July 2016 News
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updating three brand new machine tools at our factory

Earlier this month we purchased three new machines for one of our workshops: a new vertical band saw, a linisher and an off-hand grinder.

The three machines were delivered with all of the correct documentation.

To comply with the requirements of The Supply of Machinery (Safety) Regulations 2008, a machine supplier must be able to demonstrate that:
  • The machine complies with the EHSRs (Essential Health and Safety Requirements) of the Supply of Machinery Safety Regulations.
  • The machine has been assessed as complying with the EHSRs.
  • There is a Declaration of Conformity.
  • There is a Technical File (or the supplier is able to compile the file upon request within a reasonable timescale).
  • The necessary information has been provided to operate the machinery safely, such as instructions.
  • One of the prescribed conformity assessment procedures has been followed.
  • The machine carries a CE mark.
  • The machine is 'in fact' safe.

machines as they arrived at Machine Covers

With the three new machines in place we carried out a risk/PUWER assessment on each one as required under the Management of Health and Safety Regulation. The assessments highlighted that the guarding fitted to the machines could be improved upon.

Today the accepted approach to the design of any machine guarding system is based on risk assessment. BS EN ISO 12100:2010 (which replaced BS EN ISO 14121-1, which itself replaced BS EN 1050) sets out different methods. These must take into account the probability and degree of possible harm relating to any foreseeable injury.

More guidance on Risk Assessment can be found in the HSE's leaflet, A brief guide to controlling risks in the workplace, INDG163 (rev4).

selected guarding

We then had to ensure that our decision to change the guards that were supplied with the machines did not affect the CE documentation supplied by the OEMs.

simple machinery refurbishment

Refurbishment of machinery amounting to disassembly and a rebuild to original specification, albeit with replacement parts which may be newer designs, can demonstrate equal if not greater reliability and will not usually require the machine to be reassessed for compliance with the Machinery Directive.

Likewise, simply repainting a machine, undertaking servicing and routine maintenance, changing motors, replacing parts such as guards with essentially identical new ones, even the replacement of original safety critical parts with newer, better ones (e.g. modern higher integrity interlocks wired into the control system in the same way or with increased reliability features as before) does not amount to a substantial change.

The most crucial issue for us as an employer and machinery user is to ensure that our machinery is fully compliant with the Provision and Use of Work Equipment Regulation (PUWER).
  • HSE
  • Work equipment and machinery
  • Refurbished and modified machinery

machines with new guarding fitted

6" off-hand-grinder

belt sander / linisher


vertical bandsaw


electrical safety control panel
If you would like more information about our safety services and machine refurbishment contact us on 01452 770166 or
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Machine Covers · Stancombe Works · Stroud Road · Bisley, Gloucestershire GL6 7NQ · United Kingdom

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