Accidents waiting to happen05 June 2013
Common sense it may be, but all too often the use of machine guards falls way short of the legal standards. Brian Tinham talks to TÜV SÜD about problems and solutions.
Bruno Jorge, 32, of Sleaford, had his left thumb amputated after it was crushed in unguarded machinery on a production line on 26 July 2011. One month later, on 25 August, agency worker Yelena Semenchenko, 30, of Lincoln, cut her finger on the blade of a napkin-folding machine. Fast forward another 12 months and Simon Burnett, 46, of Navenby, lost all four fingers of his right hand, when it was caught between unguarded rollers.
All three incidents happened at Lincolnshire-based paper products manufacturer Staples Disposables. And all three involved inadequately guarded machinery. The firm was ordered to pay more than £116,000 in fines and costs after pleading guilty to three charges of breaching Section 2(1) of the Health and Safety at Work etc Act 1974 and one of Section 3(1).
In brief, Jorge accessed his machine to clear a blockage – normal practice on that production line – but his hand was drawn into the rollers. HSE found that, during commissioning, the manufacturer had overridden interlocked guards on the enclosure surrounding the equipment, precisely so that engineers at the Fulbeck Heath factory could access the machine. Management knew about the missing guards, but failed to act.
An investigation into the second incident, involving Semenchenko, found an electrically-interlocked guard had been removed. The company had installed the guard on the napkin-folding machine after a similar accident in 2007, for which it had been prosecuted by HSE, but then instigated a process to disable them for specific production runs. As for Burnett, the court heard that it had become standard practice to lock operators in an enclosure designed to keep them away from dangerous parts of a toilet roll manufacturing line. Supervisors and management had failed to identify and stop the practice.
Says HSE inspector David Lefever: "Staples Disposables had a poor health and safety management system, and failed to supervise factory operations... The company was well aware that machines should have interlocked guards in place to prevent people accessing dangerous moving parts of the machinery, yet it continued to put workers at risk over a prolonged period. Injury was inevitable."
Astonishing, yes, particularly given the clear requirements of the 'new' Machinery Directive 2006/42/EC (which came into force in 2009); but isolated incidents, no. Indeed, if you're thinking that, since all three happened at a site clearly lacking in terms of management oversight, such incidents must be as rare as hens' teeth, think again. HSE regularly prosecutes companies for similar offences, even though the risks and legal requirements have been well publicised. In the last few weeks alone, firms including Foreman Recycling, Genteel Associates, Bloomsbury Glass and Marcegaglia (UK) have all been fined over incidents or near misses involving inadequate and/or deliberately bypassed machine guards.
Mark Smailes, operations director at TÜV SÜD – which offers consultancy and training aimed at ensuring that industrial plants in general, and machines in particular, are fully compliant with machine guarding requirements – says he's seen it all. One of the big ones currently receiving a lot of attention from HSE, he says, is palletiser and depalletiser safety – because of the number of fatalities. The main issues here concern inadequate perimeter guarding, access doors and associated safety systems.
"They'll use interlocks, for example, but, when you close the door, the machine can start again, whether you're inside or outside," explains Smailes. "They should be using captive key exchange systems. Other problems relate to light curtains around conveyors. When pallets come through, the curtain is in mute mode, but, without physical guarding, that means operators can walk right in. EN 415 part 4 mandates a maximum gap of 200mm to the edge of the conveyor so that operators can't get past."
Allan Harris, a project engineer also with TÜV SÜD, agrees that much of this is, or should be, common sense. "If people can reach over, under or through a gap to get at a moving machine, then the chances are someone will do so," he observes. And he points to other common guarding problems on all sorts of production lines – but especially high-speed canning and bottling – particularly around conveyor sections linking each machine. "In-feeds and out-feeds should be equipped with tunnel guards ahead of the moving parts, with a minimum 850mm length. More often than not there is none or, if they have installed tunnel guarding, there's nothing to prevent access from underneath the conveyor."
Mind the gap
And much the same applies to any machinery, large or small, involving moving parts. Smailes recalls going into a paper mill and seeing a rewinding machine designed to take jumbo reels and turn them into three-ply. "It was an old machine, but guards had been fitted supposedly to prevent access to the drive area. However, people could crawl under them, because the gap was 300mm; it must not exceed 150mm. Also, the minimum guard height on high-risk machines is 1.4m from the floor, to stop people climbing over. This was 1.2m and the rest of the machine was pretty much unguarded. Had the HSE come in, they would have had an improvement or prohibition notice." And they would now have to pay the Fee for Intervention.
Both these experienced safety engineers also lament attitudes common in engineering workshops up and down the land, where milling machines, lathes, drills, etc, are frequently ignored, in terms of guarding, in the mistaken belief that trained operators are working on them so why do they need it? "They should have chuck guards, table guards on milling machines, etc. It's all in the standards, but there's just a lack of knowledge and concern out there. Too many operators and managers just don't appreciate the legal requirements."
Even when they think they understand, and employ in-house fabricators or independent workshops to manufacture and install machine guards, all too often these fall short. "We go onto plenty of sites and the guarding looks great but you check the distances and they're not adequate. So they have to pay for it all to be redone," comments Harris. And he adds: "Smaller fabricators don't tend to have the facility to CE mark their guards, so end users are having illegal guards fitted, because there's no CE mark and no certificate of conformity."
Machinery Directive 2006/42/EC
HSE's guide to buying new machinery (INDG271) makes it clear that CE marking alone is no guarantee of safety.
It is the responsibility of the end user to check that a machine is safe before it is used. They must not rely on suppliers. Why? Not least because industry statics demonstrate that suppliers make mistakes. The HSE register of convictions shows that 62% of breaches under PUWER (Provision & Use of Work Equipment Regulations) related to Regulation 11 – dangerous parts of machinery.
Since 2009, any machinery supplied in the EU has to comply with the revised European Machinery Directive 2006/42/EC, which includes significant changes in machine guarding requirements. But the devil is in the detail.
Relevant standards include: EN 953, Safety of Machinery – Guards – General Requirements; EN ISO 13857 – Safety of Machinery – Safety distances to prevent hazard zones being reached by upper and lower limbs; and EN 349 – Safety of Machinery – Minimum gaps to avoid crushing of parts of the human body. There are many others, including 'Type C' standards that apply to specific machine types. Also, the new Machinery Directive Section 1.4.1 'General requirements for guards and protective devices' ESHRs (Essential Health and Safety Requirements) now require that guards protect against the ejection of falling materials and objects.
Further, Section 18.104.22.168 has added requirements that, for fixed guards, the fixing systems must remain attached to the guards when removed – while, where possible, guards must be incapable of remaining in position without their fixings. And all of that is before we get to the safety-related systems requirements for e-stops, electronic interlocks and the like, under EN ISO 13849-1, which replaced EN 954-1 for machine builders.
Health & Safety Executive
TUV SUD Product Service Ltd
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