SAFEGUARDING PALLETISERS IN THE WORKPLACE WAREHOUSING, HANDLING & STORAGE
MACHINERY & MACHINE SAFETY
he Health and Safety Executive (HSE) has recognised palletisers and depalletisers as a class of machine that requires particular attention as injuries can be severe or even fatal, and it outlines safety principles for palletisers. This includes guarding of machine entry or exit points, with methods including interlocking moveable guards, captive key exchange systems or electro-sensitive protection equipment (ESPE), such as light curtains. Due to the size of palletisers, full body access is a common occurrence. If not appropriately guarded, unsafe access is therefore possible, as well as unsafe transfer between zones within the machine. This means that personnel can be in the machinery without the knowledge of those outside. Where light curtains are in place, it should be safe to assume that operators are fully protected, but we all too regularly see them positioned incorrectly so that they afford no safety benefit. One common area of concern is the positioning and detection capabilities of the light curtain as they tend to be positioned to detect the pallet, rather than the pallet load. This means that the gap between the light curtain and the pallet load is too large, which allows entry when in a muted state. It is therefore advised that ‘EN 415-4: Palletisers and Depalletisers’ is referenced for additional information. One option to improve safety at entry and exit points is to use a captive key exchange system. A mechanical key must be removed to isolate the machine and release another key, which the person takes with them into the palletiser. While the key is with the person, they are safe as under no circumstances can the machinery be re-started until that key is returned. Another common sight is the lack of infill panels between conveyor rollers, which is also a requirement within EN 415-4 to prevent
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trapping and crushing between the pallet and the roller. If fitted, they would prevent injury if limbs came into contact between the conveyor and the pallet. It is also essential that guards are of the correct dimensions to stop people getting under or over them, and their height must therefore be selected using Table 2 of EN ISO 13857. However, these problems are not limited to old legacy machinery with retrofitted guarding, as they are still a common occurrence with new machinery carrying CE or UKCA marking. In such cases, if the machinery manufacturer has installed guarding incorrectly, they can be prosecuted under the Supply of Machinery (Safety) Regulations.
The safety standard that should be followed to ensure safety is BS EN 415-4: Palletisers and Depalletisers. Originally published in 1997 by CEN, the European Committee for Standardisation, a decision was taken in 2006 to completely revise the Standard, taking into account changes in machinery technology. CEN’s aim was to publish the revised version of EN 415-4 by 2011, but it is still under development with further reviews conducted in 2019 and 2021. This means that while EN 415-4 had been harmonised to the old Machinery Directive 98/37/EC, when this was replaced by 2006/42/EC on 30 December 2009, it ceased to be a harmonised standard and is also not within the designated standards list for UKCA. So, technically there is no standard for palletisers and depalletisers that provides a presumption of conformity to the essential health and safety requirements of the Machinery Directive for CE marking, or The Supply of Machinery (Safety) Regulations for UKCA. While this means that machinery owners cannot be prosecuted under EN 415-4, they
Darren Hugheston-Roberts, Head of Machinery Safety at TÜV SÜD, a global product testing and certification organisation.
could still be prosecuted under the Provision and Use of Work Equipment Regulations (PUWER), or machinery suppliers could be prosecuted under the Supply of Machinery Regulations, which relates to UKCA / CE Marking requirements.
TÜV SÜD’s advice is to continue using the standard as it remains current and indicates ‘best practice’ and shows due diligence on the part of the machinery owner, until its revision is complete, published and it is harmonised and designated.
To immediately identify any issues, it is recommended that a thorough and competent PUWER assessment should be completed before any new machinery goes into operation. This assessment is vital in identifying any machinery non-conformity that can then be rectified with the manufacturer. It will also highlight any issues within the installed environment, or gaps in the managerial procedures. This will ensure the safety of anyone interacting with the equipment, and also ensure that the levels of safety at the commissioning stage do not deteriorate over time. The failures that we see on site are often due to a lack of appropriate internal expertise and physical resource to do an in-depth and correct PUWER assessment of all machinery. With palletiser machinery being on such a large and complex scale, the issue of time and expertise availability is further magnified. A decision to ‘make do’ or not invest in the appropriate expertise to perform these vital PUWER assessments on palletiser and depalletiser machinery could prove fatal - the HSE statistics prove that.
TÜV SÜD
www.tuvsud.com/uk 32 NOVEMBER 2022 | FACTORY&HANDLINGSOLUTIONS 39
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