Following an unannounced spot-check visit by the Health and Safety Executive (HSE), a signmaker has received a notification of contravention recording a ‘material breach’ requiring the sign company to remedy this at their cost (as well as pay HSE fees for HSE’s intervention). HSE spot-checks is not a new phenomenon to report but the reasons behind the contravention will without a doubt affect a large number of sign companies.
What is different here is that it involves portal frame (gantry/goalpost type) flat-bed CNC routers and the (lack of) protective guarding.
Until now, it was generally regarded – rightly or wrongly – that as these machines ‘travelled’ at speeds of less than 25 metres per minute, as long as there was a guard around the drill bits/spindle when the machine was engaged and a prominent emergency stop button, then there was no need to guard the machine any further with devices designed to cut power should anyone come too close to the machine while it was operating. For the purposes of brevity, we have highlighted the relevant text from BS EN 848-3:2012 and of course, owners and operators of such machines would have done their own thorough risk assessments beforehand to comply with this standard.
- Access to impact, crushing, shearing, drawing in and entanglement points (except tools and drives) shall be prevented by fixed guards the safety distance of which shall conform to the requirements of EN ISO 13857:2008, Table 3 or Table 4, and/or by protective devices e.g. light barrier, pressure sensitive mats or bumpers.
- Where only an impact hazard is foreseeable and the maximum axis speed is below 25 m min -1 no additional protective device is required where partial movable enclosure corners are rounded to at least 20 mm radius and no hazards exist from projecting parts e.g. screws.
- Where the maximum axis speed exceeds 25 m min-1 and where an impact hazard exists (e.g. no light barrier or safety mat in accordance with 5.3.7.1.2.3.1 is provided) a trip device e.g. pressure sensitive bumpers according to 5.3.7.3 shall be provided.
- NOTE During next revision of this document the application of the 25 m/min limit for axes speed to body, arm, head, hand or fingers impact will be considered.
The current standard was published in 2012 and would be due for revision circa 2017. However, in a letter confirming the contravention, the inspector wrote “HSE considers that the router is not properly guarded and whilst I understand that this is the condition in which you purchased the machine, in order for you to permit your employees to operate the machine safely, the guarding arrangements must be improved so as to prevent access to dangerous parts”.
The BSGA has always advocated that its Members (and the sign trade itself) conform to current standards and this is no different. We must all simply adjust to the fact that HSE considers that machines without the required guarding/protective devices are no longer acceptable regardless of the running speed of the machine and the situation must be remedied at the owner/operators’ expense. Manufacturers and/or suppliers of these machines should be able to offer either a retro fit kit or advise accordingly so that you do not receive a contravention notice.
The image shown here is a representation of the type of machine that HSE targeted and is in no way an implication that this particular machine or its manufacturers/suppliers are at fault. The reason for the HSE intervention is because the owner of the machine did not have, in HSE’s view, the necessary safety guard equipment.
The BSGA recommends that you purchase machines from manufacturers and suppliers who include safety cut out facilities as part of the standard specification on all new machines as you will want to be compliant from the first day of ownership. For machines already in place, again, ask your supplier for safety equipment that can be retro-fitted. If you are considering purchasing a used model, you should include the cost of guarding/protective devices in your calculations if these are not already present.
There is an HSE Safe Working Practice information sheet covering Routers and Machining Centres which is posted on the BSGA website. Anyone can download this either by clicking here or copying and pasting this address http://signsuk.org/wp-content/uploads/2016/09/HSE-Safe-Working-Practices-Routers-and-Machining-centres-May-2014.pdf. Copies of BS EN 848-3:2012 and other associated standards are available from the BSI http://www.bsigroup.com/en-GB/
European Sign Federation