Posted By GavinR
Hi,

I have asked this question on this site before but without much response so would really appreciate any assistance guys!

The machines we have on site (rotating and cutting hazard)there are 3 tasks in the process that require the interlock guard doors to be bypassed and the operators to work on the machinery as it rotates at variable speeds. We have mitigation precautions in place e.g. short sleeve overalls, no jewellery, no gloves, etc, and train the operators in the hazards posed.

Now we have investigated this issue to death to find a solution using the expertise of our engineers but still no solution.

If there was to be an accident on this machine involving these processes would we have any defence in front of judge due to our failure under PUWER Reg.11? If it cannot be prevented by engineering would the mitigation measures be regarded as protection or will be only be reducing some of our liability?

Any advice will be very much appreciated folks as i'm getting to my wits end trying to find a solution.

Cheers, Gavin

Posted By DRB
Sorry about the typo's. Got interrupted mid-typing!

Posted By Bob Youel

talk to the original manufacturer

Posted By Robert.
Now I understand that end product quality is critical.

could you consider:

1)A light source ie laser alignment. Since the CNC tooling is critical, a laser source could eliminate human error whe aligning and also eliminate the need to enter and view. Obvious cost involved, but you are turning out high quality product.

2)Deburring on threads. (Outside and inside diameter)Is this a low rev action? Finish cannot be achieved using scotchbrite wheels on hand tool or files". So can it be part of a re-tooling action--next job step. Eliminate the need to enter the rotary area

3) Polishing the inside and outside surfaces to remove any scars, chips or blemishes to high finish. As "2" above

There will be a time element involved in
re-tooling.

Only my thoughts.

Posted By NCL
Gavinh,

I'm no engineer but ex-enforcement and usually the only two acceptable methods of overide (for setting up purposes) is inching and slow speed hold to run controls (most CNC's seem to built in with one or both of these facilities).

However, it sounds as if you are saying that you need to run the machines at speed so these options would not be possible. However, are you are absoultely sure it has to be at speed? I have lost count of how many times I have been told a machine absolutely has to run at speed for set up but further discussion proves otherwise. Operators can be stubborn not wanting to change how they have always done things.

In my opinion overiding the guards whilst running the machine at speed is unacceptable and an accident would land you in court.

Alarm bells are ringing over the deburring process, especially internal threads. Exactly how are you deburring? I investigated an amputation during such a process (prosecuted the company for it too).

I hate to be negative but without seeing what you are doing and having further details I think you are on dangerous ground on this one.

Posted By Brian Hagyard
Gavin.

I try not to be negative on this forum, and I would applaud you for trying to find a solution to this, and while I am not an expert in engineering, my gut reaction is if you have to do these task's at speed and you cannot use the guard supplied, then you have the wrong machine for the job. There may however not be a reasonably practicable solution, but over the years I have investigated two may amputated finger's, hand's, arms etc where training alone has been relied on. We are all human and unfortunately a consequence of that is we all (including me!) lose concentration at some time - look at the number of road accidents.
As I said sorry to be so negative, I would useualy try and offer constructive advice but have man flu today (thats my excues!) Good luck with finding a workcable solution.

Brian

Posted By GavinR
Thank you Brian, i appreciate your time and any advice (positive or negative)given to my query. You all have been very helpful and i know this will be an issue for engineers to solve and not just HSE dept- just comforting to know that i have taken the right approach to this issue and that we are not being over the top as many often accused us of.

Much appreciated folks.

Posted By Sally
What do other people who manufacture the same parts do? Often if a group of customers approach the manufacturer of a machine they are willing to put more time/money into a solution.

Posted By Les Welling
Hi is it me or what? It seems that this machine is not fit for purpose and someone needs to talk to the designers who have a duty under the HSAWA surely?

Posted By Ron Hunter
I have experience in the egineering industry, turning and lathe work.
All the operations you describe are those which would be typically carried out by the turner on a conventional (i.e. unguarded) lathe. These are not "maintenance" operations, but part of the process of tool setting and producing the part.
I see no problem whatsoever in undertaking the tasks in the way you describe.

Posted By GavinR
Thanks for your reply Ron but i never said they were 'maintenance' tasks. They are part of the process of manufacturing the part, as stated in my posting. The jobs are completed on CNC machine and not conventional lathes as we have only 2 x conventional lathes remaining.
From reviewing the response's and other discussions with expert sources on the matter i think it is clear now that emery on a rotating machine (even if slowly rotating) is not an acceptable practice and one we seriously wish to stop.

Thanks for everyone's input into this question all your comments were very helpful.

Cheers, Gav

Posted By Stuart Scott
Hi Gavin - In my last place of work we too had similar problems. The work being done was the manufacture of one off or bespoke items which, given the equipment we had, made it almost impossible to automate the process. As a result interlocks and guards were often bypassed to achieve the required end result.

I had two roles in the company, initially as a Industrial Modelmaker I agreeded that this was acceptable because it allowed for the job to done right and within budget. However, with my other hat on, as a trainee H&S advisor, this went against everything I understood about H&S and against everything I was being taught at the time.

In the end, after much heated discussion with collegues who could not see the dangers they were being exposed to, the only logical answer I could come up with was to change the equipment being used to something right for the job, i.e. High Speed machining centre or just stop taking on work that was forcing us to work in a way that was unsafe. (First rule of control - eliminate the risk where possible.

Unfortunately both ways cost money. Either in expenditure, i.e. purchase of new equipment or lost revenue and re-marketing to find alternative work. Neither of which were popular answers with the management.

I never did get a resolution and have since moved on, but my leaving argument was the same as Mr Stelios (easy jet) once said "If you think H&S is expensive, try an accident"

Sorry I can't be more constructive, but I do agree with the others, at the moment the equipment being used just does not sound right for the task or the task not right for the equipment, either way one or the other definitely needs changing.

I wish you luck in implementing the changes needed, it sounds like it's being a hard job so far - Well done for trying.

Good luck.

Cheers

Stu

Posted By GavinR
Ron,

Although it is good that you have taken time to comment on this thread i think that maybe you are not aware of our products the difficulties they pose for the deburr situation. We have already considered the 'over polishing' for cosmetic appeal issue but due to the critical nature of the products polishing is required on a certain number of jobs for QA requirements to be met. We have already eliminated those cosmetic polishing jobs. I have experience in engineering shops, so have certain people who have responded on the thread and also have experience with similar productions and understand the issues raised. Others are voicing their opinions based on their knowledge and understanding of the Regs. which even without fully understanding the engineering shop environment are just as correct in pointing out the legal duties and responsibilities. I personally want to find a solution that prevents the risk to operators and complies with current legislation and do not see this as OTT approach. Maybe 'the way it has always been done' approach would not be a suitable basis in a court room or to an operators wife that has lost a husband?
Appreciate your input but unfortunately i disagree with your comments.
Cheers, Gav

Posted By Dave Daniel
Gavin - perhaps I might raise my head above the parapet...

In the "old days" of the Factories Act there were such things as "unfenced machinery attendants" who could be appointed. There are sometimes legitimate reasons for entering safeguarded areas - for example where perimeter guarding is used and close inspection of a machine part is necessary, as used to be the case with in-line transfer machines in the Motor Industry, when we had one. The Factories Act did prohibit all exposed dangerous parts of machines and many machines were techically non-compliant so everyone just avoided the issue and paid out claims anyway.

In PUWER, Reg 11 sets out a hierarchy of measures for addressing dangerous machinery, starting with guards. Where this is not "practicable" (i.e not technically possible at any cost) other measures such as training etc. are required.

So in theory it is possible to have a situation where access to unguarded machinery is legitimate, following the logic in PUWER 11(2).

The fly in the ointment is the The Health and Safety (Miscellaneous Amendments) Regulations 2002, which because certain members of the HSE believe that the first thing employers do with a new machine is tear all the guards off (exactly what they said in consultation), amended PUWER with an absolute duty to the effect that no safety device provided to meet EC "essential safety requirements" (CE marking) by the manufacturer must ever be removed... not even apparently for maintenance or if it's not adequate. (see PUWER amended Reg 10)

So although you might make a case for access under Reg 11, your no-win no-fee lawyer would just sneak in Reg 10 and point out you'd failed to meet your absolute duty.

Sorry to break the bad news - Looks like if you can't resolve this you'll just have to grit your teeth and hope. The bad news is even if you alter the safeguarding provided to make it better, you've broken Regulation 10 anyway.

What was that about the HSE and sensible risk management???.....

Dave Daniel

Posted By Eric Taylor
Just another thought, If one of your workers was to injure themselves in the course of operating these machines, the content of this thread would be enough to demonstrate you were well aware of the problems and risks involved. Be really good to see what the lawyers on both sides would make of it. Your company certainly wouldn't be able to try and hide behind anything in defence. Are you not effectively proving, in a quite public forum, that you know you are doing wrong?

Posted By TomP
Dragging back through the old grey matter I remembered this (although it took some finding):

http://www.hse.gov.uk/pubns/eis2.pdf

It says and I quote:

‘Emery cloth should NEVER be used at NC lathes.'

Employers should assess the need to use emery cloth on components rotating in a lathe. Such operations may not be necessary if:

(a) the finish being sought is only cosmetic. For such finishes the component may be held in one hand and polished by emery cloth held in the other. Alternatively a linishing belt or machine may be used;

(b) a sizing operation can be successfully performed either by turning or by further operations in a dedicated polishing, linishing or grinding machine.

You need to swap the operation to a manual lathe if you insist on manual polishing as it fits in with regulation 11 - 2(c) of PUWER which says:

(c) the provision of jigs, holders, push-sticks or similar protection appliances used in conjunction with the machinery where and to the extent that it is practicable to do so, but where or to the extent that it is not, then.....

You are still duty bound to do what you can to remove the problem. It’s all about the level of risk posed and a CNC machine is just to ‘automated’.

As an ex toolmaker I would never dream of finishing a part in a CNC machine as the tolerances were unachievable. We would hand deburr or final op in a manual lathe at low speed and this still hasn’t changed.

Might add weight to your argument..!