SIM 03/2009/16
This SIM replaces SIM 03/2003/61 and informs inspectors of an agreement between the plastics industry and HSE on the action the industry should have taken for ensuring that plastics thermoforming (including vacuum forming) machines are fitted with effective safeguards for preventing unintended gravity descent of raised parts in the event of failure of the machine's energy supply or loss of hydraulic or pneumatic fluid.
1.Over the period 2000/01 to 2002/03 there were a number of accidents at thermoforming machines that led to serious, including fatal, injuries to employees. These included, but were not limited to, injuries caused by unintended gravity descent of raised machine parts.
2.The Manufacturing Sector reached a formal agreement with the industry trade associations for users of existing machines and suppliers of machines (new or refurbished) intended for use in the UK to check, and where necessary, modify the machines to ensure that they incorporate effective devices for preventing unintended gravity descent of raised machine parts in the event of power failure or loss of hydraulic or pneumatic fluid. The agreement was endorsed in January 2003 by the Plastics Processors Health and Safety Liaison Committee (PPHSLC) on which all the main employers’ associations and trades union representing the plastics sat. PPHSLC has since disbanded but the 2003 agreement remains in force as PPHSLC’s constituent member organisations, all of whom continue in business, endorsed the agreement. The full text of the agreement is included at the appendix.
3.The text of the agreement was publicised at the time through the trade press and through the trade associations representing the plastics industry including suppliers of machinery to the plastics industry.
4. The agreement applies to plastic thermoforming machines as defined by clause 3.1 of BS EN 12409: 2008 Rubber and plastics machines - Thermoforming machines - Safety requirements. These include vacuum forming machines.
5. The agreement is limited to provision of safeguards for preventing unintended gravity descent of raised machine parts.
6. The agreement does not address all causes of serious accidents at thermoforming machines. It is recognised that serious injuries have arisen from other causes.
7. Users of existing machines (existing as at January 2003) agreed to check and, where necessary, modify their machines to ensure that they incorporated effective safeguards for preventing unintended gravity descent of machine parts.
8. Suppliers of new or refurbished machines agreed to perform the checks and carry out any necessary modifications to achieve the same result before the machines are supplied.
9. The checks, and any necessary modifications, had to be completed as soon as practicable and in any case, the agreement required that all machines were to have incorporated the required safeguards by 31 December 2004 at the latest.
10. The 31 December 2004 deadline applied to the whole UK population of thermoforming machines. It allowed employers with many machines requiring modification sufficient time to implement a prioritised remedial action plan. It also allowed time for complex technical problems to be resolved and for machines for which the modifications would be uneconomic to be phased out of use altogether. Within this overall timescale individual companies were required to expedite the remedial action as quickly as possible and take additional precautions in the meantime, including providing and maintaining effective safe systems of work.
11. Inspectors should expect to find all thermoforming machines that are capable of causing significant injury in the event of a gravity descent of raised machine parts fitted with effective gravity fall protection arrangements to the standard set out in clause 5.2.3 of BS EN 12409:2008 or equivalent. Essentially machines supplied from 1999 should have been fitted with these arrangements from new by virtue of BS EN 12409:1999 (since updated to BS EN 12409:2008) anyway and machines supplied before then should have been retrofitted with them by virtue of the actions placed on machine users, suppliers and refurbishers under the industry agreement.
12. If Inspectors encounter machines that are not fitted with suitable devices to prevent unintended gravity descent they will need to apply the Enforcement Management Model (EMM) in order to determine the risk gap and the initial enforcement expectation for the particular circumstances. They are also advised to seek advice from HM Specialist Inspectors (Mechanical) in relation to any technical issues.
13. HSAOs and inspectors should be aware of the diversity needs of the target group. They should give consideration to, and factor in issues such as literacy, English as a second language and disability (e.g. access needs).
The Diversity pages give more information on these areas.
SIM 03/2003/61 - cancel and destroy.
