Safety and Maintenance – some input from the Health and Safety Authority
March 31st, 2010One of the clients we are working with had a visit from the HSA. They asked for a list of all the “Safety Critical Components”, how they were identified and what maintenance was carried out on them. By components, they mean everything including Estops, interlocks, Pressure Relief Valves – you name it.
Senior HSA inspector, John Colreavy is quoted as follows in a recent article in Health and Safety Review;
Reflecting on the causes of maintenance accidents, John Colreavy first speaks about accidents that happen when equipment is being maintained. He highlights the importance of machine guarding, relating it to “the whole procedure for handing machinery over for maintenance and then taking it back into use”. He mentions the need for permit to work systems and isolation procedures and the possible need to have lock-out systems. He says problems can arise when equipment is being handed back. Often, he says, there is a “failure to replace guards after maintenance”. That can, he adds, be a matter of supervision.
Another issue, one which has been identified from the reports the Authority receives from plant inspectors in respect of steam boilers and air receivers is, Colreavy says, the issue of corrosion. Often inspection reports show “corrosion due to failure, in the case of steam boilers, to properly treat water and failure to drain water from the bottom of air receivers”. Such failures are both a safety issue and can lead to “expensive repair” bills.
Stressing the importance of record keeping, Colreavy says records can be used as “a feedback mechanism”. He adds that “if something keeps on breaking down, it may be symptomatic of a greater problem”.
Below is what happened to one employer who didn’t keep records:
No records
An employer who had not kept maintenance records was unsuccessful in defending a personal injuries claim brought by an employee. The court heard that the worker suffered a thumb injury when a nail from a nail gun became embedded in his thumb. One of the issues in the case was whether maintenance records were kept. The employer claimed the gun was maintained, but had not kept records. Saying that on the evidence it was a difficult case to decide, Judge Alice Doyle noted that no records had been produced in court. She awarded the injured worker €8,000 damages. (For detailed report see HSR, January/February 2009, pg18)
Highlighting their legal obligations, John Colreavy mentions a number of practical actions employers should take:
- Guards should be replaced
- Access to manuals for machines should be available and manufacturers’ guidelines should be followed
- If modifications are being carried out, they should be risk assessed and care should be taken to ensure the modifications do not invalidate the manufacturer’s safety assessment
- Employers should have preventative maintenance programmes in place to prevent breakdowns.
As a matter of good practice, he suggests keeping a register of items which are “critical to the safety of plant”.
A particular danger inspectors come across during the course of inspections is where interlocks are over-ridden and defeated. It is a practice he warns against.
Q: Can you show records for the maintenance work that you do??