You have received an HSE hand-arm vibration improvement notice. Here is what it means and what you must do.

A hand-arm vibration improvement notice is a legal instruction to take action. It means an HSE inspector has assessed your workplace and found that workers are exposed to vibration levels that pose a risk to their health, and that you have not taken reasonably practicable steps to reduce that exposure. Hand-arm vibration syndrome (HAVS) is irreversible. The regulations require you to act before the damage is done, not after.

What is an HSE hand-arm vibration improvement notice?

HSE inspectors can issue improvement notices under the Health and Safety at Work etc. Act 1974. When an inspector finds that workers regularly use vibrating tools and equipment and that the employer has not taken sufficient steps to control exposure, they can require action within a set period. The minimum is 21 days from the date of issue.

Non-compliance is a criminal offence. The HSE publishes all enforcement action on its website, and prosecutors have secured significant fines against companies where workers have developed HAVS. In several published cases, employers were prosecuted even though they were aware of the risk and had taken partial measures.

What the Control of Vibration at Work Regulations 2005 require

The regulations set two daily vibration exposure values that employers must know and act on.

Exposure action value (EAV): 2.5 m/s² A(8)

Above this level, you must take action to reduce vibration exposure. This includes introducing engineering controls, health surveillance and training.

Exposure limit value (ELV): 5 m/s² A(8)

This must never be exceeded, even taking into account any protective measures in place. Where workers regularly reach or exceed this level, the employer is in breach of the regulations.

The regulations require a risk assessment for any work involving vibrating tools or equipment. Where the assessment identifies exposure above the action value, the employer must put a programme of controls in place, prioritising those that reduce vibration at source. Health surveillance must be provided to all workers regularly exposed above the action value.

What hand-arm vibration syndrome is and why it matters legally

HAVS is a collective term for the damage caused by regular exposure to hand-arm vibration. It includes vibration white finger (Raynaud’s phenomenon), nerve damage causing tingling and numbness, and damage to muscles, bones and joints in the hands and arms.

The damage is permanent. Symptoms may not appear for years after exposure begins, which means workers often do not raise the issue until significant harm has already occurred. Once HAVS develops it cannot be reversed, only prevented from worsening.

This creates a specific legal risk for employers. A worker who develops HAVS after years of exposure, and who can show that their employer was aware of the risk and did not adequately control it, has a strong civil claim. An HSE improvement notice on file makes it very difficult to argue the employer did not know.

HSE research suggests that around 2 million workers in the UK are exposed to vibration levels that put them at risk. Sectors with the highest prevalence include engineering, fabrication, construction and automotive manufacturing. These are also among the sectors most frequently inspected.

Engineering controls: reducing vibration exposure at source

The hierarchy of controls for hand-arm vibration places engineering solutions ahead of training and PPE. The most effective approach is to reduce the vibration at source and reduce the time workers spend in contact with vibrating tools.

Engineering controls that the HSE recognises as effective include:

• Replacing high-vibration tools with lower-vibration alternatives that perform the same task.
• Using tool balancers and suspension systems to reduce the grip force workers need to apply.
• Using jigs, fixtures and workholding equipment to secure components so workers do not need to grip and support them while using vibrating tools.
• Reducing the time workers spend on vibrating tools through job rotation, work planning and scheduling.
• Ensuring tools are properly maintained, as worn or damaged tools transmit more vibration.
• Positioning workpieces at the correct working height so workers can apply tools without awkward postures that increase grip force.

Grip force is directly relevant to vibration transmission. A worker who is straining to hold a heavy component in position while using an angle grinder, or who is working at a height that requires them to reach or twist, will grip the tool harder. Harder grip means more vibration transmitted to the hand and arm.

This is where workstation and bench design intersects with HAV risk. A height-adjustable bench that brings the workpiece to the correct working height, and holds it securely, directly reduces the grip force required and can reduce the duration of vibration exposure on individual operations.

OTTOKIND heavy-duty electric height-adjustable welding and fabrication benches address both of these factors for grinding, welding and fitting operations. The bench holds components at the correct working height, eliminating the need to support heavy workpieces by hand. Height adjustment means the worker operates in an upright posture rather than reaching or stooping, which reduces the force applied to the tool and the time needed to complete the operation.

Health surveillance: what you are required to put in place

Health surveillance for HAV must be provided to all workers who are regularly exposed above the exposure action value of 2.5 m/s² A(8). It is not optional and cannot be deferred indefinitely.

The purpose is to detect early symptoms before significant damage occurs and to allow the employer to take further action if a worker’s condition is deteriorating. Health surveillance must be carried out by a suitably qualified occupational health professional.

Where an HSE improvement notice has been issued, the absence of health surveillance is likely to be cited alongside the failure to implement engineering controls. Both must be addressed within the notice period.

What happens if you do not comply

Failing to comply with an HSE improvement notice is a criminal offence under the Health and Safety at Work etc. Act 1974. In hand-arm vibration cases the consequences can be severe:

• Prosecution and unlimited fines in the Crown Court.
• A prohibition notice stopping work involving vibrating tools in the affected area.
• Civil liability for HAVS claims from affected workers, with the notice creating a clear record that the risk was known.
• The HSE publishing the enforcement action publicly.

Published prosecutions in this area include fines of £80,000 against a groundworks company and £100,000 against an engineering firm, both for HAVS-related failures. In several cases, directors were also prosecuted individually.

How DRH KIND can help you respond

DRH KIND supply OTTOKIND height-adjustable workstations and heavy-duty welding and fabrication benches to UK manufacturers. Where hand-arm vibration exposure in your business arises from bench-based operations such as grinding, welding, fitting and assembly, the right workholding and positioning equipment can form part of your engineering controls programme.

• A 2,000 kg electric height-adjustable welding bench brings heavy components to the correct working height, reducing grip force and the time spent applying handheld grinding tools in difficult postures.
• OTTOKIND production workstations position assembly operations at the correct ergonomic height, reducing the postural strain that increases grip force on vibrating tools.

These are not a complete solution to HAVS risk on their own. You will also need to review tool selection, implement health surveillance and manage exposure time. But workstation and bench design is a recognised engineering control and may be a required part of your compliance programme.

We offer a free 15-minute compliance review by phone or Teams to discuss your specific situation and whether our equipment addresses part of what the notice requires.

Common questions about HSE hand-arm vibration notices

How long do I have to comply with the notice?
The minimum is 21 days from the date of issue. You can appeal to an employment tribunal within 21 days if you believe the notice is unreasonable.

My workers use anti-vibration gloves. Does that satisfy the regulations?
No. Anti-vibration gloves are classified as PPE and sit at the bottom of the hierarchy of controls. They may supplement a broader programme, but they will not close an improvement notice.

How do I measure our vibration exposure levels?
Vibration exposure is measured as an eight-hour energy-equivalent value, expressed in m/s² A(8). Tool manufacturers are required to declare the vibration emission value for their tools. You can use the HSE’s ready reckoner tool on hse.gov.uk to calculate daily exposure based on tool vibration levels and daily usage times.

We only use vibrating tools occasionally. Do the regulations still apply?
Yes. The regulations apply to any work that exposes workers to hand-arm vibration. If a risk assessment shows that exposure is consistently below the action value of 2.5 m/s² A(8), the requirement for a formal controls programme is reduced. But the assessment must be done and documented.

Who carries out health surveillance for HAVS?
Health surveillance must be provided by or under the supervision of a qualified occupational health professional. A general occupational health provider can arrange this.

Can new equipment be offset against tax?
Workstations and fabrication benches from OTTOKIND qualify as plant and machinery under the Annual Investment Allowance, meaning 100% of the purchase cost is deductible from taxable profits in the year of purchase. For a company on 25% corporation tax that reduces the effective cost by a quarter.

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