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samf  
#1 Posted : 09 August 2019 11:10:48(UTC)
Rank: Forum user
samf

Hello all

We have two podium steps that are permanently erected to disconnect tubing from our extraction system into the trailers they are connected to. The approx platform height is about 2m. 

I have some questions about WAH regs and what we need to do:

As it has a guard rail and a locking gate, do we need to consider there is a fall risk? If so, what measures can we iplement to reduce this?

Evacuation plan - they are used very minimally - do we need to have a way to rescue an unconcious casualty from the platfrom if that were to occur?

CptBeaky  
#2 Posted : 09 August 2019 12:14:31(UTC)
Rank: Forum user
CptBeaky

"Do we need to consider there is a fall risk" - yes

"What measures can we implement to reduce this" - "It has a guard rail and a locking gate" ... Also you may consider a kick board if there is a risk of someone being struck by a falling object and have signage and a safe system of work indicating that the locking gate must be used properly/

"do we need to have a way to rescue an unconcious casualty from the platfrom if that were to occur" - Yes. You may already have this, just assess how easy it is for someone to get access using the steps themself.  Obviously the higher the likelihood of someone getting into trouble the easier the access should be. For example is there access to any chemical, gases etc. up there that may cause dizziness. If so you may need better access. It come down to your risk assessment.

It seems by your short description you already have the controls covered. You now should document them, train personnel in the proper procedures and review it when necessary.

That being said I am sure there are more qualified people than myself to answer this. However I am sure we will also want to discuss whether there is a safe way to deal with the tubing from ground level. Eliminating the risk is always the first step after all.

paul.skyrme  
#3 Posted : 09 August 2019 13:28:54(UTC)
Rank: Super forum user
paul.skyrme

Stricly speaking these platforms are for access to maintain the extraction system, which comes under the Supply of Machinery Safety Regulations, thus, they need to comply with the requirements of this.

The recognised manner is for the means of access to comply with the ISO 14122 series of standards.

The LEV should never have been supplied without compliant access plat forms as they are for regular and routine maintenance access and thus they must be covered by the CE marking of the system.

samf  
#4 Posted : 09 August 2019 13:35:32(UTC)
Rank: Forum user
samf

Originally Posted by: paul.skyrme Go to Quoted Post

Stricly speaking these platforms are for access to maintain the extraction system, which comes under the Supply of Machinery Safety Regulations, thus, they need to comply with the requirements of this.

The recognised manner is for the means of access to comply with the ISO 14122 series of standards.

The LEV should never have been supplied without compliant access plat forms as they are for regular and routine maintenance access and thus they must be covered by the CE marking of the system.

Thanks for the additional info. 

We have added these podium steps, it is not part of the LEV in that sense. Does this still mean it comes under the regulations you have mentioned or WAH regs?

paul.skyrme  
#5 Posted : 09 August 2019 14:00:41(UTC)
Rank: Super forum user
paul.skyrme

Why did you have to provide the steps, the LEV supplier should have supplied a fixed platform to allow this maintenance work to be undertaken.

It is stil WAH, but, the requirement to provide access for maintenance which this is, is down to the equipment OEM for compliance with the SMSR.

Roundtuit  
#6 Posted : 09 August 2019 14:04:35(UTC)
Rank: Super forum user
Roundtuit

Go on - whats in the trailers and why are they connected to the LEV?

paul.skyrme  
#7 Posted : 09 August 2019 14:18:04(UTC)
Rank: Super forum user
paul.skyrme

I'd hazard that it's wood waste, as this is a very common means of the disposal of wood waste, by ducting the system straight to an articulated trailer, this then goes for re-processing into perhaps chipboard or other stuff (hopefully).

The haulier goes to site with an empty and swaps over to the full and hauls it away, a bit like swapping skips, or sometimes there are two trailer bays so they can be swapped over with the system in use via a change over valve in the discharge.

samf  
#8 Posted : 09 August 2019 15:50:12(UTC)
Rank: Forum user
samf

Originally Posted by: paul.skyrme Go to Quoted Post

I'd hazard that it's wood waste, as this is a very common means of the disposal of wood waste, by ducting the system straight to an articulated trailer, this then goes for re-processing into perhaps chipboard or other stuff (hopefully).

The haulier goes to site with an empty and swaps over to the full and hauls it away, a bit like swapping skips, or sometimes there are two trailer bays so they can be swapped over with the system in use via a change over valve in the discharge.

Bang on! 

Roundtuit  
#9 Posted : 09 August 2019 21:26:49(UTC)
Rank: Super forum user
Roundtuit

I had the suspicion so now follow by asking why the system was not adequately designed in the first place

paul.skyrme  
#10 Posted : 09 August 2019 21:55:13(UTC)
Rank: Super forum user
paul.skyrme

Originally Posted by: Roundtuit Go to Quoted Post

I had the suspicion so now follow by asking why the system was not adequately designed in the first place

Agreed.

Then I could be horrible and ask why the deficiency wasn't picked up under the end user PUWER assessment especially that required by Reg 10, which should have highlighted the lack of maintenance platform as that would be required for CE marking and compliance with community requirements.

Stricly speaking the way the legislation is worded, under a PUWER asssessment Reg 10 requires an MD EHSR audit of the equipment, and this would have shown this up.

samf  
#11 Posted : 12 August 2019 07:06:08(UTC)
Rank: Forum user
samf

Originally Posted by: paul.skyrme Go to Quoted Post
Originally Posted by: Roundtuit Go to Quoted Post

I had the suspicion so now follow by asking why the system was not adequately designed in the first place

Agreed.

Then I could be horrible and ask why the deficiency wasn't picked up under the end user PUWER assessment especially that required by Reg 10, which should have highlighted the lack of maintenance platform as that would be required for CE marking and compliance with community requirements.

Stricly speaking the way the legislation is worded, under a PUWER asssessment Reg 10 requires an MD EHSR audit of the equipment, and this would have shown this up.

I do not know why the LEV installers did not provide access to the trailers. However, we are where we are now!

Getting back on track - what do you need in terms of a rescue plan for steps such as these? What would you do with unconcious casualty on the platform, for example?

paul.skyrme  
#12 Posted : 12 August 2019 12:14:19(UTC)
Rank: Super forum user
paul.skyrme

I would say that the podium steps are not suitable to be honest for the job that you are asking them to do.

samf  
#13 Posted : 12 August 2019 12:21:31(UTC)
Rank: Forum user
samf

Originally Posted by: paul.skyrme Go to Quoted Post

I would say that the podium steps are not suitable to be honest for the job that you are asking them to do.

Why? And what would you recommend?
paul.skyrme  
#14 Posted : 12 August 2019 14:48:16(UTC)
Rank: Super forum user
paul.skyrme

Podium steps are lightweight mobile equipment, for flexible inermittent use.

The requirement under PUWER is that access should be suitable, so I would be questiining the poduim steps under Reg 4, Reg 10, Reg 20, & Reg 22.

Going back to Reg 10, I would then be looking to EHSR's 1.1.2, 1.1.6, & 1.6.2.

I think that looking at these a light duty podium steps would not be considered suitable and sufficient.

I also think that I can prove that the LEV supplier is in breach of SMSR by not meeting the EHSR's.  This is not unusual because they concentrate on COSHH, and ignore their obligations under SMSR, even though:

"PART 5 Regulation 4(2)(c) Annex V: Indicative list of safety components...

6. Extraction systems for machinery emissions..."

Is specifically included in the SMSR.

You need to be looking at fixed platforms & steps/stairs/ladders which conform to the ISO 14122 series as required.

​​​​​​​
samf  
#15 Posted : 13 August 2019 08:21:36(UTC)
Rank: Forum user
samf

Hi Paul

Thank you - I have only picked this up recently, and this is really helpful. I am going to ask the LEV company why this was not supplied, as they designed the system to feed into the trailers. 

I really appreciate your help.

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