues to design and install new technology, seek construction efficiencies, reduce HSSE accidents and improve reliability and quality. It is important that every opportunity to de-risk an operation through Inherently Safe Design principles is taken. The following cross-functional check-ins are valuable formal reviews, and it is recommended that the EPC service provider follow the intent of the following workshops:

Project HSSE Kick-off: A meeting held at the start of the project between the Owner and EPC service provider’s project teams to discuss HSSE expectations on the project.

Design Review: To gather designers, clients and other stakeholders and find ways to reduce construction, maintenance, repair, and demolition safety risks associated with design. This is usually attended by the project team and designers of the Owner and EPC service provider. This is conducted sufficiently in advance so any design changes identified can be easily implemented without material, commercial, or scheduling impact on the project.

Hazard & Operability study (HAZOP): A workshop to gather designers, clients and other stakeholders and identify and mitigate potential remaining hazards and operating issues with the design of equipment and plant. This phase generally produces the initial version of the site-specific Safety and Operational Risk Register that is maintained and handed over, along with site HSSE accountabilities, between teams throughout the entire lifecycle of a project.

Project Health, Safety, Security, Environment Review (PHSSER): A pre-mobilisation safety workshop to review site specific requirements and mobilisation details. It is the final Project HSSE cross functional check, ensuring all the design, permitting, risk registers, contractors and their interfaces are understood and addressed prior to starting construction.

Construction Phase

The following steps are carried out during construction.

Site-Specific Health and Safety Agreement

The Site-Specific Health and Safety Agreement is an agreement between businesses working on a specific site that determines how H&S will be managed. Answering the questions in the agreement will indicate which supporting forms are needed and which can be removed. Safety of all areas relevant to the development of the project should also be considered.

Safety and Operational Risk Register

This site-specific register is for the EPC service provider to record significant hazards that are involved in their work and cannot be eliminated. The register is a live document that should be kept up to date during the work period. The Site Job/Hazard and Risk Register relates to site-specific hazards and risks only and does not replace a company’s overarching H&S hazard register.

Site Briefing Minutes and Toolbox Talks

Site/Briefings and Toolbox Talks provide a means of structuring briefings and meetings in a useful and logical way. The frequency should be based on need, but still at regular intervals. It is an extremely valuable meeting whereby a renewed focus on safe operations, and a discussion on upcoming risks and challenges for the day can be had between team members.

Holding daily Safety Conversations provides an invaluable opportunity to establish and maintain a Safety Culture on site.

Site Traffic Management Plan

The Site Traffic Management Plan is a live and detailed document that addresses site specific risk and is designed to:

·       Keep people and vehicles apart

·       Minimise vehicle movement including reversing

·       Ensure vehicle handling competencies of staff

·       Introduce turning and reversing vehicle controls

·       Maximise people and plant visibility

·       Define signs & Instructions

·       Keep hazards away from the plant

It is important that the EPC service provider develops this plan, ensures that changes that occur over time are appropriately updated in the document, it is clearly communicated to all personnel on site and implementation check conducted regularly to ensure implementation.

Control of Work

An effective Control of Work process provides a work environment that allows high risk tasks to be completed safely and without unplanned loss. It contains:

·       Written procedures for control of work

·       Roles and accountability

·       Training and competency

·       Work plan

·       Risk assessment of work

·       Permit to Work

·       Documentation, communication, and approval

·       Work monitoring and management

·       Safe conditions on completion/interruption of work

·       Auditing the control of work process

·       Lessons learned

·       Obligation and authority to stop unsafe work

Where proposed work is identified as having a high risk, strict controls are required. The work must be carried out against previously agreed safety procedures and a 'permit-to-work' system.

The Permit to Work is a documented procedure that authorises certain people to carry out specific work (high risk in nature and not captured in a Method Statement) within a specified time frame. It sets out the precautions required to complete the work safely, based on a risk assessment. It describes what work will be done and how it will be done; the latter can be detailed in a 'method statement'.

The permit-to-work requires declarations from the people authorising and carrying out the work. Where necessary it requires a declaration from those involved in shift handover procedures or extensions to the work. Finally, before equipment or machinery is put back into service, it will require a declaration from the permit originator that it is ready for normal use.

Task Analysis/Safe Work Method Statement

The Task Analysis/Safe Work Method Statement (TA/SWMS) register is a job-planning tool for higher-risk activities. “Higher risk” refers to activities such as working in a confined-space, asbestos-related work, working at height, working in an excavation, working next to or over deep water, or working with any hazardous product or material. A principal or main contractor can request a TA/SWMS at any time, for any activity, not just those listed above. The TA/SWMS is written in accordance with and aligned to the Permit to Work process.

Risk Assessment Matrix and Hierarchy of Controls

The Risk Assessment Matrix allows you to assess the risk of a hazardous event occurring while certain tasks are being performed. The risk assessment defines the potential/severity and probability/likelihood of a specific risk so it can be compared across projects and against other risks, be effectively mitigated, tracked over time, and communicated.

The Hierarchy of Controls table takes you through a logical flow of options, from most effective to least effective to guide you in eliminating and minimising hazardous events.

For a template Risk Assessment Matrix, see Annex D of the EPC Best Practice Guidelines.

Hazardous Works Notification

Certain activities are considered high risk and must be made note of before work begins. The Contractor controlling the site or activity must notify the authorities.

Hazardous Products and Substances Register

This register records every product, substance, and material that is brought to or used on the site by the subcontractor. You are required by national laws to record every product, substance, and material used on-site that contains potentially hazardous ingredients. The register must be completed before any work starts on-site and updated as changes occur.

Onsite Training and Competency Register

This register records the training, qualifications, experience, and competencies of your employees working on a particular site. It must be fully completed before any work starts on the site and updated as employees or circumstances change. This register is designed to be used in conjunction with a subcontractor’s company-wide training and competency register.

Site Inspection Checklist

Inspection is a vital part of hazard management. An inspection can identify an issue before it causes harm. Inspections range from specific (vehicles) to broad (sites) and differ from one industry or trade to another. An inspection checklist therefore must be customised to meet the specific requirements of a job. Parties need to agree how and when inspections will be carried out. The frequency of these inspections is determined by the Site-Specific Safety Plan (SSSP) Agreement document.

HSSE Performance Monitoring of leading and lagging indicators

The tracking of HSSE performance against key performance indicators may identify emerging trends that require direct focus. It may also identify areas of high performance that others can look to replicate. Key performance indicators (KPIs) can be both lagging indicators of safety performance, built on historical performance that shows that performance has improved or deteriorated, or leading indicators the trends from which may indicate possible future performance change. See examples of Lagging and Leading HSSE KPIs in Annex E.

Management of Change

During construction it is not uncommon that conditions change, there are discoveries that compromise the original design or change the level of risk associated to the operation. While a number of these situations have negligible impact some may be material or may compromise some other part of the design.

Changes to design or changes in risk profile should be subject to a Management of Change review that is signed off by the same cross-functional team, Owner and EPC service provider that endorsed the original design and noted on all ‘As-Builts’.

Emergency Response Plan

The Emergency Response Plan (ERP) saves lives. It must be in place before any work starts on-site and updated as changes occur. A comprehensive ERP is needed for any work that requires a TA/SWMS or a Permit to Work, such as harness rescue (above or below ground), extraction from a confined space, trench, or excavation collapse, and chemical or fuel spill. For an example ERP, see Annex C.

Project Review

Following the construction of the asset the EPC service provider and Owner should jointly hold a Post Construction Workshop. This workshop is to evaluate the effectiveness of the execution of the project against the aims and objectives. It should include H&S management provision, environmental protection, and general management of the overall project. Lessons from this workshop should be fed back into subsequent designs and handed over to O&M teams.

Decommissioning

Prior to commencing any dismantling or demolition works of the PV plant, a Structural Engineer should undertake an assessment of the risks together with a detailed investigation of the PV plant. The following consideration should be included: 

·       Whilst carrying out demolition consider different types of demolition to suit the structure i.e., Partial Demolition, Complete Progressive Demolition, and Demolition by Deliberate Collapse, Manual Demolition Techniques, and Mechanical Demolition

·       References should also be made to the O&M Manuals with regard to erection sequences and any future dismantling or modifications proposed to the plant installation

·       Demolition should be programmed and sequenced to avoid uncontrolled structural collapse. A set of operations should also be established which on a regular basis allow for debris to be cleared. Frequent checks to assess the stability of the remaining structure should be carried out. All workers should be withdrawn if the structure is unsafe. Danger points should be recognised such as floor loadings, falling debris, risk of fire hazards and the need for secure edge protection. 

As a general guideline, any dismantling or demolition works should consider local recycling, based on the relevant local legislation.

Environment

Without precaution, the environment hosting the PV power plant may be affected during the project lifetime. Hence, an effective assessment of the associated impact of the proposed development project is a crucial aspect of any environmental and social impact assessment. Since a universal methodology might not apply to every project’s environmental and social conditions, different approaches are adapted to suit the environmental context of each site.

There are several basic environmental authorisations including, but not limited to:

·       Environmental impact assessment (EIA)

·       Endangered/protected species

·       Agricultural protection

·       Historic preservation

·       Forestry

Permitting and licensing requirements for solar PV power plants differ significantly from country to country and even, within different country regions.

All necessary environmental permits, licenses and requirements must be acquired prior to start of construction. It is a common practice to hire a specialist environmental consultant to provide advice on (1) the specific country requirements, laws, and regulations, (2) to consult with the relevant environmental agencies, planning and government authorities, and to determine any additional obligations relevant to the venture. One important aspect to already consider during the planning phase is the situation at the end of the lease term. In addition, equitable purchase/lease of land and water use for cleaning of solar modules should also be considered. The site-specific permitting shall be taken into consideration when moving towards decommissioning, repowering, acquisition to the landowner, etc.

Biodiversity

Biodiversity concerns the variety of living species, including plants, animals, bacteria and fungi on the site.

The SolarPower Europe Sustainability Best Practices Benchmark and O&M Best Practice Guidelines discuss how to make sure that a high level of biodiversity is maintained during plant operations. However, certain decisions during plant development and construction are important for ensuring that the PV project maintains or even increases pre-construction biodiversity levels. The biodiversity objective is to achieve the best possible synergy between technical and ecological systems on the site.

Perhaps the most important one of these decisions concerns the choice of where to build the plant. Several studies (for example BNE study, Enerplan et al.) have shown that biodiversity can be significantly improved, if the PV plant is built on a biologically degraded site. This does not necessarily mean, that PV plants should be built on contaminated soil – and the obligation to do so should only be accepted if the resulting risk is carried by the polluter. Furthermore, sites with polluted soil might nevertheless show a high level of biodiversity if industrial activity has been terminated a long time ago.

Other opportunities are agricultural sites with low productivity, because in this case the high potential to increase biodiversity combines well with an acceptable loss of agricultural potential. Occasionally it makes even sense to maintain agricultural activities in the PV plant. However, a clear decision should be made as to whether the purpose is energy-centric or agriculture-centric.

Construction can temporarily disrupt the existing natural ecosystem. So, after the site has been chosen, an initial survey of present species - before construction - should create a baseline, which makes later studies more meaningful. The design of this initial survey should be in line with later ones.

Certain design decisions contribute to higher biodiversity of a future PV plant. Air, land, and water are the main pillars in supporting animal and plant life, so the decisions focus on these points.

Some examples:

·       Limiting soil sealing (foundations, tracks inside the plants etc.). For example, soil sealing could be limited to less than 2%

·       Roads in the PV plant should be water-bound

·       Avoiding terracing or at least limiting it to small problematic areas

·       Using the support structure as cable duct wherever possible, and hereby reducing buried cables and earth movements to a minimum

·       Avoiding the use of concrete fundaments for piles of the support structure

·       Biodiversity can help limit soil erosion (and increase soil fertility by avoiding nutrient run off), pest regulation and keeping vegetation height limited etc

·       Avoiding clearing trees and bushes wherever possible

·       Creating new hedges (for example at the Northern side of the PV plant, the hedge functions as habitat and visual screen)

·       Several studies and best practice guidelines (for example, the BNE study and the Triesdorf biodiversity strategy) underline the importance of respecting minimum row distances

·       Vegetation under the panels instead of gravel may increase transpiration (water vapour as a by-product of photosynthesis), which, to some extent, can cool panels

·       Fences should allow small animals to pass (for example, presence of spaces of 15 cm between soil and fence). For larger animals passages should be planned, if the overall surface of the plant is bigger than, for example, 10-15 ha. The width of such passages should be at least 10 m. Security and biodiversity can here be in a trade-off situation, as animals can trigger motion sensors or cameras

·       During construction the integrity of the vegetational and upper soil layer should be maintained wherever possible

·       If sowing is nevertheless necessary, seeds should stem from regionally present plants. In any case, spreading of invasive alien species must be avoided

·       The use of fertilizers or herbicides must be avoided

·       Soil type and solar radiation will impact the type of wildlife and plants. Shadow from the panels impacts plants under or next to as well as can provide a refuge for animals

·       Bird and bat boxes might be considered to help create the right balance

Given the specificities of protecting biodiversity, an external expert consultant should, where possible, be used to suggest strategies that are appropriate for a site’s size and location.

To produce the best biodiversity results, the ecosystem of a site needs to be considered in its entirety when designing a strategy. This may not be achieved entirely in the first round and the strategy can require updating as the ecosystem is mapped more accurately.

B. Risk Analysis

RM starts with the Risk Analysis (RA), for which we define the following steps:

·       Risk Identification (RI)

·       Risk Assessment (RAss)

·       Risk Prevention & Mitigation (RP)

·       Risk Plan Communication & Implementation (RC)

a)       Risk Identification

RI is the beginning of RM. As a minimum, it is important to identify and define all major risks with a significant chance of occurrence. If this does not happen or happens too late, the whole project could be jeopardised.

b)      Risk Assessment

Once a risk is identified, an assessment must take place to determine how likely it is to occur, what the impact would be, and estimate the costs of eliminating or reducing the risk.

c)       Risk Prevention & Mitigation

Once the RAss has been conducted a decision must be made on the best way to prevent (by establishing barriers) or mitigate the risk and/or its consequences.

d)      Risk Plan Communication & Implementation

Once a decision has been made on how to prevent or mitigate the risk, a plan on how to do so must be communicated.

Health, Safety, Security & Environment (HSSE)

HSSE are priorities throughout an asset’s lifecycle. There are legal requirements in most countries, and internationally accepted standards, such as the IFC Performance Standards and the Equator Principles, to ensure that solar projects do not negatively impact the environment and guarantee a healthy and safe workplace. Furthermore, international financial institutions also use HSSE, and social requirements when assessing projects. Security is often a requirement in insurance policies, otherwise claims can be void.

Good HSSE coordination is fundamental to achieving all HSSE objectives, which can be summarised as follows:

·       Establish an HSSE culture within the organisation and the relevant project team

·       Establish, implement, and maintain an effective integrated HSSE management system

·       Ensure compliance with applicable health, safety, and environmental legislation, codes, and standards and, whenever possible, with higher standards and best practices

·       Ensure surveillance of the project site, especially of high-value products, as well as components which are difficult to replace quickly

·       Ensure that intrinsically safe design is achieved by monitoring progress and preparation of results and systematically reviewing the design process, if necessary

·       Manage risks in the design, procurement, construction, installation, commissioning, operation, and maintenance activities

·       Ensure appropriate levels of skills for all staff engaged in carrying out critical HSSE activities and provide training where necessary

·       Check for any potential HSSE impacts in the project area and ensure that these are minimised

·       Make sure that the site surveillance is in line with the insurance requirements

·       Ensure that a complete inventory of all waste and discharges is maintained and that all waste is disposed of in an environmentally acceptable way, in compliance with the relevant regulations

·       Review lessons learned, performance and any opportunities to continuously improve, to update safe design

For this purpose, it is important that Asset Owner, the EPC, and other service providers meet to align on procedures to follow to avoid risks, especially when different service providers are working on the site simultaneously.

6.2. Construction and operation under EPC warranty

Health and safety: risk assessment

A. Healthy, Safety and Security

The Asset Owner has ultimate legal and moral responsibility for ensuring the health and safety of people in and around the solar plant, the security of the site, and the protection of the surrounding environment. The practical implementation is normally subcontracted to the O&M service provider. In some cases, the Asset Manager can provide or prescribe the systems, which are then implemented by the O&M service providers.

Moreover, the Technical Asset Manager should ensure that the solar PV power plant and the relevant suppliers comply with health & safety (H&S) requirements. If necessary, the Technical Asset Manager should hire an H&S expert to ensure compliance.  For more information, see chapter 2. Health, Safety, Security, and Environment

Managing the risks that solar plants pose to the health and safety (H&S) of people, both in and around the plant, is a primary concern of all stakeholders. Solar plants are electricity generating power stations and pose significant hazards which can result in permanent injury or death. Risks can be mitigated through proper hazard identification, careful planning of works, briefing of procedures to be followed, and regular and well documented inspection and maintenance.

The dangers of electricity are well known and can be effectively managed through properly controlled access and supervision by the O&M service provider. Any person accessing a solar PV power plant should expect some form of introduction to ensure they are briefed on any hazards and risks. Staff working on electrical equipment must be appropriately trained, have sufficient experience, and be supervised. It is also key that others working around the equipment - for example panel cleaners - are equally aware of the potential risks and have safe methods of working around HV and LV electricity.

Hazardous areas and equipment should carry appropriate markings to warn personnel of possible hazards and wiring sequence. Such markings should be clear and evident to all personnel and third parties (and intruders) entering the plant premises.

As well as the inherent dangers of a typical solar plant, every site will have its own set of individual hazards which must be considered when working on the plant. An up-to-date plan of hazards is important for the O&M service provider to manage their own staff and provide third party contractors with adequate information. It is usually the case that the O&M service provider holds the authority and responsibility for reviewing and, where necessary, rejecting works taking place in the plant. Failure to carry this out properly has important consequences for general safety.

Besides workers on the solar plant, it is not unusual for other parties to require access to it. This may be the Asset Owner, or their representative, the landowner, or, in some situations, members of the public. It is important that the plant access control and security system keeps people away from areas of danger and that they are appropriately supervised and inducted as necessary.

The Asset Owner is ultimately responsible for compliance with H&S regulations within the site/plant. The Asset Owner must make sure that the installation and all equipment meet the relevant legislations of the country and, that all contractors, workers, and visitors respect the H&S Legislation by strictly following the established procedures, including the use of established personal protective equipment (PPE).

At the same time, the O&M service provider should prepare and operate their own safety management systems, previously agreed with the Asset Owner, that take into account site rules relating to H&S and the potential hazards involved in the works. The O&M service provider should ensure that they, and all subcontractors, comply with H&S legislation.

The Asset Owner will expect the O&M service provider to assume the role and duties of the principal contractor under the relevant national regulations governing H&S. This involves the O&M service provider proving that they are competent and are able to allocate enough resources to fulfil these duties.

Before starting any activity on-site, the Asset Owner will deliver a risk assessment and method statements to the O&M service provider who will provide a complete list of personnel training certifications and appoint a H&S coordinator. During the whole duration of the contract the O&M service provider will keep the H&S file of each site up to date.

The O&M service provider must have their personnel trained in full compliance with respective national legal and professional requirements. This generally includes obtaining certification necessary for working in a variety of environments, such as MV and/or HV electrical plants. Within Europe, referral to European Standards is not sufficient (examples of standards used today are ISO 14001, OHSAS 18001 etc).

To achieve a safe working environment, all work must be planned in advance. Normally written plans are required.

Risk assessments which detail all the hazards present and the steps to be taken to mitigate them need to be produced.

The following dangers are likely to exist on most solar plants and must be considered when listing hazards and identifying risks. The severity of any injuries caused are exacerbated by the terrain on which solar plants are built and their remoteness.

1.    Medical problems

It is critical that all personnel engaged in work on solar plants have considered and communicated any pre-existing medical problems and any additional measures that may be required to deal with them 

2.     Slips, trips, and falls

The terrain, obstacles and equipment installed on a solar farm provide plenty of opportunities for slips, trips and falls both at ground level and whilst on structures or ladders; and for roof-top or carport systems, fall-protection and additional equipment is required when working at heights

3.    Collisions

Collisions can occur between personnel, machinery/vehicles and structures.  The large areas covered by solar farms often necessitate the use of vehicles and machinery which, when combined with the generally quiet nature of an operational solar plant, can lead to a lack of attention. General risks such as difficult terrain, reversing without a banksman and walking into the structure supporting the solar panels require special attention

4.    Strains and sprains

Lifting heavy equipment, often in awkward spaces or from uneven ground, presents increased risk of simple strains or longer-term skeletal injuries

5.    Electrocution

Operational solar plants, whether energised or not, present a significant risk of electrocution to personnel. This risk is exacerbated by the nature and voltage of the electricity on site and the impossibility of total isolation. Staff engaged in electrical work obviously suffer the greatest risk but everybody on site is at risk from step potential and other forms of electrocution in the event of a fault.  Specific training needs to be given to all those entering a solar farm on how to safely deal with the effects of electrocution. In addition to general electrical safety, common issues for solar PV power plants include arc-flash protection when working on energized circuits; and lock-out-tag-out to ensure circuits are not unintendedly energised

6.    Fire

Several sources of combustion exist on a solar farm, the most common being electrical fire. Others include combustible materials, flammable liquids, and grass fires. Safe exit routes need to be identified and procedures fully communicated. All personnel need to be fully aware of what to do to avoid the risk of fire and how to act in the event of a fire 

7.    Mud and water

Many solar farms have water travelling through them such as streams and rivers, some have standing water, and some are floating arrays. Mud is a very common risk particularly in winter as low-grade farmland is often used for solar farms. Mud and water present problems for access as well as electrical danger

8.    Mechanical injury

Hand-tools, power tools, machinery, and mechanisms such as unsecured doors can present a risk of mechanical injury on site 

9.    Weather

The weather presents a variety of hazards, the most significant of which is the risk of lightning strike during an electrical storm. Due to the metal structures installed on a solar farm an electrical storm is more likely to strike the solar array than surrounding countryside. A solar farm MUST be vacated for the duration of any electrical storm. Working in cold and rainy weather can cause fatigue and injury just as working in hot sunny weather presents the risk of dehydration, sunburn, and sun stroke. Working during sunny days for undertaking maintenance and/or testing on site can lead to sunstroke. To avoid this, drinking sufficient water and staying in the shade is recommended

10.  Wildlife and livestock

The renewable energy industry is proud to provide habitats for wildlife and livestock alongside the generation of electricity. Some wildlife, however, presents dangers. There are plants in different regions which can present significant risk, some only when cut during vegetation management. Animals such as rodents and snakes, insects such as wasps, and other wildlife and livestock can present significant risks. The nature of these risks will vary from place to place, and personnel need to be aware of what to do in the event of bites or stings. Snakes, spiders, ticks, bees, and bugs are common and pose a number of hazards where snake bites could be lethal, spider bites can cause pain and inflammation, tics bites could result in tick bite fever, bees can cause allergic reactions and bugs could fly into people’s eyes. It is therefore important that all precautions are taken to prevent or manage these incidents. Storage and application of pesticides, herbicides, and rodent poisons also introduce health and safety hazards. For example, Glyphosate was very common in controlling vegetation at solar PV power plants and has been found to be carcinogenic. Mowing has several hazards including flying objects. Every job at a solar PV site should have safety precautions identified and implemented.

Everyone entering a solar farm, for whatever reason, should have been trained in the dangers present on solar farms and be trained for the individual task that they will be performed. They should have all the PPE and tools necessary to carry out the work in the safest way possible. The work should be planned, and everyone concerned should have a common understanding of all aspects related to the safe execution of their task. Different countries will mandate written and hard copy paperwork to meet legislation, but best practice is to exceed the minimum requirements and to embrace the spirit of all relevant legislation.

Best practice in H&S sees the ongoing delivery of training and sharing of lessons learned. By increasing the skills of persons involved in the industry, we can make the industry safer and more productive.

For more information, please see the previous section "5.1 Risk assessment – health and occupational".

6.3. Operation under ownership

Health and safety: risk assessment

A. Healthy, Safety and Security

The Asset Owner has ultimate legal and moral responsibility for ensuring the health and safety of people in and around the solar plant, the security of the site, and the protection of the surrounding environment. The practical implementation is normally subcontracted to the O&M service provider. In some cases, the Asset Manager can provide or prescribe the systems, which are then implemented by the O&M service provider. 

Moreover, the Technical Asset Manager should ensure that the solar PV power plant and the relevant suppliers comply with health & safety (H&S) requirements. If necessary, the Technical Asset Manager should hire an H&S expert to ensure compliance.

Managing the risks that solar plants pose to the health and safety (H&S) of people, both in and around the plant, is a primary concern of all stakeholders. Solar plants are electricity generating power stations and pose significant hazards which can result in permanent injury or death. Risks can be mitigated through proper hazard identification, careful planning of works, briefing of procedures to be followed, and regular and well documented inspection and maintenance.

The dangers of electricity are well known and can be effectively managed through properly controlled access and supervision by the O&M service provider. Any person accessing a solar PV power plant should expect some form of introduction to ensure they are briefed on any hazards and risks. Staff working on electrical equipment must be appropriately trained, have sufficient experience, and be supervised. It is also key that others working around the equipment - for example panel cleaners - are equally aware of the potential risks and have safe methods of working around HV and LV electricity.

Hazardous areas and equipment should carry appropriate markings to warn personnel of possible hazards and wiring sequence. Such markings should be clear and evident to all personnel and third parties (and intruders) entering the plant premises.

As well as the inherent dangers of a typical solar plant, every site will have its own set of individual hazards which must be considered when working on the plant. An up-to-date plan of hazards is important for the O&M service provider to manage their own staff and provide third party contractors with adequate information. It is usually the case that the O&M service provider holds the authority and responsibility for reviewing and, where necessary, rejecting works taking place in the plant. Failure to carry this out properly has important consequences for general safety.

Besides workers on the solar plant, it is not unusual for other parties to require access to it. This may be the Asset Owner, or their representative, the landowner, or, in some situations, members of the public. It is important that the plant access control and security system keeps people away from areas of danger and that they are appropriately supervised and inducted as necessary.

The Asset Owner is ultimately responsible for compliance with H&S regulations within the site/plant. The Asset Owner must make sure that the installation and all equipment meet the relevant legislations of the country and, that all contractors, workers, and visitors respect the H&S Legislation by strictly following the established procedures, including the use of established personal protective equipment (PPE).

At the same time, the O&M service provider should prepare and operate their own safety management systems, previously agreed with the Asset Owner, that take into account site rules relating to H&S and the potential hazards involved in the works. The O&M service provider should ensure that they, and all subcontractors, comply with H&S legislation.

The Asset Owner will expect the O&M service provider to assume the role and duties of the principal contractor under the relevant national regulations governing H&S. This involves the O&M service provider proving that they are competent and are able to allocate enough resources to fulfil these duties.

Before starting any activity on-site, the Asset Owner will deliver a risk assessment and method statements to the O&M service provider who will provide a complete list of personnel training certifications and appoint a H&S coordinator. During the whole duration of the contract the O&M service provider will keep the H&S file of each site up to date.

The O&M service provider must have their personnel trained in full compliance with respective national legal and professional requirements. This generally includes obtaining certification necessary for working in a variety of environments, such as MV and/or HV electrical plants. Within Europe, referral to European Standards is not sufficient (examples of standards used today are ISO 14001, OHSAS 18001 etc).

To achieve a safe working environment, all work must be planned in advance. Normally written plans are required.

Risk assessments which detail all the hazards present and the steps to be taken to mitigate them need to be produced.

The following dangers are likely to exist on most solar plants and must be considered when listing hazards and identifying risks. The severity of any injuries caused are exacerbated by the terrain on which solar plants are built and their remoteness.

1.    Medical problems

It is critical that all personnel engaged in work on solar plants have considered and communicated any pre-existing medical problems and any additional measures that may be required to deal with them 

2.     Slips, trips, and falls

The terrain, obstacles and equipment installed on a solar farm provide plenty of opportunities for slips, trips and falls both at ground level and whilst on structures or ladders; and for roof-top or carport systems, fall-protection and additional equipment is required when working at heights

3.    Collisions

Collisions can occur between personnel, machinery/vehicles and structures.  The large areas covered by solar farms often necessitate the use of vehicles and machinery which, when combined with the generally quiet nature of an operational solar plant, can lead to a lack of attention. General risks such as difficult terrain, reversing without a banksman and walking into the structure supporting the solar panels require special attention

4.    Strains and sprains

Lifting heavy equipment, often in awkward spaces or from uneven ground, presents increased risk of simple strains or longer-term skeletal injuries

5.    Electrocution

Operational solar plants, whether energised or not, present a significant risk of electrocution to personnel. This risk is exacerbated by the nature and voltage of the electricity on site and the impossibility of total isolation. Staff engaged in electrical work obviously suffer the greatest risk but everybody on site is at risk from step potential and other forms of electrocution in the event of a fault.  Specific training needs to be given to all those entering a solar farm on how to safely deal with the effects of electrocution. In addition to general electrical safety, common issues for solar PV power plants include arc-flash protection when working on energized circuits; and lock-out-tag-out to ensure circuits are not unintendedly energised

6.    Fire

Several sources of combustion exist on a solar farm, the most common being electrical fire. Others include combustible materials, flammable liquids, and grass fires. Safe exit routes need to be identified and procedures fully communicated. All personnel need to be fully aware of what to do to avoid the risk of fire and how to act in the event of a fire 

7.    Mud and water

Many solar farms have water travelling through them such as streams and rivers, some have standing water, and some are floating arrays. Mud is a very common risk particularly in winter as low-grade farmland is often used for solar farms. Mud and water present problems for access as well as electrical danger

8.    Mechanical injury

Hand-tools, power tools, machinery, and mechanisms such as unsecured doors can present a risk of mechanical injury on site 

9.    Weather

The weather presents a variety of hazards, the most significant of which is the risk of lightning strike during an electrical storm. Due to the metal structures installed on a solar farm an electrical storm is more likely to strike the solar array than surrounding countryside. A solar farm MUST be vacated for the duration of any electrical storm. Working in cold and rainy weather can cause fatigue and injury just as working in hot sunny weather presents the risk of dehydration, sunburn, and sun stroke. Working during sunny days for undertaking maintenance and/or testing on site can lead to sunstroke. To avoid this, drinking sufficient water and staying in the shade is recommended

10.  Wildlife and livestock

The renewable energy industry is proud to provide habitats for wildlife and livestock alongside the generation of electricity. Some wildlife, however, presents dangers. There are plants in different regions which can present significant risk, some only when cut during vegetation management. Animals such as rodents and snakes, insects such as wasps, and other wildlife and livestock can present significant risks. The nature of these risks will vary from place to place, and personnel need to be aware of what to do in the event of bites or stings. Snakes, spiders, ticks, bees, and bugs are common and pose a number of hazards where snake bites could be lethal, spider bites can cause pain and inflammation, tics bites could result in tick bite fever, bees can cause allergic reactions and bugs could fly into people’s eyes. It is therefore important that all precautions are taken to prevent or manage these incidents. Storage and application of pesticides, herbicides, and rodent poisons also introduce health and safety hazards. For example, Glyphosate was very common in controlling vegetation at solar PV power plants and has been found to be carcinogenic. Mowing has several hazards including flying objects. Every job at a solar PV site should have safety precautions identified and implemented.

Everyone entering a solar farm, for whatever reason, should have been trained in the dangers present on solar farms and be trained for the individual task that they will be performed. They should have all the PPE and tools necessary to carry out the work in the safest way possible. The work should be planned, and everyone concerned should have a common understanding of all aspects related to the safe execution of their task. Different countries will mandate written and hard copy paperwork to meet legislation, but best practice is to exceed the minimum requirements and to embrace the spirit of all relevant legislation.

Best practice in H&S sees the ongoing delivery of training and sharing of lessons learned. By increasing the skills of persons involved in the industry, we can make the industry safer and more productive.

B. Risk Analysis

RM starts with the Risk Analysis (RA), for which we define the following steps:

·       Risk Identification (RI)

·       Risk Assessment (RAss)

·       Risk Prevention & Mitigation (RP)

·       Risk Plan Communication & Implementation (RC)

a)       Risk Identification

RI is the beginning of RM. As a minimum, it is important to identify and define all major risks with a significant chance of occurrence. If this does not happen or happens too late, the whole project could be jeopardised.

b)      Risk Assessment

Once a risk is identified, an assessment must take place to determine how likely it is to occur, what the impact would be, and estimate the costs of eliminating or reducing the risk.

c)       Risk Prevention & Mitigation

Once the RAss has been conducted a decision must be made on the best way to prevent (by establishing barriers) or mitigate the risk and/or its consequences.

d)      Risk Plan Communication & Implementation

Once a decision has been made on how to prevent or mitigate the risk, a plan on how to do so must be communicated.

C. Health, Safety, Security & Environment (HSSE) under LCQ

HSSE are priorities throughout an asset’s lifecycle. There are legal requirements in most countries, and internationally accepted standards, such as the IFC Performance Standards and the Equator Principles, to ensure that solar projects do not negatively impact the environment and guarantee a healthy and safe workplace. Furthermore, international financial institutions also use HSSE, and social requirements when assessing projects. Security is often a requirement in insurance policies, otherwise claims can be void.

Good HSSE coordination is fundamental to achieving all HSSE objectives, which can be summarised as follows:

·       Establish an HSSE culture within the organisation and the relevant project team

·       Establish, implement, and maintain an effective integrated HSSE management system

·       Ensure compliance with applicable health, safety, and environmental legislation, codes, and standards and, whenever possible, with higher standards and best practices

·       Ensure surveillance of the project site, especially of high-value products, as well as components which are difficult to replace quickly

·       Ensure that intrinsically safe design is achieved by monitoring progress and preparation of results and systematically reviewing the design process, if necessary

·       Manage risks in the design, procurement, construction, installation, commissioning, operation, and maintenance activities

·       Ensure appropriate levels of skills for all staff engaged in carrying out critical HSSE activities and provide training where necessary

·       Check for any potential HSSE impacts in the project area and ensure that these are minimised

·       Make sure that the site surveillance is in line with the insurance requirements

·       Ensure that a complete inventory of all waste and discharges is maintained and that all waste is disposed of in an environmentally acceptable way, in compliance with the relevant regulations

·       Review lessons learned, performance and any opportunities to continuously improve, to update safe design

For this purpose, it is important that Asset Owner, the EPC, and other service providers meet to align on procedures to follow to avoid risks, especially when different service providers are working on the site simultaneously.