Managing the

							CE   PUWER
Which legislation applies?


      Product legislation
       Free movement of goods




     Employment legislation
         Employee protection
Product 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
Manufacturer’s duties
 Design for safety

 Eliminate hazards

 Produce TCF            Purchaser
 Write manual

 Issue declaration of
  conformity
 Fix CE mark
UK 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 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 98
   Regulations 1-3
    – 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
   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
   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 ?
   Adjustments       Repair?
   Servicing         Minor modification?
                       Software changes?
   Lubrication
   Cleaning
                       Major modification
   Inspection        Redesign
   Overhaul
Inspection
   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
   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
   PUWER 98 Regulation 10
    – Obligation to choose CE marked
      equipment
    – Obligation to check that CE mark is valid*

    *new requirement
PUWER 98
   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
   Measures to bring pre CE marked machines
    up to standard
    20 - Stability
    21 - Lighting
    22 - Maintenance operations
    23 - Markings
    24 - Warnings
PUWER 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 modifications
PUWER
   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
   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
   Any modification described in the manual
Changes of Use

PUWER
   Any use described in the manual
Other modifications
   Carry out risk assessment
   Will the existing design be
    suitable/safe when the the proposed
    modification has taken place?
Risk Assessment

   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
   Introduced 1st January 1993
               Risk Assessment
      YES                            NO
              Will existing design
                  be suitable?


                                     Machinery
 PUWER
                                     Directive


 Document
Assessment
and changes
Electrical modifications


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

MHSWR/PUWER
   Any modification not described in the
    manual
Assembly modifications
MHSWR/PUWER
   Change of use of assembly
   Handling new food product
   Rearranging independently controlled
    machines
Changes of Use

MHSWR/PUWER
   Uses similar to those described in the
    manual
Significant modifications
   Modification compromises original
    equipment design
   Considered as new machines
  What is a
 significant
modification?
Mechanical modifications
Machinery Directive
   Adding assemblies not in manual
   Replacing components with ones that
    work in a different way
Electrical 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 modifications
Machinery Directive
   Any modification that could
    compromise the safety of the the
    machine
Assembly modifications
Machinery Directive
   Significant change of use of assembly
   Modifications to machines to create
    assembly
Changes of Use

Machinery Directive
   Uses specifically excluded in the
    manual
Modifications
   Maintenance covered by PUWER

   Risk Assessment covered by MHSWR

   Modification          Modification treated
    covered by PUWER       as new
                           machines/equipment
   Documentation
    covered by PUWER
    and MHSWR