Posted By Catman Hi John I think the issue you will have is the strength of the legal terms used in this part of PUWER. The hierarchy you refer to requires implementation where 'practicable'. As the term reasonably is missing, it means that it would be very difficult to justify not doing the work for cost reasons. That's the law bit.... As far as my own opinion goes, I would probably be requiring a permit every time the machine was operated with the door open. This tells me that there is a frequent dangerous operation and that the hold to run control or even a pressure mat system or similar may make sense.....and would stop people drowning in permits. I would probably try to comply with the insurance suggestion. Cheers Catman

Posted By JohnMackie Thanks guys, You have confirmed what i felt and i have raised these concerns at various levels. I have been to other companies to see how they get around this issue. They are no better off than we are. Some machines are ok, others are unguarded. This was the insurers second visit, after his first he sent me all sorts of pdfs for guarding standards etc. one of which was a industry guide that we should setup using probes (Non rotational). We used to use these when i was on the shopfloor and they are not practical in a one off environment. Not accurate enough due to magnetism etc. My main problem is that the very people who supplied and continue to supply this type of machinery, told me that what we are doing is accepted across industry. It's just that i am being given conflicting information and am seeking a definitive solution. thanks

Posted By Robert K Lewis John I am rather worried that the fine work practice has developed. The duty to protect operatives from dangerous parts is an absolute one. One then selects the controls acording to the hierarchy of regulation 11. Moving down the scale as and when it is not practicable to achieve that particular style of guarding/segregation. The risk assessment cannot simply opt for a lower standard/minimal simply to enable the machine to be used. If at the end of the process the dangerous parts can be accessed when the machine is in normal operation then the regulations have been breached. Setting up is a totally different situation as the machine will be in slow running/inching mode and this is a recognised situation where the machine speed is not sufficient to cause entrappment, the operative having time to react. The CE marking requirements anvisage that guarding will be achieved during the final set up of the production line onmce the machine is located in its working environment. Bob

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