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Posted By Trevor Anstey
We have a number of N20 low level order pickers which are being used for picking goods from narrow racking with the operator stood on the raised platform at a height of 1084mm.
This platform has no edge protection of any form and my risk assessment has picked up that the operator could (& has many years ago) fallen off. Speaking to the operators they have said that they sometimes feel vulnerable and have had near misses from falling from platform or the pallet.
After investigation it appears that the truck is not being used for the purpose it has been designed. As I understand the truck is supposed to be used as a walk along picking machine for picking with the operator at ground level & the platform raised (at bench height) to reduce handling (stretching, bending injuries) by transfering goods from racking to the raised platform & not for lifting the operator to a height of 1084mm.
The truck manufacturer has since come back & said that as per Reg 5 of LOLER 1998 " If people could fall more than 2m, the carrier should be fitted with suitable edge protection" & therefore edge protection should be fitted to there trucks as they are less than 2m (Just to add to the confusion this also goes against the ammended WAH regs)
My argument is that as far as Im concerned the truck is not designed for this purpose but we have been doing so with the approval of the truck manufactuer
This is not right & as things stand I am concerned that management will take the easy option & leave things as they are as per the manufactuer, as always I would appreciate some feedback as to where to go from here
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Rank: Guest
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Posted By Dave Merchant
The manufacturer is wrong - the WAHR's removal of a '2m limit' in use overrules the clauses in LOLER. When there's a conflict the most recent Reg wins.
If the picker is being used as a working platform then it must comply with Schedule 3.1 of the WAHR. It may not be the manufacturer's duty to fit edge protection (if they say it wasn't *designed* as a working platform of course it doesn't need any as part of the design) but if they don't fit it, you have to do something to keep the WAHR happy and edge protection is the only realistic option given the height of the surface above ground. The WAHR don't specifically say "all platforms need barriers" as it's possible to use one with nets, harnesses or air bags - however using anything other than edge protection barriers must be justified by an RA, and I doubt in this case you can.
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Rank: Guest
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Posted By Philip Beale
Your using a piece of equipment for something it was not designed for. DO NOT USE IT
it was designed for and operator to pick and place loads not to use it as a mobile working platform.
buy the right piece of equipment for the task even putting a barrier around it won't make it comply it was never DESIGNED to carry people just loads on the forks. As loads are less valuable than people a lot of safety measures were never designed into the equipment for it to be used in this way.
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