Do you need a risk assessment for pigeon guano?
If you are an employer and guano on your site could affect staff, contractors or visitors, yes. The law requires you to identify what could cause harm, decide how likely and serious it is, and remove the hazard or control the risk (HSE). Bird droppings carry biological hazards, so the COSHH regulations apply too (HSE).
If you have 5 or more employees, you must write the assessment down (HSE).
The checklist below follows HSE’s five steps to managing risk (HSE): identify the hazards, assess the risks, control the risks, record your findings and review the controls.
Step 1: What hazards does pigeon guano create?
- Contaminated dust. Disturbing dried droppings releases dust that can cause psittacosis, and droppings can carry salmonella (HSE).
- Slips. Droppings on walkways, steps, ladders and loading bays.
- Falls from height. Guano often sits on roofs, high ledges and gantries.
- Confined spaces. Some roof voids, plant rooms and ducts are confined spaces, with risks such as poor air (HSE).
- Building damage. Blocked gutters and downpipes, water getting in, and acid damage to stone and metal.
- Live birds and nests. Active nests are protected by law while in use (Wildlife and Countryside Act 1981).
Step 2: Who could be harmed, and how?
- Who: staff who work near the roost, cleaners, maintenance teams, contractors, delivery drivers and visitors. HSE reminds employers not to forget maintenance workers, contractors, visitors and the public (HSE).
- Anyone with a weakened immune system. HSE says they should not directly carry out work involving bird droppings (HSE).
- How: mainly by breathing in dust, but also through hand-to-mouth contact.
- How much and how often: a little fresh fouling on a windowsill is low risk (HSE). Large, dried build-ups in areas people use every day are not.
- Where the dust could go: ventilation systems, open doors and nearby work areas can spread it.
Step 3: How should you control the risks?
Work down HSE’s hierarchy of control, from the most effective option to the least. PPE comes last (HSE).
- Remove the hazard. Have the guano cleared by a specialist and fit bird proofing so it does not build up again.
- Keep people away. Close off or restrict access to fouled areas until they are cleared.
- Engineering controls. Seal off the work area with sheeting, isolate ventilation that could spread dust, and dampen the guano before removal. Do not use high-pressure water (HSE).
- Safe ways of working. Use trained operatives, a written method statement, permits for work at height or in confined spaces, warning signs, and hand-washing facilities with breaks taken away from the work area.
- Personal protective equipment. Gloves, disposable coveralls and suitable footwear, plus respiratory protection such as FFP3 masks or a half mask with a P3 filter. Tight-fitting masks need a face fit test (HSE).
If you bring in a contractor, check they are competent before they start. Our guide on how to choose a guano clearance contractor lists what to ask for.
Step 4: What should you record?
- Where the guano is, roughly how much, and whether it is fresh or dried
- The hazards you found and who could be harmed
- The controls in place now, and any further action, with who will do it and by when (HSE)
- The contractor’s method statement, if you use one
- After clearance: the waste transfer note, which you must keep for 2 years (GOV.UK), and the completion certificate
Step 5: When should you review it?
Review the controls to check they work, and update the assessment after any accident or near miss, or when something changes (HSE). For guano, that includes:
- After the clean-up is finished
- If birds start roosting again, or proofing is damaged
- When the area is reused, refurbished or opened to more people
- When maintenance work is planned near a roost
Quick checklist
- ☐ Fouled areas identified and mapped
- ☐ Access to fouled areas restricted
- ☐ People at higher risk identified and kept away
- ☐ Ventilation near the work area checked
- ☐ Specialist contractor appointed, with RAMS and waste carrier registration checked
- ☐ Active nests checked before work starts
- ☐ Waste transfer note and completion certificate filed
- ☐ Bird proofing fitted
- ☐ Review date set
Need help? Locus Services carries out free site surveys and clears pigeon guano safely across England, 24 hours a day. For background on the health risks, see what is pigeon guano, and is it dangerous?