17 Dec 2019

Christmas time = Reconstruction time

Not all employees these days are able to look forward to a peaceful Christmas holiday and a few days off. When manufacturing stops, maintenance rolls up its sleeves. Machines are reconstructed, and “time pressure” is a latent companion. This can quickly lead to inattentiveness or even carelessness. Hardly anyone considers occupational safety and health.

Reconstruction of the machines

expert explaining loto proceduresAn increase in unplanned downtimes, an expansion in the number of units produced or simply a necessary restoration of machines that are getting out of date are just a few reasons why companies have to invest in their equipment. Previously self-sufficient machines are linked by handling systems or robots, material feeds are connected upstream or obsolete technologies are exchanged for new ones in order to keep up with industry 4.0 and competition. Where hydraulic shears used to cut the material, modern lasers or saws are used today. Switch cabinets are renewed, programmable logic controllers are replaced by newer generations, and safety technology is modernized – a tremendous amount of work at the end of the year. But who thinks of the resulting requirements between Christmas craze and production modernization?

The ” Substantial Modification “

All the reconstruction measures described have one thing in common: the question concerning the substantial modification! As soon as machines are substantially modified, they have to be legally considered as a new machine. The following schematic can help determine what exactly is a substantial modification and how to decide in your company whether such a modification is present with your machine. But in any case, one aspect is certain: there is no getting around an assessment of safety, because occupational safety and health protection is required even in times of industry 4.0.


how substantial modification is done

Risk assessment – Hazard assessment

First of all, it is important that you document in writing the path and the result of the question as to whether or not the reconstruction is a substantial modification. Once a substantial modification has been detected, you are automatically considered the manufacturer of the modified machine – with all legal consequences. Failure to adhere to legal regulations could result in heavy fines. However, it is much more important that you endanger your employees if you disregard these regulations.

As a manufacturer, you must therefore carry out a risk assessment for the machine. At the same time, you have to reassess the hazards posed to your employees in the role of employer. The applicable regulations specify that work equipment may only be used after a risk assessment has been carried out by the employer. This also applies to substantial modifications to a machine. The protective measures determined must be implemented in accordance with the current state of the technology and safe use must be guaranteed. 

No time, no money, no priority?

Project timeframes are somehow always too short and thus some things fall by the wayside. A timely assessment of risks, well-planned safety concepts and an efficiently devised switch-off matrix are still unfulfilled on the wish list after Christmas. Nevertheless, precisely these points in the end often help to save money and above all help to avoid casualties. While the term risk assessment is coined by occupational safety and health, the origin of risk assessment lies in the CRF 1910 Subpart I Appendix B (Nonmandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection). In this context, it is important to address all the so-called life phases of the machine. It is obvious to everyone that normal operation must be carried out safely.Human error

But what about maintenance, servicing and cleaning? In fact, most accidents happen in these phases of life, as we have already described in previous articles. This is the case, for example, when energies are not switched off correctly or an unexpected start of movements occurs. In order to avoid having an injured employee under the Christmas tree after all, you should consider both the risk assessment and the manufacturer’s obligations according to the ANSI B11.0 before reconstructing the machine. An injured or dead employee may be more expensive than an early assessment of the dangers. Not to mention the pain and loss of the bereaved.

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