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#1 Posted : 11 December 2008 12:15:00(UTC)
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Posted By Paul D A subject for discussion. A risk assessment I have seen this morning has an action to completly enclose a machine that performs the same as a cement mixer. The cement mixer type machine cleans small metal pressings by abrasion.(Very low rotation speed). In applying PUWER it is 'practicable' (if it can be done, it is to be done) to completely surround the whole barreler with a fixed guard. A wire cage in effect. Why do we not see all cement mixers with cages enclosing them because if we take PUWER and the hierarchy of guarding it is practicable to do so?
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#2 Posted : 11 December 2008 12:40:00(UTC)
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Posted By Descarte Playing devils advocate for a second, I have no experience in the use of concrete mixers, but do you not require access to these frequently whilst mixing for addition of more water / concrete? Is this the same with your machine, or is it loaded and left? Is the duration in use of a concrete mixer likely to be a great deal shorter than your "slow rotating" type machine. Mixers are usually used outdoors in well ventilated areas, could there also be an issue with yours from an exposure point of view from dust, silica or rusts etc? How many of these machines do you have, 1 or dozens? and are they mobile or fixed? do they need to be moved and removed from site and placed in different location several times a day? I am sure construction sites have polices on clothing and training to ensure no items of clothing etc can be caught up in the equipment whilst in operation. I presume you have the same? I guess if answering all these your machine is very similar to the cement mixer than perhaps it isnt practical to enclose it. Playing devils devils advocate however you could also look at past history, is there precedence of accidents or injuries relating to this bit of equipment on your or similar sites which could have been prevented by enclosure? Does the costs involved outweigh the proposed benefits? Not trying to criticise or be a pain, just offering some thoughts Des
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#3 Posted : 11 December 2008 13:03:00(UTC)
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Posted By Paul D Descarte, What I'm trying to get views on is the interpretation of PUWER and how the risk assessor has come to his conclusion of requiring a cage to be built, enclosing the machine. By rights he has interpreted PUWER correctly, because there is no argument IE 'reasonably practicability'.The regulations as people know state if a fixed guard can be used it should be. Now the other question that could be asked; Is the rotating barrel a 'dangerous part'?
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#4 Posted : 11 December 2008 13:14:00(UTC)
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Posted By Tom Doyle Paul, It sounds as if the equipment risk assessment has been performed in accordance with Clause 5 of BS EN ISO 12100-1:2003. If this is the case hazards generated by the moving parts should be guarded. The intent of the risk assessment is to determine what protective measures are both appropriate and practicable for each situation. That being said, I would question the use of fixed barriers. I would think that an interlocked barrier would be more appropriate if access to the hazardous area of the mixer is required. One of the criteria for determining "adequate risk reduction" is deciding if "it certain that the measures taken do not excessively reduce the ability of the machine to perform its function". Take a look at Clause 5 of BS EN ISO 12100-1:2003. It should be helpful in this decision making process. Tom Doyle Industrial Safety Integration
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