Posted By Stuart Nagle
I had the opportunity to take the HSE to task recently on the subject of vibration. Specifically the provision of information to end users of vibrating tools and equipment.

HSE stated that it expects employers to carry out testing for vibration given out by vibrating tools they employ in all cases, and (inherently) meet the costs of doing so.

This however could mean 1 tool employed by 600 companies X 600 lots of testing X 600 lots of expense - a lot of resources tied up here!!

Why should employers do this I asked? I referred the HSE to a scenario, thus; If I produced a product that had information supplied that was, essentially known to be incorrect and it was liable to cause injury or disability to end users, as it bore little relation to actual field use of the goods, could I expect to be prosecuted by HSE when such injury or disability arose?

There was a marked quietness come over the room at this suggestion!! - and a marked absence of response - so what do you think?

My augument is this; Under the HSAW Act 74, suppliers of things for use at work are required to examine and test as necessary to ensure SFARP that their products are safe to use in the workplace (i.e. they will not harm persons using them). I argue that if the information supplied by manufacturers of vibrating tools (lab test results) are known to be unrealistic and unreliable (including by HSE as well who have recently put such into print), and in most cases bear little relation to actual field data/test results, then where does the problem lay and who is responsible for the provision of information on the product that is suitable and suffcient - the end user!!

This duty must surely lay with the equipment and/or tool manufacturer (i.e. to test and examine properly) and to supply suitable and sufficient information to end users of the product, thus to enable a reasonable assessment to be made by end users (employers or self employed) without the need to waste their resources on further testing and examination to avoid possible prosecution by HSE!!

Whilst it could be argued that risk assessment should encompass this, I disagree and would state, are employers expected to test other tools supplied for use at work in this manner - no they are not. They are required to assess the residual risks. Surely then, if a vibrating tool in use gives a much higher level of vibration in use in the field than is stated by a manufacturers lab tests (and this is known to be a factor) - simply because the manufacturers test methods are inappropriate, should the manufacturer be required to do actual field testing and product reasonable test results and supply that information to the end users- I believe they should.

Not only would this appear to be a legal duty of manufacturers under health and safety legislation (HSAW Act 74) but the costs of doing so would be a far better use of resources than expecting employers each to produce the results for them!!

here endeth the moan and other opinions on the matter would be of interest....

Posted By Merv Newman
It would seem that we need an independant confirmation of suppliers data. And I think this would also apply to CE markings. "Which" does a good job on "domestic" articles, can we persuade them to have a look at industrial equipment, or is this something for BSI ?

It could be argued that we need a BSI "vibration" standard

Posted By Jack
Stuart, I agree with the general thrust of your argument and certainly I think suppliers should be expected to provide a great deal more information.

But, however good their testing/information it could not possibly take account all circumstances of end use. Environmental factors seem to make an normous diffence to vibration levels. Horticultural machines for example vary with subtle changes in soil type. Then there is maintenance. Whilst manufacturers could provide a lot more information covering different environmental conditions and the effects of use on the machines vibration levels, it is still the vibration being experienced by the operator using the machine in it's actual state of repair and in the specific environmental conditions in which it is being operated. So, I can't see how employers can avoid any monitoring although I accept improved information from suppliers could ease the employers burden.

Perhaps much improved information from suppliers could be coupled with a national data base of employers test results taken when machines were in use might be a way forward. (Although I think some monitoring would still be required by employers). Publishing information in this way might concentrate suppliers minds in designing in reduced vibration.

Posted By ian mcnally
The trouble with this forum is you end up getting so interested in a subject that you just have to make a comment. Mine is to do with some of the smaller air picks or chisels that produce very high levels of vibration making it almost impossible to comply with the 2.8m/s 2 without a chain of people employed to carry out the task.
Don’t get me wrong, I am the first to try and encourage the employers to do their bit and I fully take on board the points raised about manufactures responsibilities.

I have recently heard of a company that carried out the same approach to controlling and monitoring vibration levels as we do and felt this was a practical approach ….well so I thought!!

I was surprised when told that enforcement action may be taken on the company despite; getting the equipment (CP9) with the lowest available emissions, it still only allowed 25min per day. The company trained the workforce to identify the hazards, rotated and monitored to check for any signs of HAV / VWF. It openly admitted exposures of up to 70mins over the day although no signs were noted by an independent OH company or complaints received.

HSG 170 does refer to a similar product, a chipping hammer and suggests that the solution is to limit exposure to 20mins per day. Is it really practical to suggest that construction sites across the country will be able to comply with this. Even after designing out hazards with engineering and other controls many tasks will still require a significant use of such equipment.

Test equipment is available to test on 3 axis but this will probably only confirm what we already know!

If someone knows of such equipment with longer exposure times let me know I'll consider buying shares.

All the time there are so many tasks which cannot be carried out another way ( with current technology) shouldn’t greater focus be placed on the manufactures who after all produce such work equipment?

Good thread


Ian