Covid-19 is one of the greatest risks posed to modern society. On our way to conquering this seemingly insurmountable challenge, we need to get back to work and kick start our economy in a safe and controlled manner.
From 1st July 2020, the ‘Flexible furlough scheme’ started, enabling businesses to bring employees back to work on a part-time basis as part of the government’s plans to kick start the UK economy. In manufacturing, this may mean that your employees will be back at work and faced with machines which may have been left dormant or been used less than normal.
Although Covid-19 safety management is paramount, it is important not to let the day-today maintenance checks and PUWER inspection planning regimes to get lost along the way.
The HSE issued an update back in April, giving guidance to employers to make it clear that whilst Covid-19 measures had to be applied immediately, this in no way let the employer ‘off of the hook’ for compliance with the existing requirements e.g. PUWER ‘98.
New HSE guidance clearly states that if “machinery has not been used for a long period of time (weeks, possibly months) then additional risks can be created from the inactivity”.
“You must ensure that you assess these risks before restarting plant and equipment. In doing so, you need to consider the following:
any extended period of inactivity is likely to degrade the condition of machines, leading to increase in corrosion (rust) and possible seizure.
it is possible that automated machine parts or processes may have moved out of calibration, from their previously recorded or registered positions. This could cause machinery to move out of sequence and make contact with passing products or other machine parts when restarted”
How do we plan for PUWER when Covid-19 is at the forefront of our minds?
Our collective response to Covid-19 has been one of shock and awe to which was necessary to get the fast and diligent response from employers, workers, and our great societies as a whole. However, now that the awareness is becoming firmly ingrained in our everyday lives, perhaps a more balanced approach to compliance and risk management would be appropriate?
This is not to say that we ignore Covid-19, but perhaps we need a more nuanced approach to prioritising your focus and resources to ensure the best overall outcomes for your workers and your employer?
As with all risk management, you need to start with a risk assessment of your operation and develop appropriate policy and implementations in proportion to those risks. All risk assessment in relation to Covid-19, will acknowledge a risk of death, and quite rightly so. However, most manufacturing will also find risk of death in relation to their machines too.
From a humble workshop lathe, to a complex automated production line, if actions are not taken to ensure their suitability and condition, they can pose huge risks (and far too often, fatal) to the employee.
The risks come primarily in the form of inspections by competent persons to ensure work equipment is safe to operate and maintain. In most cases this is done through PUWER inspections that are in addition to any other internal checks are normally done (e.g. prestart checks, preventative maintenance etc.
So how do we get a PUWER Plan in place?
PUWER inspection is one example of a recurring compliance activity and for this reason is better understood as a part of a process rather than a single event.
What happens to PUWER compliance when your mind is overrun with Covid-19 messaging?
Have you delayed your inspections?
Have you failed to even plan for where inspections are needed at all?
Delay is understandable, but a failure to plan is not.
As the HSE have pointed out, Covid-19 is not a “get out of jail free” card to ignore your duties. PUWER compliance keeps workers safe and is a part of the social contract that employers commit to when going into business. Do not let your workers or you employer down by failing to plan for PUWER compliance.
PUWER Inspection, Planning and Prioritisation is the first step on your way to PUWER compliance.
Spiers Safety have developed a PUWER risk mapping method called “PIPP”. This enables your organisation to prioritise resources where they are most needed, based on risk. The purpose of this process is to provide a rationale for generating the PUWER register and maintaining it.
It is important not to let the day-to-day maintenance checks and PUWER inspection planning regimes be lost in the noise of the Covid-19 pandemic. Covid-19 risk management is here to stay for the foreseeable future, and we need find a way to blend it into risk management without losing sight of the imminent harm that work equipment represents.
Spiers Engineering Safety are offering a free site audit to kick-start your PUWER plan for the remainder of 2020 into 2021!
Click here to find out more.