Feature Machine Safety Keeping your guard up
When considering the safety of machinery, many in the materials recycling industry may ask why they should worry - surely their machinery supplier takes care of all of that? The Health & Safety Executive (HSE) thinks differently and in its guide to buying new machinery (INDG271), it states that CE marking is not a guarantee of safety and that ‘the manufacturer is claiming that the machinery complies with the law. You still need to check the machine is safe before it is used’. Paul Laidler of TÜV SÜD Product Service explains
T
he HSE Register of Convictions shows that 62% of breaches under The Provision and Use of Work Equipment Regulations 1998 (PUWER) have been committed under Regulation 11 - Dangerous Parts of Machinery. The aim of this particular regulation is to prevent access into dan- gerous parts of a machine and to stop the movement of these dangerous parts of a machine before anyone can enter the dangerous zone. Suggested methods of doing this include using physical guards and protective devices. However, guards are often treated sur- prisingly casually and continue to be the cause of many severe injuries that could have been prevented had appro- priate guards been used. To try and tackle this problem, the updated Machinery Safety Directive (2006/42/EC) came into force in December 2009, introducing a range of new requirements for guards. While previous incarnations of the directive referred only to ‘safety components’, the latest edition gives an indicative list of what those safety components are - one of which is guarding.
Health and safety requirements Essential health and safety require- ments (EHSRs) cover aspects such as guarding and other safety features that manufacturers must build into their machines before the guard can carry the CE marking to show that it con- forms to EU requirements.
Section 1.4.1 of these EHSRs requires
Above: Paul Laidler, business director for Machinery Safety at TÜV SÜD Product Service
Below: guards are often treated surprisingly casually and continue to be the cause of many severe injuries that could have been prevented had appropriate guards been used
that guards must protect against the ejec- tion of falling materials and objects. For example, if a grinding wheel explodes, can the guarding contain that explosion? Section 1.4.2.1 requires that all fixed guards must be removable only with the aid of tools, that guards should be inca- pable of remaining in position when their fixings have been removed, and that their fixings need to remain attached to the guard when the guard is removed from the machine. This means that ordinary machine screws and bolts can no longer be used as a means of attaching guards unless provision is made for the screws or bolts to be held captive when the guard is removed. One of the other requirements of Section 1.4.2.1 states that guards should be incapable of remaining in position when their fixings have been removed. This means that some care- ful thinking will be required to ensure, for example, that hinged guards open automatically when they are released, and that guards on the top of machines are not retained in position by gravity when their fixings have been removed.
Guards and their associated safety devices such as interlocks (covered in EN 1088) can, and often are, defeated. Interlocks, in particular, have been prone in the past to being defeated in order to keep production running. Recent updates of EN 1088 also included suggestions such as gluing and welding in order to pre- vent defeat by removal.
Reviewing the workplace Requirements do not just relate to new machinery being brought into the workplace, but also cover existing machines. So, if a maintenance team are not fully aware of the requirements they can fall foul of the law. Any new guards added to existing machinery must be put through the entire CE marking process, including risk assessment and the compilation of a technical construction file, before a dec- laration of conformity for CE marking can be made.
EN standards
EN standards are the recognised source of guidance across most busi- ness sectors and machinery safety is no different. There are in excess of 500 standards relating to all aspects of machinery safety, including guarding. Just a few examples, as mentioned above, are EN 953, EN ISO 13857 and EN 349. These can all be used to ensure that your equipment conforms to the requirements of both the Machinery Directive and PUWER.
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Regulation 10 of PUWER also requires that an employer must ensure that any equipment subject to European directives complies with all applicable ESHRs of the directives that apply to it. This includes ensuring that they, or the manufacturers from which they buy machinery, have CE marked their products correctly and followed the right procedures. Clearly, achieving full standards compliance for a guard to carry the CE marking is no trivial task. CE marking, along with the design and manufac- ture of guards, now requires specialist expertise as guards perform an indis- pensable function to minimise the risk of injury as well as meeting the multi- tude of regulatory requirements. The plea of ignorance is not accept- able as failing to comply with the Machinery Directive and PUWER, whether knowingly or unknowingly, can have serious and far reaching con- sequences for machinery designers, the manufacturers that use them and their operators.
TÜV SÜD Product Service
www.tuv-sud.co.uk T: 01489 558 100
Enter 229 JUNE 2013 Machine Safety
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