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#1 Posted : 05 December 2003 21:47:00(UTC)
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Posted By Stuart Nagle I had the opportunity to take the HSE to task recently on the subject of vibration. Specifically the provision of information to end users of vibrating tools and equipment. HSE stated that it expects employers to carry out testing for vibration given out by vibrating tools they employ in all cases, and (inherently) meet the costs of doing so. This however could mean 1 tool employed by 600 companies X 600 lots of testing X 600 lots of expense - a lot of resources tied up here!! Why should employers do this I asked? I referred the HSE to a scenario, thus; If I produced a product that had information supplied that was, essentially known to be incorrect and it was liable to cause injury or disability to end users, as it bore little relation to actual field use of the goods, could I expect to be prosecuted by HSE when such injury or disability arose? There was a marked quietness come over the room at this suggestion!! - and a marked absence of response - so what do you think? My augument is this; Under the HSAW Act 74, suppliers of things for use at work are required to examine and test as necessary to ensure SFARP that their products are safe to use in the workplace (i.e. they will not harm persons using them). I argue that if the information supplied by manufacturers of vibrating tools (lab test results) are known to be unrealistic and unreliable (including by HSE as well who have recently put such into print), and in most cases bear little relation to actual field data/test results, then where does the problem lay and who is responsible for the provision of information on the product that is suitable and suffcient - the end user!! This duty must surely lay with the equipment and/or tool manufacturer (i.e. to test and examine properly) and to supply suitable and sufficient information to end users of the product, thus to enable a reasonable assessment to be made by end users (employers or self employed) without the need to waste their resources on further testing and examination to avoid possible prosecution by HSE!! Whilst it could be argued that risk assessment should encompass this, I disagree and would state, are employers expected to test other tools supplied for use at work in this manner - no they are not. They are required to assess the residual risks. Surely then, if a vibrating tool in use gives a much higher level of vibration in use in the field than is stated by a manufacturers lab tests (and this is known to be a factor) - simply because the manufacturers test methods are inappropriate, should the manufacturer be required to do actual field testing and product reasonable test results and supply that information to the end users- I believe they should. Not only would this appear to be a legal duty of manufacturers under health and safety legislation (HSAW Act 74) but the costs of doing so would be a far better use of resources than expecting employers each to produce the results for them!! here endeth the moan and other opinions on the matter would be of interest....
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#2 Posted : 06 December 2003 01:21:00(UTC)
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Posted By John Murgatroyd I think you'll find that most employers agree with you. So much so that they already pay little attention to H&S acts until a visit is imminent. They employ safety consultants to advise them what they can get away with.....sorry, to advise them the minimum that is needed. You may have better luck if you can get the insurers to specify who does what, since the employers pay much more attention to them than to the HSE.
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#3 Posted : 06 December 2003 18:48:00(UTC)
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Posted By Merv Newman It would seem that we need an independant confirmation of suppliers data. And I think this would also apply to CE markings. "Which" does a good job on "domestic" articles, can we persuade them to have a look at industrial equipment, or is this something for BSI ? It could be argued that we need a BSI "vibration" standard
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#4 Posted : 06 December 2003 22:03:00(UTC)
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Posted By Stuart Nagle John. Sorry but I must agree to disagree with you on this one. Most employers (and I am not one) make the effort - sometimes a great deal of effort - to comply with H&S requirements, and in my experience it is more often than not employees who cause problems by failing to comply with the employers/legal requirements. Unfortunately, when something does go wrong it is usually the employer who gets it in the neck in the courts..... I am please to see changes taking place whereby an employer can seek redress against remiss employees for failing to carry out their legal duties whilst in the workplace and it is heartening actually to see that HSE have actually prosecuted employees recently. It is all too easy to lay the blame at an employers feet, and although I am well aware that there are still many who have the attitude you state of 'what can I get away with', they are in an ever increasing minority....
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#5 Posted : 08 December 2003 08:11:00(UTC)
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Posted By Jack Stuart, I agree with the general thrust of your argument and certainly I think suppliers should be expected to provide a great deal more information. But, however good their testing/information it could not possibly take account all circumstances of end use. Environmental factors seem to make an normous diffence to vibration levels. Horticultural machines for example vary with subtle changes in soil type. Then there is maintenance. Whilst manufacturers could provide a lot more information covering different environmental conditions and the effects of use on the machines vibration levels, it is still the vibration being experienced by the operator using the machine in it's actual state of repair and in the specific environmental conditions in which it is being operated. So, I can't see how employers can avoid any monitoring although I accept improved information from suppliers could ease the employers burden. Perhaps much improved information from suppliers could be coupled with a national data base of employers test results taken when machines were in use might be a way forward. (Although I think some monitoring would still be required by employers). Publishing information in this way might concentrate suppliers minds in designing in reduced vibration.
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#6 Posted : 11 December 2003 14:09:00(UTC)
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Posted By Benedict Thierry Check out the National Noise and Vibration Centre. Re - similar thing - different regulation - COSHH - Manufacturer MSDS apply to product only - yet - where manufacturer's instructions on product label include combining the product with a carrier (not water) that has its own MSDS - when mixed according to manuf. instructions you have a solution with a possible significantly greater potential to harm than the two individual products on thier own. - Who supplies the MSDS for the mixed product - the manufacturer - when asked said no - the regs say yes - the HSE say - logically it should be the manufacturer - but if not available or won't supply then there are two other ways to prepare MSDS for mixed solution - both of which incur costs to the emloyer and your choice may be restricted to one if you do not have a competent chemist on your payroll. Benedict
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#7 Posted : 16 December 2003 16:38:00(UTC)
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Posted By ian mcnally The trouble with this forum is you end up getting so interested in a subject that you just have to make a comment. Mine is to do with some of the smaller air picks or chisels that produce very high levels of vibration making it almost impossible to comply with the 2.8m/s 2 without a chain of people employed to carry out the task. Don’t get me wrong, I am the first to try and encourage the employers to do their bit and I fully take on board the points raised about manufactures responsibilities. I have recently heard of a company that carried out the same approach to controlling and monitoring vibration levels as we do and felt this was a practical approach ….well so I thought!! I was surprised when told that enforcement action may be taken on the company despite; getting the equipment (CP9) with the lowest available emissions, it still only allowed 25min per day. The company trained the workforce to identify the hazards, rotated and monitored to check for any signs of HAV / VWF. It openly admitted exposures of up to 70mins over the day although no signs were noted by an independent OH company or complaints received. HSG 170 does refer to a similar product, a chipping hammer and suggests that the solution is to limit exposure to 20mins per day. Is it really practical to suggest that construction sites across the country will be able to comply with this. Even after designing out hazards with engineering and other controls many tasks will still require a significant use of such equipment. Test equipment is available to test on 3 axis but this will probably only confirm what we already know! If someone knows of such equipment with longer exposure times let me know I'll consider buying shares. All the time there are so many tasks which cannot be carried out another way ( with current technology) shouldn’t greater focus be placed on the manufactures who after all produce such work equipment? Good thread Ian
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#8 Posted : 17 December 2003 09:59:00(UTC)
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Posted By Dave Daniel My experience mirrors yours Stuart. My clients had spent much time and money trying to manage vibration levels from their two polishers, one of whom has 30 years "on the tools" and has early VWF. When this was reported to the HSE, the subsequent visit deteriorated into threats to serve an improvement notice claiming that the risk assessments were unsuitable and insufficient, with the usual claims from the HSE basic training course ("most other companies - unspecified - do much more ...etc.). A range of impractical measures presumably taken out of a HSE memo were trailed past. We have yet to find out who "most other companies" are... We double-checked that the tools we used were the best available, and then were referred by the HSE to tools claiming to have very low vibration levels but in fact on testing had higher levels than the Bosch tools in use. As a result of our efforts no improvement notice was served. No improved controls were identified, but much time and effort was expended proving the company innocent. I cannot support the cynical comments of one of your respondents who claims that employers only do things if they are forced to. My client has spent huge amounts of time and money on this problem even before the HSE were involved. On a separate note, I met a HSE inspector in August who stated in a public meeting that whatever an employer did, he would only ever consider it "barely acceptable". With such biased views still prevalent in the HSE your experience if hardly surprising. We still await the promised letter from him. I would like to know how he would rate his own performance on his own scale! There is a desparate need for data on vibration levels if anyone is to comply with the proposed Regs. The "European Hand-Arm vibration database" in Sweden was only funded for 2 years until 2001, and much of the data is very old. Most manufacturers do not publish vibration data in readily available publications, yet the HSE proposal assumes that risk assessments will be easy becuase it is just a simple matter of looking up such data! I feel that the HSE cost benefit statement should be challenged and at the very least some research funded. The proposed Regs leave the company with no option but to sack their two polishers and let someone else break the law because we cannot find ways of doing the work without exceeding the threshold.
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