Risk Assessments

Statutory Requirements And Introduction
Risk assessments, here in Ireland, like most other European Member States, are a statutory requirement.

Under Regulation 10 of the Safety, Health and Welfare at Work (General Application) Regulations of 1993 [SO 44 of 1993], it is the duty of the employer, in preparing their safety statement, to be in possession of an assessment in writing of the risks to safety and health of the work place.

These risks are to include any, which put groups of employees at unusual risk and to implement controls that will protect the employees against such risks. These controls are to include any protective equipment to be used.

Under the Machinery Directive 98/37/EC manufacturers of equipment or their authorised representative in the European Union, must, under Article 8(2) (A), (b) and (c) draw up a Technical Construction File, provided for in Annex V.

A specific component of that Technical Construction File is a description of methods adopted to eliminate hazards presented by the machinery, i.e. a written risk assessment.

At the time of going to press, there were no statutory duties on the manufacturer of machinery to supply the end user with such risk assessment, the only requirements were under Annex I, Section 1.7.4 for machinery, to be accompanied by instructions for use of the machinery throughout its life cycle.

The life cycle of work equipment include: –

* Transportation
* Assembly
* Commissioning
* Putting into Service
* Operation
* Maintenance
* Adjustments
* Dismantling
* De-Commissioning

It is worth noting that ALL machinery, on being out into service, must be accompanied by a translation of the instructions in the language of the country in which, the machinery is to be used AND by the instructions in the original language.

Other directives placed further duties on employers in relation to the safe use of work equipment and these have been implemented into National Legislation which, provides for the employers to ensure that: –

  1. Employees are made aware of safety and health risks relevant to them, even if they do not use the equipment and when the safety of equipment depends on the installation conditions, that
  2. An initial inspection is carried out after installation and before it is first put into service and
  3. That an inspection is carried out after assembly at a new site or in a new location

The results of these inspections are to be recorded and kept available for inspection by inspectors of the Health and Safety Authority for five years.

This then is a further example of another statutory requirement for a risk assessment of the work equipment.

A final requirement for risk assessments from Council Directive 2001/45/EC has been implemented into National Legislation under the Fifth Schedule, Para 1 (3)(d) of the Safety, Health and Welfare at Work (General Application) (Amendment) Regulations, 2001 [SI 188 of 2001].

“Control shall be safe and shall be chosen marking appropriate allowances for failures, faults and constraints to be expected in the planned circumstances of use”

The only method choosing control system is assessing the dangers that exist from its failure and this is a risk assessment as described in EN 954-1: 1996.

There is not another topic or area within machinery or work equipment legislation that has been replicated statutorily several times than that of risk assessment and it is for that reason will continue through all of its chapters to bring the message home to manufacturers and users of machinery, the necessity to carry out comprehensive and, as far as possible, objective risk assessments.

Objectivity is the ideal application in risk assessments, however, humans vary and therefore subjectivity creeps into the equation when attempting to establish a level of risk. In trials using twelve people of different vocations using the ‘What If’ and ‘Hazard Risk Number’ (HRN)’ approached the group achieved is nine of twelve applications, the same result.
Whilst other safety practitioners may prefer different risk assessment approaches, the author feels that a 75% agreement between groups is an acceptable common train of thought and most certainly a device for a harmonised approach to risk assessment.

On many occasions the author has been asked ‘where do you draw the line?’ and the answer will always be the same, i.e. the risk assessment must look logically at what is foreseeable and what is not, for example, it is foreseeable that a grinding or cutting operation on a non-metallic material may cause dust but the probability of a hardwired emergency stop system failing is small.

Risk assessment is about applying common sense to a system of work rather than trying to second-guess the future. As human beings, we may miss some factors that could arise from operating machinery and the risk assessor should not be overly concerned that this omission may result in an injury to the operator for the probability is, that by carrying out a risk assessment you have done all that is reasonably possible to implement controls that will either reduce the likelihood of the hazard or more preferably eliminate it altogether.

JGMA can carry out various types of risk assessment that will satisfy all legislative requirements.

CE Compliance Audit

Failure Mode & Effect Analysis (FMEA) is another inductive risk assessment method, the principle purpose of which is the consequences of component failure. The main disadvantage is that it deals with the components of work equipment and does not take into consideration the operator/machine interaction. FMEA is most probably, best suited to small sectors of …

EN ISO 14121-1:2009

This method of risk assessment is relatively simple to apply and takes into consideration all aspects of the work equipment, throughout its life cycle. This is an inductive approach in that we are assuming various defects or abnormal situations, then plotting the result and event or hazard. The approach is a ‘hands on’ in that …

Functional Safety Assessments

A safety statement is an employer commitment, in writing, towards the safety, health and welfare at work of their employees. To construct a safety statement takes time and serious consideration on behalf of the employer, for it is a legal document that will demonstrate to the world what lengths the employer has gone in search …

Hazard Risk number (HRN)

The Hazard Risk Number (HRN) is a numerical figure that represents the severity of a risk once certain assumptions are made. Great care must be taken with this type of risk assessment since it is very easy to make the incorrect assumptions subjectively. Used correctly, it is an extremely useful tool for it assists the …

Preliminary Hazard Analysis (PHA)

The objective of PHA is to identify, for a specified system or piece of equipment, the hazards presented throughout its lifecycle. It identifies the potential for dangerous incidents and the positive controls implemented to mitigate same. The method is more qualitive in nature, however it must be addressed on a continuous basis throughout the machinery …

Protection Level (PL)

The Protection Level (PL) of a machine is the level of safety to which the safety related functions are required and available. Harmonised standard IN ISO 13849-1:2009, replaces EN 954-1/1A and the old category of safety, using a hierarchial series of protection levels in an ascending order thus; PL a-Lowest functional safety level PL b …