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#1 Posted : 10 March 2005 17:33:00(UTC)
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Posted By Debbie Shepherd We have a current dilemma - from a cost/recycling point of view we have been re-using FIBCs in which our powder raw materials were supplied, for use in house for storing blended product prior to production of coatings. Most of these FIBCs are supplied as single use bags with appropriate weight rating labels etc. This re-use has been current practice for many years without incident, however a recent H&S audit by our corporate H&S manager(based in USA) has identified this as unacceptable practice. Previous risk assessments unfortunately did not spot this! I am fairly new to my role and accept that if an FIBC is designated single use then thats what it is designed for and if we did have an injury incident we would have little defence. My production colleagues are up in arms, citing the fact that there has never been an incident and the cost of sourcing multi use bags will be a cost we cannot afford. Any advice? Examples of failures resulting in seriious injury? Bag loops are inspected before hoisting, we do not exceed the SWL limit and we have pre use checks on hoists in place.
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#2 Posted : 11 March 2005 00:48:00(UTC)
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Posted By Mike Charleston Debbie I can't specifically help with your particular question but you've given me an opportunity for a rant! Don't worry - it is a related rant! Does your supplier really believe that these Big Bags are only suitable for a single use - or is it the usual case of them covering themselves against multiple usage? Apart from my work in OSH I am also a specialist in a technique called Reliability Centred Maintenance (RCM), which is a means for looking at the maintenance routines for equipment "in their operating context" to deduce what checks are needed and how frequently they should be done. This can have a major effect on maintenance workloads, mainly through eliminating or reducing the preventive routines that manufacturers recommend. Think of two gearboxes of the same size/capacity/specification in two different circumstances. In one, the gearbox is used intermittently during a day shift of 8 hours; in the other, the box is operating continuously on a 24-hour basis. The manufacturer will simply say "ah yes, a box of this type XX needs weekly checks of blah, monthly checks and adjustments of blah, etc" - but RCM allows us to recognise that the boxes are clearly being used in very different ways (the operating context), so the maintenance routines should also be different. But then the MD needs a clear reasoning for reducing maintenance routines before he cuts costs (well, some do anyway!) - so the whole process is recorded and then available as an audit trail in the case of having to justify the outcomes. That is the point where cautious company managements get their knickers in a twist by saying "oh no, we can't change away from what the manufacturer says - because they know what they are doing" - yet the changes are logical, properly thought out and in effect, based on risk assessment. So, rant over ..... and surely what it comes down to is a risk assessment, whatever the study may be called by practitioners. If your colleagues think that your Big Bags are good for more than a single use, go for it - but make sure you have a record of what conclusions were drawn, who was involved and what enquiries were made along the way. Mike
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#3 Posted : 15 March 2005 10:41:00(UTC)
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Posted By Debbie Shepherd Anyone have any helpful advice on this one who has experience of similar issue....I need to resolve this week with production colleagues in a constructive way.
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#4 Posted : 15 March 2005 12:25:00(UTC)
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Posted By Robert K Lewis Debbie Unfortunately this is common practice now and has been since PUWER and LOLER were introduced. The issue for the supplier was to avoid any need for testing, although it is probably true to say that there would not be any real deterioration in design capacity for the 1st six months of use. Unfortunately they have come to you as second hand and if regarded as lifting equipment they need to betested and certified. I would look at them more under PUWER, much as if a bucket, rather large albeit, and see if a downrating of capacity and inspection regime could be brought about. Good luck, I have been down this path on site Bob
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#5 Posted : 15 March 2005 13:05:00(UTC)
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Posted By Debbie Shepherd Thanks for the helpful response Robert - I will get reading!
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#6 Posted : 16 March 2005 20:26:00(UTC)
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Posted By Wazza We use bags too, though not single use (not that I'm aware anyhow), however, we do use them for our own purposes. I agree with earlier posts that stated the 'supplier' is covering themselves. Surely, you have an assessment based approach on likelihood .v. severity for injury against control measures, so do another assessment with the production personnel involved in the practice of use of these bags. Speak with the supplier and ask for their 1 use approval certification etc. Then suggest you approach your US colleague and tell him/her your findings. Its all well and good auditing these things, but they are missing the point - what is the hazard (potential to do harm) and the risk (likelihood of the harm being realised or happening), it its low - controlled - then suggest your write your RA and continue in the use of your bags. Yanks, sometimes they think they are the police of world peace, but now the safety police.....whatever next......... Best of luck. Wazza
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