Maintaining Safety
Statutory inspections are commonplace in all workplaces; inspections of plant however can be traced back in the North West to the Industrial Revolution during the textile industry boom in the mid-19th Century.
There are no statistics available on the number of incidents involving steam boilers during this time but there were numerous boiler explosions which resulted in either injuries or fatalities. An engineer from Manchester stated that by periodically testing and examining plant the likelihood of mechanical faults causing incidents/accidents would be greatly reduced (this of course would need to be carried out by a suitably trained/competent person). In 1854 the Manchester Steam Users’ Association was born and their function was to carry out inspections of steam boilers.
In 1882 the Boiler Explosions Act came into force requiring that explosions of boilers must be reported to, and investigated by, the Board of Trade to establish the reasons behind the explosions with a view to minimising future boiler explosions.
However it was another 19 years and many more explosions later before the requirement for statutory, thorough examinations to be carried out by “competent persons” was introduced into the Factories and Workshops Act 1901.
This requirement became the bench mark for companies as the first ever statutory provision requiring regular inspection of plant and machinery and paved the way for further requirements for inspection and examination under legislation to improve safety.
In 2006 the requirements for thorough examination and testing extend to the following main items of plant.
Boiler Plant/Pressure Systems
The requirements for the maintenance of the above plant have been established in the Pressure Systems Safety Regulations 2000 and define a pressure system as a system comprising of one or more vessels with associated pipe work and protective devices. It must also include liquids (this includes steam and gases stored under pressure). Under these regulations a “Written Scheme of Examination” would need to be carried out on any plant that complies with the above.
A “Written Scheme of Examination” would follow the thorough inspection and after a risk assessment had been undertaken. This document would have to be drafted by a suitably trained/competent person. It would also have to specifically state the frequency of examination of the different parts of the system. In addition to the examination there is also a requirement to undertake tests of the system whilst pressurised. There are guidelines on the frequencies of testing and examination which is published by The Safety Federation (SAFed). They are as follows:
| • | steam boilers and steam ovens – 14 months; |
| • | steam pressure plant – 26 months; |
| • | hot water boilers (>100°C) – 14 months; |
| • | air pressure plant – 26 months; |
| • | air conditioning plant (> 25kW) – 48 months; |
| • | refrigeration plant (> 25kW) – 48 months; and |
| • | other pressure systems – 26 months. |
Hot water boilers only come under the PSSR if they work above the 100°C stated. However, it is strongly recommended that all hot water boilers in use on commercial premises are inspected at regular intervals. Refrigeration and air conditioning plant are only covered by the PSSR when they exceed the stated 25kW. Not all pressure systems have to be examined under the PSSR; it is only required when capacity is greater than 250 bar litres (to find this value you would multiply the pressure by the vessel’s capacity). Domestic boilers are not excluded from the regulations.
Lifting Equipment
The regulations covering this type of equipment are the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER). LOLER covers equipment used to lift and lower both persons and goods such as forklift trucks, cranes and passenger lifts etc. The examination and testing of this plant must be carried out in conjunction with the “Written Scheme of Examination” and be undertaken by a suitably trained and competent person, who is impartial in their views (i.e. independent lift engineers). The Regulations specifically state that:
| • | initial examination is undertaken before the equipment is used; |
| • | an examination is undertaken after the installation of the equipment, to ensure adequate installation; |
| • | regular inspections are carried out on equipment likely to deteriorate in certain conditions; and |
| • | re-inspections are undertaken following any events likely to harm the integrity of the equipment, such as extreme weather conditions etc. |
There are frequencies specified under the Regulations which are as follows:
| • | 6 monthly – this would normally apply to passenger lifts, access platforms etc. (this also applies to eye bolts, slings and shackles); and |
| • | 12 monthly – would normally apply to forklift trucks and cranes etc. |
There is also scope within the Regulations to base the inspection and testing frequency on risk assessment. This approach is normally when the risks are inherently lower and longer gaps between inspections may be more practical. The “competent person” carrying out the assessment would be required to produce a written report after the completion of any examination. In certain cases if the equipment is found likely to pose serious imminent danger the Inspector must send a copy to the Enforcing Authority.
There are certain details required within a thorough examination report such as:
| • | the name and address of the user for whom the examination was made; |
| • | the location of the examination; |
| • | sufficient information to identify the piece of equipment (log number); |
| • | the dates of the last thorough examination and of the current examination and report; |
| • | information on the Safe Working Load (SWL); |
| • | the circumstances of the examination following installation or after an accident, for example, details of any defects spotted and any remedial action taken; |
| • | any further recommendations, such as non-destructive testing; |
| • | the name, address and qualification of the competent person compiling the report; and |
| • | the date of the next examination. |
Local Exhaust Ventilation Systems (LEV)
LEV is a device that captures hazardous airborne substances close to the source. LEV is used in many processes such as spray booths in garage paint shops. They can also be found in places such as wood working factories.
There are three main regulations that govern the use of LEV within the working environment for controlling airborne substances, these being:
| • | The Control of Substances Hazardous to Health 2002 (COSHH) |
| • | The Control of Asbestos at Work Regulations 2002 (CAWR) |
| • | The Control of Lead at Work Regulations 2002 |
The COSHH Regulations require that employees are not exposed to substances that are hazardous to a person’s health. Exposure should be controlled sufficiently by means other than Personal Protective Equipment. Therefore, if practicable, LEV should be installed to remove the hazards from source.
There are frequencies stated for the maintenance of LEV, these are:
| • | 1 month – LEV in shot blasting of raw castings and Jute cloth manufacture; |
| • | 6 months – LEV in non-ferrous metal-working; and |
| • | 14 months – LEV in all other activities. |
LEV was usually overlooked when it came to the examination requirements other than in the Health and Safety at Work etc., Act 1974, until the COSHH Regulations initially came into force in 1988.
LEV normally consists of a capture hood (not too dissimilar to the hoods above most domestic cookers), exhaust ducts, extraction fans and filter/collection bags. Other equipment that would fall under the scope of LEV would be:
| • | vacuum cleaners permanently connected to exhaust systems and fitted to portable tools; |
| • | welding fume extraction equipment, such as portable “elephant trunk” ducting; |
| • | low volume/high velocity extraction equipment for cutting processes; |
| • | fume cupboards in chemical/ biological/medical laboratories; and |
| • | oven or furnace flues used to remove toxic fumes from combustion processes. |
Maintenance of LEV is required by COSHH and would include:
| • | a visual inspection of the equipment; |
| • | dust tests/samples should be undertaken (Tyndall lamps are used normally); |
| • | static pressure behind the hood; |
| • | test of the air velocity of the area near the captor hood; |
| • | the velocity of the ducting between the captor hood and the main ducting pipes; |
| • | velocity and static pressure at the main exhaust ducting; |
| • | static and total pressures at the inlet and exhaust fan; and |
| • | static pressure at the inlet and outlet of the dust collectors and filters, to help calculate the differential pressure. |
Power Presses
Power presses are used to work on cold metal. They would normally consist of a flywheel and clutch.
Examination and testing of this equipment is a requirement under the Provision and Use of Work Equipment Regulations 1998 (PUWER). PUWER Part IV states that within four hours of every working shift an appointed person is required to set the tools and carry out a basic inspection of the equipment and associated guarding. The thorough examination required under PUWER is to be undertaken by a competent person.
Although hydraulic presses do not fall under this requirement we would recommend that they should be inspected nevertheless. Inspection frequencies for such equipment are dependant on the type of equipment and guarding in use. Guarding for this equipment usually falls under the following categories:
| • | fixed guards; |
| • | interlocking guards (these guards prevent the equipment activation until the guard is in the correct position); and |
| • | photoelectric guard (a beam of light which when broken would deactivate the equipment). Inspection frequencies are: |
| • | 6 monthly – power presses with interlocked guards, press brakes with photoelectric guards and guillotines in printing works; and |
| • | annually for power presses with fixed guards and guillotines outside printing works. |
Power presses are unlike boiler plant and lifting equipment in that there is not the same flexibility in the requirements to apply a risk assessment-based approach to the inspection regime.
Electrical Equipment
Electricity at work is governed under the Electricity at Work Regulations 1989 (EAW) and the British Standard BS7671 which embodies the Institute of Electrical Engineering (IEE) Wiring Regulations (16th Edition). The British Standard is a guidance document on the design, installation and inspection frequencies on electrical systems.
The obvious purpose for thorough examination is to reduce the risk of serious faults in which someone may be at risk of injury by coming into contact with faulty equipment/systems.
Peninsula Comment
Competent Persons
A competent person is defined in the thorough examination of the above equipment as “a person who has the appropriate practical and theoretical knowledge and actual experience of the plant they are examining to enable them to detect any defects or weaknesses and to assess their importance in relation to the safety and continued use of the plant”. Please note that the responsibility clearly lies with the organisation that owns the equipment, so therefore if an independent engineer is employed to carry out the above inspections and examinations and fails to do it properly this would only be a failure of contract and the organisation would still be liable if a breach of health and safety legislation has occurred.