replace the guard!

Replacing the guard is not an option as the workpiece that is being trialled is to large. The industrial drill is operated from a control panel, with the operative some distance away from the rotational head and actual work area. The area is to be barried off with signs/limited access as the tooling runs. All trip hazards are to be removed/area made clear. Have I missed anything?

Yes, the proper application of the hierachy of controls!

Follow Reg 11 of PUWER. I agree, Ron is legally correct.

The operatives taking part are skilled and reasonably practicable measures are being taken to ensure safe operation. To hit the avoid button & say no machine should be operated without its guard would limit development and growth of the company. Reg 11 of PUWER permits the consideration training/instruction of operators, but it is the last option in the hierarchy of controls given in Reg 11. You should follow the hierarchy of controls to the extent practicable. Guarding is not covered by the term 'reasonably practicable' but by the term 'practicable' - this is a higher legal duty. So while you comments are laudable regarding jobs and company growth, this does not out weigh your employers duties under Reg 11 PUWER. If you are unsure of how Reg 11 can be enforced, I would suggest you look up some machinery accidents on the HSE Prosecutions database. REG 11 (1) Every employer shall ensure that measures are taken in accordance with paragraph (2) which are effective – (a) to prevent access to any dangerous part of machinery or to any rotating stock-bar; or (b) to stop the movement of any dangerous part of machinery or rotating stock-bar before any part of a person enters a danger zone. (2) The measures required by paragraph (1) shall consist of – (a) the provision of fixed guards enclosing every dangerous part or rotating stock-bar where and to the extent that it is PRACTICABLE to do so, but where or to the extent that it is not, then (b) the provision of other guards or protection devices where and to the extent that it is PRACTICABLE to do so, but where or to the extent that it is not, then (c) the provision of jigs, holders, push-sticks or similar protection appliances used in conjunction with the machinery where and to the extent that it is PRACTICABLE to do so, and the provision of such information, instruction, training and supervision as is necessary.* Reg 9 covers training

Oh I do agree with you, if we were to do everything to the 'T' as it say in legislation then nothing would be done anywhere, somethime we have to think about the situation and I fully agree that in this instance, it is controlled, therefore I go ahead with it.

Many thanks for all your posts - it is always good to get your valued opinions and advice. Regards Paul.

This is a trial run only. For normal production, full fixed guards would be fitted as standard.

Well said Ron - correct. If it is 'practicable' to guard the drill with fixed guards once in normal production, then it is 'practicable' to do so in a trial situation. Paul-ps - you have defeated your own argument, I think. Can't remember the full definition - but 'practicable' means to the 'extent technically possible'

The guard that the machine currently has fully encloses the work area. This is a very expensive & new machine with a skill operator, not a bench mounted pillar drill with a plastic guard. The size of the trial workpiece is larger than the current full length guards can enclose. Additional guards would be manufactured at a cost of ££££? should the trial be a success. We need to run manufacturing trials to win orders, to keep 500+ in a job. In the real world not every task can have ££££££ thrown at it, where sensible risk reduction will be sufficent.

Ron - I'm interested - What would your solution be? Regards Paul.

Paul, For the trial, can the piece not be done in two halves? Simon

Assuming that a risk assessment has been completed, the risk controls would have included the guard among other things. With the guard and other things in place, the RA should have resulted in some resultant degree of risk. If you go back to your RA and remove the guard from the set of risk controls, you should end up with a different resultant risk. (If you don't end up with a different resultant level of risk then clearly there is an issue with the RA process) The questions to be answered are: Can the organization and the workers tolerate new resultant risk? In the event that an injury occurs would the organization be able to stand behind its decision to remove the guard and then use the equipment? Interesting discussion. Cheers, Tom

PUWER doesn't stop you 'boxing' the operator in (for want of a better way of describing it - I appreciate this isn't what happens in practice) The point is you prevent access to the dangerous parts of the machine while in operation. See Reg 11 item 1(b) Non uncontontrolled general access to the work environment. Safe shut down and isolation, when access is required. It should be straigh forward enough to do and still comply with PUWER Reg 11.

In the first instance, contact the manufacturer of the machine. You say it's fairly new, that shouldn't be a problem.

"You say it's fairly new, that shouldn't be a problem.2 Well in my experience it will be a problem. Machines now come from the far east, ex iron curtain and a few from Italy. They are all CE marked & lots of pretty paperwork but without exception ( the ones I've examined) are substandard with regard to safety devices. I'm not trying to have a brag but I have 20 years experience getting equipment certified through CE /Euronorms/ IEC /BS / CSA etc so I do have an inkling at what I'm talking about