Power Tools Are Us Machinery Directive Report Construction Essay

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What is a Machine? - It is defined under the Machinery Directive 2006/42/EC as ' an assembly of linked parts or components, at least one of which moves'

The Machinery Directive 2006/42/EC (Hereafter called The Directive) provides the harmonisation of the essential health and safety requirements for machinery in Europe and is bought into force in the United Kingdom through the Supply of Machinery (Safety) Regulations 2008.

As the power operated hand tools that you manufacture do not come under Annex B of The Supply of Machinery (Safety) Regulations 2008 - ' Machinery excluded from the Regulations' ,they must comply with the legislation.

The main legislation that your company needs to comply with is:

The Supply of Machinery (Safety) Regulations 1992, which implement The Directive in the United Kingdom, and which contain detailed requirements for manufacturing safe new machinery;

the Health and Safety at Work etc Act 1974, which contains general requirements for the manufacture and supply of safe workplace machinery (including second-hand machinery);

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The Provision and Use of Work Equipment Regulations 1998

Electrical Equipment (Safety) Regulations 1994, which apply to most electrically powered machinery used in workplaces; and

Other pieces of legislation that stem from the main legislation which will be explained later in this report.

Complying with the Legislation

The vast majority of machinery may be self certified by you ,the manufacturer, who must meet the administrative and protective requirements of The Directive. Under The Directive most machinery supplied in the United Kingdom has to carry CE marking (which means it is safe to use) and its supporting documentation and must satisfy wide ranging health and safety requirements. This applies to everywhere in the European Union so compliant machinery can be supplied to any member European Union state. To comply, each different tool must have the following : the requisite technical file, Declaration of Conformity and CE marking and is in fact 'safe' (Meaning that when the equipment is properly installed and maintained and used for its intended purpose, it will not endanger the health or result in death or injury)

Failure to comply means that the machinery cannot be supplied on the UK market and the company or designated responsible person may be convicted or subject to a fine dependent on the scale of the compliance failure. This could cost the company a lot of money and reduce their reputation.

The Obligations of a Responsible Person

In order to comply with these regulations and draw up the necessary paperwork your company must designate a responsible person.( Supply of Machinery (Safety) Regulations).

This person then needs to

Ensure that the power tools manufactured by you and their safety components conform to the essential Health and Safety requirements in Schedule Three of the Supply of Machinery (Safety) Regulations.(See section below - Ensuring Machinery Safety)and in the harmonised British Standard for machinery safety - BSEN292 parts one and two - Safety of Machines. Basic concepts, general principles for design. Basic terminology, methodology. This requires a risk assessment. A harmonised British Standard such as BSEN1050 - Safety of Machinery. Principles of Risk Assessments should be used. (Barrett, Howells, 2000) that they conform to a harmonised standard applicable to the particular class of machine in question (for example BS EN ISO 28927-5:2009 - Hand-held portable power tools. Test methods for evaluation of vibration emission. Drills and impact drills ).

The responsible person needs to draw up a technical file for each different tool. This must contain technical specifications and drawings, details of essential safety requirements and standards complied with, precautions taken and tests carried out. Information documents such as operating instructions must also be provided in the language of the user. This file must be kept for at least ten years.

They need to make a declaration of conformity. This must contain the address of the manufacturer and serial number. It is a statement which confirms the identity of the manufacturer and the machinery for which they are claiming compliance. It has to be signed to confirm that the correct procedures have been followed

The responsible person needs to CE mark each different tool. This needs to be affixed in plain view to indicate compliance. It must show the year of manufacture, a serial number, and other ratings as required by the relevant standards. It can only be affixed once the tool complies to all the relevant directives and has all of the above paperwork.

Ensuring Machinery Safety.

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The company needs to ensure that the machinery can be used safely. They must identify the health and safety risks that are associated with each piece of machinery which mechanical and non -mechanical hazards associate . The British Standards document- BS EN 292 Safety of machinery, (parts 1&2) classifies mechanical hazards as follows:

Entanglement i.e. of hair or clothing in revolving drills, friction or abrasion, cutting, shearing, stabbing/puncturing, impact, crushing, drawing in and ejection.

Non mechanical hazards that are relevant to the powered hand tools are electricity (i.e. shocks, fires), noise, vibration, ergonomics ad manual handling.

The likely risks from all of the above need to be assessed and these risks eliminated. If the risks cannot be eliminated then measures need to be taken to prevent the likelihood of injury.

For the mechanical hazards the Provision and Use of Work Equipment Regulations requires effective measures to be taken (so far as it is reasonably practicable) to either prevent access to any dangerous part of the machinery or stop any movement of any dangerous part of machinery before any part of a person enters the dangerous area.

The measures to be taken must be in accordance with the following hierarchy:-

Fixed guard (where practicable, but where or to the extent that it does not:

Other guards or protection devices, where practicable, but where or to the extent that does not:

Protection appliances such as holders or push sticks (for example for a small table saw), but where or to the extent that does not:

Information, instruction, training and supervision.

For the non mechanical risks the following should be undertaken

Electricity: This is covered by the The Electrical Equipment (Safety) Regulations 1994. It concerns all equipment designed for use within the voltage ranges 50 V ac to 1000 V ac and 75 V dc to 1500 V dc. All electrical equipment must be safe i.e that as far as is reasonably practicable the tools will not cause injury or death to a person. The equipment should be designed and and constructed to ensure it is safe when connected to any electricity supply. Electrical equipment will be presumed to satisfy this requirement if it is constructed to include protective earthing, is double insulated or provides an equivalent level of safety. Arcs or temperatures that can cause a danger must not be produced.

Noise : This is covered by the Supply of Machinery (Safety) Regulations 1998 and the Noise at Work Regulations 1989. Each tool must be tested before the point of any sale and made sure that it is within a certain decibel level. If it goes above this level then safeguards such as noise dampening enclosures may be considered. As a designer and supplier of the tools you should choose designs and materials which give a quiet running for example nylon gears, belt drives. If the tool is noisy the recommended Personal Protective Equipment should be recommended in the manual that accompanies the tool.

Vibration. Again this is covered by the Supply of Machinery (Safety) Regulations 1998 and must be tested for and minimised as much as possible. Vibration sources should be isolated within the tool and even eliminated if possible. All new tools must take into consideration best available technologies to ensure vibration is, if not eliminated, then reduced as far as possible. If it cannot be eliminated, as the supplier you must provide information about the risk of vibration. (HSE 'Reducing Risk Of Hand-Arm Vibration Injury From Hand Held Power Tools.) Vibration emission data needs be to reported and can be done via harmonised standards such as BS EN 1033:1996 Hand-arm vibration - Laboratory measurement of vibration at the grip surface of hand-guided machinery - General (in revision).

The Health and Safety Executive (HSE) has just launched a new strategy called the Noise and Hand Arm Vibration Programme. (HSE. http://www.hse.gov.uk/vibration/hav/workingwithus.htm). It is aimed at eliminating new noise induced hearing damage as an occupational disease by 2030 and controlling new cases of hand-arm vibration syndrome by 2015. One of the industries it is going to be targeting is the construction industry and the HSE is going to work closely with suppliers to the industry to ensure they know how to meet their new strategy.

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Ergonomics of the tools should be considered. This should be considered when designing all the tools. An easy to use interface should be applied to the design if possible and such things as repetitive strain injury should be taken into consideration and prevented, for example is the use of the machine repetitive and can this be varied in any way. Guidance for ergonomic use should be placed in the users manual.

Finally, manual handling of the tools should be considered. More than a quarter of the accidents reported each year to the enforcing authorities in the United Kingdom are associated with manual handling (Marsh, L. 2007) Assessments should be made of each tool i.e. weight, correct way to handle and hold and details of such placed in the user guide under correct handling procedures.

As your tools are going to be used in the construction industry, then specific design requirements for their safe use should be considered. For example, they may be being used at height on a scaffold hence the tool, for example a drill, may need to have a loop in the shaft or somewhere on the design so there can be a method for attaching it to part of the scaffold so that it cannot fall and potentially injure somebody below. People working in the construction industry may also be wearing specific personal protective equipment (PPE) which needs to be considered so that such things as handling tools with gloves is not uncomfortable.

Hence in summary. You as a supplier are bound by law under the Machinery Directive 2006/42/EC and hence The Supply of Machinery (Safety) Regulations 2008 to ensure all your tools supplied are safe to use. This includes looking at all aspects and impacts of the tools to be supplied and ensuring they meet the regulations as stated above and have had all the necessary test, risk assessments and are accompanied by all the necessary paperwork. The tools also need to be looked at in respect of the construction industry as companies in this industry will be looking for safety and comfortable handling from the tools they buy and also will be working the HSE on vibration and noise. Hence is will be good for your business to comply with all of the legislation and work with the enforcers.