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.

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.

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.

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...

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.

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.

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?

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