CE PUWER Which legislation applies Product legislation Free

CE PUWER

Which legislation applies? Product legislation Free movement of goods Employment legislation Employee protection

Product Directives n New machines/equipment – Even if for own use n New assemblies of machines – New or old machines n n Old machines imported into EEA Significantly modified machines/equipment

Supplying new machinery Manufacturer’s duties n Design for safety n Eliminate hazards n Produce TCF n Write manual n Issue declaration of conformity n Fix CE mark Purchaser

UK H&S Regulations n Health and Safety at Work Act – Management of health & safety at work • • • Workplace health safety & welfare Provision and use of work equipment (PUWER) Manual handling Display screen work Personal protection equipment COSHH Noise Electricity at Work Construction Design & Management CDM Lifting operations & lifting equipment

PUWER 98 n n Use of Work Equipment Directive 89/655/EEC Enacted in the UK by – – The Provision & Use of Work Equipment Regulations 1998 Applied employers providing equipment for their employees to use Introduced 1 st January 1993 Amended 1 st January 1998

PUWER 98 n Regulations 1 -3 – n Procedural Regulations 5 -9 4 - Suitablility of work equipment 5 - Maintenance 6 - Inspection* 7 - Specific risks 8 - Information and instructions 9 - Training *new requirement

Suitability of work equipment n n PUWER 98 Regulation 4 Every employer shall ensure that work equipment is so constructed or adapted as to be suitable for the purpose for which it is used or provided

Maintenance n PUWER 98 Regulation 5 n ensure that work equipment is maintained in an efficient state, in efficient working order and in good repair Ensure that where any machinery has a maintenance log the log is kept up to date n

What is maintenance?

Are these maintenance ? n n n Adjustments Servicing Lubrication Cleaning Inspection Overhaul n n n Repair? Minor modification? Software changes? Major modification Redesign

Inspection n n PUWER 98 Regulation 6 Where safety depends on installation conditions If exposed to conditions causing deterioration which is liable to result in dangerous situations Exceptional circumstances

Inspection n PUWER 98 Regulation 6 Ensure the results of and inspection is recorded and kept until the next inspection Ensure equipment is accompanied by physical evidence of the inspection if moved from one undertaking to another

Conformity to EU legislation n PUWER 98 Regulation 10 – – Obligation to choose CE marked equipment Obligation to check that CE mark is valid* *new requirement

PUWER 98 n Measures to bring pre CE equipment up to standard 11 - Dangerous parts of machines 12 -Protection against specific hazards 13 - High or very low temperatures 14 - Controls for starting & making a significant change 15 - Stop controls 16 - Emergency stop controls 17 - Controls 18 - Control systems 19 - Isolation from sources of energy

PUWER 98 n Measures to bring pre CE marked machines up to standard 20 - Stability 21 - Lighting 22 - Maintenance operations 23 - Markings 24 - Warnings

PUWER 98 n Regulations 25 -30 – Mobile Equipment* n Regulations 31 -35 – Power presses* n Regulations 36 -39 – Procedural *new requirements

What about modifications?

Modifications that are part of maintenance Ø Ø Covered by PUWER 98 No risk assessment No documentation No CE

Mechanical modifications PUWER n n n Any activity described in the manual Replacing like components with like Repairs to bring machine back to its original condition Strengthening assemblies Strengthening guards

Electrical modifications PUWER n n n Any activity described in the manual Replacing components with like components Lowering rating of fuses or MCBs Adding e-stops Adding interlocking devices

Software modifications PUWER n Any modification described in the manual

Changes of Use PUWER n Any use described in the manual

Other modifications n n Carry out risk assessment Will the existing design be suitable/safe when the proposed modification has taken place?

Risk Assessment n Management of Health and Safety at work Regulation 3 Every employer shall make a suitable and sufficient assessment of risks to a) employees b) persons not in his employment arising out of or in connection with the conduct by him of his undertaking n Introduced 1 st January 1993

Risk Assessment YES PUWER Document Assessment and changes Will existing design be suitable? NO Machinery Directive

Electrical modifications MHSWR/PUWER n n Adding assemblies not described in the manual e. g. an inverter Small alterations to the circuit diagram

Software modifications MHSWR/PUWER n Any modification not described in the manual

Assembly modifications MHSWR/PUWER n n n Change of use of assembly Handling new food product Rearranging independently controlled machines

Changes of Use MHSWR/PUWER n Uses similar to those described in the manual

Significant modifications n n Modification compromises original equipment design Considered as new machines

What is a significant modification?

Mechanical modifications Machinery Directive n n Adding assemblies not in manual Replacing components with ones that work in a different way

Electrical modifications Machinery Directive n n n Adding assemblies not described in the manual e. g. an inverter Replacing components with others that work in a different way e. g. relays with a PLC Altering circuit diagram significantly

Software modifications Machinery Directive n Any modification that could compromise the safety of the machine

Assembly modifications Machinery Directive n n Significant change of use of assembly Modifications to machines to create assembly

Changes of Use Machinery Directive n Uses specifically excluded in the manual

Modifications n Maintenance covered by PUWER n Risk Assessment covered by MHSWR n Modification covered by PUWER n Documentation covered by PUWER and MHSWR n Modification treated as new machines/equipment