Rank: Forum user
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We have slightly modified a piece of equipment on one of our manufacturing machines The fixed guard is 1.0m high, and this is required for access. It is possible to lean over this guard and just reach an inrunning nip. This guard height does not conform to BS EN 294:1992 (Safety distances). The problem we have is that by raising the guard the machine would be unusable (even if interlocked), and we can see no other alternatives So the current situation is that I am not allowing the machine to run, but we need to resolve this So I would appriciate any advise as to how to deal with this.......... Would signage, instruction & Training be adequate?
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Rank: Super forum user
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apologies if I have mis-understood your scenareo....could you fit a small safety light beam on top of the guard that should access be attempted the light beam will be tripped and stop the equipment?
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Rank: Forum user
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Hi guru No we can see no other options to increase the guarding or safety and still have it usable. My question really is would signage and training be sufficient to run this machinery. the nip is not easily accessable, but it can be reached by leaning over the guard
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Rank: Forum user
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If the danger zone is reachable as described, then I don't think signage and training alone would be sufficient. IMO you need to explore other guarding alternatives. I don't picture very well what you have but could you not increase the reach distance?
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Rank: Super forum user
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Hi Jack Bit difficult to visualise the machine but have you considered 1)moving the fixed guard out a couple of inches or so. 2) guarding the inrunning nip itself 3) fitting a piece on the top of the guard that is horizontal and adds a few inches to the distance between the top of the guard and the nip.
Take care John C
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Rank: Forum user
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Thanks for your comments The problem is, is that access is required beyond the guard at specific times whilst running. We have spent a long time looking at this, and have come to the conclusion that it cannot be made any safer, and still able to run. The nip is not easily accessible, but by leaning over the guard, you are able to just reach it.
I just wondered what your thoughts were in this situation. Should I refuse the machine to run, or accept guarding & training?
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Rank: Super forum user
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Can you tell me what is the likely injury if contact were to be made with it?
Are we talking about being dragged into the machine and killed or, a finger crush or a mere cut?
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Rank: Forum user
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Should he reach the nip, it would certainly be a lost finger, at least. Possibly crushed hand
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Rank: Forum user
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Why is access beyond the guard required ie what are they doing and is there a way to avoid having to do it
Not sure what industry you are in but this problem of 'needing' access to inrunning nips was very common in the Paper Industry until a lot of effort was put into finding solutions by the whole industry.
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Rank: New forum user
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Looks like there needs to be a balance between allowing 1. "access is required beyond the guard at specific times whilst running" and 2. stopping access to the in running nip!!!! Can you adjust the distance of the guard from the machine so that 1 can happen but 2 cant?
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Rank: Super forum user
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you mention at the start you have slightly modified the equipment you are using. Has this modification created the problem you are now facing?
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Rank: Super forum user
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At the end of the day if you can reach an inrunning nip that can cause injury then you have to prevent access, no amount of risk assessment is going to stop injury being reasonably foreseeable.
I know PUWER is confusing in this respect but if you read it carefully on the matter of guarding you will see that the duty is essentially absolute, deriving as it does from the old FA 1961 duty. Case Law has not changed and it will be extremely dificult to convince a judge that this is a satisfactory situation when somebody is injured.
Bob
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Rank: Super forum user
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Perhaps I should add that in-running nips are often best guarded by close fitting mechanisms but we would need detailed drawings to work this out. Look towards some form of angled bar that would prevent the finger being drawn in, or consider a small local guarding system
Bob
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Rank: Super forum user
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Jack I think that you already have your answer but under pressure to accept the situation.
Ask yourself "when someone has a serious injury with this will you be comfortable when challenged about the standard of guarding by the HSE".
That said we do not understand the m/c or the process.
There are certain m/cs and processes where it is acceptable to allow access to a moving part when the m/c can only "inch" or go at a slow speed eg 20 foot per min but certainly not at normal line speed. Steve
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Rank: New forum user
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Rather than look at Guarding the full machine can you guard the nip point, if contact can be made then the nip point requires a guard. Have you discussed this problem with machine manufacturer.
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Rank: New forum user
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Sorry, without an image of the machine, its hard to comment. But! Would a separate control box that required to hands to operate and located at a safe distance be acceptable. I can't really grasp why it is necessary to have access beyond the guard and as mentioned earlier the authorities would look pretty hard at what had been done in the event of an accident. I suppose what I am saying is that I doubt notices and training would suffice, could you ask your friendly local HSE Inspector for advice?
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Rank: Super forum user
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This type of discussion hasn't worked for others in the past - we can't see the problem! I do think the real answer lies above. You modify the machine - you create the problem, therefore there can be no justification in relaxing PUWER requirements. Maybe the answer lies in reconsidering the design of the modification - the person in your Organisation who designed this mod. has taken on Section 6 duties of the Health and Safety at Work Act. I wonder - are they aware of that?
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Rank: Super forum user
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Perhaps you could upload some photos of the machine to a site like Flickr and provide links for contributors to view the photos.
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Rank: Forum user
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Hi,
In relation to puwer regulation 11 does make provisions for machines where fitting a fixed would prevent it's use by providing a hierarchy of control, 1, fixed, 2 other devices such as light guards, interlocks ect,3 protection such as jigs and holders & finally 4 training, information, instruction & supervision.
My background is butchery where many bandsaw and other machines with exposed dangerous parts are used and quite often training hierarchy 3 & 4 were often used.
What I would say is the specific machine may have a BS standard, worth having a search fro if not already done.
Hope this helps.
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Rank: Forum user
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I have been reading the comments on here with some interest. I too am going through some PUWER requirements for guarding and can say we have done a lot in this area to prevent injuries. Some are being readdressed for certain areas but all the while ensuring that the operators are not exposed.
That said some of the queries I have had can relate. Such as one area which alteration to the guarding has been suggested to accommodate the area directly beneath the machine to be swept of material from the process. 300mm from the floor has been requested simply to get the head of the broom in and sweep towards them. All the while the machine is running.
I have had queries such as "Someone can lie on the floor and put their arm in and perhaps come into contact with moving parts" or "Someone could lay down and crawl through to get to the moving parts".
Now I can protect the whole thing by have the guard straight to the floor, but following on from Anderson8 surely information, instruction, training etc must come into play too!
Can we apply common sense and if someone wants to defeat a guard they will. But who in their right mind will want to go to those lengths - surely responsibility has to also go to the operators not to put their safety at risk.
That said in this scenario guarding the nip point would be much more beneficial. As suggest a small section of angle or similar to cover the nip point and prevent accidental access to it would seem logical.
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Rank: Forum user
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Your risk assessment should consider reasonable misuse and take action to mitigate.
It seems you have already started to do this.
Follow the 4-step PUWER reg 11 guarding hierarchy as far as is 'practicable'
For you Diploma students - the relevant case law is? I have forgotten - 'Uddin' comes to mind and chasing a pigeon off a machine???
Legal definition of 'practicable' - to the extent technically possible, cost/trouble etc shouldn't be considered. If my memory serves me correctly.
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Rank: Forum user
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quote=Jack Althorpe].......... Would signage, instruction & Training be adequate? Jack IMHO then should someone be injured then I think trying to use Signage, Instruction & Training as a defence would be unlikely to do the company much good. If you are between a rock and a hard place in convincing someone otherwise then perhaps the following examples may assist in focusing their attention: http://www.hse.gov.uk/press/2009/coissw24809.htmhttp://www.hse.gov.uk/press/2010/coi-ne-03810.htmHTH Steve
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Rank: Super forum user
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ITER you are trying to remember Uddin V Associated Portland Cement Manufactures Ltd, contibributory negligence, breach of a statutory duty. You don't need to be a dip student.
I was under the impression that if you modify a piece of work equipment then you have no longer the security of manufactures instructions, and still require the minimum standards to be applied from reg 11-24 PUWER If you place a guard then it has to be fit for purpose under reg 11 (3) not easily bypassed and secure and at distance to prevent access to dangerous parts
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Rank: Super forum user
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Puwer Reg 11 derives almost directly from the FA 1961 sec. 14 and the duty is absolute and does not even relate to a practicable solution. If a part is dangerous effective measures must be taken. I am sorry to say that you have to ensure the nip is not dangerous or ensure contact cannot be made with the dangerous part. One of my pet problems with PUWER is that the abrasive wheel exemptions particularly were not continued forward. This actually means that technically we are back in the pre 1971 era. The ability to assess risk as set out for reg 12 etc follows once dangerous parts are effectively guarded and abrasive wheels cannot be used where the operative can touch the exposed wheel.
HSE are taking a relaxed view but the case law is established when a wiley unionist sees the oppoortunity in an accident claim
Bob
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Rank: Forum user
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boblewis I don't disagree with the general direction of your argument.
But I disagree about disregarding the term 'practicable'
Sure its an absolute duty to follow Reg 11, but each level of the 4 step guarding hierarchy has to be followed to the extent 'practicable' i.e. you don't drop a level, until the options at each level have been considered.
Thats how it was explained on my Diploma, many years ago.
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Rank: Super forum user
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ITER
The point that is most important, I think, is that the machine has been modified away from the manufactures specifications. In this instance then you have moved away from the practicable argument, you have taken away the replace the dangerous with less dangerous and switched them round. This is not what the regulations require. You have come to the realms of regulation 4 (a) its initial integrity; (b) the place where it will be used; and (c) the purpose for which it will be used. If this was considered at the start then adoptions to the guarding would not have been required, or could have been discussed with the manufactures and different arrangements for the guarding of parts made. if the guard that is in place is not meeting with the requirements of the machine then surly there is no way that you can move further down the hierarchy of controls. I was under the impression that the hierarchy was introduced for "machines of a certain age"
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Rank: Guest
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So essentially, are we saying you can't make a modification if doing so makes the equipment more dangerous? If a guard or other device cannot achieve the same level of protection the the equipment should not be used and should ideally be returned to its original state. While I am sure there are very good reasons the post does not make it clear why the modification was made in the first place. Is it a case of the equipment - in it's original state is unsuitable for the job asked of it?
As regards maunfacturers specs, we had the opposite about five years ago. We had a small grinder which was fed by a chute. while the casings etc was interlocked you could simply pull out the chute and have direct access to the impeller blades. We discussed with the supplier who couldn't see the problem so modified it ourselves by adding a collar so you could not remove the chute without using tools. about two months ago I was doing some maintencance and got hold of a revised parts catalogue and manual to find the grinder now ships with a modified housing that includes a mod, similar to the one we introduced. Nice of them to let us know!!
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Rank: Forum user
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Reading through the posts the only things to add to the above that I can think of are:- 1. What is the age of the machine? If supplied since Jan1993 then it should have a CE mark, and certificate of conformity, meaning it should comply with all the relevant standards and Essential Health and Safety Requirements.
2. Who made it? Is the manufacturer still in business? Can you follow up your problems with them? Following on from above, if the machine is newer than 1992 then the manufacturer should have carried out a risk assessment on it as part of the CE certifcation process. That should have addressed the issue to which you refer. In a nutshell, you may have some recourse to the manufacturer if you believe it's not safe. They should be able to help at least - newer version modifications etc?
3. If the machine is essentially home made, or (more likely) older, then it's more difficult and PUWER98 are the only guidelines you have.
In this case my only suggestion is to get a working party together, made up of engineers, managers and including the operator(s), to try and come up with an imaginative solution that enables the machine to be safely operated but in a way that's compliant with PUWER98.
Hope that helps?
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Rank: Forum user
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Jack,
I don't quite understand whether the nip was accessible before your modification, or not. If it wasn't, and your modification made it accessible, then you have effectively supplied a new machine and need to comply with the Supply of Machinery (Safety) regulations. If it was, you might need to apply those regs anyway, depending on the extent of modification.
In general, access to an in-running nip is not permissible.
How often is access required to the nip? If access required only occasionally, by a skilled person, can you fit a more effective guard that can be opened using a key by a skilled person?
There is some useful guidance on guarding these nips in BS PD 5304. By the way, BS EN 294 has been superseded by BS EN ISO 13857.
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Rank: Super forum user
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ITER at post 25 - The joys of HSE drafting
bob
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Rank: Super forum user
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ITER wrote:boblewis I don't disagree with the general direction of your argument.
But I disagree about disregarding the term 'practicable'
Sure its an absolute duty to follow Reg 11, but each level of the 4 step guarding hierarchy has to be followed to the extent 'practicable' i.e. you don't drop a level, until the options at each level have been considered.
Thats how it was explained on my Diploma, many years ago. I concur! http://www.hse.gov.uk/pubns/priced/puwer.pdf See page 38
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