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Many involved in industry are blissfully unaware of the potential penalties that they are at risk of receiving if they contribute to an accident even in an indirect way (currently in QLD, up to two years jail and/or $60,000 max. fine for individuals or $300,000 for companies). This contribution may be as a result of not understanding their responsibilities in providing a safe work place or equipment. There are numerous standards that apply to safeguarding of machinery such as the AS4024 series. More standards exist to cover many specific situations (such as AS1219 Power Presses, AS2939 for industrial robot systems and AS1755 for conveyors, there are other standards relevant to specific machinery such as woodworking machinery). Some of the specific standards do not in themselves fully cover all aspects of design of safeguarding systems. Even if one feels they have followed the relevant standard there may well be another standard with even more rigid requirements that the designer/organisation is not even aware of. The Queensland Workplace Health And Safety Act 1995 (Reprint 3) section 26 states: "(3) If an advisory standard or industry code of practice states a way of managing exposure to a risk, a person discharges the person’s workplace health and safety obligation only by: (a) adopting and following a stated way that manages exposure to the risk; or (b) adopting and following another way that gives the same level of protection against the risk." The safest way to discharge one’s obligation is to be able to demonstrate that the organisation has followed a recognised standard. The organisation may choose another method of safeguarding without reference to the standards, however this is fraught with danger, as the onus will be on the organisation to prove its effectiveness. It is too late to wait until an investigation is undertaken as a result of an injury to find out that your safeguarding is not adequate. A formal, documented audit of the machinery should be undertaken to establish the level of safeguarding required. This should be recorded as evidence of how the safeguarding level was established. AS4024, "Plant 2000 Advisory Standard" and "A Guide To Practical Machine Guarding" (both available from QLD Dept. of Employment Training & Industrial Relations) provide guidance to perform an audit. The purchaser of equipment must be sure that the equipment they are purchasing, whether new or second hand is used in a manner that meets compliance with the relevant standards. A further complication is where the end user is purchasing equipment from multiple vendors that they are installing into a single installation. All the components of the system must interact efficiently and safely. No individual component can degrade the level of guarding that applies to another component or to the overall system. There are several control measures to consider to manage a risk: 1. Eliminate the risk 2. Minimise the risk 3. Where neither of the above is possible use administrative controls and appropriate personal protective equipment. Commonly minimising the risk is most appropriate. Three strategies that can be applied, often in conjunction with each other, to minimise the risk are: 1. Fixed/Interlocked Mechanical barriers. 2. Safety monitoring devices (light curtains, gate switches etc). 3. Automation of the process to remove or limit operator interaction with the moving or dangerous part of the process. Safety monitoring devices will almost always have to be used in conjunction with mechanical barriers to provide adequate protection. There are many different safety devices that can be used. The complexity and cost of the devices depend on the category of the machine being protected. AS4024.1 provides guidelines to determine the category of monitoring and interlocking required. Both mechanical guarding and safety monitoring devices alone are compliant costs. They do not assist in improving the output efficiency of the process and therefore have limited direct payback. Automation, whilst only a safety option when used in conjunction with the other two options, does provide the potential of improvement in the process and therefore can provide potential for payback. When considering the safeguarding of machinery and processes it is important to ensure that the person or organisation charged with the responsibility of implementing the safety system are aware of the relevant standards and solutions. To assist organisations to comply with these requirements and to ensure the safety of persons employed at a workplace a network of professional companies has decided to assist organisations to comply with the legislative requirements. The steps in the process are: 1 Prepare a Risk Analysis (RA) for the items of equipment will place the priority in order of considered risk. In this risk analysis identify: · Possibility of Avoiding Hazard, Severity of Potential Injury /Consequence, Frequency of Exposure · Short Term Analysis of the Level of Risk · AS4024.1 Machine Guarding Table – Category 1 – 4 · Applicable Standards. The Risk Analysis and guarding analysis will provide recommendations on Categories required and 2 Design Review To discuss the conclusions and recommendations with relevant company staff etc and review the proposed system and prepare any implementation drawings to ensure that they comply with the requirements of the Act, Regulations, Code of Practice for Plant, AS3000, AS4024.1 and other identified standard. 3 Site Installation and Commissioning – by utilisation of professional staff plan, co-ordinate and commission the solution using proven safety solution products and practices (including Electrical and Mechanical systems). 4 On completion of the implementation of the system and guarding complete an “on site test and commission” to review and test to ensure the system meets the Act and associated requirements and provide a completed signed off RA for the organisations records. SOPs can also be prepared as required. |
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