Rank: Forum user
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Hello Everyone,
I work for an engineering company, last week we were inspected by the HSE and have been issued an improvement notice for the lack of guarding on our 4 (very old) manual milling machines. I am very new to the world of engineering, eventhough I am learning fast my knowledge is of course limited so I am hoping that I can draw on your experience.
Having explained the situation to our manual millers their first reaction is 'we can't do our job if the machines are guarded' which I was expecting. So my issue now is to find a guard that protects as well as one the millers can work with. Does anyone have any suggestions or experiences of guarding that works. I have found some on the internet but wondered if anyone had introduced them successfully?
Many Thanks
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Rank: Super forum user
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Oooh. Harsh. We always used to turn a blind eye to them as they are notoriously difficult to effectively guard and still be usable. Same with old manual lathes.
If you're new to engineering then you need to get hold of HSG 129. H&S in Engineering Workshops. Free to download from the HSE website www.hse.gov.uk
Variety of options. What we used to call fish tank guarding seems to be the simplest. Not saying it's either effective or very usable though. Sorry.
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Rank: Super forum user
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Having worked in the machine tool industry for some years there are some types of machinery that is just impossible to guard and still operate. I challenged on HSE inspector to suggest how you guard a manual metal spinning machine. After some cogitation and discussion he agreed that it simply could not be done. I have yet to see anyone come up with a workable guard for a manual wood spinning lathe.
My reaction would be to go back to the HSE inspector and ask, since you are insisting we guard these machines, can you please suggest how we might do this. It is unreasonable, in my view, simply to insist that you do the impossible without being able to suggest a solution.
Chris
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Rank: Super forum user
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Its maybe harsh of the HSE, but you should follow Reg 11 of the Provision and Use of Work Equipment Regulations.
The old chestnut about a machine being impossible to operate if guarded won't cut any ice, if it can be shown that it is 'practicable' to so guard the dangerous parts of a machine.
In the case of a milling machine guards can be purchased.
There are machines that need access to dangerous parts eg bench grinders, where some of the wheel has to be exposed to use the machine.
Again this is satisfactory as one the hierachy steps in Reg 11 is to provided instruction and training in the use of machines, provided the other steps in the guading hierachy has been followed to the extent practicable beforehand.
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Rank: Super forum user
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But Reg 11 has to be taken with a pinch of salt for many machines. Milling machines being one of them. That's why I never enforced on them (on the say so of other more experienced inspectors who were training me at the time). That's why I think it's harsh of them, though obviously well within their rights to enforce. So it's either inexperience on the part of the inspector, an over-zealous inspector, or a sign of the FFI times.
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Rank: Super forum user
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When the HSE prosecute for breaches of PUWER and in particular the duty to guard dangerous parts of machinery their lawyers have more than a smattering memory of the HoL decision in the case below:-
Summers (John) & Sons Ltd Ltd v Frost (1955) 1 ALL ER 870
The House of Lords decided that the duty was absolute, that the employers were liable and that it did not matter that the consequences of securely fencing the machine in accordance with statutory obligation would be to render it commercially unusable.
Of course the action was brought under the Factories Act 1937; however the decision is still regarded as good law when argued in the correct context.
If you care to PM me I will provide you with details of a good machine guarding outfit that can and will assist you to full compliance without breaking the budget.
Hope this helps.
Jon
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Rank: Super forum user
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Angela
Are these horizontal or vertical milling machines or both?
If horizontal, specific regulations made in 1928, but revoked by PUWER.
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Rank: Forum user
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Thanks everyone for your advice.......its proving quite a toughy to solve.
The machines in question are vertical milling machines. We the HSE Inspector came round we did try to argue the point but she was very insistant that there were no excuses anymore to not guard these machines. Unfortunately she couldnt offer any suggestions on the type of guarding we could use.
Currently going through HSG 129 with a fine tooth comb!!
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Rank: Forum user
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Angela you have a PM.
Reagrds,
Paul.
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Rank: Super forum user
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ClaireL
When you say that you "turned a blind eye" to enforcement when a breach occurred am I correct in my assumption that in the event of a serious injury following a breach of PUWER (Reg.11) the HSE would not commence proceedings. This appears to be somewhat odd and I would welcome knowledge of the rationale for such inaction.
Failure to do so would/could also impact on any civil action an injured party might take.
Breaches of PUWER is fertile territory for the HSE now.
Jon
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Rank: Super forum user
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Hi Angela
You could fit an adjustable guard similar to that on a vertical drill or provide a telescopic trip device with DC injection braking.
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Rank: Forum user
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Peter, thank you I will suggest this
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Rank: Super forum user
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John M wrote:ClaireL
When you say that you "turned a blind eye" to enforcement when a breach occurred am I correct in my assumption that in the event of a serious injury following a breach of PUWER (Reg.11) the HSE would not commence proceedings. This appears to be somewhat odd and I would welcome knowledge of the rationale for such inaction.
Failure to do so would/could also impact on any civil action an injured party might take.
Breaches of PUWER is fertile territory for the HSE now.
Jon
There are some items of equipment that modern standards of guarding are difficult to achieve on old machines. Inspectors (used to) use discretion. I used to use discretion on guarding of SOME machines. Nothing was ever put in writing but it wasn't actually enforced. I never enforced on pillar drill guarding either. If there was an accident the book would have been thrown at them (but I never investigated an accident on a milling machine or pillar drill - that's not to say they never happen). But hey, I didn't say life was fair.
Times have changed though.They seem to enforce everything nowadays. A money making exercise that has little do do with safety.
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Rank: Super forum user
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ClaireL
Thank you for this nugget.
PUWER is an area of safety regulation that I have spent a great deal of time and effort exploring and producing solutions. All so often I hear from turners, borers, toolmakers fitters etc that they cannot work efficiently if guarding is in place. More often than not this is incorrect - it was never a fundamental part of their apprenticeship and old tricks tend to die hard. Some just cannot be bothered to fix portable guarding for the job in hand.
Many moons ago in a shipyard in Korea I saw a young lad spinning on a borer attached to his workpiece- fortunately he was not too badly injured.
Mills can be tricky to guard - but doing nothing is not an option.
Jon
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Rank: Forum user
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I am saddened at some of the responses to this question.
Since when did this forum become a mouthpiece for the "it can't be done" and lets "turn a blind eye" to a serious health and safety problem.
Yes a serious problem. People still get entangled in these machines or lose eyes from flying debris.
We are now in the second decade of the 21st century, and can't resolve a legal problem that was made quite clear 80 years ago with the Factories Act.
#3 gives an example of something that is "impossible to guard". Maybe. But that is not an excuse not to guard or attempt to guard thousands of others that could, and should be guarded.
#4 is quite correct, guards can be provided. Magnetic stands with either open mesh or plastic screens have been available for more than 40 years.
#6 quite rightly raises the Factories Act of 1937 and the associated Case Law that used to be the bread and butter of the old NEBOSH law modules. (Have these sort of things stopped being taught?)
#10 well said. In the event of any accident or injury I doubt that any of the "can't be done" merchants will spring forward to your assistance and say " I said it was all right not to bother about guarding because it was difficult!"
#14 well said. We should all be about producing solutions.
In situations as described in the original question I have always mad the following statement:
"It is nearly fifty years since the Americans put a man on the moon (unless you believe the conspiracy theories) and you are saying you cant solve this simple problem?"
How would the Americans have dealt with the Apollo 13 disaster if they had taken the view that this is difficult so perhaps we shouldn't bother?
To paraphrase the words of Gene Kranz: "doing nothing is not an option".
It certainly shouldn't be for any safety professional who wishes to hold their head up high in the workplace.
Rodger Ker
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Rank: Super forum user
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I am one of the ones who think the Americans did not put a man on the moon. But that's another story.
Yes, of course most things are achievable......if you have enough money. But the reality is that most small business do not have endless amounts of money. If they did they would by new CNC milling machines. Retrofitting guards on old machines can result in a compromise too far. Experience and training can count for a lot. That is certainly what has to happen in woodworking for example. Also there are plenty of industries where the Regs are often not workable - agriculture is one. Perhaps you would be surprised to know that agricultural machinery (such as combines) can be opened whilst operational, allowing access to dangerous rotating parts. Not saying that it's right (in fact I think the industry should change) but even the regulators accept that as the state of play.
I think what give H&S a bad reputation is blindly waving the regs about insisting that everything is achieved to a gold standard. That doesn't mean ignoring H&S standards it means careful application.
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Rank: Forum user
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I am always surprised that when the "it can't be done" strategy has failed, the fall back cry is "we don't have endless amounts of money" and "blindly waving regulations and requiring a gold standard".
Forty five years ago, (before the Americans either did or didn't put a man on the moon) as an engineering apprentice working in a large machine shop, long before guarding was commonplace, the magnetic bases with wire mesh or perspex attached as guards were commonplace and in regular use.
They were, then, and still now, inexpensive, versatile and cost effective.
Rodger Ker
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Rank: Super forum user
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One of my customers had an inspector in last week, improvement notice issued, so we now have this issue to solve in 8 (now 7) weeks.
In their risk assessments I have always recommended guarding the machine so that a hand cannot make contact with moving parts. They have not acted upon that recommendation but have provided the operators with small perspex shields on magnets that can be moved around but are not a complete protection.
The inspector has said the Perspex shields are not sufficient, a complete enclosing guard is needed, and he has made his demand more difficult to comply with by insisting any guard be interlocked (the machine has various powered parts).
The company is considering appealing against the improvement notice, but I recall the inspector saying milling machines and PUWER were a matter on which that HSE could not be swayed, so I don't think an appeal will be successful.
The engineers think the machine won't be usable for a variety of jobs they use it for.
Any advice would be welcome.
JohnW
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Rank: Super forum user
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I have just had a customer visited by HSE, I'm not their H&S advisor.
They are an engineering company, they were told to guard their 3 old manual milling machines too.
The comment from the inspector went along the lines of, as long as I see it on there, I'll be happy, what the operators do later I don't want to know about.
He admitted the machines would be impossible to use, but he had to see the guards there.
They can be guarded, it is very difficult and expensive for what is achieved, and interlocking is a LOT more, as to incorporate interlocking, and be in FULL compliance with HSE guidance on PUWER98, you could end up having to totally redesign the control system on the machine, that then in itself would then have to contain safety related parts, and so it goes on...
I can recommend a supplier of guards I have been dealing with for years, & offer some guidance myself if you want, please PM.
I actually have a manual milling machine myself, it's a Bridgeport Turret Mill.
Is it guarded?...
It's behind a locked door, so it is safe, no one can get at it! ;)
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Rank: Super forum user
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Would a light guard give you more flexibility ?
but still the issue of interlocking it sorry.
Ah the good old days of my apprenticeship, with small crescent shape marks on my arms from the swarf. However now I know why we had to have short sleeve overalls.
Chris
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Rank: Super forum user
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some great comments here
my thoughts are these;
in gereral terms UK employers have not invested in new kit as times have changed and thats one reason why we are no longer a leading manufacturing nation - its as simple as that -- having worked throught Europe and had the chance to measure one culture against another that is my conclusion so we should invest when times are good so as we can keep going in times of bad - poor investment is why we have such old kit around that is hard to guard etc.
NB: these same employers who have no money to invest on manufacturing kit have plenty to spend on new cars etc!
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Rank: Super forum user
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Bob Y - I agree entirely.
Back to the issue:
I've been hearing the same whine (we can't do the job with guards in place) from machinists for at least 25 years!
Yes you can, but it needs expert advice not cheap lash ups
And yes its has to be interlocked otherwise it will not be used
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