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 the responsibility to ensure the health and safety of those working in and around these installations, both on and offshore.

In this blog we discuss recent examples where both the courts and the HSE have considered issues relating to the safety of people working with turbines.

The duty of wind farm operators

The primary legislation governing health and safety in the UK is the Health and Safety at Work etc. Act 1974. This Act places a duty on employers to ensure, as far as reasonably practicable, the health, safety, and welfare of their employees and anyone who might be affected by their operations. For wind farm operators and contractors 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:

  1. Working at Height: Maintenance and inspection tasks often require workers to operate at significant heights, posing a risk of falls.
  2. Electrical Hazards: The high voltage equipment used in wind turbines can present serious electrical hazards.
  3. Mechanical Risks: The moving parts of wind turbines can cause injuries if not properly guarded.
  4. Environmental Conditions: Workers are often exposed to harsh weather conditions, which can exacerbate other risks.

Fatal Accident Inquiry into the death of Antonio Joao Da Silva Linares

Antonio Joao Da Silva Linares died on March 15, 2017, after falling at the top of a wind turbine at the Kilgallioch Wind Farm. He fell five metres onto the elevator deck of the turbine and suffered severe head and chest injuries. The Fatal Accident Inquiry found that the otherwise “diligent” worker had not attached his harness to a fall arrest system, which would have prevented his death.

The recommendations made by the Sheriff in his determination following this Fatal Accident Inquiry, issued in late 2024, and the comments from the Health and Safety Executive (HSE) on those recommendations, highlight key safety measures which need to be carefully addressed by the industry. The key recommendations made were:

Recommendation 1: Joint Health and Safety Drills

  • Focus: Conduct joint health and safety drills involving all contractors and subcontractors.
  • Action: Implement rescue-from-height drills at the design stage, throughout the construction phase, and regularly during the wind farm's lifecycle.
  • Benefit: Ensures readiness and response efficacy for all personnel involved in rescue operations.

Recommendation 2: Rescue Equipment

  • Focus: Availability of suitable stretchers to keep casualties horizontal and minimize chest pressure.
  • Action: Review and potentially upgrade existing stretcher arrangements in wind turbines.
  • Benefit: Facilitates safer and more effective rescues, reducing the risk of further injury during evacuation.

Recommendation 3: Fall Arrest System Technology

  • Focus: Utilise technology to detect when a person disconnects from a fall arrest system.
  • Action: Collaborate on technological improvements, including interlocks on gates, ergonomic enhancements, and alarm systems.
  • Benefit: Enhances fall prevention and immediate response to potential fall hazards, protecting workers at height.

Following the 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 disconnections.
  • Ergonomic Improvements: To assist safe transfer between systems and anchor points.
  • Alarm Systems: To provide immediate alerts in case of disconnections.

The HSE called for stakeholder groups to coordinate industry actions in response to these recommendations.

Occupational health and hygiene concerns

The HSE has recently received reports from a wind farm operator about significant occupational health and hygiene concerns related to wind turbines. In response to those reports the HSE recently 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 and other personnel.

To address the issue, the operator in question has implemented several 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 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 identified risk.

Risk Assessment and Mitigation

Although the full extent and prevalence of this issue is not yet known, the risk 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 mitigation 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.

Conclusion

The safety and well-being of those working on wind farms is paramount. As the technology of turbines evolves and the sector grows further, new and unexpected risks will inevitably arise. By addressing these new risks as soon as they arise, operators will not only comply with their legal duties but will create an increasingly safe working environment for everyone working to deliver sustainable energy solutions and support the UK's transition to Net Zero.

Contributors

Claire Campbell

Senior Solicitor

Malcolm Gunnyeon

Partner