In the Industry 4.0 era, there is a multitude of equipment, technology and site options to bring any manufacturing operation bang up-to-date
Managing ageing assets was cited as the 2nd biggest day to day challenge by nearly 1,000 procurement professionals, in the annual Indirect procurement report for Maintenance, Repair and Operations (MRO), carried out by RS Components and the Chartered Institute of Procurement and Supply.
Typically when looking to invest in new machinery, or to simply maintain, improve or upgrade equipment that still has plenty of life left in it, your main considerations will usually be around cost, future-proofing and smooth integration to minimise disruption and downtime. In this scenario, one very important factor can often go amiss – safety in an aging workplace, where the aging aspect is that of the equipment, not the people.
While carrying out such works to improve equipment and sites, it’s crucial to ensure staff safety isn’t compromised. Considering machine safety regulations, the rules required when extending or altering electrical supplies – as well as reviewing risk assessments for the required PPE – is something you should prioritise. We’re here to help you navigate the main considerations.
Machinery modification and staying compliant
After making an initial investment in any equipment, it’s right to expect to get full value from it over its lifespan, but it’s equally important to ensure that equipment continues to be compliant throughout its working life. The Use of Work Equipment Directive 2009/104/EC was implemented into UK law under the Provision and Use of Work Equipment Regulations 1998 - more commonly known as PUWER98. This directive states that during the lifetime of machinery, employers must take measures to ensure that machinery is kept at a level that enables it to continue to comply with the provisions applicable at the time of its manufacture. This of course means staying on top of maintenance to keep the machine operating optimally, but also means that in the event of modifications – something many businesses are implementing to extend the life of their equipment – the machine must still conform to the Machinery Directive.
In the event of substantial modifications, the machine will be treated as new, and therefore will need to go through a conformity assessment as all new machines do when first brought to market. While it can be difficult to define what constitutes a substantial change, guidance from the Health and Safety Executive and some European bodies provide some guidance on this. The main considerations are around whether the modifications present any new hazards or risks, whether any technology has significantly changed, and whether the limits of the machine have been changed. For instance, the fitting of a computerised or PLC control to a machine which was formerly manual might be considered a substantial change, whereas a like-for-like component replacement might not.
It is also important to consider compliance around electrical installations. The 18th Edition of BS 7671 came into full effect on 1st January 2019 - a set of requirements for electrical installations that is just as relevant in the industrial and commercial world as in the domestic. It states that any significant electrical work must carried out by a suitably qualified electrician – ideally with certification – and the age of the original installation and how substantial the work is must be considered, to ensure it meets the stated requirements. As well as potentially voiding commercial insurance if inspections following an incident suggest incorrect electrical installation, failure to comply can led to serious consequences if problems occur post re-work, and the safety of employees put at risk.
Keeping workers safe in times of change
In the way significant changes made to machinery and electrical installations are subject to compliance and re-assessment, the same applies to personal protective equipment (PPE) provided to operators and staff. Ascertaining that the PPE provides the correct level of protection, as well as ensuring, as the process could now be considered ‘new’, that the PPE complies with the current standards, is required.
One example of change in this area is the European Glove Legislation in 2016. The standard specifies the testing, marking and performance levels required for gloves protecting against mechanical risks such as abrasion, blade cut, tear, puncture and where relevant, impact. A revision to this legislation involved a new test being introduced to determine cut protection, with the cut test being designed to be a more realistic representation of a cut injury, using a straight blade to perform one cut at a constant speed and force.
As well as PPE, site safety in relation to the environment should be paramount at all times. There are emergency safety elements that are vital when needed, but can often be forgotten about in the case of refurbishments and refits. One such example is emergency lighting - forgotten lighting that needs to work when required. It is vital not to forget these simple but essential safety systems. There is evidence that since the 2016 update to the code of practice for the emergency lighting of premises (BS 5266-1:2016) many installations may have been modified without review or have simply not been reviewed and are potentially non-compliant with current requirements.Standards state that any change to an escape route requires a corresponding change to the lighting, and a new risk assessment must be conducted before the refurbished area can be deemed fit for purpose. Building owners and businesses should not see emergency lighting as a ‘fit-and-forget’ solution, and consider on-going maintenance costs as well as up-front costs of refurbishment, in order to remain compliant and of course, keep workers safe.
The workplace is an ever-evolving entity, with the arrival of new technologies, products and best practice reviews. Whether changes are significant, small, or even non-existent, there are both requirements and opportunities to embrace the current workplace safety products and best practice. Working with a partner such as RS will allow you to find out more about the options available and learn about the benefits they can bring to your workplace and employees, to ensure your business is efficient, compliant, and most of all, safe.