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Guarding of hydraulic press brakes - legal requirements

The principal legislation relating to machine guarding in Western Australia is Section 23 of the Occupational Safety and Health Act 1984 (the Act).

Contents

  1. Introduction
  2. Methods of compliance in respect of hydraulic press brake guarding
  3. Guarding of the point of operation
  4. Removal of guard at the point of operation
  5. Practicability
  6. Interpretations of AS 1219 1994-Power presses: Safety requirements

1. Introduction

Section 23 of the Act requires suppliers to ensure plant they supply is safe for persons who properly install, maintain or use it. This must be established by testing and examination.

Suppliers must (under Section 23(1)(c) of the Act) provide adequate information in respect of any dangers associated with the plant they supply and the conditions necessary to ensure persons properly using the plant are not exposed to hazards. Suppliers must also provide the specifications of the plant and details of the proper maintenance procedures for the plant. Test and examination results, and all of the information referred to above must be provided when the plant is supplied and thereafter whenever requested.

In late 1996, new regulations, the Occupational Safety and Health Regulations 1996, ("the Regulations") were introduced, which changed the approach to machine guarding from that taken in the previous Regulations.

Under the Regulations, designers, manufacturers, importers and suppliers all have a responsibility to consider the hazards associated with various phases in the life of plant and take the necessary, practicable steps to reduce the associated risks.

In terms of hydraulic press brakes, regulations 4.23, 4.24, 4.25, 4.26, 4.27 and 4.28 (which relate to designers, manufacturers, importers, suppliers, installers and employers respectively), require this approach, and consideration of means described in regulation 4.29 to minimise any residual risk.

Western Australian importers and suppliers must assume the responsibilities of designers and manufacturers who are not located in Western Australia. Western Australian manufacturers must assume the responsibilities of designers not located in Western Australia. The legislation makes virtually no distinction between importers/suppliers of used plant and new plant. In a similar way, the legislation makes no distinction between a person importing a single item of plant for their own use at a workplace, and a person in business as an importer. Nor is any distinction made between a business that supplies plant as its principal activity, and a person selling an item of plant merely because it is no longer required; their duties are identical.

Regulation 4.29(i) introduces a hierarchy of safeguards in respect of plant guarding; requiring consideration of a permanently fixed physical barrier where practicable, followed by an interlocked physical barrier where access to the dangerous area is a necessity. Where neither a permanently fixed physical barrier or an interlocked physical barrier is practicable, a physical barrier securely fixed by fasteners that require a tool to remove them, must be considered.

Only where none of the physical barrier options are practicable can a "presence sensing" safeguard system be used. In many cases physical barriers will be practicable.

Australian Standard AS 4024.1 - 1996 Safe guarding of machinery - General principles ("AS 4024.1 - 1996") is an approved Code of Practice (under Section 57 of the Act), and provides good information on the selection and use of machinery safeguards.

2. Methods of Compliance in Respect of Hydraulic Press Brake Guarding

AS 4024.1 - 1996 refers to Australian Standard AS 1219 - 1994 Power presses - Safety requirements (AS 1219-1994) in respect of Power Press guarding.

AS 1219 - 1994 was developed jointly by State Government Authorities, the Confederation of Australian Industry, the Federal Chamber of Automotive Industries, the Metal Trades Industry Association of Australia and the Safety Institute of Australia. It may, as a result, be said to have the support of many of the influential bodies involved in the metal-working industries. WorkSafe Western Australia accepts that hydraulic press brakes guarded in accordance with this Standard will meet the requirements of the legislation.

The following points from AS 1219 - 1994 are provided here for the guidance of designers, manufacturers, importers, suppliers, erectors and installers, owners, employers, self-employed persons, etc.

3. Guarding of the Point of Operation

Options available include:

  • Fully enclosed dies.
  • Limitation of stroke - where the stroke is always 6mm or less.
  • Guarding - in accordance with the new Regulations, as described previously.
  • Other means, that provide an equivalent level of safety to that of (a), (b) and (c) above. Note: this does not include two-hand control devices.

4. Removal of Guard at the Point of Operation

Access to the hazardous area during production work is only permitted where a risk assessment has been conducted, and where it is impracticable to insert the work piece into the machine without bypassing an interlocking guard or intruding on a non-contact guard.

However, it should be noted that removal of an interlocking guard, or muting of a non-contact guard is permitted only if one or more of the methods described in clause 6.4.3 of AS 1219 - 1994 is employed.

Note: So there is no misunderstanding regarding this point, use of pulse mode or slow descent mode as described in clause 6.4.3 of AS 1219 - 1994 is only acceptable as a safety solution on machines equipped with a guard at the front of the brake press.

5. Practicability

"Practicable" is a term defined in the Act. It includes (amongst other things) a component related to cost. However, it does not include consideration of the "ability to pay". The consideration here is the cost of the safeguard versus the consequences of not controlling the identified risk. It will hardly ever be an issue in respect of guarding an hydraulic press brake, because physical barrier guards, whilst not as convenient as non-contact guards, are relatively inexpensive.

6. Interpretations of AS 1219 - 1994 Power presses - Safety requirements

Only officers of Standards Australia can provide definitive advice as to the meaning of sections of Australian Standards. If you require further information about the meaning of any provision of AS 1219 - 1994 you should contact Standards Australia.

Note: This Guidance Note supersedes previous issues on the same subject titled "Guarding of Hydraulic Press Brakes Guidance for Owners", issued by the former Department of Occupational Health, Safety and Welfare.

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