Welcome Guest! The IOSH forums are a free resource to both members and non-members. Login or register to use them

Postings made by forum users are personal opinions. IOSH is not responsible for the content or accuracy of any of the information contained in forum postings. Please carefully consider any advice you receive.

Notification

Icon
Error

Options
Go to last post Go to first unread
Andy Adams  
#1 Posted : 13 March 2012 21:13:46(UTC)
Rank: Forum user
Andy Adams

Hi All

I have a query regarding guards (or lack of) on old machinery being used in some companies. The company are going for OHSAS 18001 and have been told by their consultant that they should have suitable guards in place. However they are reluctant to add guards as they claim they will get in the way and cause a bigger health issue. They have a good track record of zero accidents. No loose clothing or long hair is allowed near machinery.
PUWER is un clear re guards and so I would appreciate your thoughts.

Thanks
jfw  
#2 Posted : 14 March 2012 00:50:26(UTC)
Rank: Forum user
jfw

Approx 5 years ago I joined a company with machinery that pre-dated PUWER by a couple of years and lacked guarding. Lots of rotating shafts and belts at high speeds.

Between accepting the job and starting there was a serious accident, (the weekend shift before I started), which caused an amputation. So I walked straight into a major HSE investigation on day one.

The management team thought their machinery was OK, because this was the first serious accident in 16 years, but I very quickly found out the opposite. It turned out the previous production manager had removed alot of guarding and what was left, he had removed the interlocks from as they slowed down production. Which the HSE investigation also discovered as they started interviewing people.

The outcome was a prosecution and hefty fine for a breach of Reg 11 of PUWER and 2 improvement notices (the first for "Access to the machine has not been prevented to the extent so far as is practicable", and the second for "Insufficient Risk Assessment" because the RA had not identified the part of the machine that caused the injury).

To this day I do not know how the HSE did not issue a prohibition notice, there was a significant lack of guarding in that plant. I believe the inspectors took pitty on me, as it was my first day and I was able to convince them that I could work with them to bring the level of safety up to a level that would satisfy them.

The action plan involved re-risk assessing the whole site as it quickly became apparent that none of the RA's were sufficient, which took a team of four assessors 6 months to complete and a full guarding audit, with a plan including funding to bring the plant up to standard. All of which were in the included in the requirements of the improvement notices.

I met a lot of resistance about adding new guards, but I worked with the operators, involved them in the design process and got them to accept it with reluctance. The guarding took 18 months to design and install, but because operators were involved with the guarding designers I had their buy-in. Their was slight dip in outputs initially, but they were quickly back up to the same levels.

Therefore in answer to your question, I would not be worried about OHSAS 18001. The consultant is right, get the guards in place, but design them so that they are both protecting the hazard, while not getting in the operators way and get the operators involved with the design.

There is no point looking at OHSAS 18001 until you have the basics in place. Without the basics in place you are exposing operators/technicians/engineers to hazards and if it should go wrong it will have a big impact on individuals lives and the company.

In the case I reference, the fine was small in comparison to the capital expenditure on guarding, (over £250K), the civil claim for the injured person, which to date I believe still has not been finalised, but interim payments made to date are more than double spent on guarding and not forgetting the affect the injury has had to the life of the injured person and their family.

This was a large multi-national company and the site in question employed nearly 300 people with an annual turnover of £125million. An incident like this at a smaller company could be the end of that company. I know of one profitable manufacturing company that had a fatality on unguarded machinery, which 3 months later found itself being liquidated as the prohibition notice meant they could not meet orders and therefore the cashflow dried up.

Therefore just because there is a good track record, does not necessarily mean the same for the future if you have machinery of the nature you describe.

JJ Prendergast  
#3 Posted : 14 March 2012 08:46:37(UTC)
Rank: Super forum user
JJ Prendergast

Andy Adams wrote:
Hi All

However they are reluctant to add guards as they claim they will get in the way and cause a bigger health issue. They have a good track record of zero accidents. No loose clothing or long hair is allowed near machinery.

PUWER is un clear re guards and so I would appreciate your thoughts.

The excuse 'that guards will get in the way and cause a bigger health issue', is as old as the hills and will be little or no defence in the event of an accident, where it can be shown that there is an practicable way of guarding a particular machine.

Your consultant is correct.

PUWER is pretty clear in my opinion - follow the hierarchy given in Reg 11 - so far as is practicable. You should recognise that 'practicable' has a particular meaning inthe context of machine guarding.

There are plenty of guidance books and other material available about how to guard common types of machinery. Search the HSE web site, British Standards etc. PD5304 is still available for use, to demonstrate broad principles of guarding.

JFW post is a good indicator of what can happen. Take his/her advice.
Thomo  
#4 Posted : 14 March 2012 10:54:56(UTC)
Rank: Forum user
Thomo

Hi Andy
Sounds like you have a few die hard workers.
Firstly you need management support, they want the 18001 accreditation then they have to abide by it and not question at every hurdle (Guards shouldn’t be a hurdle anyway it’s just common sense).
Secondly check with your insurance on any modifications of equipment (some have specific rules on mods). Don’t go welding a guard on you found down the local DIY shop that will get you in all sorts of trouble! In some cases replacement of the equipment has been the best solution.
The consultant should be able to give you details of guard manufactures and as JFW says work with operator’s designers and insurer’s to design a good guard that is fit for purpose and easily maintained.
If the guard is still in the way and there is no way of avoiding it then do RA on removing the guard for that job and replace after use. But make sure this has been agreed by all.
Ron Hunter  
#5 Posted : 14 March 2012 12:03:09(UTC)
Rank: Super forum user
Ron Hunter

This from L22 PUWER ACoP preamble:

"At present, not all work equipment is covered by a product Directive; nor are product Directives retrospective. However, equipment which was provided for use in the European Economic Area before compliance with the relevant product Directives was required, may need to be modified to comply immediately with regulations 11-24 of PUWER 98."

As others have said, Regulation 11 is quite clear, and you must note that the heirarchy given at Regulation 11(2) is to be applied to the extent that it is practicable. There is no "reasonably practicable" qualification there.
Andy Adams  
#6 Posted : 14 March 2012 14:16:17(UTC)
Rank: Forum user
Andy Adams

Hi All

I thought as much re guarding . I really appreciate your input and comments. Thank you all very much.
Graham Bullough  
#7 Posted : 14 March 2012 15:24:46(UTC)
Rank: Super forum user
Graham Bullough

Andy

The age of the machines/machinery involved is immaterial. If they have parts which can cause injury or worse, surely access to them should be prevented. The old British Standard 5304 (apparently written for BSI with expertise from HSE and its main predecessor HM Factory Inspectorate) and presumably its successors contain useful clear guidance with illustrations about identifying dangerous parts and preventing danger from them.

If some people oppose guards on the grounds that they would "get in the way", it's worth asking them for some detail. Perhaps they want or need to be able to see if a part, e.g. a transmission drive, is moving or not, at the correct speed, or needs lubricating or replacing, etc. If so, guards made of mesh or suitably perforated sheet metal might be appropriate to prevent danger but still allow vision and also lubrication if necessary. This might also avoid the problems liable to arise if imperforate guards are routinely removed to allow regular lubrication.

As for guards being liable to cause "a bigger health hazard", this doesn't make much sense. If you can find out what the objectors mean by this, perhaps you could share it with us on this forum.

Some machines have moving parts which look dangerous but are known and accepted as not being dangerous. One classic example is that of the (paper moving?) arms located on top of a Heidelberg printing press. When I first saw such a machine during my first few months with HSE I asked the experienced inspector with me why they weren't guarded. He said that such machines had been around for many years but had never been known to cause any injury or perhaps nothing more than a light bruise. Therefore, though the arms looked dangerous, there was some sort of general acceptance/agreement between HSE and the printing industry that no guarding was needed for them. (I should add that this scenario is mentioned here purely as a example. The agreement, possibly an informal one, which have been superceded, perhaps in the light of injuries occurring and/or changes to such machines.)
Phillips20760  
#8 Posted : 19 March 2012 17:06:12(UTC)
Rank: Forum user
Phillips20760

Agree with Graham. If you're not 100% with transcribing PUWER get a copy of BS 5304. It really is the bible - so much so that you may recognise some of the pictures in 'newer' guidance documents.....
GeoffB4  
#9 Posted : 19 March 2012 18:02:01(UTC)
Rank: Forum user
GeoffB4

Not sure if this on topic or not but here goes. I do consultancy work for a large factory. Whilst most guards are in place there was a dearth of emergency stops on some equipment. Despite objections from operatives (not managers) a number of extra emergency switches were fitted to meet the RA recommendations. Inadvertant switching and losing production was one objection.

Approximately 6 months after fitting, and whilst walking around the factory, one of the objectors came and thanked me. He'd managed to get his hand entrapped (that's another story) but also managed to immediately stop the equipment with one of the new emergency stops. No further problems with RA recommendations after that.
Graham Bullough  
#10 Posted : 19 March 2012 18:46:48(UTC)
Rank: Super forum user
Graham Bullough

GeoffB4 - Forum users shouldn't worry too much about whether their responses are sufficiently 'on topic' or not. Topic discussions tend to be more effective if they include different slants and approaches. Anyhow, I think your information was very pertinent to share. The absence of further problems after what the reformed objector told you suggests that you were able to use it in subsequent discussions with management and/or employees, perhaps without needing to mention any names. Also, if the employee's workmates and supervisor/s knew about the incident, he might well have become a new staunch ally in support of the new emergency stops.

You've probably also thought of using the incident as the basis for a short exercise during training sessions, e.g. get trainees to consider in teams what the various adverse consequences would have for the employee and others including the company if the emergency stop either hadn't existed or had been inoperative through lack of maintenance, etc. For the employee, it seems he might well have suffered a drastic and permanent physical reforming of his hand, plus all the ensuing problems and inability to do everyday tasks which tend to be taken for granted.
Doug Florence  
#11 Posted : 19 March 2012 19:24:34(UTC)
Rank: New forum user
Doug Florence

Of course the fact that the guy got his hand trapped indicates some other problem. Basically, if you need to press an emergency stop for safety rather than machine protection reasons your primary safety strategy has failed.

EN9531997 +A1:2009 Safety of machinery - Guards - General requirements for the
design and construction of fixed and movable guards is the modern guard standard replacing parts of BS5304 but depending on the aspects you are interested in you would probably need to look at some other EN standards as well. BS5304 attempted to cover everything to do with guarding machines in one standard. The text of BS5304 is still available from BSI as PD5304 and it is as near a standard gets to "a good read", but you are probably better to study the current standards.

EN 13857:2008 Safety of machinery - Safety distances to prevent hazard zones
being reached by upper and lower limbs is pretty crucial for making sure you use the correct mesh sizes and reach distances when building guards.
Users browsing this topic
Guest
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.