Posted By George Wedgwood
This is the text content of the survey questionnaire and the pro forma letter which is intended to be sent by inspectors. It is a useful check on your safety of machinery whilst working on it and for the safety itens fitted etc. However, some of the questions are not easy to answer!
Regards, George
"Following a number of recent fatalities resulting from inadequate isolation procedures adopted, HSE inspectors will be visiting a range of premises in the coming months to consider the following issues at these machines:
o Is the hardware right?
o Are the procedures right?
o Does the employer have an adequate risk control system for managing those procedures and maintaining the hardware?
It is important to note that this initiative is not targeted only at the metals recycling industry, but at the range of industries indicated below.
This is an enforcement initiative and where standards are found to be below minimum legal requirements, inspectors will take formal enforcement action.
The machines to be targeted in each industry are:
Industry Machinery
Recovered Paper Balers recovered paper industry
Hoggers Shredders and Safety ISBN 0717622673
Conveyors
Plastics Granulators
Agglomerators (aka
Crumbers/Densifyers)
Shredders
Conveyors
Rubber manufacture Bale cutter
Bale guillotine
Internal mixer
Conveyor
Scrap metal Balers
Crushers
Fragmentisers
Box shears
Corrugators Corrugating plant
Balers
Wood reclamation Chippers (aka hoggers/
reducers/granulators/
shredders
Note: There are British Standards dealing with safeguarding at conveyors.
FOLLOW UP INSPECTIONS
Where conditions found at the first inspection fall short of minimum legal requirements in any significant respect a return visit will be made to check that the required improvements have been implemented. In most cases the follow up inspection is likely to be the visit at which an Improvement Notice or Prohibition Notice served at the first visit is subsequently checked/discharged. In the case of a prosecution the return visit will be after the court case has been heard.
Some inspectors may decide to use an introductory letter if they so wish.
A press release is being issued to relevant trade journals. The BMRA was formally informed of the initiative on 28 October 2004.
HSE inspectors will be asking for information as indicated in the proforma below.
To look at machines for which access into, or working inside with safeguards removed, could result in serious personal injury if safe intervention procedures are not followed. The type of tasks to be considered are: setting; cleaning; clearing blockages; running repairs; adjustments on the run.
Machine 1 Machine 2 Machine 3 Machine 4
Hazard elimination and risk reduction
Has the employer taken all reasonably practicable steps to eliminate/minimise the need for people to gain access into danger zones by:
Question – Answer Y, N or N/A Machine 1 Machine 2 Machine 3 Machine 4
2.1 Minimising the chance of blockages (e.g. pre-sorting of feed materials, ensuring feed conveyors are evenly loaded, ensuring steady feed rates etc)?
2.2 Providing feed conveyors with reversing facility?
2.3 Ensuring machines and guards allow rodding of blockages from outside the guard enclosure?
2.4 Providing misfeed detection and warning systems?
2.5 Providing machinery that can be adjusted automatically (by motorised adjusters etc)?
2.6 Providing machinery that can be adjusted manually from outside the guard enclosure?
2.7 Ensuring dimensions in fixed guards for insertion of adjustment tools do not allow bodily access into the danger zone?
2.8 Providing viewing aids (e.g. internal lighting, clear viewing panels, CCTV, mirrors etc) that allow people to see critical parts of the process without the need to gain access?
In relation to reducing the need for access, what course of action was taken as a result of your visit? Answer none, verbal adv, written adv, IN, PN, proposed PR – all that apply and numbers in ().
Machine 1 Machine 2 Machine 3 Machine 4
Hardware
Machinery safeguarding, interlocks and emergency stop devices
Note – The quality of safeguarding and any associated interlocking devices will vary depending on the potential harm if access is gained behind it. Points to consider: How large is the opening when the protection is removed? Severity of injury? Frequency and/or exposure time to the hazard? Possibility of avoiding the hazard?
Question – Answer Y, N or N/A Machine 1 Machine 2 Machine 3 Machine 4
3.1.1 Are you satisfied with the method of safeguarding?
3.1.2 Are you satisfied with the standard of safeguarding?
3.1.3 Are you satisfied that interlocking is provided where required?
3.1.4 Are you satisfied with the standard of interlocking where provided
3.1.5 Are all items of machinery fitted with one or more emergency stop devices (ESDs) that have clearly identifiable, visible and quickly accessible controls?
3.1.6 Where several machines operate together, does each ESD stop the other machines where necessary?
3.1.7 Do the ESDs stop the dangerous movement or process as quickly as possible without creating additional hazards?
3.1.8 Where necessary do the ESDs trigger safeguard movements e.g. release of clamping pressure?
3.1.9 Does the operation of the ESD require physical resetting to start the machine?
In relation to machinery safeguarding, interlocks and emergency stop devices, what course of action was taken as a result of your visit? Answer none, verbal adv, written adv, IN, PN, proposed PR – all that apply and numbers in ().
Machine 1 Machine 2 Machine 3 Machine 4
Isolation and lock-off devices
Where access is required, has the employer provided robust isolation and lock-off devices that ensure that:
Question Machine 1 Machine 2 Machine 3 Machine 4
3.3.1 The drive to the dangerous part of the machine can be isolated from energy sources?
3.3.2 Any stored energy can be dissipated before access is allowed?
3.3.3 Actuators for energy isolation systems are suitably positioned, clearly labelled to identify the items of machinery they isolate and marked ON/OFF?
3.3.4 They are fitted with the means of locking in the off position where necessary?
In relation to isolation and lock-off devices, what course of action was taken as a result of your visit? Answer none, verbal adv, written adv, IN, PN, proposed PR – all that apply and numbers in ().
Machine 1 Machine 2 Machine 3 Machine 4
Procedures
Safe systems of work
Where the need for access into danger zones cannot be eliminated, has the employer:
Question Machine 1 Machine 2 Machine 3 Machine 4
4.1.1 Identified the tasks that require access?
4.1.2 Performed a suitable and sufficient risk assessment for each task?
4.1.3 Taken account of the potential for human error (e.g. slips or lapses of memory, communication errors etc) as part of the risk assessment?
4.1.4 Taken account of the potential for violation of rules by employees and the factors that influence the potential for rule violation (e.g. workload, time pressures, practicality of the rules)?
4.1.5 Taken account of the need for safe access and egress?
4.1.6 Taken account of the risk of slips, trips and falls from height?
4.1.7 Taken account of the risks from manual handling associated with the task?
4.1.8 Taken account of the relevant instructions in machine manufacturers’ instruction manuals?
4.1.9 Provided and maintained a suitable permit–to-work system where appropriate?
4.1.10 Provided appropriate emergency shutdown procedures?
4.1.11 Provided a safe system of work for each task?
In relation to safe systems of work, what course of action was taken as a result of your visit? Answer none, verbal adv, written adv, IN, PN, proposed PR – all that apply and numbers in ().
Machine 1 Machine 2 Machine 3 Machine 4
Energy isolation and lock-off
Are there robust energy and isolation lock-off procedures that:
Question Machine 1 Machine 2 Machine 3 Machine 4
4.3.1 Specify the correct isolators for the intervention task?
4.3.2 Check that stored energy has been dissipated where appropriate?
4.3.3 Ensure the isolator(s) are securely locked in the off position?
4.3.4 Include a final check to confirm that machinery has been isolated from all sources of energy?
4.3.5 Communicate the fact that people are working in the danger zone to everyone who needs to know e.g. anyone who might start the machine?
4.3.6 Personal padlocks are provided and, where appropriate, multiple lock hasps?
4.3.7 Spare keys for isolator locks are not accessible?
In relation to energy isolation and lock-off procedures, what course of action was taken as a result of your visit? Answer none, verbal adv, written adv, IN, PN, proposed PR – all that apply and numbers in ().
Machine 1 Machine 2 Machine 3 Machine 4
Routine maintenance and inspection of safety related parts
Note – Please consider preventive maintenance and inspection by both the operator and maintenance staff. e.g. In many industries two levels of safety checks are appropriate:
Daily visual and fictional tests; and
Less frequent but more detailed inspections and checks carried out by a competent machine setter or maintenance staff.
Has the employer provided effective procedures for routine maintenance, inspection/testing of and reporting defective:
Question Answer Y or N
4.5.1 Fixed and moveable guards and access doors, gates, panels and electro-sensitive protective devices?
4.5.2 Interlocking devices?
4.5.3 Emergency stop devices (ESDs)?
4.5.4 Power isolation devices?
In relation to routine maintenance and inspection, what course of action was taken as a result of your visit? Answer none, verbal adv, written adv, IN, PN, proposed PR – all that apply and numbers in ().
Machine 1 Machine 2 Machine 3 Machine 4
Management system
Managing and organising the safe systems of work (SSOW)
Is there evidence to show the following:
Question Answer Y or N
5.1.1 Managers and supervisors understand and accept their responsibilities for the operation of the SSOW?
5.1.2 Managers and supervisors are held accountable for the correct operation of the SSOW?
5.1.3 That, where appropriate, employees or their representatives were adequately involved and consulted during the preparation of any safe systems of work they are required to follow?
5.1.4 Rules relating to the SSOW are effectively communicated and understood?
5.1.5 Employees required to apply and follow the SSOW have been properly trained in the SSOW?
5.1.6 The SSOW are properly followed in practice?
5.1.7 Managers and/or supervisors monitor compliance with the SSOW?
5.1.8 Managers and/or supervisors take appropriate remedial action if SSOW are not followed properly?
5.1.9 Managers review the operation of the SSOW at appropriate intervals?
In relation to managing and organising the safe systems of work, what course of action was taken as a result of your visit? Answer none, verbal adv, written adv, IN, PN, proposed PR – all that apply and numbers in ().
Machine 1 Machine 2 Machine 3 Machine 4
APPENDIX: Letter preceding visit
Your reference:
Our reference:
Direct line :
Dear
SAFE INTERVENTIONS
HSE has launched a 3 year enforcement led campaign to reduce the number of fatal and serious injuries caused when operators carry out interventions such as clearing blockages and performing running repairs inside dangerous machinery without the correct safeguards in place along with robust isolation and lock-off procedures.
The aim is to achieve a reduction by:
• raising awareness about the risks and standards required for safe isolation and lock off;
• ensuring that robust isolation and lock off procedures are implemented; and
• ensuring that employers have, or put in place, sound risk control systems for managing these procedures.
I will be visiting you as part of this project on (date agreed or a date to be agreed) in order that I can adequately assess your arrangements for ensuring safe interventions.
So that we can both obtain as much as possible from the visit some advance preparation by you will be necessary. This will involve you arranging for the following to be available at the visit: –
• machinery manuals – operational and maintenance
• staff training records
• risk assessment records
• systems of work and any written procedures for operating / maintaining the machinery
I will need to speak with relevant operators, fitters and maintenance staff along with any engineering staff and your safety adviser / manager.
Optional para below depending on whether you have sent it already.
The questions that I will be raising are being shared with relevant trade associations and their members and are freely available. If you have not seen a copy and would like one let me know and I can send the questionnaire out in advance of my visit.
I look forward to meeting you."