When PUWER is not enough

Many employers assume that if they carry out regular inspections of production machines, in line with the Provision and Use of Work Equipment Regulations (PUWER), that they have done all that is necessary to meet their legal obligations.

In particular, responsible organisations are careful to ensure that their machines are inspected in line with Section 6 of PUWER, which includes a requirement that if machines are exposed to conditions that may lead to deterioration, the inspections must be repeated "at suitable intervals". Since, in reality, every machine is exposed to conditions that may lead to deterioration, the requirement effectively means that all machines must be regularly inspected.

It would seem reasonable to assume that, provided these PUWER inspections are conducted conscientiously and at appropriate intervals, machinery is safe. Unfortunately, if that machinery incorporates electro-sensitive protective equipment (ESPE), this may not be the case.

ESPE includes, light guards and laser scanners, and is increasingly taking the place of traditional guarding on machines. Because of the growing popularity of ESPE and the need to ensure that it is properly used and maintained, the Health and Safety Executive (HSE) has published guidance note HSG180, ‘Application of electro-sensitive equipment using light curtains and light beam devices to machinery’.

The section of HSG180 that deals with inspection refers directly to Section 6 of PUWER and also states that "inspection and testing is required where the safe operation [of the ESPE] is critically dependent on its condition in use and deterioration would lead to a significant risk to the operator or other worker. If this is the case, then installations using ESPE should be inspected at suitable intervals."

The right timing

Of course, this raises the question of what a suitable interval is. The answer is provided in paragraph 124 of HSG180, which states that "the recommended maximum period between each periodic inspection and test is six months for type 4 ESPE and twelve months for type 2 ESPE, but this will depend on the equipment it is fitted to and the risk as a whole."

The types of ESPE referred to in HSG180 are defined in IEC 61496-1, ‘Safety of machinery, Electro-sensitive protective equipment; Part 1: General requirements and tests’. Type 2 ESPE has a means of periodic test to reveal a failure to danger, while Type 4 will not fail to danger for a single fault and is resistant to an accumulation of single faults.

By now it will be clear that the frequency of periodic testing required for ESPE depends on multiple factors, and that a six-month interval will apply in many cases. Now consider the periodic PUWER assessments. There is, of course, no simple answer to the question of how often these should be carried out, but the norm seems to be annual assessments. In many cases this will not be regular enough to meet the recommendations of HSG180 for ESPE installed on a machine. This means that that inspection of ESPE must be treated as a separate task, and not simply as part of the routine PUWER assessments.

The right person

HSG180 also raises the issue of the competence of the person performing the inspection as there are many factors that require skilful evaluation. These include ensuring that the equipment is the correct distance from the danger zone; ensuring suitable safeguards prevent access to the danger zone from directions not covered by the ESPE; testing the overall response time and the detection capability; inspecting the stopping performance monitor; and testing the primary machine control elements to ensure correct functionality.

Once the ESPE inspection has been completed it must also be documented so that evidence can be produced to verify that the appropriate inspection regime has been followed.

The use of ESPE on machines offers many benefits and, if correctly applied, can provide levels of safety at least as good as those offered by more conventional guarding and protection techniques. However, to ensure that ESPE dependably fulfils its purpose, simply relying on routine PUWER inspections is not enough and it must be regularly inspected and tested against the HSE guidance note HSG180. So, while this topic remains fresh in your mind, it is advisable to start making your ESPE inspection plans right now.

TÜV SÜD PMSS has a new chairman and divisional director

Alan Chivers, founder and CEO of renewable energy consulting firm PMSS has been appointed as Chairman of the company, and will, over the coming month’s handover certain day-to-day responsibilities for the TÜV SÜD renewable energy division to Scott Craig, in the role of Divisional Director.

To read the full article, please click here.

Upcoming free webinar: 'Machinery Total Compliance Solutions'

TÜV SÜD Product Service will be hosting a free webinar about machinery safety compliance on Wednesday 11th December 2013 at 2pm.

Paul Laidler, Machinery Division Director at TÜV SÜD Product Service will provide a presentation covering the complete scope of activities that companies can implement to ensure that their machinery is safe, reliable and compliant. This will include topics such as understanding of essential machinery safety legislation, PUWER assessments, CE marking of machinery, functional safety compliance, machine guarding and remedial engineering solutions.

Click here to register

TÜV SÜD and KTL to cooperate over IEC 61850

The international technical services provider TÜV SÜD and state-owned Korea Testing Laboratory (KTL) plan to cooperate closely over IEC 61850 implementation in the future. The two parties signed a Memorandum of Understanding (MoU) to this effect in Munich. The international IEC 61850 standard provides the basis for communication in smart grids.

To read the full article, please click here.

TÜV SÜD 2013: Revenue of around EUR 2 billion and 1,200 new jobs

TÜV SÜD again lives up to its reputation as a job engine. At the end of 2013, the technical services company employs 20,000 staff worldwide – a new record, and over 1,200 experts more than in 2012."This year has been a continuation of our sustainable success story. Every year since 2005, we have created at least 1,000 new jobs", said Dr Axel Stepken, Chairman of the Board of Management of TÜV SÜD AG, at today's year-end financial results conference in Munich.

To read the full article, please click here.

TÜV SÜD Product Service to host free webinar about battery testing and certification

This month’s complimentary webinar from TÜV SÜD Product Service will be held on 21th November and is titled 'Introduction to Battery Testing and Certification'.

The presentation will provide an introduction to Battery testing and certification. TÜV SÜD experts from the UK and France will cover a number of topics which will include safety and performance testing of batteries, examples of a typical test program, safety requirements for transporting batteries and battery certification.

For more information, click HERE or click HERE to register for this webinar.

TÜV SÜD Inaugurates Testing Center in Xiamen

TÜV SÜD, a leading global inspection, testing and certification provider, has launched its new testing center in Xiamen. Dr. -Ing. Axel Stepken, Chairman of the Board of Management of TÜV SÜD AG, and Mr. Dirk von Wahl, President CEO of TÜV SÜD Greater China, attended the ceremony. As TÜV SÜD's inaugural testing facility in Fujian Province, China, specializing in the textile and footwear industry, the Xiamen testing center will partner local clients with services backed by global experience, leading industry expertise and state-of-the-art facilities.

The center aims to facilitate the transformation and upgrade of China’s consumer manufacturing industry by increasing the international competitiveness of China’s textile and footwear companies through a locally based diversified one-stop service with nationwide coverage. During the trip, Dr. -Ing. Axel Stepken met with the leader from General Administration of Quality Supervision, Inspection and Quarantine of P.R.C. (AQSIQ) and the both parties exchanged the experience in EU market entry and supervision mechanisms and TÜV SÜD’s 150 years of marketization.

Please click here to read the full article.