1. Introduction
2. Obligations of employers
The employer is required to ensure that the machinery available to employees are originally designed or appropriately adapted to the performance of the applicable operation so that they can be used without threat to the safety or health of the employees.
In case there is no possibility of ensuring the operation of machines without risk, the employer is required to take necessary steps to minimise the risk.
The interpretation of the requirements of Social Directives is made more difficult by the fact that they are not described in detail in harmonised standards, like the essential requirements of Economic Directives. For this reason, older machines can be assessed by the comparison of the solutions implemented in them to the solutions of new machines as well as using the requirements of applicable standards harmonised with economic directives. However, the application of the above does not mean that the requirements should be exactly the same. This reasoning would lead to the absurd situation where the technical requirements of social directives would become unnecessary and only the requirements of economic directives would be applicable, resulting in decommissioning of nearly all older machines.
It is to be remembered that the assessment of requirements compliance in the case of inaccurate provisions should be primarily based on risk assessment.
One very important requirement for the employer is ensuring that the woodworking machines are compliant with minimum OSH requirements for their whole period of use in the facility.
3. Types of inspection
All types of inspection serve this purpose:
§ initial, after installation and before commissioning and first use of the machine (equipment) or after installation in different work station or another location,
§ periodic, at time intervals required by regulation or specified by the employer,
§ special, in the case of possible deterioration of the safety level related to the machine, as a result of, for example:
- modifications,
- natural phenomena (e.g. flood, fire),
- extended machine downtime,
- dangerous damage or accidents at work.
4. Inspections of machines in use
The inspections may be provided by institutions operating based on an independent set of regulations or appropriately qualified persons authorised by the employer.
It is recommended that the assessment team is composed of persons with complementary work experience, qualifications and competence, in particular: OSH inspector, chief mechanical engineer, chief electrical/power engineer, shift foreman and machine operator.
In the case of initial inspections, the machine should be assessed for compliance with all requirements. The same should be provided for special inspections, unless it is certain that some features remain unchanged. They can be omitted during the inspection.
The inspections are governed by control checklists according to:
§ Directive 2009/104/EC concerning the minimum safety and health requirements for the use of work equipment by workers at work (resolutions concerning the minimum safety and health requirements for the use of work equipment by workers at work)
§ National regulations.
Planning actions related to discovered non-compliances should be governed by solutions used in new machines of the same type or by risk analysis pertaining to the matters in which non-compliances were discovered.
In the case of periodic inspections, the procedures may be somewhat different. The scope of these inspections, unless otherwise specified by independent regulations, may include the most crucial, safety-related elements. They may include checking only those safety requirements with possibility of a different result, i.e. pertaining to elements subject to wear or impact (e.g. working tools, guards, brakes) or the variable features of machines (e.g. electrical measurements, harmful substances emission). It is not always required to do the full inspection of the machine. However, the periodic inspection should include the scope necessary to ensure that the minimum safety requirements described in resolutions are still fulfilled.
The results of the inspections should be recorded and maintained to be available on request of interested institutions, in particular work conditions supervision and inspection bodies, for the period of 5 years from the conclusion of the inspection, unless otherwise specified by independent regulations.
Records from the last inspection should always we available at the equipment operation location.
5. Inspection of a new machine supplied
The employer should, in their own interest, control the compliance and completeness of each new machine supplied intended for use at their facility. This does not mean another compliance assessment, but checking whether the labelling, documentation and auxiliary equipment of the supplied machine are compliant with the general requirements of the 2006/42/EC directive.
For this reason, the employer should require that all new machines (new introduction to the market or use in the European Union) come with:
· Operation and Maintenance Manual (OMM)
· EC Declaration of Conformity
· full labelling (including the CE mark)
· special equipment and accessories
The contents of the operation manual should be compliant with directive 2006/42/EC. The manual should contain all the data, drawings and information as well as:
· a copy of the EC declaration of conformity for the machine and should be:
· made out in at least one of the languages of the EU member states – inscription “Original manual”
· translated to the language or languages of the country of the user – inscription “Translation of the original manual”
The EC declaration of conformity should be made out in the same languages as the operation manual and should contain:
· name and address of the manufacturer or authorised representative;
· name and address of a natural person or name of a legal person with EU address of residence, authorised to prepare technical documentation;
· full identification of the machine;
· confirmation of conformity with the machinery directive and other directives applicable to the machine;
· number of the notified body in the case of the full quality assurance procedure;
· number of the notified body and the certificate No in the case of EC-type examination procedure;
· compliance with harmonised standards and other standards – if used for the purposes of compliance assessment;
· name, position and signature of the authorised person;
· place and date of issue
The marking should be visible, legible and permanent (recommended methods include engraving, stamping, embossing, screen printing, etc. on riveted plates or aluminium foil permanently affixed to the machine) and should include at least:
· name and address of the manufacturer and authorised representative – if any;
· machine determination (name);
· CE marking;
· designation of series or type of the machine;
· serial number, if any;
· year of production of the machine – interpreted as the year of production completion;
· appropriate marking for machines intended for use in potentially explosive atmospheres;
· full information regarding the type and necessary for the assurance of safety, such as: top speed of rotating elements, largest diameter of used tools, weight;
· data regarding the weight of the machine and its parts moved during transportation;
· electrical specifications (not directly specified in the NMD)
CE marking must be placed in immediate proximity to the name of the manufacturer or its authorised representative and should be provided using the same technology, which results in the practical effect of manufacturers placing the CE mark directly on the machine’s nameplate.
Accessories and special equipment mean tools, instruments and other accessories required for the adjustments, maintenance and operation of the machine without generating risks. This means that especially all the non-typical, special equipment elements should be provided. Typical tools, spanners, screwdrivers, etc. may, but do not have to, be supplied with the machine and the user – employer should check whether the four aforementioned item groups were provided and are compliant – e.g. whether the operation manual and declaration are in Polish.
6. Examples
6.1. Case study No 1. Lack of guards and protective equipment.
The wood saw-bench (fig. 1) in use is not equipped with tool (circular saw) guards and the belt transmission drive. Material guide was also missing. The saw-bench was not equipped with the kerf splitting wedge – a device required in this type of machines for protection against the deflection of processed material.
Probably, the safety equipment was dismantled on purpose to “facilitate” the operation and was lost.
Non-compliances:
· Machines posing the risk of items falling or being deflected are equipped with protection measures appropriate for the risk; and
Fig. 1 Wood saw-bench with removed guards and protective equipment
· In case of possible contact with moving machine parts resulting in potential accidents, guards or other protective devices should be applied to prevent access to the hazard area or to stop the movement of dangerous parts.
Preventive measures
Equipping the saw-bench with:
· fixed belt transmission guard;
· adjustable circular saw top guard;
· adjustable circular saw bottom guard (due to the exposed saw-bench design);
· guide;
· splitting wedge compatible with the installed circular saw.
6.2. Case study No 2. Lack of chain transmission guard
The wood saw-bench (fig. 2a) in use had an unguarded chain transmission of the saw unit travel assembly which resulted in the risk of seizure in the areas near the transmission drive wheel areas. For technical reasons, a full guard of the whole chain transmission was not recommended, therefore guards were installed only in danger zones.
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Fig. 2 Wood saw-bench chain transmission in the seizure risk zone
Non-compliance:
· In the case of possible contact with moving machine parts resulting in potential accidents, guards or other protective devices should be applied to prevent access to the hazard area or to stop the movement of dangerous parts.
Preventive measures
Equipping the saw-bench with:
· fixed chain transmission drive wheel guards.
6.3. Case study No 3. Lack of machine stability
The woodworking machine (fig. 3) was not secured to the foundation by the user. Due to the light machine construction and the occurrence of vibrations, the machine may be displaced during operation, resulting in losing its stability.
Non-compliance:
· Machines and parts of such machines must, where necessary for the safety and health of workers, be stabilised by clamping or some other means.
Fig. 3 Leg of the woodworking machine not secured to the foundation
Preventive measures
Permanent securing of the machine to the foundation using the bolt holes in the legs provided for this purpose.
6.4. Case study No 4. Lack of warning labels
Permanent guard of the dangerous machine parts (fig. 4) was not labelled. This results in a potential risk to employees opening the guard.
Non-compliance:
· Machines are equipped with warning signs and labels necessary for the safety of employees.
Fig. 4 Permanent guard of the dangerous parts of the woodworking machine after labelling
Preventive measures
Labelling the guard with a warning pictogram and additional labelling of the direction of revolutions of the dangerous moving parts of the machine.