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Posted By RBW100
Morning all,
I have a question on machinery guarding. If you look at a typical vertail form fill and seal machine, they gerally have interlocked guards around the sealing jaws for obviosu reasons. They also have a large opening at the interlocked guards to allow the newly formed bags out of the machine. It would be possible (on the machines I have seen) for you to lie on the floor at the side of the machine and reach up through the opening I have described above and make contact with the moving jaw.
Do most here assume that this is something that you do not expect someone to do? Or do others who operate these mahcines fit their own guards?
Rob
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Posted By RBW100
I wish this forum allowed us to edit posts, as I could then correct the shocking typos in my first post!
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Posted By holmezy
RBW100,
It is unreasonable to try and cater for someone deliberatley try to deafeat a guard so lying down and reaching up wouldn't be something I would consider. Most machine guards can be defeated IF the operator is determined to get in or around the interlocks etc, using all manner of things. I try and consider the operator to be "sensible and have a degree of understanding of the why's and wherefore's of guarding" and to use a little "common sense" which aint that common.
If you have guarded the machine adequately and the operator does something to deliberatley defeat (ie lie on the floor and reach in) the guard, then I think you have done all that is reasonable. From my experience in CNC machines, both operating them and trying to guard them, the more complex the guard, the more effort the (awkward)operator puts in to try and defeat it! Its a bit like a challenge.
I once saw an operator use highly polished prism's that he had made out of stainless steel on the CNC milling machine, which were then mounted on a pedastal and aligned in such away that it "fooled" the light beam and allowed him to walk into the danger area. Absolutely brilliant what he had done,but a pity about all the time and effort put into it to defeat the guards, when he should be producing work. Then its dowm to management and supervision.
your name sounds like a robot out of Star Wars or similar, by the way!!
Holmezy
cider tonight me thinks....
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Posted By MP
Rob
The number if times I've turned up at accidents and gone "I can't believe they've done that!"
Without seeing the machine it's difficult to be precise but, do you think someone will possibly try to access the jaws to free some bags?
If so, maybe some re-training needed too perhaps
I'd be inclined to physically rule this possibility out anyway and extend the guards.
Bear in mind needs of maintenance though
Regards
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Posted By RBW100
That would be my approach too, its good to know that I'm not the only one!
By the way, we have not altered the guards, they are as supplied by the machine manufacturer.
I think it is foreseeable that someone could reach up to try and clear a blockage, but given that they would need to lie on the floor to reach the jaws, that must be seen as unreasonable behaviour.
I suppose that any risk assessment must assume that whilst a person is not trained, they do have some level of self preservation built in.
Rob
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Posted By Robert K Lewis
Holmzey
Except I have seen a number of inspectors do just this. The duty is absolute, in spite of the RA parts of PUWER and just because you do not expect someone to do something this does not mean that it is able to be discounted - Remember Mr Uddin and his pigeon chase on the roof.
Bob
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Posted By Mitch
C3PO (sorry couldn't resist it)
Have you spoken to the manufacturer/looked at their RA?
Mitch
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Posted By MP
...aha! A picture, as they say, is worth a thousand words.
It's nothing like I imagined. Not even close.
I see your problem. Tricky.
The only option may be to extend a "U" shaped polycarb(?) tunnel along the exit route for about 6 inches I suppose. (space permitting)
Maybe a warning sign near the exit too?
Regards
Mike
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Posted By holmezy
Bob,
Yes, it is (was) an absolute duty, however, I have never come across any cnc machine that could not be accessed by some degree of ingenuity. Milling centres are normally surrounded by 6 foot enclosures and interlocks but if someone wanted to go and get a ladder and climb over the guards, then that would be possible. Similarly, if someone wanted to deliberately rewire an interlock switch, then its possible. I thought that the absolute duty had been relaxed due to the access required to dangerous parts on a pedastal grinder. Operating a centre lathe allows access to all sorts of revolving parts and you could guard everything, then not be able to operate it? You could, effectively, guard anything to such an extreme standard that it becomes un operable or uneconomical to produce.
I've also met inspectors who think that access to parts should be absolutely prohibited,to a point of machine becomes non operable or un economical,,,,, and others that do accept that if a person really really, really wants to get into a machine, they will, and was happy with a "practicable" approach.
Funny old world....
Holmezy
definatley cider for me...
Holmezy
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Posted By holmezy
RBW100
just seen the picture. A tunnel guard, as suggested could be used, but would it stop access whilst still allowing bags to be removed. You could fit a sliding guard that drops down or a "cat flap" type guard (and is interlocked?)to prevent access that the operator has to physically raise. Not the best level of protection, and easily defeated. You could just put a big sign on it saying "DO NOT PUT FINGERS IN HERE, IT WILL MAKE THEM BLEED" or similar. At least you have tried to do something.
I would happily argue that, provided the dangerous parts are out of normal reach as per BSEN294:1992, then the operator would have to do something out of the ordinary AND deliberatley, to gain access.
Maintenance and cleaning operations would also have to be considered of course.
Holmezy
mmhh....cider...
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Posted By Mitch
I have a pen on my desk if I stick it in a piece of blu tack and smash my head down onto it I will injure myself, should I therefore fit a guard to the desk, pen, or my head. Answers on a post card please.
Never mind a virtual pint I'm going to get bladdered before I lose the will to live.
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Posted By Heather Collins
Of course not Mitch - it isn't a machine is it?
I've seen people do the daftest things imaginable to defeat guards and reach into areas where they had absolutely no business being.
Doesn't cut any ice with HSE when you say "well we never thought they'd do that".
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Posted By Mitch
Strewth your on the ball. Whatever ever happened to reasonably practicable (nearly Friday)
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Posted By MP
...you can't beat a good guarding thread
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Posted By holmezy
Mitch,
just so you don't think I've gone totally non sensible, I did qualify my last post by saying that I'd argue the point that you can't legislate for someone who is determined to do something.
I agree with you, we should be (reasonably)practicable about the guarding issues.
As for your pen / head interaction, I would suggest that you try it with a permamenet marker, and rather than go for extreme pain, try and build up to a level that you feel will require a safety device to be fitted and step back a little. This way you can happily bang your head all day long, suffer no pain and as a bonus, you get to play "dot to dot" on your forehead later.
Holmezy
Suns gone, ciders off, bring on the Pedigree....
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Posted By Heather Collins
Go and read Regulation 11 of PUWER Mitch and then come back and tell me where it uses the words "reasonably practicable"?
I'll give you a clue. It doesn't.
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Posted By Mitch
Or not 2 b
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Posted By Robert K Lewis
Totally agree with Heather - It is a total fallacy that you risk asess exposure to a dangerous part of a machine. the old FA section 14 set an absolute standard and that cannot be reduced to a sfrp standard even if we wish. Strictly we are back in the pre 1970 days wrt grinding wheels and their use is probably in breach opf PUWER.
The exemption was in the Abrasive Wheel Regs and not transferred to PUWER. Eventuially it will be done but I think any inspector who permits a risk assessment way out of the problem is misunderstanding the purpose of the regulations. In the end a few civil claims from injured operatives may focus minds as it did pre 1970.
On this particular machine one might well think of using a light curtain to guard the opening when not in operation as I think the bag itself will prevent access during filling. Can you access moving parts with no bag present? If so guard it by redesigning the outlet access - if not then record the assessment.
I feel suddenly very old:-)
Bob
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Posted By Mitch
Apologies to all I was just be facetious, my point being though that if you apply PUWER you should not have to concern yourself with 11. I would be happy to use the machine given in the example and I would be happy to manage people using the machine. If an incident occurred I would not be prosecuted under PUWER Reg's and would happily use the defence of reasonably practicable having applied PUWER as required, assessment, information training and more importantly management.
Yours humbly....
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Posted By RBW100
The bag does not prevent access.
Would a light curtain detect the bag leaving the machine and hence stop it, perhaps?
A tunnel guard may be possible.
I have seen a number of these machines in a various factories and at trade shows, all have this potential issue.
I might ask a manufacturer if this was considered in their machinery assessment.
Rob
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Posted By RBW100
Just noticed that there is a standard that relates to this type of machine:
BS EN 415-3: 2000 Safety of. packaging machines - Part 3: Form, fill and seal. machines
I do not have a copy of this but it may mention this issue.
Rob
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Posted By MP
just a thought, what does the manufacturer say?
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Posted By holmezy
and I mean't to say what what Mitch so elequently said! I'd argue the same.
Whilst I accept that the regs are absolute, in real life its sometimes not practicable or reasonable to do it without effecting the prposed functionality and use of the machine.
Holmezy
not quite as humble, but getting thirsty...
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Posted By Mitch
PS the pen is a mechanical propelling thingy with a red laser mounted in the end!
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Posted By Robert K Lewis
Case law states clearly that an absolute duty must be met even if it makes the machine inoperable. We may feel it is ridiculous but the Law Lords have set the precedent and who are we or the HSE to argue.
Regulation 11 sets out a heirarchy and 2(b) only follows if 2(a) is not practicable. Practicable has no reference point to the use of the machine, only to the technical methods available to do the task.
Fixed guards
then
Other guards
then
Jigs etc
then
information etc
Practicable is the operand in all choices to progress to the next lower level.
I see no ability to assess risk in this whatever the HSE may wish to argue.
Bob
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Posted By Malcolm Hogarth
RBW100
Regards spelling, you can edit your thread before posting - just click on Check spelling.
Mitch - Reg 11(2)b is 'practicable', not reasonably practicable.
Malcolm.
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Posted By Mitch
Malcolm,
I know!
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Posted By Robert K Lewis
RBW
Light curtains are only of use if the time of possible exposure is limited only to the time in which you can access the parts without the bag present.
You now need to consider how you can physically prevent the operator reaching under the guard and upwards to the dangerous parts. This will depend on factors present in your workplace and without that information I can only talk to the air. The location of the equipment and its interfaces with other equipment all play a part. I am sure many of us would be happy to provide consultancy assistance with this but without detailed knowledge of your process we can go no further. The standard to be met is practicable and not whether it prevents use of the machinery.
Bob
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Posted By Mitch
So if you follow the hierarchy you end up with '(d) the provision of information, instruction, training and supervision.' ?
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Posted By holmezy
To All,
It may not seem it, but I do understand the relevant regs but less of my problems!
Obviously the absolute duty as per case law is not ideal, ie Case law states clearly that an absolute duty must be met even if it makes the machine inoperable. Clearly we cannot guard machines to such an extent that they become in operable eg grinding wheel, pillar drill most electrical hand tools etc, so what can do is try and make them as safe as possible, following the hierachy, so as to remain useful to us.
With regard to the photo of the machine, I would be happy allowing it to be operated in the condition it is (assuming it complies with BSEN 294, meets essential H+S requirements and is SAFE, not necesarily CE marked). It has a fixed guard that allows it to operate "safely" and I dare say comes with I.I.T which then requires a degree of Supervision. I would also expect any residual risks to be identified, ie you could, if you so wanted, lie on your back and put your arms, at a stretch into the machine and damage your digits, SO DON'T!
Yes, you could guard it further with a light beam, cat flap, adjustable guard, tunnel etc but what real benefit are you achieving? Or shall we just put the whole machine in an interlocked enclosure and move the control panel outside so the operator is protected by distance.
How many of you would allow employees to use it as is?
Holmezy
Ok, its Pedigree tonite!
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Posted By Mitch
me me me me
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Posted By MP
as I said
...you can't beat a good guarding thread
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Posted By Adrian Watson
Holmzey,
I wouldn't allow it to be used in its present condition!
I have personal knowledge of a similar circumstance in Southampton where the operative did go under the guard to "clear a blockage" on a granite cutting saw. The person was trapped and crushed by the moving bed. He died as a result of his injuries!
The managing director was convicted of manslaughter and imprisoned for two years.
The moral of the story. Guard the dangerous parts of the machine.
Regards Adrian
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Posted By Mitch
Adrian,
I know a bloke (served my apprenticeship with him) who caught his hand in a pillar drill, with a chuck guard fitted, but I wouldn't stop anyone with training and experience using a pedestal drill, I would manage it though.
Mitch
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Posted By Robert K Lewis
Mitch
Only if everything else is impracticable. Then if you choose to do it that way you recognise the substantial risk to the organisation and the employee if it fails.
Holmzey
The court logic is if you put people to work with dangerous parts exposed and the employee is injured there is no defence unless you have done all that was practicable. If the employee dies as a consequence - Now where are my notes on CM? Chose to risk assess rather than guard as per regulations, case law is well known - Now is there a Gross Breach? hmmm
Bob
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Posted By holmezy
thats 1 no
and 2 yes's.
And yes, I agree that we should guard dangerous parts of machinery. Under the proviso's that I stated, and its difficult to see without examining the machine close up, I think this ones OK.
Incidentally, I'm well aware of the level of protection offered on stone cutting machines, especially older type bridge saws. It usually consisted of a chain across the front!! Easily defeated and certainly not adequate. Newer ones have interlocks, light beams etc and are much better, if still lacking a little. The stone industry moves in mysterious ways and is 30 years behind everyone else with regards to technology!
Holmezy
soon be pedi time....
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Posted By holmezy
Bob,
I'm not choosing to RA rather than guard. What I am suggesting is that if you follow the regs ie absolutely.. then you won't be able to operate the machine so its not practical. Where do you draw the line? Mitch stated that a pillar drill with a chuck guard still allows access to moving parts so to the letter of the regs, all pillar drills are unsafe and employers are in breach. Numerous examples of machines allow access to moving parts , eg centrelathes, grinders, drills, conventional milling machines etc etc. Whatever the regs say, in the real world we guard as much as we can, then rely on I.I.T.S.
Even if you could reach the moving parts on the bagging machine by doing something entirely and extremely stupid and reach up to clear a blockage whilst laying on the floor on his back, I would allow it to operate as is. IF it proves that lots of folks are doing it and getting the fingers chewed then I would suggest that the type of guard is wrong entirely. If its too hard to remove the (fixed) guard to clear the blockage and the common practise is to reach under, then fit an adjustable guard that is interlocked and easy and quick to open that isolates the machine.
And I fail to see how, in this case we have gone from a person having his fingers chewed to it being a CM case.......but glad to hear your taking notes!
I'm still a yes by the way......
Holmezy
feeling a bit parched now...beer time looms
Anyone for a pint?
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Posted By Adrian Watson
Holmzey,
This one was a new machine in 2003 with light guards to 9" above the ground. The person crawled underneath the light guard.
Regards Adrian
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