Hi all. I work for a large trust and we have several schools with design tech using circular saws, band saws etc. What i want to know is, are my technicians who are trained for use and teaching of these items deemed suitably trained for P.U.W.E.R assessments of each item. I have also soursec a company that will train my maintenance team on the use, inspection and service of this equipment. A consultant has said that we should also have them serviced by an external company.

Any one come accross this? any advice?

Malc

Hello Malc,

Now this depends on your definition of technicians IMHO.

It seems that you are employed by a local authority or education authority?

The technicians are these, classroom technicians, or are they machinery maintenance technicians?

There is a world of difference.

The following is IMHO obviously, but, and I must be careful with regard to forum rules, it is a big part of what I do, and I’ve just gained my CMSE® qualification with TUV-Nord.

To be competent to undertake PUWER assessments, one must have a good understanding of the requirements of PUWER, and the engineering requirements of these.

Along with a good knowledge of the standards that underpin the requirements of the PUWER regulations.

Also, a good knowledge of the machinery directive requirements to assess under Reg. 10.

The assessor also needs to have a god understanding of machinery, it’s operation and maintenance.

There is a difference between undertaking a PUWER assessment and maintaining / servicing the machinery.

They are closely linked, but to do both the individual needs enhanced competencies in both spheres.

External servicing, I would recommend, but never too forcefully, as has been described, if the technicians are maintenance technicians competent in mechanical and electrical maintenance of the machinery, and fully familiar with the maintenance requirements of the equipment and you have robust maintenance procedures in place, user checks in house maintenance checks, by competent individuals then fine, if you have any doubt’s just get them done by an independent, but, make sure they are competent. I’ve seen a few who are well known in the industry who have provided a sub-standard service, both of what would be expected commercially and falling short of statute law competence too.

Woodworking machinery is not Annexe IV in the machinery directive for the sake of it, there is a VERY good reason for it, and, thus it needs an above average person to be inspecting and maintaining it, with a very good understanding of the safety requirements.

Even down for example to the differing stop times required which is a simple one, if anyone knows?...

Thanks all for the advice. They are school tech guys and a bit miffed about me asking this - hey ho - as they belive they are compentent as they "know" the equipment, but as you point out, do they know the PUWER regs relating to this? "A machine user often knows their machines so well they pick up faults sooner.  The fact that we have so many elderly machines still working efficiently and safely speaks volumes for the work of past and present technicians"  - this comment makes me wonder a: are the to old and should be replaced? b: would an external company be familier wirth them?

I will see further info from a comnpany offering training to see what they would cover, in particular PUWER understanding. Thanks

Just offering my advice of PUWER assessments. I have conducted PUWER assessments for many years. Very useful before doing actual risk assessments.

A written PUWER assessment should cover these topics:

Equipment (Regs 4, 5, 6, 7) suitability, maintenance, ergonomics

Training (Regs 8, 9)

Dangerous Parts of Machinery, Unsafe Condition (Regs 11, 12) - moving parts, dangerous parts, ejected material including dust, exhaust fumes, unsafe condition e.g. excessive vibration, excessive noise, any disabled device. Also identify additional hazards that may be present when cleaning, repairing, clearing blockages, changing tools, changing filters and other maintenance. Need for guards, LEV etc etc

Temperature (Reg 13)

Controls and Control Systems (Regs 14, 15, 16, 17, 18) are ALL the controls clearly visible, marked, identifiable and unambiguous? e.g. ON switch, OFF switch, Emergency stop, Up, Down, Left, Right etc

Isolation from energy source (Reg 19)

Stability (Reg 20)

Lighting (Reg 21)

Maintenance (Reg 22)

Markings (Reg 23) e.g. ON/OFF switches colour-coded, PPE mandatory signs

Warnings (Reg 24) e.g. for hot surface, moving parts etc

Mobile, self-propelled and robotic machines (Regs 25-30)

Conformity with EC Community requirements (powered equipment) (Reg 10)

Also there may be Specific Site Conditions to consider and specific Guidance and other issues to consider.

Is a record kept of accidents and near misses.

John W            

Regarding PUWER it covers machinary used by an employee, we have just bought a machine which is two machines that work and interact together via a conveyor belt, is this one or two puwer assessments? 

All well and good Paul, and I don't disagree with the gist of your post. My point is more about the terminology. Some seem to refer to a checklist (which without appropriate application is no more than a tick-list) as constituting a compliance check, when we know that assessing compliance against the Regs. needs significant and often industry-specific knowledge, training and experience.

I'm generally wary of un- or ill-defined terms being bandied about (this being a case in point) which can (and often do) mean many different things to different people.

To quote the Regulation 4 ACoP:

"There is no specific regulation requiring a risk assessment in PUWER. Instead the requirement to carry out a risk assessment is contained in the Management Regulations, which have general provisions relating to the safety of work equipment."

Various companies advertising on the web would have us believe otherwise, and the web is awash with PUWER assessment templates and all sorts to trap the unwary. 

Oh for a spill chucker! ;)

I think, Ron, that we fundementally agree, that there is, a requirement for an assessment, but, it isn't just a tick box exercise.

Whilst a checklist is a valuable aide memoir, and I use one when doing assessments, to make notes against the specific regulations where there is non-compliance, and then back this up with photo's again as an aide to my memory for when I do the final report and assessment, it does often require the use of a tape measure, and very often requires the customer, i.e. end user to undertake further works or analysis, we merely identify areas where their equipment is definitely non-compliant, and then do them a subsequent RA against how dangerous we feel the non-compliance is, very often I find myself cross referencing perhaps a dozen EN standards to verify the equipment does or does not comply, and TBH, most of the work is of an Engineering nature.

We very often see poorly implemented "safety updates" which have been ill thought out, and require complete re-engineering, or modifications to control systems to install safety circuits implementing safety functions which have no basis in EN 13849-1 & no verification under EN 13849-2, or emergency stops added to equipment which don't comply to EN 13850.

The issue being is that there is nothing else to base the mods on, except current state-of-the-art.

HSE guidance in the ACoP even directs the reader that way IMHO.