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StefanMilkov  
#1 Posted : 06 April 2016 14:09:07(UTC)
Rank: New forum user
StefanMilkov

Hello, Me and my colleagues are trying to "convince" a machinery supplier that in order to achieve "not easy to defeat" fixed guards or interlocks, the tool required to fix/remove the guards must be "special", not an ordinary spanner, etc. The problem is that in every piece of legislation that I have read like PUWER, Machinery Directive 2006, ISO 14120, ISO 14119, etc. it is mentioned just tool or tools, but not special. If anyone has more information or advise, please share with me. Thank you in advance.
Ian Bell2  
#2 Posted : 06 April 2016 14:22:07(UTC)
Rank: Super forum user
Ian Bell2

I would agree with that in principle. I think it says that in BS PD5304
StefanMilkov  
#3 Posted : 06 April 2016 14:41:08(UTC)
Rank: New forum user
StefanMilkov

Thank you, but I can not find BS PD5304. Can you be more specific. Thank you.
Alan Haynes  
#4 Posted : 06 April 2016 14:46:41(UTC)
Rank: Super forum user
Alan Haynes

I think he means BS5304 Question - If you are buying the machine from the supplier- why are you not just specifying what you want?
chris42  
#5 Posted : 06 April 2016 14:53:15(UTC)
Rank: Super forum user
chris42

No I think he does mean PD5304 availible from BSI. It changed from a BS to PD.
safetydude1  
#6 Posted : 06 April 2016 15:13:50(UTC)
Rank: Forum user
safetydude1

The Supply of Machinery (Safety) Regulations 2008 Schedule 2 Part 1 principles of safety integration -(e) "Machinery must be supplied with all the special equipment and accessories essential to enable it to be adjusted, maintained and used safely"....Best I can find.
Ian Bell2  
#7 Posted : 06 April 2016 16:02:48(UTC)
Rank: Super forum user
Ian Bell2

Correct the BS book on machinery safety is now PD5304 Just Google, it comes up easy enough. It was a British Standard but got down graded a few years ago.
JohnW  
#8 Posted : 06 April 2016 17:01:19(UTC)
Rank: Super forum user
JohnW

Stefan, If your employer is in court they are expected to have followed approved codes of practice, PUWER ACoP L22. So you can point your machinery supplier to what the ACoP expects. With regard to PUWER Reg 11 the ACoP says things like:
Quote:
Guards and protection devices must be designed and installed so that they cannot be easily bypassed or disabled. This refers to accidental or deliberate action that removes the protection offered .... guards must be suitable for their purpose, and one consequence of this is that simple mechanical bypassing or disabling should not be possible ....movable panels in guards giving access to dangerous parts or movable guards themselves will often need to be fitted with an interlocking device. This device must be designed and installed so that it is difficult or impossible to bypass or defeat.
JohnW
Ian Bell2  
#9 Posted : 06 April 2016 17:06:58(UTC)
Rank: Super forum user
Ian Bell2

Just include the requirement into the specification/contract for the supply of the machine.
walker  
#10 Posted : 07 April 2016 09:42:00(UTC)
Rank: Super forum user
walker

I think you are going about this from the wrong direction The idea of tool removable means "not removable with your fingers" (my definition). Therefore the "removee" made an additional conscious decision to obtain a tool and remove the guard or whatever. If you feel you need special tools to defeat such people then it's your company management, discipline and supervision that is questionable. I'd put my efforts into safety culture improvements if I were you.
imponderabilius  
#11 Posted : 07 April 2016 12:23:47(UTC)
Rank: Forum user
imponderabilius

walker, couldn't agree more. If I ware to secure guards to every drill/grinder/etc. with "special" tools, most of my work would boil down to looking for suppliers of special screws and dedicated screwdrivers ;)
StefanMilkov  
#12 Posted : 07 April 2016 14:29:42(UTC)
Rank: New forum user
StefanMilkov

Thank you all. It was helpful. Many thanks.
paul.skyrme  
#13 Posted : 07 April 2016 18:09:33(UTC)
Rank: Super forum user
paul.skyrme

I have managed to defeat every safety interlock & device that I have ever needed to. I doubt very much that a safety interlock exists commercially that I can't defeat. The "tool" thing is a bit, of a red herring. A coin is not a tool. A Torx key, is a tool A tamper proof Torx key is a more secure tool. Now if you are in an office environment where you have a machine used by users who are not "engineeringly" skilled, then simple hex head screws, slotted, pozi & philips would defeat their attempts to remove them at a basic level. If you are in engineering, say an automotive manufacturing plant, they will have almost all kinds of driver bit on site, they will probably use a lot of them on their production lines. So, how far do you go, you can get bespoke fasteners made which have unique heads, and, you can patent the tool to remove them. Great, now the interlock is securely fixed. I bet I can still remove it & defeat it. Your next issue, is as safetydude1 has said, you have to provide any special tools with the machine. So if you affix the interlocks with patented fasteners, you have to provide the tool to remove the fasteners with the machine, & make if commercially available. Unless you can PROVE that it is not safe for ANYONE to remove the fastener, good luck with that. You just need to apply common sense, and good sound engineering practice, then ensure that you have good procedures in place to reinforce this. If anyone wants to take me up on the defeating interlocks challenge, then I’ll do it for free if I can’t, if I can, then you have to pay up in full. (As per all the best adverts, terms & conditions apply!) ;)
Ian Bell2  
#14 Posted : 07 April 2016 18:35:25(UTC)
Rank: Super forum user
Ian Bell2

Rather a pointless perspective in my view. As engineers, I guess we all know given the resources and time safety guards/devices can be defeated/removed etc. I think we mean the ordinary sense of the word/requirement - not easily defeatable/removable by hand/manual effort that can reasonably be foreseen.
Roundtuit  
#15 Posted : 07 April 2016 20:37:07(UTC)
Rank: Super forum user
Roundtuit

Locked doors only keep out the honest man. Even patented specialist interlock key systems can be over ridden is someone has acquired duplicates - been there to see it and by good grace no fatality or injury resulting from such poor/illegal practice.
Roundtuit  
#16 Posted : 07 April 2016 20:37:07(UTC)
Rank: Super forum user
Roundtuit

Locked doors only keep out the honest man. Even patented specialist interlock key systems can be over ridden is someone has acquired duplicates - been there to see it and by good grace no fatality or injury resulting from such poor/illegal practice.
paul.skyrme  
#17 Posted : 07 April 2016 20:50:40(UTC)
Rank: Super forum user
paul.skyrme

Roundtuit Not necessarily illegal, it depends on why the interlocks are being defeated. I wrote another missive in response to Ian's post, but once again this site ate it and threw an error, and I couldn't be bothered to re-do it because IOSH can't sort their software out. So it's gone into the ether never to be recovered. It's about time this site was sorted properly.
imponderabilius  
#18 Posted : 12 April 2016 12:28:11(UTC)
Rank: Forum user
imponderabilius

Well, I can't really see a problem here - if someone's interfering with things provided for safety, they are in breach of HSAWA and can be disciplined for that. You provide guards on machinery but also employ competent people who should understand the importance of using those guards. If they do not understand it and they remove guards, it proves they are not competent and in breach of HSAWA. Note on file, note on file, dismissal. You get rid of one, the others will stop the practice.
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