Jeremy Procter of Procter Machine Guarding examines BS 4163: 2007 and explains the implications for machine safeguarding.
On 31 May 2007 BSI published BS 4163: 2007 'Health and safety for design and technology in schools and similar establishments - Code of practice', which supersedes the 2000 version of the same Code of practice (CoP). Throughout the CoP there are references to machine guarding, so this present article highlights those and, in particular, the changes introduced in the latest edition of the CoP.
However, before looking at the various clauses in detail, it is worth putting the CoP into its legislative context. As the Foreword explains, schools, colleges and similar educational establishments are covered by the Health and Safety at Work etc Act 1974, which places a general duty on employers to ensure, as far as reasonably practicable, the health and safety of not only employees, but also other persons affected by their activities. Furthermore, the Management of Health and Safety at Work Regulations 1999 require employers to perform risk assessments to identify what should be done to comply with the general duty and any relevant Regulations made under this Act. The Provision and Use of Work Equipment Regulations (PUWER) place specific requirements on employers to ensure that all work equipment is safe; two of the main requirements are for employers to provide safe work equipment that conforms to relevant safety standards, and ensure that, where necessary, appropriate safety devices are available.
Given the legal requirements outlined above, the CoP provides a means of demonstrating that reasonably practicable steps have been taken to minimise the risks from machinery and other hazards - though there is no legal requirement to comply with the CoP. It should also be noted that, in addition to the CoP's recommendations, teachers need to provide training and supervision to ensure the safety of students and others, and it is essential that the teachers have recognised training in health and safety.
Many of the changes to the CoP relate to updated recommendations. For example, the following have been brought up to date in the 2007 edition: student-to-teacher ratio; recommendations relating to liquefied petroleum gas (LPG); lower exposure action level for hazardous noise; and guidance relating to electrical installations. In addition, there are several new subclauses, including one discussing vibration, and others giving the hazards and risk control measures for specific types of machinery and equipment - such as blow moulders, plasma arc cutting and low-temperature casting.
One entirely new clause that deserves close attention is Clause 16, Computer-operated equipment. This is divided into a number of subclauses for laser cutters, rapid prototyping (including 3D printers, stereolithography, laser sintering and laminated object manufacture), rapid printing machines, and computer numerically controlled (CNC) machines. This last subclause runs to more than five pages, partly due to the number of different types of CNC machine, but also because of the numerous hazards associated with CNC machinery and the correspondingly wide-ranging risk control measures.
In common with many other subclauses throughout the CoP, this new addition for computer-operated equipment highlights the need for fixed guards (removable only with the use of a tool) or interlocked guards to enclose the drive mechanisms. Furthermore, Clause 7, 'Management of the teaching environment', Subclause 7.4 (e) states that health and safety monitoring should be carried out regularly to ensure that 'equipment guards and protective interlocks are in place and properly adjusted.'
It is sometimes the case that machines in educational establishments are not used as much as their equivalents in production environments, resulting in older machines continuing to be used for longer. Older machines still fitted with their original guards and safety-related control systems - or even those upgraded at some point in their working lives - might therefore have safeguarding measures that are not up to the current standards. Establishments with older machinery should therefore take note of BS 4163 subclause 2.3, which states that the phrases 'as far as reasonably practicable' and 'adequate control' should be understood to mean that up-to-date good practice is applied as appropriate. Fortunately, Subclause 2.3 also goes on to clarify how far an establishment should go in applying control measures.
At the back of the CoP is a reference section that lists Government publications, HSE (Health and Safety Executive) publications and British Standards publications. While this is undoubtedly very helpful, it is a good example of a document being out of date almost as soon as it is published. For example, it refers to publications from the IEE (Institution of Electrical Engineers), which is now the IET (Institution of Engineering and Technology), the DfES (Department for Education and Skills), which is now the DCSF (Department for Children, Schools and Families), and the DTI (Department for Trade and Industry), which is now BERR (the Department for Business, Enterprise and Regulatory Reform). It also seems remiss that the CoP does not list BS EN 1050:1997 'Safety of machinery. Principles for risk assessment' - which was superseded in September 2007 by EN ISO 14121-1, 'Safety of machinery. Risk assessment. Principles'.
Despite these minor shortcomings, BS 4163:2007 is essential reading for those responsible for health and safety or machinery in establishments where design and technology is taught.
To discuss any requirements for safeguarding machinery, please email or telephone +44 (0)2920 882222.