How does the SSOW apply if you disable guards? Explain that one to the HSE!!!!!!!!!! SBH

edwill7 is correct with good advice. Unfortunately, it's rare to find anything either on the HSE web, or within the guidance which states anything "can't be done". This is quite right given the variation of activities conducted across industries, it would be difficult to provide specific guidance or rules for all eventualities. What almost all regulatory guidance does outline however, is a hierarchy of control should be applied when controlling risk. . Does the machine absolutely have to be running, or is this a short cut? . If so, carry out a risk assessment and record control measures, for example, permits to work, training, cordon off area, lock away & sign in sign out override keys etc . Minimise the amount of time this activity is conducted. If you can show a process has been followed, and control measures have been applied, then firstly you are unlikely to have an incident, secondly, if one does occur you will be able to demonstrate this, and have a system to review to prevent a reoccurrence. Hope this helps

Hi Boro, How is your relationship with the HSE? As an ex inspector myself I would recommend contacting him/her for an authoritative judgement. You might be worried by this but I would expect the inspector to be helpful. I would have been! Alternatively your relationship may be coloured by less than stellar performance and you might want to file my so called assistance in your WPB [waste paper bin] This sort of problem arose all the time I was an inspector and it's always better to discuss the issue first rather than investigate a serious/fatal trapping/crushing accident

In the good old days pre PUWER the FA1961 had a set of regulations setting out how maintenance could be done with moving machinery. It included Training, competence, inching capability, clothing requirements etc. PUWER expects all things necessary to be done to make the work safe. Essentially you will need a specific RA and associated safe system of work for individual tasks. Machine speed and inching coupled to some guarding will be the best start

Health and Safety law does not prohibit high risk work and is instead concerned with the manner in which work is carried out. Even in PUWER we can work through the hierarchy of controls to arrive at the 'soft' controls. However, the point is that they are arrived at after proper consideration of the work to be done and the hazards and risks involved and not because it just seemed easy to do it that way. I have supported 'live' working with a 'Safe System of Work' in place where I considered it was justified and that the 'Safe System of Work' was in fact a SSoW etc. I have declined to support it where I did not think it was justified or where there was no 'SSoW'. Regards.

I'm pretty sure this is already prescribesbin puwer regs(reg 14 or 15). I think also around para 244 in the PUWER AcoP