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Posted By T. Fowler
Is there any regulation disallowing the modification of equipment guarding when the use to which the equipment is to be put is rather different to the norm and the standard guard is therefore not quite adequate?
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Posted By Ron Hunter
You have an absolute duty to ensure that work equipment is safe at all times. Your post reads that you intend to modify or use an existing machine for something other than its intended/designed purpose, with an increased risk of entrapment/ejection or whatever - could you elaborate?
From your description you could not 'supply' this machine without re-doing all type testing for all relevant essential safety requirements (maybe your not in the supply business)
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Posted By Fred Pratley
As long as the guarding is as effective (or better) than the original and meets the standard, not a problem.
regards Fred
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Posted By T. Fowler
Thanks for the replies
I'm not in the supply business, I am a H&S Adviser, advising the manager of a mechanical engineering workshop. He wants to change the size of a guard on the rear of a guillotene so that he can site it in the corner of a workshop. The walls would act as guarding so safety is not compromised. My thinking is that provided the guarding is effective - a judgement made by a competent person - adaptation of guarding would be allowable. I put the question just in case there was anything hidden away in PUWER etc, that I don't know about. From initial responses it seems there isn't.
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Posted By Lynne Ratcliffe
have sent info separately
Regards
LMR
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Posted By Alan Hoskins
Hi Tony,
Be careful of using the walls as a guard - what if they then relocate the equipment away from the wall?
Alan
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Posted By John Beadle
You should contact the supplier of the machine before making any modifications, as they should hold a safety file on the machine. Changes should be added to the file. The design of the guarding must comply with all BS EN standards; also additional training will have to be given on the machine if it changes how the machine is to be operated.
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Posted By Dave Daniel
Technically yes there is a prohibition. The Health and Safety (Miscellaneous Amendments) Regulations 2002 contain a specific absolute prohibition about altering or removing anything on a machine provided to meet a CE requirement, even as far as I can see when necessary for maintenance.
The HSE put this in because they said the first thing people do is take all the guards off and under PUWER there is no specific offence! I actually think it reintroduced a conflict with the Machinery Directive which was removed in 1998.
The implication of this, as I have pointed out to an HSE inspector serving a notice, is that technically you can't modify a CE-marked machnie even if the safety arrangements could be improved.
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