PUWER

1
CE

• PUWER

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Which legislation applies?
Product legislation Free movement of goods
Employment legislation Employee protection
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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

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Supplying new machinery

• Manufacturers duties
• Design for safety
• Eliminate hazards
• Produce TCF
• Write manual
• Issue declaration of conformity
• Fix CE mark

• Purchaser

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UK HS 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

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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

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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

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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

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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

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What is maintenance?
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Are these maintenance ?

• Adjustments ?
• Servicing?
• Lubrication?
• Cleaning?
• Inspection?
• Overhaul?

• Repair?
• Minor modification?
• Software changes?
• Major modification?
• Redesign?

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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

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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

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Conformity to EU legislation

• PUWER 98 Regulation 10
• Obligation to choose CE marked equipment
• Obligation to check that CE mark is valid
• new requirement

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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

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PUWER 98

• Measures to bring pre CE marked machines up to
  standard
• 20 - Stability
• 21 - Lighting
• 22 - Maintenance operations
• 23 - Markings
• 24 - Warnings

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PUWER 98

• Regulations 25-30
• Mobile Equipment
• Regulations 31-35
• Power presses
• Regulations 36-39
• Procedural
• new requirements

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What about modifications?
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• Modifications that are part of maintenance
• Covered by PUWER 98
• No risk assessment
• No documentation
• No CE

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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

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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

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Software modifications

• PUWER
• Any modification described in the manual

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Changes of Use

• PUWER
• Any use described in the manual

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Other modifications

• Carry out risk assessment
• Will the existing design be suitable/safe when
  the the proposed modification has taken place?

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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

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(No Transcript)
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Electrical modifications

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

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Software modifications

• MHSWR/PUWER
• Any modification not described in the manual

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Assembly modifications

• MHSWR/PUWER
• Change of use of assembly
• Handling new food product
• Rearranging independently controlled machines

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Changes of Use

• MHSWR/PUWER
• Uses similar to those described in the manual

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Significant modifications

• Modification compromises original equipment
  design
• Considered as new machines

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What is a significant modification?
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Mechanical modifications

• Machinery Directive
• Adding assemblies not in manual
• Replacing components with ones that work in a
  different way

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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

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Software modifications

• Machinery Directive
• Any modification that could compromise the safety
  of the the machine

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Assembly modifications

• Machinery Directive
• Significant change of use of assembly
• Modifications to machines to create assembly

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Changes of Use

• Machinery Directive
• Uses specifically excluded in the manual

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Modifications

• 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