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Additional Guarding Installed - how to document and manage?
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pmace  
#1 Posted : 11 April 2014 22:30:38(UTC)
Rank: Forum user
pmace
Hello there, I'm looking for some advice or shared experiences for what I'm hoping is an issue others may have managed in the past. I work for a contractor who perform installation of mechanical and electrical equipment all over the EU. I operate in the UK and Ireland. It has inadvertently come to my attention that sometimes in our area we add extra items of guarding to some installations of machinery and equipment. For example where there may be small areas of electrical buzz bar partially exposed. I feel we should be additionally documenting this as part of a design risk assessment process. As we did not initially design and manufacture the equipment but we could be considered a designer by the installation of the extra guarding. Machinery safety is not my forte at all. Could anyone outline the proper approach to this issue? I'm being told by those involved in the one issue I've described above that it's no big deal. But in the event of a failure or other issue of the materials we've added I feel we could be legally liable or exposed. Could someone point me in the right direction or share how this might be appropriately and simply controlled? Thanks in advance. PMACE
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JohnW  
#2 Posted : 12 April 2014 13:19:33(UTC)
Rank: Super forum user
JohnW
Hello pmace, When I'm dealing with a client's equipment I conduct what is in effect a PUWER assessment, when the equipment is received and review/update the assessment whenever we make changes to controls, guarding, training, procedures etc. In a PUWER assessment you can list a series of questions associated with each section of the PUWER regs and the sequence of these questions follows the regs as they are described in the ACoP L22. So for the Regs 4, 5, 6, 7 these are questions about location, condition, maintenance and ergonomics. For regs 8 & 9 ask questions about training. For regs 11 & 12 identify the dangerous parts and ask the question: Have effective and suitable measures been taken to prevent contact with the dangerous parts of the machinery? This may be the area of concern that you mention above. Regs 13-18 ask questions about controls/switches isolation etc etc. Regs 23 & 24 ask about markings, warnings etc etc. And then do a risk evaluation much like you might do on a risk assessment document. Keep a history of the PUWER documents so that you can justify any changes you make to a machine or the operating procedures. JohnW
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paul.skyrme  
#3 Posted : 12 April 2014 23:08:33(UTC)
Rank: Super forum user
paul.skyrme
I have to ask, why is this "additional" requirement even in existence? IF this is new equipment and it is CE marked then it should not require any modifications to meet ANY requirements. IF it does, then it is not suitable, or, your company is commissioning it in an unsuitable way. In which case, you need to be taking responsibility for CE marking the unit.
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JohnW  
#4 Posted : 13 April 2014 10:18:36(UTC)
Rank: Super forum user
JohnW
paul.skyrme, Just because a machine is new and CE marked doesn't mean you can't put your hand into it and have it crushed. My main client has just bought a brand new Wegoma welder and we are thinking to put some additional protection on it. It has a light beam so the traverse movement doesn't knock you over if you were to stand inside (which you have to). But there is nothing to stop you putting your hand in the clamps which you might do if someone else presses the button.... and for some big pieces it does need two persons to operate, one to hold the piece and one to press the button........ http://www.wegoma.de/ind...d-horizontal-wsa-4h.html JohnW
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paul.skyrme  
#5 Posted : 13 April 2014 17:05:36(UTC)
Rank: Super forum user
paul.skyrme
So JohnW, What you are saying is that in effect, it is OK for these companies to sell equipment that does not meet the requirements of the relevant safety standards? If the machine is designed and built in accordance with the relevant standards, and is the correct equipment for the task, then it should not need any further works. Now if you start modifying CE marked equipment, then how are you going to proceed? You have immediately invalidated the CE mark.
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JohnW  
#6 Posted : 13 April 2014 23:37:46(UTC)
Rank: Super forum user
JohnW
Paul, I didn't say it was OK. We want to make the machine safer than what our German colleagues made. If one lad is positioning a PVC kerb against a clamp and another lad is pressing the button, if we can put in a safeguard then we will. The Wegoma is still being 'commissioned' so there may be scope to involve the supplier in safeguarding it. If you look at the link it's the same machine (the clamps are at the far end) we have already built a 'cage' round three sides - as I say, an operator has to 'enter' the machine, on the fourth side. JohnW
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paul.skyrme  
#7 Posted : 14 April 2014 07:00:17(UTC)
Rank: Super forum user
paul.skyrme
Surely work "holding" equipment would be safer? I know the Wegoma machines, unfortunately. I don't rate them highly on many counts. I am also familiar with the way that they are used.
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