The Job After the Job: Is Set-Up and Pack-Down in Your Risk Assessment?
Most risk assessments are written for the job while the job is “the job”.
Dig the trench. Run the laminator. Fit the kit. Assessors usually land on the bits that feel significant: equipment, people, permits, scanning, how an excavation is supported, how production is meant to run. That is often where the serious risk sits, and it deserves the attention.
The gap is everything around that productive window.
Set-up, prep and post-job work
The awkward steps are less photogenic and easier to skip:
- Getting plant and materials to site
- Unloading, staging and set-up
- Prep that is treated as “just getting ready”
- Cleaning rollers, blades, hoppers or work surfaces
- Clearing a jam or changing a roll “between runs”
- Pack-down and loading for the journey home
- Transport of kit that cannot go on the road under its own steam
- Workshop cleaning, wash-down and maintenance once kit is home
I have seen hoppers used as ad hoc carry cases for materials and equipment. The task risk assessment never mentioned it. The people on the ground still did it, because the clock was running.
Some businesses cover those steps in other documents: a transport assessment, a workshop assessment, a separate maintenance method. That can be entirely sound. The problem is when nobody owns the join, and the only live pack describes production and goes silent the moment production ends, or before it properly starts.
What HSE said about a laminator cleaning task
On 12 August 2026, the Health and Safety Executive reported that Reflex Flexible Packaging Limited was fined £60,000 and ordered to pay costs after a worker suffered a severe crush injury at the company’s Telford premises.
According to HSE’s press release:
- The worker, a laminator operative and shift supervisor, was cleaning the machine’s rollers with rags after a production run had finished
- A rag became caught between two in-running rollers and their left hand was drawn into the nip point up to the wrist
- A colleague activated the emergency stop; the worker needed hospital treatment, two operations and later physiotherapy
- HSE found the company had failed to provide a fixed guard to prevent access to the dangerous nip point during cleaning
- The company’s risk assessment and safe system of work were not suitable and sufficient; the cleaning operation had not been properly assessed and the risk of being drawn in during cleaning had not been identified
- The safe system of work also failed to give clear instructions on use of the foot pedal to rotate the rollers during cleaning
- The company pleaded guilty to breaching Regulation 11(1) of the Provision and Use of Work Equipment Regulations 1998
- Sentencing was at Birmingham Magistrates’ Court on 10 August 2026
- HSE noted this was the second time in less than a year the company had been sentenced, following a fatal incident at another of its sites for which it was sentenced in November 2025
HSE Inspector Zach Morris, quoted in the same release, said dutyholders should not focus solely on normal machine operation when considering access to dangerous parts. They must also consider cleaning, maintenance and repair, where workers may be exposed to dangerous parts that are inaccessible during normal operations.
That is not only a packaging lesson. It is a PUWER lesson, and a wider reminder that the job before and after the job still counts.
The management test
Could someone get hurt during set-up, prep, cleaning, maintenance, changeover, loading, unloading or workshop work, even if the productive task looks well controlled?
If the answer is “possibly”:
- Prefer doing the task with the equipment isolated where that is reasonably practicable
- Where movement is genuinely required, follow the hierarchy in PUWER: engineering controls such as fixed guarding first, then other controls, then a method people can actually follow under time pressure
- Write set-up, prep, pack-down and post-job work into the assessment and the safe system of work, or into another live assessment that the people doing the work know exists
- Check that what happens on a busy shift matches the paperwork
“Be careful with the rag” is not a control measure.
Beyond the factory floor
The same gap shows up on sites. A trench pack can be excellent on excavation support and still say nothing useful about how plant arrives, how materials are staged, how kit is cleaned before it leaves, or how non-roadworthy equipment gets home. If those steps are controlled elsewhere, good. If they only exist as habit, the operation is only half assessed.
A useful check this week
Pick one machine or one site package. Watch the job before and after the job. Ask the person who actually does it:
“Show me how you set this up, clean it, unjam it or pack it down when production is busy.”
That answer is usually more useful than a perfectly tidy risk assessment on a shared drive.
Further reading
- HSE press release, 12 August 2026 (Reflex Flexible Packaging Limited laminator case): https://press.hse.gov.uk/2026/08/12/packaging-manufacturer-fined-for-second-time-in-less-than-a-year-after-workers-hand-crushed-in-laminator-machine/
- Provision and Use of Work Equipment Regulations 1998 (PUWER) – HSE: https://www.hse.gov.uk/work-equipment-machinery/puwer.htm
- Safe use of work equipment: Approved Code of Practice and guidance (L22) – HSE: https://www.hse.gov.uk/pubns/books/l22.htm
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