23.05.2008

IPAF clarifies Balfour Beatty position

IPAF has issued a statement clarifying its position and that of the working group it chairs which is looking at the risks and possible actions required regarding overhead crushing accidents while operating aerial work platforms.

A full text of Balfour Beatty’s paper, which is still contingent on the testing of a device to cut all functions through a trip wire, is published below the IPAF statement.

Here is IPAF’s bulleting released this morning.

Balfour Beatty Policy & Background Information - Procurement & Operation of MEWPs (Issue 1 – April 2008)

IPAF was recently made aware of the above document. It was distributed to a number of hire companies and IPAF has concerns over a number of issues it raises.

The document refers to a Working Group (WG) led by IPAF to investigate MEWP accidents attributed by Balfour Beatty to operators being trapped against the platform controls at height. Such accidents may occur if operators come into contact with overhead objects while working in confined or congested areas at height and then lose control of the MEWP because they are trapped against the platform controls.

The outcome of this work was that the WG issued a statement explaining what any features fitted to a MEWP should achieve if they are to protect against trapping accidents, i.e. accidents caused by sustained involuntary operation of the platform controls. Input was provided to the WG by IPAF, HSE, Balfour Beatty, the Powered Access Interest Group (PAIG), Powered Access Certification (PAC) and the Construction Confederation.

The Balfour Beatty Information unfortunately interprets the statement as a retro-fit proposal that has been agreed by the WG. This is a misinterpretation of the purpose of the statement and IPAF is currently communicating with the WG members to clarify the situation. IPAF’s members warn against unauthorised modifications to CE-marked MEWPs and do not endorse a blanket recommendation for retrofits.

This will be unnecessary for many models and can be dangerous if carried out incorrectly. If companies have any questions about the need for a retrofit they should seek advice from the manufacturer.

The Balfour Beatty Information also proposes safety measures that should be applied to MEWPs on Balfour Beatty worksites to prevent accidents attributed to the sustained involuntary operation of controls.

While IPAF supports any initiative that makes MEWPs safer it is concerned about the modification of CE-marked MEWPs without the manufacturer’s agreement. It should be noted that the modifications suggested are likely to invalidate the manufacturer’s CE mark. IPAF urges anyone considering the modification of a CE-marked MEWP to contact the manufacturer and/or relevant notified body before planning such modifications.

IPAF members are requested to advise IPAF’s technical officer of any situations in which they are being asked to retrofit equipment or apply modifications to MEWPs.


Here is the Balfour Beatty bulletin:

Balfour Beatty
Policy & Background Information
The Procurement & Operation of
Mobile Elevated Working Platforms (MEWPs)

Policy

Introduction

This document contains Balfour Beatty’s Group Policy and Guidance on the procurement and operation of boom type Mobile Elevated Working Platforms (MEWPs).

Scope

This policy applies to all boom type MEWPs used on Balfour Beatty sites in the UK.

The procurement and operation of other MEWPs remains unchanged: each operating company shall have robust arrangements in place for managing the risks from using MEWPs so as to protect the safety and health of all those affected.

Objectives

The policy aims to provide effective protection against the risk of crushing for MEWP operatives. It seeks to ensure that MEWPs used on all Balfour Beatty sites are either fitted with appropriate protection of the control panel by the manufacturer, or have the most recent retrofit available to prevent inadvertent operation of the MEWP. The policy is introduced after extensive consultation with Balfour Beatty operating companies and with the MEWP supply chain.

Policy

Boom type MEWPs with shrouded foot pedals and unprotected control panels shall not be used.

All boom type MEWPs shall provide additional protection of the control panel which ensures:

o Adequate separation of controls (and their triggers) from surrounding objects

o Protection of triggers against entanglement with loose clothes, hoses, cables, etc.

o Prevention of accidental contact between the operator and the platform controls which could result in sustained involuntary operation and potential crushing of the operator against an external obstruction.

Implementation

At April 2008, MEWPs meeting these standards include all those with additional protection specified and fitted to the control panel by the manufacturer, including:

o Genie MEWPs manufactured since 2003, with canopy protection above the control panel

o Genie MEWPs with manufacturer’s retrofit of canopy to control panel. Further protection is expected to be provided by an automatic cut-out wire, currently under test and final development by Blue Sky Access. Subject to successful trials and CE marking, it is expected that cut-out wires will become available for retrofit by Blue Sky Access during 2008. They will then become the company minimum standard for both hired MEWPs and Balfour Beatty owned MEWPs.
All future orders for MEWP hire are to take account of this Balfour Beatty Group Policy, with immediate effect.

Background Information

1.1 Introduction
This document provides background information to Balfour Beatty companies on the rationale for the Group Policy on the procurement and operation of boom type Mobile Elevated Work Platforms (MEWPs).

1.2 Background
There are about 20,000 boom type MEWPs in the UK with shrouded foot pedals and unprotected control panels. This configuration is expected to be in use for the next ten years. When such machines are used in locations with overhead hazards, they can pose a risk
of crushing to the operator. If the operator becomes trapped against an external beam or obstruction, he may be unable to operate the controls and unable to prevent sustained involuntary operation of the MEWP.

The use of MEWPs with unprotected control panels has featured in at least five UK fatal accidents and numerous major injuries since 2002.

1.3 Regulations

Boom type MEWPs with this configuration (shrouded foot pedals and unprotected control panels) appear not to comply with either the Machinery Directive’s Essential H&S Requirements relating to the design of machinery, or with BS EN 280:2001 for the design of MEWPs.

The Machinery Directive 98/37/EC

This Directive provides the regulatory basis for the harmonisation of the essential health and safety requirements for machinery at European Union level.

Annex 1 of the Directive sets out “Essential Health & Safety Requirements” including the need to assess use of machinery for Danger Zones: ie any zone within or around machinery in which an exposed person is subject to a risk to his health and safety. It then states that control devices must be:

• Located outside danger zones (except emergency stops)

• Positioned so that their operation cannot cause additional risk

• Designed or protected so that the desired effect, where a risk is involved, cannot occur without an intentional operation.
There are approximately 20,000 boom type MEWPs in the UK with control levers exposed within danger zones above the control panel.
BS EN 280: 2001 MEWP Design

This standard appears not to recognize:

• The risk of operator crushing against overhead obstructions, or

• The concept of danger zones, and

• Assumes that MEWP operators ‘are not incapacitated and can assist in the operation of the overriding emergency device’
MEWPs are currently CE marked to BS EN 280: 2001

• The standard does require ‘all controls to be constructed to prevent inadvertent operation’

• Boom type MEWPs with shrouded foot pedals and unprotected control panels appear not to comply with this requirement

• This configuration is expected to be in use for the next ten years, because the amended BS EN 280 has no requirement to retrofit additional protection to existing machines. 1.4 Industry Proposals
A task group from BB, the Construction Confederation, IPAF, PAC (Powered Access Certification) and PAIG (Powered Access Interest Group – Hire Companies) have held a series of meetings in 2007 and secured HSE’s agreement to the following retro-fit

proposal:

General Requirements

To prevent accidental contact of the operator’s torso with the platform controls which would cause sustained involuntary operation of the controls and subsequent MEWP or platform movements that could trap the operator between the controls and an object outside the platform.

The above may be achieved by features that provide the operator with the capability to:-

• maintain operation of the control if they are pushed over the control
panel and adjacent structure, or where this is not possible

• release the control(s) before sustained involuntary operation occurs. Minimum Requirements for controls with triggers in platforms
Controls and, where fitted, their triggers should be separated from surrounding objects by separation distances that allow the control and trigger to be operated and/or released in all control and trigger positions and control panel locations.

Platform controls with triggers should be protected against entanglement with loose clothes, hoses and cables etc.

1.5 Retro-fit Options

There are two retro-fit solutions to prevent crushing risks in MEWPs:

- A canopy fitted over the control panel (Photo 1), available immediately

- A cut-out wire across the control panel (Photo 1), under final testing.

Why attach additional protection or cut-out wire across the control panel?

- In July 2003, one of our MEWP operators was fatally crushed against an overhead beam.

- HSE issued a warning of operator crushing to industry in October 2005

- We have been lobbying the powered access sector and the HSE for MEWP retrofit since then.

What are the advantages of the additional canopy above the controls?

1) It prevents the operator from landing on the controls

2) It provides additional time for the operator to release the controls to limit the potentially crushing movement of the basket

3) It enables the machine design to comply with the requirement for no controls within danger zones.

What are the disadvantages of the additional canopy?

1) The operators torso will be pinned between the overhead obstruction and the control panel canopy earlier than it otherwise would have done against the top of the control panel

2) Avoidance of serious injury relies on the operator releasing/ reversing the controls

What are the advantages of the cut-out wire?

1) Powered movement of the MEWP is cut-out at the earliest opportunity without reliance on conscious response from the operator

2) Thereafter, the operator’s torso can move down onto the top of the control panel or protective canopy before being pinned against the overhead obstruction

3) Design responsibility will stay with Blue Sky Access who will secure CE marking for the arrangement

4) The cut out wire triggers immediate power loss rather than the dampened response to the emergency stop.

What are the disadvantages of the cut-out wire?

1) Site trials are required to ensure that the cut-out wire is sufficiently robust for the required application.

1.6 What is the Powered Access Sector Doing About Retrofit?
IPAF presented the industry’s retro-fit proposal to their

Manufacturer’s Technical

Committee on 25th October 2007. Apparently there was an acceptance that action would be necessary, but no commitment to timing and a concern about the impact of retrofit on liability for past accidents.

In November 2007, Genie (one of the two largest MEWP manufacturers) issued an instruction to its hire companies worldwide to retrofit approximately 42,000 MEWPs with a canopy similar to that shown in Photo 1 to prevent operator crushing against
overhead obstructions.

Could we instruct MEWP Hire Companies to attach additional protection on all machines hired to us?

The Hire Companies refuse to take action which the manufacturers do not sanction, for fear of breaching the machine’s CE marking.

1.7 BB’s actions

If we wait for other MEWP manufacturers to instruct hire companies to retrofit additional protection to the control panel, we will be at risk of a repeat fatality.

We are therefore taking the following actions:

- Adopt a policy of hiring only MEWPs which have the canopy protection above the control panel. MEWPs produced since 2003 have this arrangement and we should be able to source sufficient machines with due notice

- We are funding the Blue Sky Access (BSA) Company to secure CE marking for the cut-out wire attachment, which should be available during 2008.

When available this is expected to provide our MEWP operators with the maximum protection against crushing.
Please register to see all images

The control panel shroud and proposed trip wire

Vertikal Comment

We have to admit to having ‘sat’ on this bulletin since it was issued, while waiting to see the outcome of testing on the Blue Sky trip wire.

While we do understand Balfour Beatty’s concern and frustration at the slow pace of progress on this issue, we do think that any such action by one contractor that requires a machine to be modified in critical areas is in itself potentially dangerous.

The problem is that in so many cases a solution to one apparent problem can create another one, sometimes more serious than the one being ‘solved’.

The foot pedal issue has been around for years and as long 15 years ago some manufacturers moved away from shrouded pedals. However the arrival of new safer electronics prevented jamming the switches closed making shrouds safer.

There are arguments against foot pedals being used at all, but that is another subject.

It is our opinion that:

1.Having contractors/users unilaterally modifying machines or demanding modifications is bad practice. Even though it may be well intended.

2.The trip-wire cut-out switch is not a good idea and is not the solution to this issue.

With two major companies having now demanded modifications – Balfour Beatty in the UK and BHP in Australia, to all machines working on their sites, this does suggest that the industry has dragged its feet on this subject and failed to address a subject that is of clear concern to many users.

It is easy to say that staff within these two companies have over reacted or are getting carried away. However if you have ever been involved with a fatal accident, particularly if you have been the one to tell the immediate family, you will understand how after trying to change the industry actions such as this are taken.

The industry needs to accelerate any work on this issue making strong recommendations and a clear definitive statement.

If only some of the national members on the EN280 vertical committee would address real issues such as this, rather than waste time on theoretical risks perhaps action such as this might have been avoided.