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Guru  
#1 Posted : 05 August 2014 14:45:15(UTC)
Rank: Super forum user
Guru

Hi all,

I'm well aware of EN ISO 14119 and in particular, Section 7 which mentions (amongst other things) that machines shall be designed in such a way that it minimizes the motivation for defeating the interlocking devices etc.

My question is, if an interlocking device on a door is secured to the body of the equipment via a number of standard screws, would this be seen as enough to meet the requirements?

2 view points to consider. If secured via a number of screws, then it would take a conscious effort on someone's part to disable the component. The viewpoint here is, although the component has been by-passed, it was only achieved by using a tool and effort.

The second viewpoint, is that a screwdriver is such an easily accessible tool, that any interlocking device secured via screws would be viewed as easily by-passable in the first instance anyway.

I have my own views, but I'm keen to hear other opinions?

Thanks.
simplesafety  
#2 Posted : 05 August 2014 15:18:26(UTC)
Rank: Forum user
simplesafety

I supose it depends if a screwdriver is a tool that is available to the operator using the machine -
i.e do they use screwdrivers in that area as part of their job (readily available) or will they need to go fetch one from an engineer to overide the interlock?

You could always use hex screws or another odd shaped head to deter this action even further.

But to give my opinion, using just screws is cutting it a bit fine, even if screwdrivers are not readily available in the area - I'd choose another type of fixing, just to further reduce any potential possibility / liability.

If a member of staff did overide an interlock with a tool from his work bench, your defences may be limited, as under the PUWER regs the liability to prevent access is absolute (PUWER 11.1 Every employer shall ensure....)
Animax01  
#3 Posted : 05 August 2014 15:39:58(UTC)
Rank: Super forum user
Animax01

How about using a different type of screw, such as a torx or a star drive?

These aren't so readily available, and you could argue that the effort required would be somewhat more concerted. Especially if you do not make such tools available in the work place, say only the engineers had access to.

Pete
Safety Smurf  
#4 Posted : 05 August 2014 15:49:08(UTC)
Rank: Super forum user
Safety Smurf

I would expect it more likely they would tape over the switch than try to remove it.
Swygart25604  
#5 Posted : 05 August 2014 16:12:31(UTC)
Rank: Forum user
Swygart25604

Star drive fixings, as per Animax01. Then the operator would need a very concerted effort to find the tool needed to defeat the guard or interlock, meaning gross misconduct & dismissal.

In certain industries, there is a Japanese phrase, which is "poke yoke", meaning "idiot proof". What we are talking about here is the next level of idiot.....

There are also a number of different types of switch....not just the ones you tape over. Light curtains, magnetic switches, etc etc all need affixing to machinery in some way or other.
chris42  
#6 Posted : 06 August 2014 09:17:55(UTC)
Rank: Super forum user
chris42

I'm sure this subject was discussed on my diploma course and that the outcome was that the fixings should not be easily removed using normal easily accessible everyday tooling.

Problem is I have a small cheap tool set in the back of my car that has a screw driver with interchangeable bits (which includes torque and hex type bits). Extract From the HSE report below indicates people may be assisted by their managers or perhaps instructed by same to overcome such devices ( and gather necessary tools at back of desk to do so). Those who have been in engineering will now what I mean ( they were once the maintenance guy etc). There are special fixings which are one way or have snap off heads, so the only way to remove would be grind or drill, as these devices should not normally need to be removed once fitted.


From HSE report RR974 dated 2013

Common activities associated with defeating were setting, proving, swarf removal and deburring . Semi-CNC machines were identified as being commonly defeated in the sample used in this research. Managers and operatives/supervisors perceived this practice to be the ‘norm’.


Chris
kevkel  
#7 Posted : 06 August 2014 11:00:25(UTC)
Rank: Super forum user
kevkel

Nuts and Bolts my friends. Requires two tools to remove. But as safety smurf said its more likely they will tape over or jamb a matchstick into the interlock to defeat it. Depends on type of course!
A Kurdziel  
#8 Posted : 06 August 2014 12:13:25(UTC)
Rank: Super forum user
A Kurdziel

Sometimes you need guarding for the routine stuff but need to be able to acess for maintenance (by designated, competent staff) What do you do then?
chris42  
#9 Posted : 06 August 2014 13:13:15(UTC)
Rank: Super forum user
chris42

I thought this was about interlocking devices, not guarding as a whole. Therefore I would hope the equipment has been designed to allow for fixtures for work holding etc to be changed without having to dismantle the machine.

For maintenance again having to dismantle the device from the door etc should not be necessary. As once the door is open the machine is either safe or additional isolation is also required.

Interesting web site on subject (see section under implications for fixings) :-

http://www.machinebuilding.net/ta/t0178.htm

Chris

edwill7  
#10 Posted : 07 August 2014 11:53:51(UTC)
Rank: Forum user
edwill7

You need to tghoroughly consider why somebody would want to defeat the interlock.
Does the are need regular cleaning; resetting; unjambing etc. I spent 17 years in the aggregate industry and employees were extremely innovative in creating tools they could use with guards in place to remove spillage (dust, stones). The business incorrectly made the guards bigger, stronger and heavier to both contain the spillage and stop access.
The secret is to remove the need to bypass the guarding on a regular basis.
JohnW  
#11 Posted : 07 August 2014 16:14:20(UTC)
Rank: Super forum user
JohnW

My main customer has an engineering dept with a vertical milling machine. Following an Improvement Notice (thread a couple of months ago) they fitted a proprietary moveable guard which has an interlock fitted - so if the guard is moved or swung open the power is cut off. HSE inspector approved the guard, notice closed off.

The guard is useable for most jobs but they have a job planned where the product will need supporting by a jig and this means they can't close the guard.

Can the interlock be disabled and the job conducted via a Permit To Work and an engineer supervisor present?

John
edwill7  
#12 Posted : 13 August 2014 11:52:53(UTC)
Rank: Forum user
edwill7

JohnW wrote:
My main customer has an engineering dept with a vertical milling machine. Following an Improvement Notice (thread a couple of months ago) they fitted a proprietary moveable guard which has an interlock fitted - so if the guard is moved or swung open the power is cut off. HSE inspector approved the guard, notice closed off.

The guard is useable for most jobs but they have a job planned where the product will need supporting by a jig and this means they can't close the guard.

Can the interlock be disabled and the job conducted via a Permit To Work and an engineer supervisor present?

John


I would risk assessed the operation with the gaurd removed. Include the control measures in the permit to work. Have the engineer sign off the PTW once the gaurd is re-instated. It is better to allow the operation to happen in a controlled manner than to find out that it was done off the radar or out of hours.
JohnW  
#13 Posted : 13 August 2014 15:56:05(UTC)
Rank: Super forum user
JohnW

Thanks Ed, that was my line of thinking.

The engineers may have a way to make the height of the guard adjustable which will solve some jigging problems.

P.S. although the guard was 'approved' by the inspector and the IP removed, the guard (a proprietary off the shelf unit) doesn't protect 360deg from flying bits due to tool breakage.
It does avoid entanglement which was a greater risk.

John
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