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#1 Posted : 03 March 2005 21:29:00(UTC)
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Posted By Martin Taylor This is a bit of a legal technical one I am afraid but I am interested in checking my opinion of the way that the Supply of Machinery regs deals with noise in the design and supply of machinery. A supplier has offered us a machine with 2 options - 75dB and 80dB with additional costs for the former due to noise abatement enclosure. My understanding from the machinery regs is that the design should reduce the airborne noise to the lowest practicable level and as such the supplier can not legally put the 80dB machine on the market. Obviously when I tell my engineers this (and the supplier as well) they are not too happy. Anybody out there like to back me up or shoot me down? thanks Martin
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#2 Posted : 04 March 2005 09:59:00(UTC)
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Posted By Roger the Dodger I'm a bit rusty on the machinery supply regs, but this seems to be a reasonable argument. Equally as a purchaser of new machinery, if the funds permit you should go for the lower noise machine. If the noise regs get the Action levels dropped to 80dBA, as opposed to the 85dBA at present, that would give more weight to your argument too.
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#3 Posted : 04 March 2005 16:04:00(UTC)
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Posted By Martin Taylor thanks for the feedback Rodger - it's good to get some support on this one - it feels as though I am the only one interested in doing things right with this one - anybody else out there with views? ta Martin
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#4 Posted : 04 March 2005 20:30:00(UTC)
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Posted By Stuart Nagle Martin. you don't state what the machinery is or its application, so i'll have a stab in the dark on that... Generally the supply would be based on exposure (i.e. if the louder machine was positioned elsewhere and/or enclosed would it be a such a hazard) The heirachy of supply starts with the designer to design machines that comply with (existing) standards relating to the particular type, use, systems and technology reasonably available... In this case, new technology or higher specification would appear to account for the quieter machine, but that does not mean that a slightly louder version is 'illegal' or does not comply with existing standards, only that additional effort over and above the existing standards may have been taken by the manufacturer (hence the heftier cost). secondly, the person specifying the plant or equipment should assess the hazards and risk posed in respect of its use (including of course noise) and select the plant or equipment based on this. Where noise is the primary hazard the heirachy is; select a machine that, so far as is reasonably practicable, offers the least noise hazard (is it reasonably practicable to accept the additional costs), next consideration would be enclosure or other methods to reduce noise/vibration etc at source - the machine in operation, next, removal of persons from the hazard zone if possible, and finally if persons cannot be removed, measures implemented to reduce the risks of exposure to acceptable levels, e.g. by the employment of PPE and/or a suitable mix of all the previous measures... There is a BS or BS EN/BS EN ISO that goes into all this in some detail that would be worth you looking at, but at present the relevant reference escapes me.... Regards... Stuart
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#5 Posted : 06 March 2005 07:24:00(UTC)
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Posted By Paul Grady If you look as the EHSR's they give you the various control measures, from the top of the scale "eliminate the risks" to the lowest level of protection "adequate instruction". I always say there are two parts to any machine supply. 1. Fit for intended use. Where a manufacturer can believe how a machine will be used, in ideal conditions (that may include "no personnel in the vicinity") 2. Fit for application How a purchaser will actually use the machine.(i.e. the personnel involved, the way the User Company will use and apply the machine). You find the OEM usually claims to be suitably vague about the detail of the eventual use. A level of control options are offered by the Manufacturer. Its up to the user to carry out suitable risk assessment to match the level of controls to his application. This is a necessary 'sliding scale' to meet the reasonably practicable criteria.
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#6 Posted : 07 March 2005 09:07:00(UTC)
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Posted By Martin Taylor thanks for the replies everybody - now I am getting a little confused between the risk assessment approach where I should quite sensibly look at the application and discuss with the supplier the 'best' overall option and the terms of the SUpply of machinery directive which seem to my reading to be very specific they require "manufacturers, importers and suppliers to design and construct machinery so that the risks from noise emissions are reduced to the lowest level taking account of technical progress" (schedule 3 section 1.5.8). I guess another way of asking the question is which takes precedence - design to specific EN standards or the Supply regs? any further thoiughts? Martin
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#7 Posted : 07 March 2005 14:28:00(UTC)
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Posted By D. Hilton Martin This is an interesting problem, the requirements of Directive 98/37/EC relating to noise emissions from machinery state: “Machinery must be so designed and constructed that risks resulting from the emission of airborne noise are reduced to the lowest level taking account of technical progress and the availability of means of reducing noise, in particular at source”. The ISO 1999 Standard, defines "hearing loss" as a permanent increase of the auditory threshold (the minimum audible sound level) affecting the intelligibility of speech. A double entry table is used to assess the percentage risk of "acquiring" hearing loss if exposed in the workplace to a certain average sound level for 8 hours per day, 6 days a week for a given number of years: for example, the case of an employee working at 6 days a week exposed to an average sound level of 95 dBA during an 8-hour shift and supposing that the employee started employment at the age of 17 and stays at this particular job until the age of 47, that is, a 30-year exposure. ISO 1999 reveals a 29 percent risk of suffering speech intelligibility handicap. That is, almost 3 out of 10 such persons will experience difficulties in understanding normal speech. Similarly, whenever working hours are halved, the criterion is applied subtracting 3 dBA from the actual sound level. Again, take for example, the case of an employee working 3 nights a week exposed to an average sound level of 106 dBA during a 4-hour shift. We have half the days and half the time per day, so 3 dBA must be subtracted twice, yielding 100 dBA. Suppose, further, that the employee started employment at the age of 15 and stays in this trade till 30 -- that is, a 15-year exposure and a 37 percent risk of suffering speech intelligibility handicap. That is, almost 4 out of 10 such persons will experience difficulties in understanding normal speech -- at the age of 30. A closer look at ISO 1999 reveals that at 80 dBA the risk is 0% for any extension of working life. Applying the criteria of ISO 1999, we can see that the risk resulting from the emission of airborne noise at 80 dBA are 0% and similarly the resultant risk at 75 dBA is also 0% and if this criteria is used it could be said that the machinery was so designed and constructed that risks resulting from the emission of airborne noise are reduced to the lowest level. Regards Darren
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#8 Posted : 07 March 2005 15:11:00(UTC)
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Posted By Steven Taylor Martin, In addition to all of the above comments, you also need to take into account what the noise at work regs say "YOU WILL NOT DEAFEN YOUR EMPLOYEES", so then, under current regs you are required do all your risk assessements etc etc. However under the new regs due out in Feb 06, you will be required not to carry out risk assessment as the first port of call but to actually reduce the noise levels. This may or may not help you in making a decision with the specific model of machine to buy, however if you look at all the arguements that have taken place with regard to the new regs you can put money on them being reviewed again and lower levels being introduced. Would it not then be wiser to spend the extra money at implementation opposed to 10 x that if the levels are dropped again in the future, when there will be a need again to lower the levels at source.
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