Appendix to OC 690/13 - Safe operation of batch ball mills used in potteries and allied industries

OC 690/13a

APPENDIX 2 Legal requirements
(paragraph 7)

The pressure systems safety regulations 2000

1 The Pressure Systems Safety Regulations 2000 (PSSR) will apply to a BBM if it contains, or is liable to contain a relevant fluid, which includes steam at any pressure, a gas including air at a pressure greater than 0.5 bar gauge or hot water at a temperature above 110C.

2 PSSR require users to:

1) establish safe operating limits for each BBM;

2) produce a written scheme for examination of vessels by a competent person;

3) have BBMs examined in accordance with the written scheme;

4) cease operation if the competent person identifies imminent danger;

5) provide safe operating instructions; and

6) ensure proper maintenance.

3 The Regulations also provide a partial exemption from PSSR (Regs 5(4), 8-10 and 14) for small BBMs which are less than 250 bar litres (ie maximum allowable pressure x volume) provided they do not contain steam.

4 In practice, most BBMs are not intended to be run at pressures above 0.5 bar g and hence are not treated as pressure vessels. They are therefore not subject to any periodic thorough examination or test by independent bodies. Most BBMs are discharged by running out the contents under gravity. However, if they are pressurised to more than 0.5 bar g either as an intended part of the milling process or to assist the discharge of product then they will be subject to PSSR and will require a competent person's examination, etc. In the absence of the precautions outlined in this document it is possible for pressures greater than 0.5 bar g to be reached routinely during milling, users will have to take steps to ensure that this cannot occur and provide suitable evidence that this is the case before they can avoid the requirements of PSSR.

Management of health and safety at work regulations 1999

5 Regulation 3 requires employers and self-employed persons to make and maintain a suitable and sufficient assessment of the risks to the health and safety of employees, other workers and "the public", for the purpose of identifying the measures to be taken to comply with the requirements imposed under Relevant Statutory Provisions. The significant findings of the assessment must be recorded by employers with five or more employees. Risk assessment should be a common-sense consideration of the risks in the work activity to identify remedial action necessary. Significant findings which have to be recorded should be considered as those which require action to comply with RSPs and the level of detail recorded should be broadly proportional to the risk. Quantified risk assessment will rarely be required. The focus should be on those risks that are liable to arise out of the work activity.

Provision and use of work equipment regulations 1998 (eg training, maintenance, inspection).

6 Equipment must be suitable for the intended use. Regulation 4(1) covers the integrity of the work equipment in terms of both design and safeguarding.

7 Equipment must be properly serviced and maintained. Regulation 5(1) deals with the frequency of servicing intervals and the appropriateness of maintenance management techniques.

8 Equipment must be inspected when equipment or parts of equipment could deteriorate and lead to danger and this will not be adequately controlled through operator checks and normal servicing regimes (Regulation 6).

9 There are three circumstances when a user should carry out an inspection. These are where:

1) the safety of the equipment is critically dependent on its being correctly installed or reinstalled and failure to do this would lead to a significant risk;

2) safety of the equipment is critically dependent on its condition in use and there is likely to be deterioration which would give rise to a dangerous situation; and

3) 'exceptional circumstances' which are likely to have jeopardised the safety of the work equipment. The depth and level of the inspection should be adequate to identify deterioration leading to risk and the action necessary to avoid a dangerous situation.. Employers will need to decide whether their own employees are competent to carry this out or whether further training is required or whether third party inspection will be necessary.

10 Employers will need to provide information, instructions and training not only to those who actually use work equipment, but also to employees supervising or managing its use (Regulations 8 & 9).