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Dano1  
#1 Posted : 10 May 2010 08:58:50(UTC)
Rank: New forum user
Dano1

I am looking for some clearance on the PUWER regs.

In the company I work for we have cooking areas which have a number of different pieces of equipment, the supervisor does a start up sheet that incorporate the general area is safeand the equipment in it is safe to use.

Obviously the type of inspection will relate to the risk of the machines becoming dangerous and therefore the inspection being relative to this.

What I am am struggling to understand is the use of Pre use checks and do they need to be documented.

I am trying to put in place a general pre use check/inspection for the start of each shift, this ensures the machinery is checked and no damage has occurred causing the machine to become dangerous.

My only worry is the point made in the regulation 6 paragraph 135 that pre use checks don't have to be recorded.

Firstly am I doing right by trying to record that the machinery is safe for use prior to start of work.

Secondly is it more in the wording of Inspection and Pre use checks.

I am going on the basis of how could I defend the company if it went wrong.

Any help or guidance would much appreciated
Paul Walsham  
#2 Posted : 10 May 2010 10:39:10(UTC)
Rank: Forum user
Paul Walsham

We do both pre and post checks of all equipment used on packaging lines. These are recorded and kept for twelve months.
Juan Carlos Arias  
#3 Posted : 10 May 2010 13:24:36(UTC)
Rank: Forum user
Juan Carlos Arias

Of course you are taking the right approach in implementing formally recorded pre- use checks. Although PUWER might say they do not need to be documented, how else would you be able to prove that they were in fact done if something went wrong? Make sure that you make them simple enough for operators to complete properly and give them a high profile. You will probably need to actually carry out audits in the Start Up Sheet system and train the operators in the adequate filling in of the forms, the reasons why these are done and the consequences of not doing them or even worse falsifying them. Bear in mind that a good system can help you help defend the company but a not very well managed one can cause even more damage than not having it documented.
ajb  
#4 Posted : 10 May 2010 14:10:15(UTC)
Rank: Forum user
ajb

The paragraph in PUWER says no need to record pre-use checks - yes do them, but only record them if you think there will be a benefit. After all, your RAs, SSOW, information, instruction and training you provide to your operatives, your management systems for checking things are being followed, defect reporting system, safety management culture etc etc etc will all stand you in good sted for putting up a reasonably practicable defence. If you and your employees can answer, competently, questions put to you by an Inspector in the aftermath of an incident this will show to them you and your employees know what you are doing eg what you do, why you do it, when you do it, who showed you what to do, how long ago..... If they ask for a pre-use check record sheet, politely point them in the direction of PUWER and tell them that there's no legal requirement to have one. After all you can train a monkey to tick a box so just because you've got reams of paperwork it doesn't prove anything except that you've got reams of paperwork. The inspector will still be asking the same questions to you whether you've got this sheet or not.
Steve Sedgwick  
#5 Posted : 10 May 2010 15:38:37(UTC)
Rank: Super forum user
Steve Sedgwick

Unless a component failure gives rise to a substantial risk of serious injury or death I would not expect to see a detailed pre-start check list for it. NB the thread talks about a "Cooking Area"

If the risks are substantial then consider a check Iist.
I investigated a death several years ago caused by a failure of a safety critical part that did not get its pre-start operator check that may have identified the fault before the accident; the previous shift had done the check and found no problem with its function.

The operator at the time of the accident knew that this prestart check should be done but believed that the check had been done earlier in the shift by others, the accident happened near the end of his shift and this was the first time that this plant was used on that shift.
There was no way he could check if the pre-start check had been done because checklists were not being used.

So the point of this is focus on the significant and particularly serious risks and be proportionate with the controls. Do not build unnecessary bureaucratic systems for the lesser risks as this can undermine the safety critical controls that need absolute adherence

Steve
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