Rank: New forum user
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Hi, I am looking for information on the use of interlock bypass keys being used to bypass interlocks in order to debug machines. Engineers and Techs thing it is ok when used by experienced engineer or tech as they need machine powered up. Dead man switch reduced pressure by 50% but causes a different issue making it not feasible. I am very uncomfortable about this as it goes against corporate rules etc and also would be impossible to control across various shifts and experience levels. Would appreciate some advice on this issue from anyone with experience in the area. Many Thanks Emma
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Rank: Super forum user
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What you are describing is a deliberate act defeating an item applied in the interests of Health & Safety in direct contravention of HASAW Act / regulations and likely to be a disciplinary offence under most contracts of employment (possibly even Gross Misconduct with summary dismissal).
That said in a previous employment (which spanned the introduction of the Moving Machinery Directive) I was involved in the manufacture, bench test and commissioning of equipment that had interlock control systems as integral features for normal designed operation - here our activities were documented as a mini Risk Assessment detailing the purpose and why there was deemed to be no "safer" method to conduct the required task including the use of by-pass switches as part of the systems test. Given the potential danger to those with less experience / lower competence each activity required the work area and equipment to be cordoned off and signage at the control system before the task commenced. Over time we eventually managed to identify simple design changes to eliminate a number of our exceptional activities e.g. adding an external communications port so that we did not have to work in a live electrical panel to programme logic controllers.
More recent employments have seen newer equipment that deliberately has "Test Engineer" programmes built in to their control systems - these allow maintenance practices by disabling the standard operational cycle, or requiring a manual trigger to initiate each step rather than fully automated - eliminating some risks but then presenting fresh ones.
In all cases tasks were conducted by trained competent staff on equipment segregated from the general work population in accordance with documented company approved procedures.
Your post seems to indicate corporate rules are blanket (exclude maintenance considerations?) with your Engineers / Technicians as day workers leaving tasks for afternoon / night shift completion and the term "debug" actually describing fault diagnosis activity without Risk Assessment on production equipment already in service and available to the wider work population. What you seem to be missing are agreed practices designated by the company and followed by the employees.
IMHO you need Human Resources, Operations and Maintenance to review the on-going Near-Miss / Dangerous Occurrences at site against current company documents such as contracts of employment, training plans, operating procedures etc.
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Rank: Super forum user
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What you are describing is a deliberate act defeating an item applied in the interests of Health & Safety in direct contravention of HASAW Act / regulations and likely to be a disciplinary offence under most contracts of employment (possibly even Gross Misconduct with summary dismissal).
That said in a previous employment (which spanned the introduction of the Moving Machinery Directive) I was involved in the manufacture, bench test and commissioning of equipment that had interlock control systems as integral features for normal designed operation - here our activities were documented as a mini Risk Assessment detailing the purpose and why there was deemed to be no "safer" method to conduct the required task including the use of by-pass switches as part of the systems test. Given the potential danger to those with less experience / lower competence each activity required the work area and equipment to be cordoned off and signage at the control system before the task commenced. Over time we eventually managed to identify simple design changes to eliminate a number of our exceptional activities e.g. adding an external communications port so that we did not have to work in a live electrical panel to programme logic controllers.
More recent employments have seen newer equipment that deliberately has "Test Engineer" programmes built in to their control systems - these allow maintenance practices by disabling the standard operational cycle, or requiring a manual trigger to initiate each step rather than fully automated - eliminating some risks but then presenting fresh ones.
In all cases tasks were conducted by trained competent staff on equipment segregated from the general work population in accordance with documented company approved procedures.
Your post seems to indicate corporate rules are blanket (exclude maintenance considerations?) with your Engineers / Technicians as day workers leaving tasks for afternoon / night shift completion and the term "debug" actually describing fault diagnosis activity without Risk Assessment on production equipment already in service and available to the wider work population. What you seem to be missing are agreed practices designated by the company and followed by the employees.
IMHO you need Human Resources, Operations and Maintenance to review the on-going Near-Miss / Dangerous Occurrences at site against current company documents such as contracts of employment, training plans, operating procedures etc.
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Rank: New forum user
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Hi, Thanks for your reply. It is really restricted to particular fault diagnosis on a certain type of purpose built equipment as opposed to maintenance activities and by experienced people - I feel there needs to be an engineering solution to prevent this happening but am meeting a lot of resistance. I need to do a deeper analysis around this issue. Thanks for your helpful input. Emma
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Rank: Forum user
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Emma, I know Paul Skyrme is busy (really busy) but as soon as he sees this I'm sure he will help you.
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Rank: Super forum user
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Emma, The short answer is yes it is acceptable.
Also, no it is not acceptable.
The more detailed answer, is that it depends on the machinery, and a lot of other factors. Who is purpose building the machinery? I would expect it is CE marked, so how to the manufacturers instructions advise that the work is undertaken?
More details and information required.
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