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#1 Posted : 10 May 2007 16:39:00(UTC)
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Posted By James Dudding
Hi all,
I currently have an issue with one of the senior managers at our company. We have found that a large amount of the fixed machinery guarding in the factory has only 1 or 2 bolts holding it when it has perhaps 8 bolt holes. The manager insists that it takes too long for fitters to put all the bolts back in and that as the guard is still fixed and requires a tool to remove it is adequate. I argued that if the guard was designed to have x amount of fixings then it should always have x amount of fixings as the guard may be designed to contain something as well as keep people out. He will not concede this point and I am not in a position to overule him. Is there a line in any legislation e.g. PUWER relating specifically to this which I can beat him over the head with?

Thanks

James
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#2 Posted : 10 May 2007 16:44:00(UTC)
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Posted By SeanThompson
Check the manufacturers instructions, this should give you some guidance.
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#3 Posted : 10 May 2007 16:47:00(UTC)
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Posted By Dan Malone
Hi,

You should look at BS 953 Safety of machinery
Guards, General requirements for the design and construction of fixed and movable guards

Section 5.5.4 Secure fixing states

Guards, or parts of guards, shall be secured by fixing points of adequate strength, spacing and number to remain secure under any foreseeable loading. Fixing can be by means of mechanical fasteners or clamps, welded or bonded joints or other means suited to the
application.

The manager may be right in the amount of bolts that are holding the guard in place.

It certainly is a starting position for you.

You might also look at information for general design of machinery.

Regards
Dan
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#4 Posted : 10 May 2007 16:57:00(UTC)
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Posted By holmezy
Hi,

When the machine was manufactured, they obviously did'nt put extra holes in, just for the sake of it, (extra costs, etc)therefore you could argue that all the bolts are required. Plus, I wouldnt accept his arguement that it takes too long for a maintenace fitter to refit the bolts, Cant be that time consuming?? And how often are maintenace required to access the guarded area?

And think about the argument from the manufacturer in the event of an accident, he is going to say that the guard was not fixed in line with his machinery spec.

For the sake of an extra few minutes, (or whatever??) refit the bolts.

I'll bet that in the time you spend arguing the point the bolts could have been re fitted!!

Good luck.

Holmezy
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#5 Posted : 10 May 2007 17:01:00(UTC)
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Posted By Pete48
James, the point as you outline, is that things are designed to be used in the manner in which they are designed. Change that and you accept the fact that you have, to all intents, made a design change. If you are competent to do so and have recorded your design change; then clearly you can do so and will understand exactly what you have accepted as a duty and what you need to review to ensure continued compliance to codes etc.
If on the other hand, you have just left out 6 securing bolts because you think they are unnecessary or waste time and you have made no technical assessment of the impact on the safety design for the machine, then....??? Just asking yourself why would a machinery company spend money putting in 8 bolts unless it was necessary seems a sensible question!
So does this chap have the authority, written in your company systems, to re-design machinery in use or not? That is probably a better point to make than trying to use the law. If your company isn't that organised then try helping to determine the changed safety profile of the machine by talking to the supplier or someone with detailed knowledge of the type of machine that you are dealing with. (that could be an engineer not just a safety person)
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#6 Posted : 10 May 2007 17:23:00(UTC)
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Posted By David Bannister
Just a thought... Is some of this guarding designed to keep stuff in eg fragments from a disintegrating flywheel? If so then you could use the argument that two bolts just won't do the job.

The previous posters have all made valid and good points.

The "don't care" attitude by this manager is possibly dangerous and infectious and I believe you are probably right to challenge it, although as pointed out on several previous threads by better posters than me - choose your battles carefully.

Good luck.
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#7 Posted : 10 May 2007 19:34:00(UTC)
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Posted By Peter Leese
Sorry guys, I just can't go along with this. If the guard is substantially held by two bolts then does it matter?

I can see in a safety critical situation eg 6/8 nuts on a car wheel, but for a fixed guard?

I'd say you'd be better spending your time on something that matters!

Today I spent some time analysing a 3 page risk assessment (at £500 a day) for making soup - forgive me my cynicism, but there are better more productive topics to be discussed, don't you think.
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#8 Posted : 10 May 2007 20:17:00(UTC)
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Posted By Merv Newman
Two different situations.

1. designed to keep things in

2. designed to keep things out.

In the first situation where there is the possibility of material being projected from the work area with a certain amount of force then guarding needs to be designed and maintained at the level required to contain it.

In the second situation, keeping hands,arms, fingers out of the danger area then a minimum of barrier is required. Such barrier needing a "tool" to remove it. (spanner, screwdriver or key) ie a deliberate act.

I'm sure that most of the old hands have come across something like a pulley drive where the guard is supposed to be attached by about eight screws and maintenance have "lost" 6 out of the eight.

Is it dangerous ? Does someone need a kick in the fork ? Your judgement. Do a risk assement.

Merv
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#9 Posted : 11 May 2007 07:43:00(UTC)
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Posted By Pete48
Peter, but why then did the manufacturer design it with 8 bolts? Just so they could charge a little more for the machine? Or maybe, just maybe there are other reasons.
Which 2 bolts are being used to hold this guard? Exactly what is the guard protecting? what is the design material of the guard? Does it have other functions beyond safeguarding that might be affected by the removal of 75% of the bolts?
Would it be acceptable if a technician had left it like that or is it just OK because s senior manager has said he doesn't think it matters because it interferes with his production efficiences?
I disagree with you in dismissing it so lightly: although I might well end up agreeing with your judgement if we, as 2 competent people, were to inspect and examine the machine together on site. (and no I don't mean I want to do that!!)
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#10 Posted : 11 May 2007 08:06:00(UTC)
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Posted By Peter Leese
Pete - it is a principle that is being talked about.

If it is safety critical then make sure it is safe. If it is not safety critical then why waste the time. The point being made is, because 8 bolts have been provided, is it essential 8 bolts have to be fitted. I'd suggest the answer in most cases is - No.

What we do have to guard against (if you'll pardon the pun) is being unnecessarily pedantic when we don't need to be, because it will less effective when we do - if that makes sense!

That's not dismissing it, it is looking at it with real world constraints of time, pressure, and human nature.
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#11 Posted : 11 May 2007 08:26:00(UTC)
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Posted By James Dudding
Hi all,
Thank you for your responses, just to clarify a couple of things, this issue is more about general practice and 'culture' than a specific item of machinery. It is the fact that it is common place to leave out x amount of fixings without carrying out any assessment of the risks or logging any changes to the machinery. If this was a case of a redesign of the machinery and a senior engineer recorded that it now only needed y number of bolts I can accept that. In my opinion it is a dangerous habit to get into as I cannot see the time saved as being proportionate to the potential increase in risk. In response to Peter how do you define a safety critical situation? When does this become an issue that matters, when a piece of machinery comes through a poorly secured guard and hits the operator? I cannot accept that manufacturers routinely over spec their guarding and that it is up to a guy on the shop floor to decide that some bolts are not necessary.

Regards

James
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#12 Posted : 11 May 2007 09:14:00(UTC)
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Posted By Peter Leese
I cannot accept that manufacturers routinely over spec their guarding and that it is up to a guy on the shop floor to decide that some bolts are not necessary.

You're right James, it should be the safety advisor who decides, not the manager and fitter with the experience. Sorry.
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#13 Posted : 11 May 2007 09:26:00(UTC)
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Posted By James Dudding
Peter, I appreciate your sarcasm, in my opinion it is up to a competent mechanical engineer to decide if a machine can be safely redesigned in conjunction with a suitable risk assessment. A fitter deciding on their own that bolts are not needed because they take too long to put in, not recording the fact that he/she has done this and not telling anyone about it is bad form. The Manager in question knows that this goes on but could not say which guards may or may not have bolts left out as he lets the fitters decide this on an ad hoc basis.

James
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#14 Posted : 11 May 2007 09:28:00(UTC)
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Posted By Stewart Fullarton
Hi,

Some valid points have been made above, and i am of the opinion, that, If a fixed gaurd has 8 bolts then 8 should go back in (End of).

However i was in a similar situation in my old job in manufacturing, before long all the machines looked tatty and the operators got used to having gaurds hanging off. Its no supprise that people get injured when gaurds are missing, drop off and people get used to working in these conditions.

1. Because the gaurd does not have all the bolts in, does that mean that this machine jams and breaks down oftern requiring the removal of said gaurd ??? might be a maintenance or material issue ???

2. The fitters and operators get used to working this way so it promotes poor safety culture ? and encourages violations.

3. If an opertor or fitter was injured due to a gaurd not being fixed correctly....... you can bet they would win an injury claim based on the fact that all the bolts were not fitted.

Just because it still looks fixed with two instead of eight dosent mean its safe. After all i like all four bolts fitted to each wheel of my car.

Rant over.

Change the fitters perception, get operators to speak up, look at problematic areas and resolve.
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#15 Posted : 11 May 2007 09:33:00(UTC)
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Posted By Paul Leadbetter
I think there are two issues here: does the guard need all of the fixings with which it was originally supplied; and, how is safety managed?
Guarding is a safety issue and must be managed by competent people; the manager concerned and the fitters who are not replacing all of the fixings may or may not be competent but, at the very least, they ought to consult the safety advisor when making the decision to use less fixings than were originally fitted.
If the time taken to remove and replace all of the fixings is an issue, this suggests that the guard is removed a lot; in which case, would an interlocked guard be more appropriate?

Paul
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#16 Posted : 11 May 2007 12:05:00(UTC)
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Posted By Stephen Mitchell
I agree with Paul's response;

If guards need frequent removal then interlocked guards are the best route to take, this does not have to be a time consuming or costly a alternative measure (however they will require periodic testing).
On a further note it may be worthwhile finding out if/why the guards in question need removing so often, i.e. is this due to changeovers on the machines or due to the fact that the machines require fixing or unjamming regularly; in which case it may then be a maintenance problem with the machines in general.

Steve
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#17 Posted : 11 May 2007 12:28:00(UTC)
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Posted By James Dudding
All of the machinery has interlocked guarding in areas which require frequent access/adjustment. The guarding in question is fixed guarding which only needs to be removed for routine maintenance i.e. bi-weekly intervals at most, some only annually.
I appreciate all your responses but can anyone think of a particular British Standard, ACOP etc which states that guarding should be refixed as designed unless a risk assessment takes place? The Manager will only accept what I am saying if I can back it up with black and white!

Thanks

James
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#18 Posted : 11 May 2007 12:54:00(UTC)
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Posted By Glyn Atkinson
On a practical basis -

How big is the guarded area?

What are you guarding, how would it bite you if you got in under the guard?

What moving parts are accessible if the guard was removed?

Does the guarding need eight fixings ?

Are the two in use at one end with the rest swinging in the wind?

Do the fixings have to be tool operated ?

Could eight quick release wing nuts do the same job and the use be reinforced through training and works instructions to operators using the machine?

What size handcuffs does the manager require for his court appearance after any accident?

I suppose the last one is the sarcastic one, but will be the one that lots of safety guys and gals on here will be thinking privately from reading the thread thus far, only I have put it more politely !!
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#19 Posted : 11 May 2007 13:34:00(UTC)
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Posted By Paul Leadbetter
Glyn

If the need is for a fixed guard, I don't think that wing nuts will be acceptable fixings.

Paul
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#20 Posted : 11 May 2007 14:40:00(UTC)
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Posted By Merv Newman
Paul,

your last comment is correct. A "tool" should be required to undo the fixings. i.e. a deliberate act. Same is true for electrical cabinets.

Maintenance people are taught during their apprenticeships when and how to lose the "unnecessary" bolts.

Going back to my previous reply, if it is a question of keeping something in then maintenance will be careful to put everything back. If it is a question of keeping fingers out they tend only to do the minimum. Two screws. Classical example is a belt drive where the manufacturer has supplied eight screws. Maintenance will remove the eight and "lose" six.

When number 7 is lost and the guard is really swinging in the wind then you need to do something about it.

This said, really professional maintenance people will not lose the screws and will replace them all.

Then again, I know of belt drive guards which are hinged on the bottom side, needing only one screw to be undone to give access.

I am no longer sure of the point of this discussion.

Merv
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#21 Posted : 11 May 2007 18:42:00(UTC)
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Posted By Peter Leese
It's OK Merv.
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#22 Posted : 11 May 2007 19:54:00(UTC)
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Posted By Pete48
The last time I was involved with fixed guards and their fixings, it was after an employee had lost three fingers on each hand after they were caught in opposing drive chains. He had removed the guard with only one loose screw that could be undone by hand. He didnt know any better and the accident happened in the middle of the night shift.
safety critical or not, improperly fitted guards are not acceptable, it shows a disregard for safety that may cover other things.

Is there anything in either EN292 or EN 1050 that would help you. I no longer have access to copies and the ref number may have been changed to ISO series.
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#23 Posted : 11 May 2007 21:17:00(UTC)
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Posted By Kieran J Duignan
Jemes

Was the tail of your question was more revealing than you intended, when you wrote:
'Is there a line in any legislation e.g. PUWER relating specifically to this which I can beat him over the head with?'

The ACOP in relation to Regulation 4 of PUWER specifically refers to 'ergonomic risks', which, if you conduct valid ergonomic risk assessment validly, could be a relatively sophisticated way of educating users of the machinery about the issues.

At the same time, 'beating him over the head' is a curious style of implementing any kind of safety regulation: while it is likely to result in predictable behavioural change, it may not be in the direction of your preference.
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#24 Posted : 12 May 2007 04:48:00(UTC)
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Posted By martin gray1

Agree with previous comments go to the machinery manufacturer they will tell you why it needs x amount of bolts, they don't spend cost where it is not needed.
MG
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#25 Posted : 13 May 2007 10:51:00(UTC)
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Posted By Peter Leese
As always Kieran, you word it better.
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#26 Posted : 13 May 2007 12:06:00(UTC)
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Posted By Merv Newman
Kieran,

I dunno. Beating them over the head with something is an oft felt thought for many H&S people. Yeah !

A lump of wood or a hard bound copy of HSG65. Anything will do if it gets there attention and their thoughts moving in the right direction.

Merv (speaking figuratively and metaphorically at the same time) (not easy that)
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#27 Posted : 13 May 2007 12:45:00(UTC)
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Posted By Kieran J Duignan
Yes, if I understand you correctly, Merv....

You advocate the head as the object of a forceful assault on the grounds that, on the basis of a reliable, valid methods of 'suitable and sufficient' assessment, risks to other parts of the male anatomy might be more costly?

On that basis, am I correct in understanding that, in social as well as financial terms, you advocate the rear rather than the front or side of the head, sir?
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#28 Posted : 14 May 2007 06:19:00(UTC)
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Posted By Merv Newman
The last time I suffered a work related accident (a few years back now) the inquiry consisted of my boss asking "how did you do that ?"

Having heard my explanation he then implemented corrective and preventative measures : a clout around the ear and instructions never to do that again.

I didn't

Worked for me.

Merv
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#29 Posted : 14 May 2007 11:23:00(UTC)
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Posted By Glyn Atkinson
Reply to Paul,

I agree with the tool part requirement for the fixed guard, but many operators also have tools available for work on their machines, so a quick release system using either nuts or wing nuts ( just a first thought ) could be locally overriden by any user.

- Better perhaps for the system to be agreed and supervised and monitored so that all fixings are in place but engineered to be available for quicker release for regular changes, settings etc.

If the manager wants time saving, then engineer in a different way to fix all 8 nuts so that they can be used / fixed / torqued up (and understood to be in use) as intended but not to prevent a quick release via some engineered tool.

As I stated previously - the guarding is not just about time of release, it's how the guard is intended for fit and safe purpose to guard agianst unsafe access to whatever is behind that guard.

A wing nut can be manufactured including a spring washer, torqued up to prevent hand removal, but released by a simple made up lever, then quicker to spin than a normal nut.

Or supply an air powered torgue wrench or drill attachment to release the original nuts quicker?

Just another thought !
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#30 Posted : 14 May 2007 15:07:00(UTC)
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Posted By Gareth W Jones
In response to all the good information given on this thread I can only say :

When my maintenance manager comes to me and says... They shouldnt do that (in regards to an employee sticking his finger in a gap that has been found) My reply is always the same, Make it so They Couldnt do that.

No Shouldnt`s just Couldnt`s !!!

Gareth.

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#31 Posted : 14 May 2007 16:11:00(UTC)
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Posted By Darren J Fraser
Have you considered a different approach..........

Explain a hypothetical accident involving a fixed guard failure due to insufficient fixings, this accident could result in a visit by the HSE and/or the police in the worst case, followed by an investigation which could lead to the said manager having to justify why only two fixings were in place, and that using "it takes too long for the fitters to replace all the fixings" would not be a suitable defence, especially if it went to court.

Of course you could always contact your insurance carrier and ask them if they would be so kind as arrange for one of their assessors to pay a visit and provide suitable advice, after all they are covering you level of risk and therefore would be interested to see how you as a company are managing that risk exposure,

or dare I say it,

invite your local inspector along for a cup of tea, slice of cake and a chat, and invite said manager on tour of the facility with the inspector.

By the way, a liability insurance report is normally of a suitable and sufficient density to beat them around the head with.
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#32 Posted : 14 May 2007 16:54:00(UTC)
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Posted By Peter Leese
I'm happy with that approach Glynn, where you are working with the manager and operatives on the shop floor.

Isn't that what we are about, instead of being confrontational?

It's an old adage but still valid - if you have to resort to quoting the law to get things done, then the case is lost.

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#33 Posted : 15 May 2007 12:28:00(UTC)
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Posted By Shaun Brennan
James

i agree with all of above said, in my argument i would just say 8 holes,8 bolts, show me offical manufactuers guidelines that say different and i will back down.

Bugsy
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#34 Posted : 15 May 2007 20:56:00(UTC)
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Posted By Alan Nicholls
Just a thought

Some years ago (in a previous job)we had the visit from the friendly Insurance assessor regular inspections for brake press and power presses etc. On his travels around the factory floor he noticed one of the other machines had fixed guard with more than half of the fixings missing or broken. His thoughts on the matter were very clear. If you have an accident with this machine in this condition you aint insured,FIXIT!!

So beware, as previously stated, you wouldn't drive your car with only 1 of the 4 wheel nuts fitted would you. They are there for a very good reason!
I'd love to see the risk assessment to justify that one!
Regards Alan N
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#35 Posted : 16 May 2007 22:45:00(UTC)
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Posted By Barry Cooper
Guys
Talking about fixed guards. Question, would a padlock requiring a key (is this a tool) to unlock it, be classed as secure fixing? Just that all our supervisors keep asking that bolts be replaced with locks, and I am resisting this idea. Your thoughts please.

Barry
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#36 Posted : 26 May 2007 08:34:00(UTC)
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Posted By Colin
There is long standing case law on this. A piece of plant, equipment, machinery or pretty much anything in the workplace, must be adequately maintained. If a fixing, particularly one securing a guard or cover, is missing it cannot be argued that the machinery is adequately maintained. Simple as that!
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#37 Posted : 27 May 2007 12:21:00(UTC)
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Posted By Peter Leese
shakes head in disbelief>>>>>
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#38 Posted : 10 June 2007 10:55:00(UTC)
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Posted By Colin
Whilst not a regular contributor to this forum, as an engineer and safety practitioner with some 30-years experience in the machinery sector I do feel compelled to outline the requirements relating to the original question, as the possible consequences of some of the approaches suggested could be serious.

There are two issues here. Firstly, there is the legal requirement to effectively guard machinery and comply with the various associated regulatory requirements. Secondly, there are the management and behavioural issues of achieving compliance in practice.

These form a hierarchy. The legal requirement is predominant. Indeed, the provision of effective guarding is more often considered an absolute duty. In this particular case the behavioural issues relate to management rather than inherent human characteristics (unless you elect to include laziness). The manager is responsible for ensuring that the guards are maintained in a safe and efficient condition. This includes the guard fixings. The ‘3-wheels on my wagon and I’m still rolling along’ scenario will not provide a cogent defence.

The question of the function of the guard, to prevent access, restrict ejections, or both, is relevant only in terms of the machinery design. If the machinery was supplied under one of the Directives these requirements should have been the subject of design risk assessment, which gives rise to an assumption that the guard is correctly designed, and a failure to maintain the guard fixings gives rise to a breach of PUWER and the HSAWA. If the machinery was supplied prior to the Directives then the employer is under a duty to assess its safety through risk assessment under the Management Regulations, and any applicable technical requirements. Either method should give rise to an adequately designed guard, which must be maintained in that condition.

That said manufacturers do sometimes provide poorly designed guarding and the suggested redesign process with risk assessments applied by suitable qualified designers seems appropriate, although in cases involving machinery supplied under the Directives this must follow the prescribed process.

The new Machinery Directive 2006/42/EC revises the design requirement for fixed guards (EHSR 1.4.2.1). The requirement for removal by tool only is retained, whilst requirements that guard fixings must remain attached to the guard or the machinery when the guard is removed and, where possible, that guards must be incapable of remaining in place without their fixings, are introduced. I guess this should go some way to eliminate the ‘throw away the bolts’ culture, although I cannot recall having been instructed in this particular practice during my engineering training. It also implies an underlying intent on behalf of the directive’s drafter that all of the guard fixings should be in place.

I am in general agreement with the suggested view that this topic should be of little relevance in the modern environment, but not for the reasons suggested. The requirements for machinery guarding have been around for a long time, certainly back into the annals of the various Factories Acts, and during the last 30 odd years in more modern statutes, regulation, ACOPs, standards, directives, publications, etc. On this basis alone it is amazing that the subject gives rise to so many different views and interpretations, and that so many managers in industry, construction and other sectors continue to adopt, what seem to me, such indifferent attitudes to a simple concept. Provide adequate guards to meet the particular application and maintain these (including the fixings) in a safe and efficient state.

There is some discussion of the ‘beating over the head’ metaphor. Could this is the correct approach? As professional practitioners we owe our employers and fellow employees a duty of care. Do we fulfil this duty by ignoring such situations, particularly in areas so fundamental as machinery guarding? In addition there are the underlying cultural, management and behavioural aspects to consider. Will anything change whilst the senior manager continues the current approach? No! Do the employer’s policy and operating procedures state that its acceptable to leave fixings out of guards. No, unless the employer has lost the plot!

In his original posting James states that the manager in question is a ‘senior manager’. Possibly sufficiently senior to be considered a ‘controlling mind’? God forbid, but if the failure of an incorrectly fixed guard gave rise to a serious accident I would guess that the manager, having been aware of the malpractices, and deliberately ignoring, or perhaps endorsing these, would be considered negligent, possibly grossly so, giving rise, in the case of fatal injury, to a possible gross negligence manslaughter charge! In addition it may be inferred that the reason the malpractice was condoned was for financial gain in saving maintenance time. Not an enviable position for the manager in question! My guess is that if these factors were perhaps pointed out, that the manager in question’s approach, if not that of the fitters, may change, assuming of course that someone can find the bolts?

Trust this is of some assistance in what is perhaps not as simple and mundane a subject as it may first appear.

Best regards

Colin.
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#39 Posted : 11 June 2007 08:43:00(UTC)
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Posted By Peter Leese
Colin, to sum up your letter, I've extracted just one sentence:

'Provide adequate guards to meet the particular application and maintain these (including the fixings) in a safe and efficient state.'

I am in absolute agreement. So if three bolts effectively holds an eight bolt guard then mission accomplished. It if doesn't we're in trouble.

This is where the expertise of the fitter/engineer/manager comes into play - and the phrase 'risk assessment'. For the safety manager to talk about ignoring this expertise and wanting to hit people on the head is a travesty of what we are about.
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#40 Posted : 11 June 2007 10:20:00(UTC)
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Posted By Jim Walker
In a past life, I was equipment safety standards engineer for a big multi national (just to explain I know what I'm on about!).

It was my responsibility to interpret safety standards & law and translate them into a design. I then had to sign a declaration that the equipment conformed to requirements and could be CE marked. This is highly complex job, requiring competence way beyond anything a H&S practitioner or fitter or maintenance manager would understand.

Quite simply if you modify a machine (leave out nuts that were designed in by the competent person) then the equipment is no longer "CE marked" and thus breaches PUWER. Argue it as long as you like, the number of nuts are there for a good reason, leave them off at your peril.

In passing - one definition of a competent person is one who knows his (her) limitations - this forum is getting too heavily populated with people that do not abide by that.



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