Rank: Forum user
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Thought I'd ask the experts out there for your opinions.
Had a BSI audit yesterday, and received an NCR for not monitoring trigger times for vibration.
This was for joiners on a constriction site, using hand tools. (saws, drills etc.)
We have assessments, with trigger times, and they are briefed, but he was still not happy, as we do not know if they exceed the levels for the day.
How do you guys manage this?
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Rank: Super forum user
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Record trigger times
or measure using a HAV meter...
It depends on risk assessment - if I was miles from any action levels I would just record as such, if I was approaching action I would measure and record to prove levels, if I was close to limit I would record very very carefully.
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Rank: Super forum user
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Initially we monitored tool use for an average day which showed use was within acceptable levels, but instruction to employees and managers if there is unusual activity to not use each tool for more than "x" time.
We eventually went to an electronic devise that the employee took from a base station logged to them and they took it from tool to tool ( just like a count down timer).
The HSE were happy with option one with the training/ instruction I provided. They were more than happy with option 2 ( expensive)
Chris
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Rank: Super forum user
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If you already have the vibration assessments for your tools, you could carry out a periodic assessment of what a "typical" day's work looks like, obviously with the employees' cooperation. Check that this is within limits and show it to anyone auditing you. Not every company can justify the cost of expensive monitoring. We use Reactec but it's only ever in use for a tiny fraction of our workforce.
Whoever's in charge of your joiners on site should also have the info on the tools and understand how to keep the joiners under 400 points or whatever limit you select.
Good luck
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Rank: Forum user
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Thanks for the comments.
Was planning to record the times for a joiner for a typical day/week, see if we're close to the limits, then go from there.
Can't justify monitoring devices, too expensive, although one for the monitoring might be the way forward.
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Rank: Super forum user
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Always a thorny issue, where a proportionate approach might be sensible.
Your Risk Assessment should be clear how the initial exposure (trigger) times came about.
The Auditor will look for evidence that the R/A assumptions remain valid - usually via some robust review and validation process - much as you propose.
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Rank: Forum user
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I might be going off at a tangent here but I think your auditor may be groing further than auditing what you do and into telling you how to run your business. You may be abel to reject that NCR assuming you are happy with your methods.
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Rank: Forum user
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That's an interesting point David.
When does auditing become interfering?
His NCR was for not having a risk assessment in place, which I suppose is correct. We had assessed each item, and briefed the guys, but did not have an assessment which addressed the various tools together, and totalling the exposures.
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Rank: Super forum user
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I wonder what the auditor means by monitoring? While you are required to carry out an assessment which will of course require you to consider both vibration levels (either through measurement or manufacturers or database derived data) and the exposure/trigger time, I do not believe that there is a requirement for on-going (daily or day to day) monitoring. There is of course to review the assessment periodically.
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Rank: Super forum user
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Rank: Super forum user
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Ask your auditor to show you where in INDG175 (3rd edition) HSE advice is that all trigger times should be recorded? He/she is using an outdated approach - it's possibly right when first beginning to gather data, but often 'over the top' if exposures are actually quite low.
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