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Use of skid steer loaders in poultry sheds

SIM 01/2004/05

This SIM informs inspectors about the safety requirements for Skid Steer Loaders and the action to take when users have removed part or all of the ROPS/FOPS for use in old style poultry sheds. It updates information previously issued in NIGM/13AG/1992/10 and AIC 1989/19.

Summary

This guidance informs inspectors about the safety requirements for skid steer loaders.  It describes the key safety issues, and the action to take, when users have removed part or all of the operator’s cab in order to allow the machine to be used in poultry sheds that have height restrictions.  Such buildings may prevent the use of a machine that is fully compliant with EN standards.

Introduction

1. To advise inspectors on the agreed set of measures to control the risks associated with the use of modified skid-steer loaders in poultry sheds. 

Action

2. FOD inspectors who encounter deficiencies in the implementation of the control measures should consider taking the appropriate enforcement action detailed in this guidance.

Background

3.  Skid steer loaders are small, highly manoeuvrable compact loaders found in use across a range of industries including agriculture and construction.  They are usually fitted with a shovel or bucket at the front but can be operated with a range of other attachments, such as pallet forks, brushes etc.  The attachment arms are hinged at the rear of the machine; their movement past the body of the machine creates a shear trapping risk.  A cab, entered from the front, protects the operator from this trap and also provides roll over protection and protection against falling objects.

4. Skid steer loaders are the machine of choice for most farmers or contractors who carry out the removal of poultry litter/manure and clean out poultry sheds between crops. However, most machines are over two metres high when fitted with a cab incorporating a Roll Over Protective Structure (ROPS) and Falling Object Protective Structure (FOPS).

5. Many older style poultry sheds are less than two metres high at the eaves and the height clearance to the raised feeders/drinkers can be as low as 1.5 metres.  At the time of drafting this revised SIM (March 2012) there are no suitable alternative machines (such as small tractor loaders, telehandlers or skid-steer loaders) with cabs available on the market that are less than 1.5 metres high that are suitable for carrying out this type of work in sheds with limited clearance.

6. To overcome this, owners/operators have removed all or part of the cab ROPS/FOPS structure thereby allowing them to operate in the reduced headroom of some poultry sheds.

7. These machines have a short wheelbase so are unstable on anything other than level, even ground, thus the removal of the ROPS/FOPS potentially puts the operator at significant risk, should the vehicle overturn.

8. The complete removal of the ROPS/FOPS also exposes the operator to a shearing hazard between the loader arms and the frame of the machine because the cab structure also incorporates Side Protection Screens (SPS). An operator was killed when he leaned out of the cab’s central “safe” zone and was crushed by the descending loader arm.  In this case, the ROPS/FOPS/SPS had been completely removed.

9. In addition, some owners/operators have removed the ROPS/FOPS/SPS and also disabled other safety features in the process. These include the safety interlock bar that isolates the foot operated controls which the operator has to step over in order to reach the driving position. There have been fatalities and other serious injuries to operators who have accidentally operated the foot controls when mounting or dismounting the machine.

10. Where the height clearance in the poultry shed allows, a vehicle with a fully EN compliant cab should always be used (e.g. for activities such as litter/manure removal, cleaning, sweeping, laying bedding etc).

Design features of skid steer loaders

11. Skid steer loaders manufactured to BS EN 474-3 are very compact machines with a short wheelbase and narrow track. Independent motors are used for left and right pairs of wheels. Steering is accomplished by varying the speed of the hydraulic motors on respective sides: tight turns can be achieved by reversing the motor driving the wheels on the inside of the corner.

a drawing of a skid steer loader

12. Because the operator occupies a central position very close to the zone of movement of the loader frame, they must enter and exit through the front of the machine and over the bucket. Inadvertent operation of the lift arms, bucket or other attachments may also be possible. The operator is enclosed by a cab incorporating ROPS/FOPS, often consisting of perforated steel plate to the sides, rear and top.  The front of the cab is usually an opening without a door.

13. The ROPS/FOPS is required to protect the operator from vehicle overturns and falling objects respectively.

14. The SPS are required to protect the operator from a risk of crush injuries due to the loader arm movements at the side of the cab.

15. Common safety features on skid steer loaders include:

Accident history

16.  Typical accidents with skid steer loaders have included:

17.  Typical causes of accidents/deaths:

Advice to users

18. The Provision and Use of Work Equipment Regulations (PUWER) 1998 requires duty holders to ensure that work equipment complies at all times with the Essential Health and Safety Requirements (EHSR) that applied to the equipment at the time of its first supply or first use. Skid steer loaders also come within scope of the European ‘C’ standard on mobile construction machinery namely BS EN474-3: 2006+A1:2009 ‘Earth-moving machinery – Safety – Requirements for loaders’.

19. As a result CE marked machines are regarded as meeting the relevant EHSRs - in particular EHSR 3.4.3, which requires specified earthmoving machinery (including loaders) with a capacity exceeding 15 kW to be fitted with ROPS. The standard also prescribes that loaders are designed and fitted with FOPS if they are used for applications where there is a risk of falling material and side protection (SPS) to prevent the operator from reaching into a shear trap while seated.

20. Therefore, if a user subsequently removes any part of the ROPS, creates a shear trap by removing the SPS or removes the FOPS where there is a risk of falling material, then the machine becomes non-compliant i.e. the requirements of regulation 10(1) of PUWER are no longer met and the risk of injury to operators is increased.

21. In the absence of suitable vehicles fitted with ROPS/FOPS/SPS which can access poultry houses with limited height clearance, HSE has discussed potential solutions with the poultry industry and agreed a set of control measures. These measures should reduce the risks associated with modified (non-compliant) skid steer loaders used in poultry houses.

Control Measures

22. Alternative solutions to non-compliant skid steer loaders should be used where possible e.g. select and use smaller machines (as and when they become available on the market) or other suitable equipment to access the sides of the sheds where restricted height is a problem and then use a fully compliant skid steer loader, telescopic handler or other machine (i.e. CE marked machine with an unaltered ROPS/FOPS/SPS fitted) to remove the debris from the centre of the shed, where generally there are greater clearances.

23. Otherwise, implement a control strategy that includes the following elements:

24. A written safe system of work/method statement should:

25. This guidance should be read in conjunction with HSE publication ‘Controlling exposure to poultry dust’. This describes the requirements, where reasonably practicable, to use vehicles with enclosed ventilated cabs (fitted with filtered air intakes) as the first option to prevent exposure to harmful poultry dust. It also provides guidance on RPE/PPE requirements where ventilated cabs with filtered air intakes are not available.

26. Training for skid steer operators is a legal requirement under PUWER.  Operators should receive basic training in how to operate skid steer loaders safely and this should also be supplemented with training applicable to the use of modified machines if operators are required to drive them.  Operators and their supervisors should be familiar with the contents of this SIM and the system of work/method statements set out in paragraph 24 as necessary.  For more details about organisations that provide training and/or competency assessments– see Further references.

Enforcement action by inspectors

27. If deficiencies are encountered Inspectors should consider taking enforcement action.  Examples are given below:

Benchmark standard

28. The benchmark is compliance with PUWER and all the relevant BS, EN or ISO standards including BS EN 474-1: 2006+A1:2009 and BS EN 474-3: 2006+ A1:2009. This standard includes the requirements for the fitting of FOPS, ROPS and SPS that prevents the operator from reaching the trapping parts between the side arms and fixed parts of the machine when the operator is seated in the operator’s position.

Risk gap

29. The risk gap from Enforcement Management Model (EMM) table 2.1 for the key scenarios is summarised below. Inspectors may use these scenarios as a guide to making their assessment of actual risk and the subsequent risk gap. However, inspectors must ensure that they base their assessment of risk on the actual operator protective measures found on the machine.

Scenario Actual risk Risk gap

Top of cab removed but used in circumstances where an unmodified machine could operate.

Risk of a serious personal injury

Substantial

Side Protection System removed

Risk of a serious personal injury

Substantial

Any machine where, the safety bar/operator restraint system has been removed

Risk of a serious personal injury

Substantial

Appropriate standards

Title Authority

Provision and use of work equipment Regulations 1998

Defined

BS EN 474-1:2006+A1:2009 Earth- moving machinery - Safety - General requirements

Established

BS EN 474-3:2006+A1:2009 Earth-moving machinery - Safety - Requirements for loaders

Established

BS EN ISO 13857:2008 Safety of machinery - Safety distances to prevent hazard zones being reached by upper & lower limbs

Established

Further references

31.    For details of operator training courses/competency assessment for skid steer loaders see the following websites:

Other sources of training/assessment may also be available.

Contacts

32.  For further advice on occupational safety issues contact Agriculture and Food Sector, Worcester.

For further advice on occupational health issues contact Agriculture and Food Sector, Nottingham.

Updated 2015-05-22