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Posted By GavinR
Hi, we have a new machine arriving to site soon and our maintenance boys have to break out the crate. This is a 9 ton wooden crate and approx 4 m high. The suggestion of how they used to do this was to used the toes of a FLT to prise open the panels and basically tear of the side panels a section at a time. The roof and back panel will remain attached until the end when the FLT will raise the roof panel back and allow gravity to do the rest. I have never witnessed this process before and I'm a little unsure of this technique being considered. Needless to say the risk assessment i have developed so far requires the surrounding areas to be closed off and barrier ed throughout to ensure no staff or contractors will be standing in the working area. To manually demolish the crate would require working at height and excessive manual effort so i can certainly see their reasons for using the FLTs. I have requested a method statement be submitted by maintenance manager but just wondered if anyone knows of a recognised practice for stripping large sized crates?
Cheers
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Posted By Ron Hunter
The simplest (and most simplistic?) answer is that any structure be dismantled in the reverse fashion to that in which it was constructed.
It wasn't put together using a FLT, you should not therefore entertain the concept of it being dismantled in this fashion. I would be further concerned that similar cavalier attitudes would be applied in moving and installing the machinery.
Does Section 6 duty on the supplier not extend to the unpacking and erection/installation on site?
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Posted By GavinR
Hi Ron, we have suitable arrangement set up for unloading and transporting the load to its location. This has been reviewed and agreed with suitable assistance from machinery movement contractor due to weight and size involved so really the only concern i have is the 'break out' from the crate. I was considering contacting the supplier to request advice but in all honestly i figured they would tell me to go jump with a matter like this. I thinking a process involving a scissor lift to raise the guys into position and FLT for supporting the panels as they are loosened and brought down to the ground may be the best option. Might as well contact supplier.
Thanks for your advice.
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Posted By Peter Still
Gavin,
If you feel the supplier would tell you to "go jump" if you ask for guidance on how to safely take these machines into service, you could quote the Machinery Directive at them, particularly 1.7.4.2. "Contents of the instructions", item (p) "instructions with a view to ensuring that transport, handling and storage operations can be made safely, giving the mass of the machinery and of its various parts where these are regularly to be transported separately"
Peter
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Posted By GavinR
Hi,
Thanks again for your feedback. The main reason i can't forsee any real assistance from the supplier is that it is being shipped from US and the company used to pack the machine is not the same as the suppliers. I have tried to get in contact but to no avail.
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Posted By Ron Hunter
Duties then fall to the importer into the EU. (Including conformance with product safety directives!)
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Posted By Peter Still
Gavin,
Who's responsible for the CE Marking and Declaration of Conformity?
Peter
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Posted By kaggs
Legally you are bound by the 1992 regs but at specification you could have requested 'adaptation' to the New Machinery Directive which kicks in on 29th Dec this year in the UK - it just means that your Declaration of Conformity couldn't have quoted the new directive but the machine would have been adapted to it. This would have meant that the exporter (in the USA) would need to have given the name and address of an 'authorised representative' in the EU which would make the job of the regulatory authorities much easier. However, Group 1 of the Essential Health and Safety Requirements (which are mandatory) does state:
1.7.4. Instructions
(a) All machinery must be accompanied by instructions including at least the following:
— a repeat of the information with which the machinery is marked (see 1.7.3), together with any appropriate additional information to facilitate maintenance (eg addresses of the importer, repairers, etc);
— foreseen use of the machinery within the meaning of 1.1.2(c);
— workstation(s) likely to be occupied by operators;
— instructions for safe:
— putting into service;
— use;
— handling, giving the mass of the machinery and in various parts where they are regularly to be transported separately;
— assembly, dismantling;
— adjustment;
— maintenance (servicing and repair);
So, it is still a legal requirement for them to supply this information to you but also one of the reasons why we have a new directive!
All the best.
email us at enquiries@gloverassociates.co.uk if you need any help.
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Posted By GavinR
Hi Guys,
There is no problem with CE Marking for the machinery, that has all been agreed and the machine is compliant. We will proceed with PUWER assessment on arrival as normal. This is not a concern, the main issue was simply breaking out the crate as i have never witnessed this before and had some concerns with previous methods. I'm now confident with the process so thanks again for your advice.
Cheers
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Posted By Peter Still
Gavin,
If you don't have instructions from the supplier on how to safely take the machine into service, including unpacking it from its crate, then I'm sorry but it isn't fully compliant with the machinery directive, either the current (98/37/EC) or the new one that comes in later this year (2006/42/EC).
Peter
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Posted By GavinR
Hi guys, sorry if I'm being very ignorant to the requirements here but are you saying if we do not unwrap the machine from the wooden box in set manner prescribed by the manufacturer (which hasn't been provided and supplier is outside EU, so as the importer it is our duty to decide how to do this) then we are in non compliance with the machinery directive??
If this is the case how are we supposed to remove the machine and have it placed on our shop floor for future use? The installation methods are obviously avaiable from the manufacturer.
I'm curious to hear the response to this?
Cheers guys.
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Posted By Glyn Atkinson
Is this too simple??
Remove lid of crate with care, using suitable hand tools.
Gain safe access to inside of crate to fit suitably tested lifting strops / shackles on suitably tested lifting points on machine.
Lift contents out of crate and lower to ground.
Remove crate from premises and dispose in suitable manner.
Ok, it's hellishly thin in detail, but it'd got to be better than smashing crate with flt truck forks???
You must be able to lift the machine by suitable cranage to get the bottom off the machine and site the machine in situ and add utility supplies??
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Posted By Peter Still
Gavin,
As you are the importer then you are accepting the responsibilities under the Machinery Directive (or more specifically the Supply of Machinery (Safety) regulations 1992). Those responsibilites include supplying instructions for safe transport and installation, so I guess technically you are in breach of the regulations, but that doesn't help with your original question.
Given that this is not the sort of machine that can be lifted out of the box, so that you need to dismantle the crate from around the machine, I don't think you should be abusing a FLT to do so. As someone else suggested can you get a scissor lift alongside the crate? The crate should be dismantled from the top down, being aware of the danger that parts of the crate might drop and for such a heavy machine there could be some heavy lumps of timber involved in the crate.
Peter
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Posted By GavinR
The m/c will not be lifted out of the box via a crane as this is not possible and i believe removing the box is a much better procedure than raising a 9-10 ton m/c machine up to that sort of height to remove it.
According to maintenance dept who have completed this task in previous years, it is extremely difficult to 'break open' the box due to it contruction and robustness. During the risk assessment they stated they feel manual efforts to open the box would introduce more hazards from working at height and operating cutting equipment. The procedure suggested by maintenance is not ramming the crate until it falls apart but a systematic procedure using the FLT to remove sections of the crate at a time using the FLT to lower panels to the ground. FLT is only machine or person permitted in the area and it is completed in a sequence so nothing can collapse. Supervisor will restrict all access to the area until completed. Does this not sound sensible approach?
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Posted By Melanie Fellows
It sounds sensible to me.
All different avenues approached and investigated, this one sounds like you have thought it through & documented it.
Mel
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Posted By Peter Still
Gavin,
If you're confident that you've addressed all the risks by exclusion, supervision, PPE, etc, then I guess that's all you can do. My concern though is that you're planning to use an FLT for a purpose that it wasn't designed for. Difficult to know if that's likely to be significant without seeing the FLT or the crate, but there might be a chance that stresses applied to the FLT are outside its design criteria.
Would it make sense to have the FLT inspected afterwards?
Peter
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Posted By GavinR
Thanks again guys for your invaluable feedback. Yes, i would agree for that it prob would be good practice to have our service engineer come in and inspect the truck after use to confirm there has been no damaged caused. Thanks again for your help, much appreciated.
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Posted By Ron Hunter
I revert to my original reply of 6th. I effect, you have absolutely NO idea of the loading you are applying to the FLT. You are seriously compounding your errors here.
Others have suggested that what you are doing is "sensible". I strongly disagree.
Gavin, beware of participating in this and putting your name to a Risk Assessment which concludes this is all "safe". This could come back at you with a real vengeance when the accident happens.
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