The company produces roll labels, on equipment including Mark Andy machines. In the opinion of the inspector, "there is not a safe system of work in place to isolate and lock off power supplies to the Mark Andys and associated equipment during maintenance, clearance of blockages and safety checks on the machine to prevent the plant from being started whilst someone is in a position of danger."
In the SSS response to this, we were able to show that there are no hidden space and there is nothing special about roll label machines such as Mark Andys which makes them different to thousands of other pieces of machinery. Therefore, in the absence of the HSE issuing improvement notices to every company which does not have an isolation system, the improvement notice and FFI were contestable.
In response to this, the HSE retracted the improvement notice and corresponding FFI.
This was an example where intervention is occurring for a spurious reasons, one suspects so that FFI targets can be met. SSS understand that the HSE budget for an inspection and letter incurs an FFI of £750 and an inspection and improvement of prohibition notice incurs an FFI of £1500.
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Details of the objection were the following:
- In other companies where people have been injured on roll label presses, the injuries have occurred where interlocks on guards over in-running nips have been disabled.
- The client company have a rigorous interlock checking system and so the primary cause of injury on these presses is controlled.
- Isolation and lock-off is essential when there is the possibility of a person being in a hidden position of danger, but roll label printers such as the Mark Andys at the client company have no hidden spaces.
- The nature of roll label printing where there is a continuous web means that there is no such thing as a blockage.
- Similarly, safety checks are those on the presses are the checking of interlocks. This is done by lifting each guard and verifying that the machine cannot be started. This obviously requires power to the machine.
- Therefore, clearance of blockages and safety checks cited in the improvement notice are either not carried out or cannot be done with the machine isolated.