Rank: Forum user 
|
The safe distance stated with machine guarding is equal or more than 850mm. This is the distance from your shoulder to the point of contact of live machinery. Where i am working this safe distance applies with the machine guarding but if you really wanted to, you could technically (willfully) get within this safe distance by reaching in with your shoulder and there is a possibility you could come into contact with live machinery. If this was to happen, would you (the company) be protected or could you be liable? Personally I feel you would because you haven't put extra control measures in to protect against everything (even someone willfully perdorming this act). If anyone could provide me advice on this it would be much appreciated. Thanks
|
|
|
|
|
|
Rank: Super forum user
|
Aaron, I have this disciussion with many customers. My stance is that in this situation the employer has not prevented access to dangerous moving machinery; the regulations require this. Just because you have a sign saying 'do not approach with 850mm of the moving machinery' is not sufficient protection. Just because you have said so in a toolbox talk is not enough. If anyone deliberately enters that zone - then your training was not effective - that's what a judge in court would say I suspect. And of course there is the chance that someone will trip over a cable or something and fall into the danger zone and get caught up in the machine.
Look at the PUWER regs and comply.
John
|
|
|
|
|
|
Rank: Super forum user 
|
Check out BS EN ISO 13857 for details of safe distances etc this will give you giuidance on distances and heights of guards etc. As John says SSOW are not reliable lines of defence etc when the basic guideline may not have been met?
|
|
|
|
|
|
Rank: Forum user
|
John, That is exactly my feelings towards this to, if you can eradicate the risk then why shouldn't you. Thank you for your feedback. I will take this up with my client and go from there. Aaron
|
|
|
|
|
|
Rank: Super forum user 
|
Usual caveat applies as it is always difficult to paint a full picture in words via OP text.
We can't meaningfully discuss the issue without applying the practicability test. Additional barriers, isolation, permit to access, may help control. If I can reach past a guard, is it actually doing its job?
|
|
|
|
|
|
Rank: Super forum user 
|
No because the regulations state that you have to consider 'normal and abnormal use'. This could extend to some bypassing the safety measures and if you know they can be then it is up to you to do something about it.
|
|
|
|
|
|
Rank: Super forum user
|
You need to read and understand Reg 11 Dangerous parts of PUWER. Also understand the term 'practicable' when applied to machine guarding. Basically what is technically possible, rather than the lower standard 'reasonably practicable'
Reg 11 has a hierarchy of guarding which should be followed to the extent 'practicable'.
|
|
|
|
|
|
Rank: Super forum user 
|
The whole idea of safe guarding is just that it seperates people and dangerous parts of machinery so thay they remain safe. Reach distance is only part of this. As an end user there is PUWER, but the OEM must comply with the Machinery Directive, and thus if this is a machine which is less than 20 years old, then there should be no reason that dangerous parts can be accessed when in use.
|
|
|
|
|
|
Rank: Forum user
|
In this case, all they would have to do is extend the guarding by length because there is space to do that, so it is technally possible to increase the reach distance so there should be no reason why this can't be done. Thank you for all your feedback, much appreciated.
|
|
|
|
|
|
Rank: Forum user
|
I do not understand this, as you could willfully put your hand under a drill guard and contact the chuck/tool, do this mean the drill is non-compliant with PUWER 11?
|
|
|
|
|
|
Rank: Forum user
|
"I do not understand this, as you could willfully put your hand under a drill guard and contact the chuck/tool, do this mean the drill is non-compliant with PUWER 11?" Think I just killed it.... Would be interesting to hear peoples thoughts...
|
|
|
|
|
|
Rank: Forum user
|
The drillis an example where there is a hazard, yes, but it is possible to show that for it to fulfil its function the more desirable actions of (a) designing out the hazard or (b) safeguarding the hazard are not practicable.
I'm not claiming this is right, but it is clearly the route the drill manufacturers take.
|
|
|
|
|
|
Rank: Forum user
|
Good point well raised Mebo. I think your logical approach is probably the stance that would be taken, however, potentially you could fully safeguard the hazard to prevent contact, it would just make the job more awkward. It is an interesting concept, am I correct in thinking that this is an absolute duty (PUWER11) i.e. to protect from hazardous parts of machinary etc. - It is a similar debaucle to the E-stops on pedestal grinders and older drills issue!!!!!
|
|
|
|
|
|
Rank: Forum user
|
The same arguement goes for a bench grinder, if you guard it to prevent access to the dangerous part i.e. the wheel, then you couldn't use it. So the guarding has to be "practicable", same as abench saw, so you then have to consider 'reasonably practicable'.
|
|
|
|
|
|
Rank: Super forum user
|
Can we stop this nonsense about access to the working zone of cutting machines when they are hand fed/hand operated. If you want to exclude acess to the cutting point of a pillar drill completely, then one also has to prevent access to any other device or implement, which is manually "operated" that can be used to cause injury. Just a few that spring to mind, pistol drills, angle grinders, knives, forks, spoons, glass, pens, pencils, staples, I can smash a pane of glass with a brick and use the sharp pieces to stab myself, so I need to sue the people who made the glass! SERIOUSLY, come on, please.
|
|
|
|
|
|
Rank: Super forum user
|
the duty to guard dangerous machinery goes back a fair way... One of the key cases was Summers and Sons V Frost - look it up. Decided under the Factories Act '37, but the same absolute duty to prevent access to dangerous parts.... Their lordships decided the law effectively banned the use of abrasive wheels because if you could use the wheel you could put your hand into it... As a result of which, we got the abrasive wheels Regs, the Woodworking Machine Regs, the Power Press Regs and etc.... Never got round to metalworking machines, although I dont know why... Then we got HSWA, with absolute dutiues removed as old statutes repealed... Which kind of made sense... Until we got the PUWE Regs...... Which tried to reintroduce absolute duty to prevent access to dangerous parts of machinery (a knife is not 'machinery')... Except that these Regs were subordinate to HSWA, so have to be interpreted read in terms what is practicable (I think....) Any advance on "what is practicable"? If someone can stick their shoulder into a gap that is positioned to keep people at "arms length" and reach the dangerous parts then the gap is too wide. If the gap has to be that wide - then it needs to be set further from the dangerous parts... Simples?.
|
 2 users thanked Steve e ashton for this useful post.
|
|
|
|
Rank: Super forum user
|
Originally Posted by: jamesangus47  Good point well raised Mebo. I think your logical approach is probably the stance that would be taken, however, potentially you could fully safeguard the hazard to prevent contact, it would just make the job more awkward. It is an interesting concept, am I correct in thinking that this is an absolute duty (PUWER11) i.e. to protect from hazardous parts of machinary etc. - It is a similar debaucle to the E-stops on pedestal grinders and older drills issue!!!!!
It wouldn't make the job more awkward, you just fit a telescopic guard that encases the drill and chuck. The only time you would then have contact with drill or chuck is when you are changing the drill.
|
1 user thanked Invictus for this useful post.
|
|
|
|
Rank: Forum user
|
Originally Posted by: Invictus Originally Posted by: jamesangus47 Good point well raised Mebo. I think your logical approach is probably the stance that would be taken, however, potentially you could fully safeguard the hazard to prevent contact, it would just make the job more awkward. It is an interesting concept, am I correct in thinking that this is an absolute duty (PUWER11) i.e. to protect from hazardous parts of machinary etc. - It is a similar debaucle to the E-stops on pedestal grinders and older drills issue!!!!!
It wouldn't make the job more awkward, you just fit a telescopic guard that encases the drill and chuck. The only time you would then have contact with drill or chuck is when you are changing the drill.
Thats the route I was going down.... you can fuolly safeguard the equipment however it makes the job 'more awkward' - awkward or safe? what would be RP?
|
|
|
|
|
|
Rank: Forum user
|
We went off the original subject a bit there as i was talking about safe distances with moving machinery (gantry grippers and conveyors) not power tools. My feeling is still the same and the company would still be liable unless they had gone as far as reasonably practicable.
In respect to the drills etc, i feel that as long as the guarding is adequate to the point it doesnt make the use of the drill awkward, then the supplier has done as much as they can to protect you. Then you would follow down training route and make sure the people using the drill are qualified and are aware of the potential hazards.You have gone as far as reasonably practicable.
|
|
|
|
|
|
Rank: Super forum user
|
For fixed machinery and large integrated production lines, likely there is a C type standard that the machinery must comply with, then after that there are the requirements of the B type standards. So, the reach distances and gaps will be fully defined there depending on the equipment, the hazards, the height of the guarding and the potential injury. There is no one size fits all.
|
|
|
|
|
|
Rank: Super forum user
|
|
|
|
|
|
|
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.