ce puwer. which legislation applies? which legislation applies? product legislation free movement of...
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CECE PUWERPUWER
Which legislation applies?Which legislation applies?
Product legislationFree movement of goods
Employment legislationEmployee protection
Product DirectivesProduct Directives
New machines/equipment– Even if for own use
New assemblies of machines– New or old machines
Old machines imported into EEA Significantly modified
machines/equipment
Supplying new machinery Supplying new machinery
Manufacturer’s duties Design for safety Eliminate hazards Produce TCF Write manual Issue declaration of
conformity Fix CE mark
Purchaser
UK H&S RegulationsUK H&S Regulations 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 98PUWER 98
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 1st January 1993– Amended 1st January 1998
PUWER 98PUWER 98 Regulations 1-3
– Procedural Regulations 5-9
4 - Suitablility of work equipment5 - Maintenance6 - Inspection*7 - Specific risks8 - Information and instructions9 - Training
*new requirement
Suitability of work equipmentSuitability of work equipment
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
MaintenanceMaintenance
PUWER 98 Regulation 5 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
What is maintenance?
Are these maintenance ?Are these maintenance ?
Adjustments Servicing Lubrication Cleaning Inspection Overhaul
Repair? Minor modification? Software changes?
Major modification Redesign
InspectionInspection
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
InspectionInspection
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 legislationConformity to EU legislation
PUWER 98 Regulation 10– Obligation to choose CE marked
equipment– Obligation to check that CE mark is valid*
*new requirement
PUWER 98PUWER 98
Measures to bring pre CE equipment up to standard11 - Dangerous parts of machines12 - Protection against specific hazards13 - High or very low temperatures14 - Controls for starting & making a significant change15 - Stop controls16 - Emergency stop controls17 - Controls18 - Control systems19 - Isolation from sources of energy
PUWER 98PUWER 98
Measures to bring pre CE marked machines up to standard20 - Stability
21 - Lighting
22 - Maintenance operations
23 - Markings
24 - Warnings
PUWER 98PUWER 98
Regulations 25-30 – Mobile Equipment*
Regulations 31-35 – Power presses*
Regulations 36-39 – Procedural
*new requirements
What about modifications?
Modifications that are part of maintenance
Covered by PUWER 98 No risk assessment No documentation No CE
Mechanical modificationsMechanical modifications
PUWERPUWER 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 modificationsElectrical modifications
PUWERPUWER Any activity described in the manual Replacing components with like
components Lowering rating of fuses or MCBs Adding e-stops Adding interlocking devices
Software modificationsSoftware modifications
PUWERPUWER Any modification described in the manual
Changes of UseChanges of Use
PUWERPUWER Any use described in the manual
Other modificationsOther modifications
Carry out risk assessment Will the existing design be
suitable/safe when the the proposed modification has taken place?
Risk AssessmentRisk Assessment
Management of Health and Safety at work Regulation 3
Every employer shall make a suitable and sufficient assessment of risks to
a) employeesb) persons not in his employment arising out of
or in connection with the conduct by him of his undertaking
Introduced 1st January 1993
YES NORisk Assessment
Will existing design be suitable?
PUWER
Document Assessment and changes
Machinery Directive
Electrical modificationsElectrical modifications
MHSWR/PUWER Adding assemblies not described in
the manual e.g. an inverter Small alterations to the circuit diagram
Software modificationsSoftware modifications
MHSWR/PUWER Any modification not described in the
manual
Assembly modificationsAssembly modifications
MHSWR/PUWER Change of use of assembly Handling new food product Rearranging independently controlled
machines
Changes of UseChanges of Use
MHSWR/PUWER Uses similar to those described in the
manual
Significant modificationsSignificant modifications
Modification compromises original equipment design
Considered as new machines
What is a significant
modification?
Mechanical modificationsMechanical modifications
Machinery Directive Adding assemblies not in manual Replacing components with ones that
work in a different way
Electrical modificationsElectrical modifications
Machinery Directive 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 modificationsSoftware modifications
Machinery Directive Any modification that could
compromise the safety of the the machine
Assembly modificationsAssembly modifications
Machinery Directive Significant change of use of assembly Modifications to machines to create
assembly
Changes of UseChanges of Use
Machinery DirectiveMachinery Directive Uses specifically excluded in the
manual
ModificationsModifications
Maintenance covered by PUWER
Risk Assessment covered by MHSWR
Modification treated as new machines/equipment
Modification covered by PUWER
Documentation covered by PUWER and MHSWR