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HELP - Working Space During maintenance Activities
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Posted By Joanne Laing
Hi
I'm currently having "discussions" with our German project manager over the installation of a new piece of equipment - i've requested that a minimum space of 1.2m be provided for access to machinery for our maintenance engineers - based on my risk assessment.
Although being maintenance it is not carried out very often, the nature of the job, requiring special tools to undo guards etc, means that they need to have safe access.
I've been told that unless i can show documentation that says there is a minimum space requirement then they will only get 50cm?? Meaning they will have to squeeze in and try to work. I'm pretty sure that any space for maintenance is based on the risk assessment under PUWER which is waht i thought i was employed to advise on?
Can anybody out there confirm this or point me in the direction of other documentation etc?? Your help would be greatly received.
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Posted By Frank Hallett
Joanne - you're quite correct in that PUWER requires the needs of maintenance to be actively considered [Reg 22]. There is no ACoP to this Reg however, only Guidance. If you can obtain a copy of L22 you can read it for youself - if not, email me and I shall send you the extract.
Ultimately, you must assess the hazards implicated by ALL mainteneance operations and then go to whichever of the myriad other Regulations are most appropriate as well as PUWER. For instance, the Electricity at Work Regs, The Manual Handling Regs, possibly even the Confined Spaces Regs, or even the good old catch-all of the MHSW must all be considered for relevance.
Maintenance activities tend to be far more hazardous than routine work and are also frequently made next to impossible by failures such as the one that you've identified.
Frank hallett
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Posted By Chris Pope
I think there has been a posting about this recently to do with electrical plant rooms.
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Posted By Joanne Laing
Thanks Everyone for your help - you'll be amused to know that i've actually now been told that risk assessments aren't law and i'm making it up!
The battle continues!
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Posted By Jenny R Harris
Joanne,
PUWER etc. directs you, the employer, to identify what standards you need to have in place for maintenance but it doesn't really deal with the supply and installation issue.
The routes you could take to persuade your supplier to comply with your demands include:
1. The contract you placed with them to supply and install - what does it say about complyng with your requirements? You are the client, as such you have a certain amount of power. Is there a clause about with-holding a percentage of payment till you are happy with the product.
2. Section 6 of HSWA - duties of those who install etc. in paragraph 3
3. Supply of Machinery (Safety) Regulations 1992 - again EU wide duties on those in the supply chain to ensure machinery achieves the essential health and safety requirements. These duties are however placed only on those who design the piece of equipment. Tied into this there are design requirements to enable safe mainenance within BS EN ISO 12100 : 2003 parts 1 and 2.
If you contact me by e-mail I can e-mail back extracts from the latter.
You may already have go this far...... but hope this helps.
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Posted By Frank Hallett
Hi Joanne
It appears that your real difficulty is a Project Manager who shouldn't be in that position 'cos they have no obvious knowledge of even the Working Safely level of H&S. Unless you can get the right person to influence this you're probably on a loser!
My advice is to make sure that you spell out in an email to the Project Manager and EVERYONE ELSE involved in this project in very simple words the requirements as you see them; and accompany that with a similar simple exposition of the potential penalties that will be attracted for failing to ensure sufficient room for maintenance.
Keep the evidence and identify that you at least understand HSWA Ss 36 & 37 'cos you will be the name in the frame for starters!
email me direct if you need anything specific.
Frank Hallett
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HELP - Working Space During maintenance Activities
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