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Oxy  
#1 Posted : 18 January 2018 16:34:28(UTC)
Rank: Forum user
Oxy

Hi,

New to the forums.Hoping someone can advise. An employee in my organisation is planning putting togeher a steel plate bender together by himself, instead of the company buying one due to cost. Obviously I have my concerns, he is a general handy man/R&D technician, and I am confident with his ability and the drawings shown that have been shown that it will function correctly (Its a fairly simple concept). The device will be clamped on each side using a vice, and a self propelled handle to bend the thin steel. Anyway, the question I am asking is if we carried out a PUWER assessment to ensure it met all applicable PUWER regulations, a risk assessment and approriate training was given could this be used? This is the first time while working here the guys have looked at the 'home-made' route. Thanks.

paulw71  
#2 Posted : 18 January 2018 16:45:51(UTC)
Rank: Super forum user
paulw71

The below link may assist.

https://www.conformance.co.uk/adirectives/doku.php?id=puwer

Ian Bell2  
#3 Posted : 19 January 2018 08:37:40(UTC)
Rank: Super forum user
Ian Bell2

It's worse than that Jim, to quote a phrase. Long gone are the days when you can knock something together in the company maintenance workshop. Your company is supplying a machine and 'placing it on the market's. It doesn't matter that it is for own use only. You can make the 'machine' but you also have to show it complies with the EU Machinery Directive/Supply of Machinery Regulations You need to identify which Essential Health and Safety Requirements and technical standards the machine complies with. Then put together a Technical File. Then Mark the machine with a 'CE' Mark. It is illegal to supply a machine otherwise. There are few exceptions, in fact if the machine falls I to a particular class, then it will need independent assessment by a Notified Body.
chris42  
#4 Posted : 19 January 2018 09:40:52(UTC)
Rank: Super forum user
chris42

Mmmm The OP suggests it is human powered!

I’m sure I was told while training that to be classed as a machine and therefore come under  “The Supply of Machinery (Safety) Regulations 2008” that it had to be powered by something other than a human or animal ( unless lifting a load). It is obviously a tool, ( So PUWER applies), but I don’t think it meets the definition of Machinery.

This was some years ago, but may be worth checking the definition and or a further comment from others on here who deal with such things more regularly than me.

Chris

thanks 1 user thanked chris42 for this useful post.
Thomo on 29/01/2018(UTC)
Ian Bell2  
#5 Posted : 19 January 2018 09:51:22(UTC)
Rank: Super forum user
Ian Bell2

There are exclusions, the latest version of the MD guidance needs to be consulted for the exact definition of a 'machine'. Agree whether human or powered comes into it, there is also a definition of a machine 'being a series of linked parts, at least one of which moves.' Could come down to interpretation of definitions whether to invoke the MD. Haven't got time to look it up now.
Bigmac1  
#6 Posted : 20 January 2018 12:32:07(UTC)
Rank: Super forum user
Bigmac1

A chain is a machine!! just to add to your woes sorry lol

chris42  
#7 Posted : 22 January 2018 09:14:24(UTC)
Rank: Super forum user
chris42

Originally Posted by: Bigmac1 Go to Quoted Post

A chain is a machine!! just to add to your woes sorry lol

Yes, but only if it is lifting a load or is powered. The same goes for “linked parts or components, at least one of which moves". As below. My bold and Underlining to aid the point. So I still do not think that a human power plate bender is a machine as defined by “The Supply of Machinery (Safety) Regulations 2008”. On my training course there was much discussion about an old fashioned manual whisk  ( with the crank handle on the side with a crown and pinion gear) is not a machine as defined.

 

Products to which Regulations apply; definition of “machinery”

4.—(1) These Regulations apply—

(a)to products in respect of which the following conditions are satisfied—

(i)that they fall within one of the descriptions of products specified in paragraph (2);

(ii)that they do not fall within any of the categories of products specified in Schedule 3 as being products to which these Regulations do not apply;

(iii)that they are placed on the market or put into service on or after 29th December 2009; and

(iv)that these Regulations are not disapplied in respect of them by regulation 5; and

(b)to partly completed machinery, as defined in regulation 6.

 

(2) The following descriptions of products are specified in this paragraph—

(a)assemblies which fall within one of the following descriptions—

(i)an assembly, fitted with or intended to be fitted with a drive system other than directly applied human or animal effort, consisting of linked parts or components, at least one of which moves, and which are joined together for a specific application;

(ii)an assembly as referred to in sub-paragraph (i), missing only the components to connect it on site or to sources of energy and motion;

(iii)an assembly as referred to in sub-paragraph (i) or (ii), ready to be installed and able to function as it stands only if mounted on a means of transport, or installed in a building or structure;

(iv)assemblies of machinery as referred to in sub-paragraphs (i), (ii) and (iii) or partly completed machinery, which, in order to achieve the same end, are arranged and controlled so that they function as an integral whole;

(v)an assembly of linked parts or components, at least one of which moves and which are joined together, intended for lifting loads and whose only power source is directly applied human effort;

thanks 2 users thanked chris42 for this useful post.
Charlie Brown on 26/01/2018(UTC), Thomo on 29/01/2018(UTC)
hilary  
#8 Posted : 22 January 2018 09:35:33(UTC)
Rank: Super forum user
hilary

I concur with Chris, I do not believe that this is a machine as described by the Supply of Machinery Safety Regulations.  We were purchasing a cradle that the component was fitted into and then rotated by handle and this did not fall under CE marking until we decided to add a motor to make it easier.  Then it became a major headache!

Ian Bell2  
#9 Posted : 22 January 2018 10:57:55(UTC)
Rank: Super forum user
Ian Bell2

That's fair enough. I couldn't remember the full definition of a machine for MD purposes or had time to look it up again, last week.
paul.skyrme  
#10 Posted : 25 January 2018 19:26:18(UTC)
Rank: Super forum user
paul.skyrme

It's not a machine unless it is powered by something other than human effort.

So by the sound of it the sheet bender is not a machine, mind I've seen them on the market, and I bet that it will cost more to make than buy!

matelot1965  
#11 Posted : 26 January 2018 00:03:45(UTC)
Rank: Forum user
matelot1965

Some other legislation you may want to look at is the employer liability (defective equipment) act 1969 if things went a little pear-shaped the employer maybe liable for providing defective equipment
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