Hello all,

I'm looking for some help or advice on how to comply with PUWER regulation 6. Here's a bit of background on us that might be relevant; we are a small design consultancy and fabrication company consisting of 8 people (staff and management). We only recently expanded into the realms of dealing with health and safety; I've been given the task of getting us compliant. I've worked the workshop floor for 4 years previously to this and know most of kit better than other staff (laser machine and welding kit being the exceptions). I've composed RA's for nearly all of our kit, where we identified a significant residual risk we have developed SSoW's, implemented weekly checks on the dangerous machinery, keep maintenance logs and have a PUWER assessment check list in place for general compliance.

What I really need help with is where the "inspection" statute comes in. We record a weekly check of the safety features and have 12 monthly services as planned preventative maintenance (recorded); so, where does an inspection fit into this? How do people comply to this reg? Do you need a dossier with all the inspection requirements and records of inspections? Or just a record that an inspection has been carried out? What different features would an inspection cover from a user check of ESD's, guards, visual electrical inspection and control system inspections? I believe we have staff experienced and competent enough to inspect our machinery and wont need an external service as long as I can figure out their place in it all.

The main areas we are concerned about are with relation to our guillotine, press brakes, power rolls and plasma cutting gear. If anyone has any advice or help for me; it would be much appreciated. I really don't know where to start drawing the line between these procedures......

Peas out

Pete

Thanks for the reply! That's the most useful info I've been given so far. Certainly a good starting point.
I'm a little unclear on one other thing now though; we have 2 hydraulic press brakes which have no fly wheel or clutch system to operate their stroke. Are these subject to the same regulations (power press regs)? Or just covered by PUWER in general?
Also the ACOP states a guillotine does not apply to regs 32-35; sooooo, does this mean theres no statute for inspection and we devise the schedule at our discretion based on use, manufacturers info, etc?

"Regulation 6 states:
(1) Every employer shall ensure that, where the safety of work equipment depends on the installation conditions, it is inspected –
(a) after installation and before being put into service for the first time; or
(b) after assembly at a new site or in a new location,
to ensure that it has been installed correctly and is safe to operate.
(2) Every employer shall ensure that work equipment exposed to conditions causing deterioration which is liable to result in dangerous situations is inspected –
(a) at suitable intervals; and
(b) each time that exceptional circumstances which are liable to jeopardise the safety of work equipment have occurred,
to ensure that health and safety conditions are maintained and that any deterioration can be detected and remedied in good time."

What is the statue for "suitable intervals" in terms of a metal cutting guillotine? Are there any? Refer to earlier question.

Also, found this:
"26 Part IV of PUWER 98 does not apply to:
(a) presses which do not have a clutch mechanism, for example pneumatic and hydraulic presses;
(b) power presses when they are being used to work materials other than metal;
(c) power presses, processes and circumstances listed in Schedule 2 of PUWER
98 (see page 33). "

So, our hydraulic presses are not subject to the statutes therein but still subject to a reg 6 inspection, presumably for us to devise?

I thought this was the case but found it very unclear trying to establish that as fact. Thanks for confirming this and for the info. Its been more help to me than anyone else (even the H&S consultancy we paid for!). My personal feelings are 6 monthly would be good for the amount of use the equipment gets, combined with RA's, SSoW's, restricted use of equipment, Toolbox Talks and the safety features of the machine itself should be sufficient to cover us. It's now just a case of devising and inspection routine and report system.

We were operating on 3 staff at first and so had no need to comply to many HSE regs, so we have no "after installation" inspection reports. Do you know where we legally stand on this now we have expanded to 8 staff? I guess the best tactic is to devise and carry out our inspections ASAP......

Thanks again.

Pete

smitch

To be honest, that's the approach I was going to take (on all fronts).

Where a failure of a clutch and fly wheel system could be dangerous to an operator; a failure of hydraulics could be just as dangerous on our machines (or pneumatic failure on our guillotine).

Thanks for the advice.

What does the acronym "IMHO" stand for by the way?

In My Humble Opion

Steve, you can be humble, I like being honest!

Sean

its our differences that make this profession and indeed the world we live in such an interesting place.

Cheers

Steve

And our insurers had very little input about PUWER regulation 6. No one seemed to think inspecting a guillotine was an issue as it is serviced by a sub-con engineer regularly.

stevel

So, Reg 6 of PUWER ACOP states "Inspection
130 This requirement for the inspection of work equipment builds on the current but often informal practice of regular in-house inspection of work equipment, some of which is already recommended in other HSE guidance.
131 Inspection does not normally include the checks that are a part of the maintenance activity although certain aspects may well be common. Nor, for the purposes of this regulation, does inspection include a pre-use check that an operator may make before using the work equipment. Additionally, while inspections need to be recorded, such checks do not."

Our operators check the safety features on a daily basis before use (not recorded) and once a week I inspect the safety features (guards, ESD's, cables, isolation points and a visual of mechanical devices such as slides, runners etc.) of the restricted machinery. We record the result of the inspection but don't have a record of each inspection (a check list/document from that specific inspection) on a register attached to the machinery. My inspection is a little more in depth, is it a good idea to have a dossier style document detailing your checks and tests in an inspection (results as well?)? I think from our conversation so far I'm pretty much compliant, just not sure how detailed our records documentation needs to be. I guess the more detailed the better? Or would this just be overkill and adding unnecessary paperwork?

So presumably as there are no statutes for "examination" of our kit (under PUWER) this will be enough? We've always checked and maintained our machines for both operators safety and productivity safety, it seems like I've been over-complicating it and this reg just pertains to recording what we already do out of common sense.

Thanks again for the advice.

I don't know if this will help, but I work in the printing industry and guillotines have specific risks associated and PIAC have produced a booklet which gives advice.'The printers guide to H&S'
Under PUWER reg 6 (2) they need to be checked by competent and trained engineers on a six monthly basis checking all safety components. The guillotine also has daily checks that the operator signs off which is kept with the machines.
I assume the basic checks will apply to any industry, hope this helps.

Bucksbloo, what you describe is good practice for that industry and for the type of guillotine used.

What MUST be done and what SHOULD be done and what COULD be done can be three different things, and what TO DO can be tricky to figure out :o)

We should always distinguish between what the PUWER reg says, and what additionally the ACoP says, and what additionally might be good practice developed by a company/industry.

The checks you mention won't apply to every industry. Inspection schedules (frequency and nature/content) depend on the specific risk assessment which should determine what hazards may be presented if the equipment is installed incorrectly, or by the equipment through deterioration of parts or mechanism, or through the conditions/environment of use.

JohnW

SDCL-Pete:
An R7 person refers to the Management Regulations, 1999. You can download the Approved Code of Practice and Guidance free of charge from here: http://www.hse.gov.uk/pubns/priced/l21.pdf
The document is highly recommended reading.

This Regulation requires every employer to have access to a person competent to give them advice on the measures that they need to take to comply with H&S law. This could be someone within the organisation (which is preferred, because they usually know how things really work) or someone outside the organisation.

The problem that can arise in appointing someone from within the organisation is to make sure they receive enough education and training to understand the breadth and depth of the issues they need to deal with. Many employers will operate with a combination of in-house personnel and access to specialist help when they need it.

Oh, and thanks btw Jane.