Rank: Forum user
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Good morning everyone, My company manufactures fork arms for fork lift trucks and we have several large CNC milling machines on site. Until recently our machines have been able to cope with the size and complexity of the forks we manufacture however times have changed and we are now beginning to manufacture larger forks that we cannot place into our milling machines because they are so large. My company wants to bypass the interlocks on the machine guards so that the fork can actually be placed into the machine to be milled. There is no other way to manufacture these forks and we cannot replace the machinery as the cost would be too great, we cannot turn down the work as again this would have a massive effect on our business. We have risked assessed this activity and drawn up draft method statements and safe systems of work and my company has decided that the risk is manageable. They have based their decision on the facts that the guards will be open no more than 200mm, the cutting tool is set back about 2 metres away from the guards so there will be ample space between the operator and the dangerous part of the machine and they have considered the training and experience of the operatives. Even though we have risk assessed the backside out of this I am still conscious that we are bypassing safety mechanisms and I have made my own thoughts quite clear to our MD. Your thoughts please.
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Rank: Super forum user
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I used to work for a company that made parts for oil rigs and shipping companies, who also did the same. I was not involved in H&S or even had any knowledge at the time of H&S, but the company had installed fixed fencing around the machines to prevent anyone gaining access to the areas where the unlock guards would be, but this guard was at the sides of the machine. not sure how your machines are set up.
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Rank: Forum user
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Our machines do not have perimter fencing around them, but we have considered this in the risk assessment. Unfortunately there will not be enough room to install fixed fencing around this particular machine but we will be installing barriers to restrict access to the whole department.
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Rank: Super forum user
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In my view for anyone to comment on this would first require them to visit the site to see the situation at first hand. I would suggest you ask a suitably qualified person from your local IOSH branch ifu3Y6 they would be prepared to visit your site to look at what you are proposing and let you have their thoughts.
Chris
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Rank: Super forum user
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One thing I would say is that interlocks are never 100% effective. Therefore, bypassing them does not create a change from a totally safe situation to a totally dangerous one.
What do you think can be done to make the risks tolerable? It is not helpful to simply say something is dangerous. Our role has to be to say how an activity done safely. I suspect you will want quite a few additional procedural controls. Clearly these are lower of the hierarchy of risk control. But as I say above, just remeber that interlocks are not as effective as you may think.
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Rank: Super forum user
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How old are the milling machines? Are they CE marked under the Machinery Directive.
There is nothing fundamentally illegal about what you are proposing. However I think it will invalidate the machine manufacturers CE Mark.
If the machines are CE marked you will now have to show how the modified machine will comply with the Machinery Directive Essential Health and Safety Requirements.
What standards you are using to show EHSR compliance - Type A, B, C.
You will have to show that the milling machine specification is satisfactory for the new work that you want it to do.
You will also have to supply/amend the Technical File required by the Machinery Directive.
The Machinery Directive is I corporates into UK law by the Supply of Machinery regulations.
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Rank: Super forum user
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Hmmm, this is an interesting one, and I don't envy you. Whilst taking the point previously made that interlocks may not always be 100% effective in making a job safe, they ARE nevertheless there for a reason, and the reason being that they're a safety factor. If you remove them, your default position therefore has to be that nobody is placed in greater danger than they were when the interlocks were operative. If you can't do this - and an accident was to result - I think you'd have a Devil of a job convincing the authorities that what you'd done was reasonable...
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Rank: Super forum user
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More to the points made by elfindavy which are perfectly reasonable, particularly in relation to interlocks, which are after all an admission that to get the job done some reduction in safety is required-I believe it would be the MD, quite rightly, who would have a devil of a job to convince the authorities.
Who took on the contract knowing full well that the equipment/resources/skills in use is inadequate for the job?
Now where in 30 plus years have I heard that before -risk taking with other peoples' lives for profit?
The reasons given by the OP are really not acceptable, if understandable, and I can see he/she is very uncomfortable with the situation .
A resigning issue?
regards
Mike
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Rank: Forum user
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I would be seeking assistance from the machine manufacturer in the first instance for something like this because as previously stated if something somehow went wrong you can have as many RAMs as you want and you will still be in a tight spot.
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Rank: Super forum user
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I agree with Mike K - it's a reduction in safety IF you don't re-engineer/redesign your machining process and machine. A machine capability assessment is required.
You have a 'management of change situation to manage. Quite a common procedure in the process industries.
As previous, if CE marking applies, show how your change to the machine complies with the Machinery Directive.
If not contact the machine supplier for advice, if a machine redesign is possible/practical. I will pay odds that they will say no.
If CE etc doesn't apply, you still need to demonstrate that your proposal meets PUWER regulation 11 guarding hierarchy in particular, 'so far as is practicable. Note this is a higher standard than 'reasonably practicable.
Don't give a typical safety response 'you can't do that'....You can in theory, just do the job properly!!
It might be too expensive and or impractical at the end of the day but h&s law does not stop you changing the function/purpose/capability of a machine within its engineering/technical limits.
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Rank: Forum user
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Thank you all for your responses. I have again spoken to my MD and we both agree that bypassing the interlocks is not the way forward and plans are in place to engineer a solution to this. A warts and all conversation helped senior management realise my guidance was the most practical and moral solution and of course the slightest hint of a disregard of duty of care. Sometimes we, as safety professionals just have to persevere and fight the good fight.
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1 user thanked pm1965 for this useful post.
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Rank: Forum user
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Well done for sticking with it and getting the Management team to understand the risks.
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Rank: Forum user
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Difficult to respond without seeing and comprehending fully what steps have been taken.
However, one question for the MD. Is this a temporary or permanent arrangement?
If temporary and safeguards are adequate, it may be argued that the precautions taken are acceptable in the short term?
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Rank: Forum user
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Hi,
As others have said, without seeing the application/task its very difficult to answer. Have you thought of other alternatives like light curtains, pressure pads etc to replace the interlock sensors?
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Rank: Forum user
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I know that this appears to be resolved but as a matter of interest the HSL has actually done some interesting research on this: http://www.hse.gov.uk/research/rrpdf/rr974.pdf
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Rank: Super forum user
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Originally Posted by: johnwatt I know that this appears to be resolved but as a matter of interest the HSL has actually done some interesting research on this: http://www.hse.gov.uk/research/rrpdf/rr974.pdf
Thanks for the link From a very quick glance it appears to put the blame for defeating the interlocks onto the operative, not the company for taking on board work without thinking of their actual capability.
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