FEATURE MACHINE SAFETY MACHINERY RISK ASSESSMENT
The Work Equipment Directive applies to all work equipment regardless of its age, including equipment that carries the CE marking. Here, Paul Taylor, head of Industrial Products (UK) at TÜV SÜD, a global product testing and certification organisation, outlines how these rules must be applied to both newly installed and modified machinery
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n our experience, many machinery owners assume that if their equipment has the CE
marking that no further action is required. However, the Work Equipment Directive, which is implemented in the UK as the Provision and Use of Work Equipment Regulations 1998 (PUWER), applies to all work equipment regardless of its age, including equipment that carries the CE marking. PUWER describes what an employer needs to
do to protect employees in the workplace. It is therefore their responsibility to ensure that all machinery meets the requirements of the Machinery Directive and PUWER, of which risk assessments are an essential ingredient. Risk assessment is therefore fundamental to any health and safety process and in particular machinery safety. Guidance on carrying out risk assessment can be found in many places. EN ISO 12100 is the main standard for risk assessment for machinery as it sets down the principles for the process.
Examples of hazards that have the potential to
NEW MACHINERY To immediately identify any issues, a thorough and correct risk assessment should be completed before any new machinery goes into operation. Problems can then be rectified with the manufacturer, so that they or the machinery owner no longer run the risk of a prosecution under the Supply of Machinery (Safety) Regulations or PUWER.
MODIFICATION The Health & Safety Executive (HSE) states that if changes to machinery “are very substantial (e.g. significant new hazards and risks are introduced or new methods of control of the machine replace those previously provided, such as computer control of a previous manual machine) it may amount to being considered a “new” machine (or new assembly), for which you must undertake conformity assessment”. The HSE goes on to state that even if changes
to machinery are not substantial, such as refurbishment, the owner must still ensure that it continues to meet the requirements of PUWER, as well as any other requirements which may also apply to the product.
RISK ASSESSMENT PROCESS The first step is to identify anything that has the potential to cause harm. Secondly, an assessment must be made of the likelihood of a person coming into contact with these hazards and how much damage it would cause.
24 SPRING 2020 | INDUSTRIAL COMPLIANCE
do harm include: A manipulating robot A moving conveyor A pallet wrapper
A risk assessment would normally be carried
out for each hazard identified. The Preliminary Hazard Analysis (PHA) method uses a Hazard Rating Number system. Referencing a table, the most appropriate phrase that applies to the hazard is chosen, the corresponding score results in a hazard rating number (HRN), which corresponds to the level of risk. The PHA takes into consideration: The likelihood of a person or persons coming
into contact with a hazard The degree of possible harm that could
be caused The frequency of exposure The number of people at risk at the same time Control measures can then be applied to
mitigate the risk: Design the hazard out. Remove the need for man-machine interface. Design-in safeguards. Reduce the possibility of occurrence. Reduce the degree of harm. Warn and inform machine operators (but only
if you can achieve adequate safety). Once the control measures have been
implemented, a re-assessment must then be actioned to ensure that they provide an adequate level of safety. The process is repeated until an adequate level of safety is achieved.
CONSISTENT COMPLIANCE Section 6 of PUWER requires that inspections must be repeated ‘at suitable intervals’ if machines are exposed to conditions that may lead to deterioration. In reality, every machine is exposed to conditions that may lead to deterioration, so the requirement effectively means that they must all be regularly inspected. Although, risk assessments must therefore
be conducted conscientiously and at appropriate intervals, we still visit sites that simply forget and have not taken any action for five years or more. The answer here is to set up an internal
process, overseen by an individual who ensures risk assessments are carried out according to an agreed schedule. Creating an internal procedure in this way successfully integrates risk assessment into the everyday working practices. It is not something that is stuck on a shelf and forgotten. PUWER requires that the persons who
determine the nature of the assessments, and carry them out, should be competent to do so. However, the failures we see on site are often due to a lack of appropriate internal expertise and physical resource to do an in-depth and correct assessment of all machinery. A decision to ‘make do’ or not invest in the appropriate expertise could result in expensive fines, or worse still prove fatal to machinery end-users.
TÜV SÜD
www.tuvsud.com/en-gb
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