HSE - Very, Very Nice Man & this week's Can of Worms!

[Steve Maskery]

Afternoon everyone. We haven't had a DADO thread for ages, have we?

I'm being very brave (or foolhardy, whichever way you wish to interpret it) and filming a sequence about dado heads on tablesaws. Now I'm pretty sure I know the score, but I thought I'd just ring up the HSE and make sure I wasn't making too much of a rod for my own back here. So I spoke to Very Nice Young Lady (actually I've no idea how old she was, but let's give her the benefit of the doubt, shall we?).

"I'd like a definitive stand on the use of dado heads in tablesaws, please."
"Well the legislation is open to interpretation, sir."
Terrific. If I can't get a definitive answer from the HSE, who can I turn to?

Anyway, I explained what I wanted and why, and half an hour later I was called by Cliff, who was very helpful indeed.

We talked about the issues and he asked if I'd seen the video clips on the HSE website.
"Ah," says I, "you mean the ones where guards have been removed for clarity?"
"Well, people wouldn't be able to see anything, otherwise", he mumbled, defensively. Anyway I don't want to knock him, he was genuinely very helpful.

So in short:

1 Dado heads must be chip limiting in design
2 They must be guarded
3 The saw must still stop within 10 seconds
4 The workpiece must be properly supported throughout the cut

and that's pretty much it. Of course, some of those are not easy to achieve with the guard supplied with the machine, and most machines don't come with a long arbor anyway, and many machines are underpowered for a stack, so those issues may also prevent the use of a dado head on a TS, but in terms of the legislation itself, the above is what matters.

Straight from the horse's mouth.

Anyone seen Scrit lately?

Cheers
Steve

 

[ondablade]

Thank you for that Steve, that's the way to separate the fact from the fiction. Although over here the chances of getting a 'nice' or better still informed guy from the public system that's not off on a head trip are pretty slim.

The question it immediately brings to my mind is why then are UK and Irish saws not fitted or at least generally offered with dado compatible spindles? There seem to be factors driving the situation beyond what you listed, but it might not be legislation per se. Are they avoiding a risk of liability, or hoping the sell upgrades, or what? Or could it be that the 10 sec stop is the bugbear versus the possibility of loosening and/or having enough braking power available?

Why also does such a fog of negativity surround the subject in the UK? Could it be that something has changed, or that it's mostly hearsay and bull based on stories from the days when the toling was much less safe? (e.g. wobble sets and the like?)

The other question is whether or not your average US pattern shimmed dado set qualifies as chip limiting, and si otherwise legal? A quick look suggests that they are at least chip limiting - the ones that came up have a raised shoulder behind the cutting edge.

It's a topic I've been sniffing around fairly recently, as I want to buy a set for my Hammer K3 panel saw. (which has the extended saw spindle option to suit) Felder and Hammer have various carbide tipped slotting sets available to suit, as do Garniga. But they are quite pricey, and there's mixed feedback on performance (generally excellent, but not as good as a standard US pattern shimmed set on plywood etc) - it'd hurt to get it wrong.

One option is to import one of the good US sets (some are cheap and nasty) that are available with the dowel pin holes from Forrest, Infinity or FS tool - cheaper than the above, and quite a few US Felder users prefer them anyway on the basis that some say they give a cleaner cut on difficult materials. Others don't by the way - I've a feeling that saw set up is in the mix somewhere.

One problem with the Hammer is that it hasn't got the clearance to run the larger 8in more (US) standard dado set, and I'm not too sure how much going to a smaller 6in or marginally larger set may (if at all) compromise the performance. (it's got more 'upcut' than an 8in)

Another issue is the ability to and pros and cons of using the kit on a spindle moulder for tenons and the like. Carbide tipped tooling is generally designed with this in mind.

The US Sawmill Creek forum recently ran a thread on dados vs. routers for slotting. The gist of the feedback seemed to be that while there were people arguing for both, the more thoughtful feedback suggested that it's a horses for courses sort of thing.

 

[tomatwark]

Question is what the HSE think are proper guards and what will work allowing you to use the saw with a dado head in it.

If you were using it in a spindle it would still have to be chip limited and properly guarded, but you may get a better finish from a proper set of tenoning cutters. It would probably depend on the quality of the tooling.

I suspect that saws sold in the UK are not generally fitted with long enough arbors because of lack of demand.
Tom

 

[Blister]

Arrrrr

Run for the hills :mrgreen:

 

[andy king]

So in short:

1 Dado heads must be chip limiting in design
2 They must be guarded
3 The saw must still stop within 10 seconds
4 The workpiece must be properly supported throughout the cut

Cheers
Steve

And of course Steve, on a saw that is compliant for use in the UK - ie. CE badged... :wink:

cheers,
Andy

 

[Steve Maskery]

Ah. Yes, well, I did say it was a can of worms, Andy. Did you have any particular saw in mind?
S

 

[andy king]

Ah. Yes, well, I did say it was a can of worms, Andy. Did you have any particular saw in mind?
S

without naming a particular brand directly, the 'sword in the stone' model! :wink:
I spoke with HSE on a similar vein a few years back and they got very interested about that particular part of the conversation saying it could and (would very likely) lead to a prosecution as its illegal to bring into the UK without proper certification.
I know you used to have one, not sure if you still do?
I'm not sure if they have finally got them in the UK properly certified now either. There was talk on here quite some time back saying it was 'immanent' but how that has progressed i don't know.

cheers,
Andy

 

[stuartpaul]

Steve,

I'm not at all surprised by a fairly down to earth response from the HSE.

They do genuinely try to help people make good, safe decisions (I hate the phrase common sense so won't use it!). They rely heavily on risk assessment to help this process, - the trouble is people need to know what they're doing to carry out a proper one (it's also not a zero risk approach taken).

Most people have a negative view of the HSE because they only get involved when something's gone wrong, - and quite honestly having been involved in some nasty accident investigations they deserve all they get!

Look forward to your video.

Stuart

 

[tomatwark]

So in short:

1 Dado heads must be chip limiting in design
2 They must be guarded
3 The saw must still stop within 10 seconds
4 The workpiece must be properly supported throughout the cut

Cheers
Steve

And of course Steve, on a saw that is compliant for use in the UK - ie. CE badged... :wink:

cheers,
Andy

Just because it has a CE mark does not mean it meets the regulations, this was raised in another thread last week. #-o

This is the EU for you :roll:

Tom

 

[andy king]

So in short:

1 Dado heads must be chip limiting in design
2 They must be guarded
3 The saw must still stop within 10 seconds
4 The workpiece must be properly supported throughout the cut

Cheers
Steve

And of course Steve, on a saw that is compliant for use in the UK - ie. CE badged... :wink:

cheers,
Andy

Just because it has a CE mark does not mean it meets the regulations, this was raised in another thread last week. #-o

This is the EU for you :roll:

Tom

Hi Tom,

The way I read that thread was that while the machines involved were CE certified, they were not up to the standards required for the PUWER regulations and industry, so modifying them to meet the PUWER regs invalidated the original CE.
It was mentioned that they were aimed at the DIY/hobby market, but in the posters own opinion, and with plenty of qualification to back it up, wouldn't meet PUWER regs should they be sold into that arena, and it seems the dealer involved was doing so.
He also mentioned the PUWER regs for industry have to meet a criteria that includes CE regulations as part of it.
The saw I referred to has no CE certification at all (at least, it didn't going back a while) and therefore was/is illegal to be sold in the UK, irrespective of its intended userbase. (there was comment on an old thread that the company involved when contacted by a forum member said it was for hobby use so didn't matter/need to iirc :shock: :roll: - they did then go on to say it was in the pipeline to get it done.)

cheers,
Andy

 

[ondablade]

No indeed Steve. As you clearly know (but for others) the CE mark just signifies a declaration by the boss of the designing company that the machine is compliant and 'safe'. I'm no expert, but done right it seems usually to grind down to a mix of (a) risk assessment to decide about safety, and (b) application of specific rules (often ISO standards) where applicable.

It's largely a self assessment based standard rather than a set of hard and fast rules - so if the boss is a risk taker the product can probably get into the market on a wing and a prayer. It's normally only after an accident that there's a detailed external review - although in my experience making the boss personally responsible seems get the attention of most.

One downside from the designer's point of view can be that accident investigations can very easily become a hunt for a witch to burn - note the phrasing. Risk assessment is in reality inevitably a judgement call, and while structured methodologies and experience tighten things up its not a black and white matter...

 

[andy king]

It's largely a self assessment based standard rather than a set of hard and fast rules - so if the boss is a risk taker the product can probably get into the market on a wing and a prayer. It's normally only after an accident that there's a detailed external review - although in my experience making the boss personally responsible seems get the attention of most.

Hi Ian,

This is true in certain areas, you can self assess certain tools and machines, but with saw tables, spindles etc, they have to be done independently by a recognised certification company - at least, that was what the HSE guy I spoke to said, as the inherent dangers of such machines and having self certified ones in the marketplace is far too dangerous to allow.

cheers,
Andy

 

[NetBlindPaul]

andy,
You are correct machines which come under Annexe 4 of the Machinery Directive MUST be independently verified for CE satus.
This is why Record Power for example use TUV.
Part of one of my previous roles was getting equipment CE marked for my employer.
As I understand the legislation almost all wood working machinery is Annexe 4.
I could check but I have a lot on at the moment.
I also find HSE very helpful, I have had several contacts with them through both my membership of IOSH & the IET (IEE).
I'm not sure who your "Cliff" was he may have been one of your local specalist inspectors, however the name of the HSE lead in wood working is not Cliff, it's Tim, (or was a few months ago when I last had contact with him!)

If you have any questions please do contact me, as I do have the copies of legislation to back up my opinions and the professional qualifications also.
I don't have enough time at the moment to spend as much as I would like on here due to other work commitments.
PM's are emailed through.

 

[ondablade]

Sounds like there's a special annex for woodworking machinery - my experience was in the design of special purpose machines. To the best of my knowledge the essential characteristic of CE in general though is the self assessment, but correct me if I'm wrong....

 

[NetBlindPaul]

Ian,
Generally self assessment, yes, however, high risk machines require additional checks by 3rd party, power presses are another class in Annexe 4.

 

[Benchwayze]

I suppose I could have a dado cutter on my Coronet saw. Not much point though really.
It isn't a true table saw. Just an attachment on my lathe. But because it's old it has a 5/8" arbor, and again I could fit a Dado cutter. But how do you cut 'dados' with a guard fitted? Wasn't the fact you have to use them unguarded, the reason that HSE didn't like them?

I always use a router to cut Dados. I find it safer, if a little slower. Although, I still have my 'wobble-saw' set up and I used it often enough before I bought a router!

I won't say I am bullet-proof. No one is, but so far I have all digits intact.

Regards
John

 

[Steve Maskery]

But how do you cut 'dados' with a guard fitted? Wasn't the fact you have to use them unguarded, the reason that HSE didn't like them?

You don't have to use them unguarded at all, John, although it is true that the guard that comes with most tablesaws is unsuitable because it relies on the riving knife for its support. You have to have a guard that is independent of the RK.

A SUVA-style guard on an arm, or a guard mounted on a featherboard fence will guard for grooves, depending on how far the groove is from the reference edge.

For housings you need to mount the guard from the rear (I can screw mine to my outfeed table), or use the SAVA guard if it doesn't need the rip fence for support (mine does, hence the rear support).

I always use a router to cut Dados. I find it safer, if a little slower.

Yes, absolutely, it is a far more suitable method. And if you take into account the setup and strike time of the dado head, it's not even slower. We home woodies don't often have to do long production runs.

Cheers
Steve

 

[Benchwayze]

Hi Steve,

Of course... You are correct!. I forgot about the overhead 'floating' guard!

Cheers
John

 

[ondablade]

So at risk of getting sucked into some ongoing game of tennis, and if one was to build on what's come to light and been tabled so far - does this suggest that a revised view of the the sale and use of dado cutters in the UK might be appropriate?

As before. If they are as seems to be the case legit, why is it that there is so much negative (and often misleading) press about? Why also are they so little sold and used, and why are so few saws set up to take them?

Does the realpolitik that has grown up around the issue actually have any basis in fact?

 

[andy king]

So at risk of getting sucked into some ongoing game of tennis, and if one was to build on what's come to light and been tabled so far - does this suggest that a revised view of the the sale and use of dado cutters in the UK might be appropriate?

As before. If they are as seems to be the case legit, why is it that there is so much negative (and often misleading) press about? Why also are they so little sold and used, and why are so few saws set up to take them?

Does the realpolitik that has grown up around the issue actually have any basis in fact?

I'd say that reading the HSE literature, they make note of risk assesment and the choice of the most suitable machine to perform the task. (iirc)
The onus on the end user is then to prove (should an accident occur) they had indeed used the correct machine, with correct guarding, so with the dado for instance, dependent on the operation being performed, a spindle with Shaw guards, powerfeed etc is a safer option, as would be a router with a straightedge.
Using a tablesaw with a dado is maybe not a problem as such, assuming its correctly guarded, with tunnel, Shaw, or SUVA type, but its whether the end user actually uses them that gives it a sort of grey area as they would need differing setups according to the work being done.
On a spindle with a flip up hood and guards attached, its a simple and speedy operation, but a tablesaw could lead to corner cutting imho - especially with programmes such as NYWorkshop showing 'guards removed for clarity' statements when in fact some of those tasks being performed are impossible with the guards on.
As for the use of them per se, i would again assume that saw tables are now designed within certain parameters, one of them being able to bring a saw blade of its intended use (3mm or so thick, correct diameter for the machine etc) to a stop within ten seconds as part of current legislation.
Having an extended arbor allowing heavier dado sets to be fitted would then mean the machine has to be upgraded to allow for that eventuality, at some cost i would imagine - and probably not viable for the lower end of the market, while the industry end has the option of dedicated machines for such work.
But also, you then have to determine what sort of dado - a steel block, aluminium...? Again differing factors that can't be accounted for at the design stage.
The manufacturer can state that a dado of 'x' dimension and 'y' weight/speed ratio etc can only be used, but end users are end users, and apart from the danger side of things, would probably damage the machine itself if an unsuitable dado was fitted, and where does that leave end user v manufacturer when it comes to a claim of a faulty product? Difficult for a manufacturer to prove I would think.
Just my own thoughts.

cheers,
Andy