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Posted By Gff
So then it's like jim says it's down to poor or over design.
these designers should be ashamed of themselves and get a grip on reality.
hold down a guard with 500 bolts, loose one and the machine is shut down.
Makes perfect sense to me
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Posted By Peter Leese
I have to agree with you Jim, too many contributors on this forum see everything as being black and white.
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Posted By Jim Walker
To the two negative responses:
How do you know that the bolts "just" hold the guard in place.
FYI a prescribed set of impact & flex tests are required on all panels. My guess is the designer was able to use lighter panels because the fixing points added to strength.
I will not speculate further as like you, I've not seen the machine.
One further thought when criticising design engineers etc:
A little learning is a dangerous thing.
Drink deep, or taste not the Pierian spring.
There shallow draughts intoxicate the brain,
and drinking largely sobers us again.
Alexander Pope (1688 - 1744) in An Essay on Criticism, 1709
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Posted By Peter Leese
'I will not speculate further as like you, I've not seen the machine.'
Indeed Jim.
That's why each situation would need to be assessed, and which despite your opinion is not necessarily outwith the expertise of the site engineer.
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Posted By Jim Walker
Peter,
Again you miss the point - just as you did in summarising Colin's "spot on" post.
A site engineer is most unlikely to have either the technical competence nor test resources available to the designer.
Do you really think someone would design for 8 bolts when 2 or 3 would do? It would be commercial suicide to design like that.
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Posted By Peter Leese
1) This is highly complex job, requiring competence way beyond anything a H&S practitioner or fitter or maintenance manager would understand.
2) In passing - one definition of a competent person is one who knows his (her) limitations - this forum is getting too heavily populated with people that do not abide by that.
Jim
(1) This is a very wide generalised statement that I sure many maintenance engineers would take exception to.
(2) Again a very wide statement, would you care to justify, or it not, then retract?
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Posted By Tabs
Halfway down this discussion, Glyn Atkinson suggested the correct response to this problem.
You could make it faster by air/electric gun to fit the bolts. That can't be beyond the wit of a fitter to arrange.
The manager and the fitter are both complicit in shortcuts because of a perception that the "wrong way" is the "fast way". All you need to do is argue for the "right way" being the "adequately faster way" (what do they do with the time "saved" that means that a few minutes is so precious?).
The guard should remain at 8 bolts unless a designer is willing to blank off the holes - and provide warranty to the safety of that.
But you don't have to do up the bolts with a spanner.
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Posted By Pete48
Peter L, I disagreed with your approach to this matter earlier in the thread and I return to do so again.
The recent posts from qualified engineers gives the proper and correct response to this question. Your approach suggests that it is OK for any engineer to modify a machine without full and proper assessment and re-certification. I challenge that assumption and I think that is what others are challenging.
Of course it is not correct to say that all and any guards that appear to be modified are per se dangerous or unacceptable. However, any practitioner who finds guards improperly fixed must questions this. After all, if the engineer is indeed adequately competent to approve and make changes then surely they would easily be able to produce the required documentation to satisfy the query?
If that had happened in this case, I wonder why the originator made the post?
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Posted By Peter Leese
Pete 48 wrote: Of course it is not correct to say that all and any guards that appear to be modified are per se dangerous or unacceptable. However, any practitioner who finds guards improperly fixed must questions this.
Thank you Pete, exactly my point. And from there it is a simple step to the risk assessment which you'll see I have advocated almost from my first posting. This would be a risk assessment carried out by the engineer and the manager, with an input from the safety advisor.
I think we need to question the contributor attitude to designers - I can immediately think of three instances with two client where new machinery has had to be modified in-house with additional guarding to ensure it is safe to work with in the UK. In a number of other cases fixed guards have been replaced with interlocked guards.
And the question asked by Tabs - just as one example try working in the bulk printing industry where profit margins are on the edge and where an extra 5 minutes downtime can make the difference between profit and loss.
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Posted By Mike Draper
James
Like Jim Walker and Colin (ref above posts) while I am now a safety practitioner, I have also spent over 20 years designing bespoke work equipment for a number of different clients (usually large process machines in continuously operating processes - fibres, polymers, packaging, process kit etc.).
Guarding standards in the UK are clear as to the goal - practicability - if it can be guarded, it must be.
Guards must also meet particular requirements for their strength and integrity, however what is often forgotten by designers is that one of the inputs to the design process is the experience of operations and maintenance.
While on the face of it, I agree that a guard that is designed with 8 fixings should be fitted with 8 fixings, it is acceptable for the user to determine alternative arrangements to suit operation and maintenance requirements, providing they can demonstrate that they have meet the needs of PUWER.
It is incorrect to say that an item of work equipment without all of the fixings in a guard violates any legal principles (either PUWER or CE Marking legislation), invalidates any insurance or no longer meets the manufacturer's original specification.
If the decision to leave out fixings has been taken by a competent person (e.g. a mechanical engineer with an understanding of guarding requirements, the use to which the work equipment will be put and any knowledge of maintenance procedures - an holistic view) then providing that PUWER requirements are in fact met, there should be no problem.
What may be true is that the modification may relieve the original supplier of their liability as a supplier - such liability may be transferred to the person carry out the modification, as they may now be deemed to be the supplier.
As a designer, it has always been my preference to use the minimum number of fixings to secure guards, ensure that guards do not stay in place unless secured and require a tool for their removal. However, also as a designer, I have always talked to the end-users to establish from their experience what access they will require for use and maintenance. This has often resulted in changes to equipment construction and guarding - changes that have ensured that maintenance practices such as leaving a few bolts out, don't happen.
I strongly recommend that you look at this with a view to doing the following:
Get someone to look at the use and maintenance of equipment in service, to identify why fixings are being left out. E.g. if an item of equipment breaks down so often it is left only half assembled, then the underlying reliability problem needs to be addressed.
Where guarding is not installed as designed, review the function and integrity of the guarding and make such changes as are required to suit maintenance and operation but with suitable records that demonstrate why such changes are needed without compromising guard function or integrity.
Look at how you procure new equipment, to ensure that operations and maintenance experience contributes to the specification of equipment that actually meets your needs.
Hope you find this useful.
Regards
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Posted By Peter Leese
Mike, an excellent response.
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Posted By Gff
Rather disappointed that such a reasonable response to a situation has been posted on this forum its not the same if its sensible
Well done Mike
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