Spindle Moulder Advice

[RobinBHM]

Just to clarify, chip limiting tooling is required for both hand feeding and power feeding on a vertical spindle moulder. Of course this is the requirement in a business with employees, although as mentioned further up the thread, self employed people will likely have insurance which will almost certainly require compliance.

full pdf here: http://www.hse.gov.uk/pubns/wis37.pdf

Extract from HSE Woodworking Information Sheet No 37 (Revision 1)

On which machines do I have to use
limited cutter projection tooling?
Where possible to fit them, there has been a
requirement to use limited cutter projection
tooling on hand-fed machines since 5 December
2003.2
The term ‘hand-fed’ includes the use of
demountable power feed units and hand-operated
carriages on which the workpiece is placed manually
or clamped.
Limited cutter projection tooling can be used with:
■ vertical spindle moulders;

 

[RogerS]

Jacob, what part of the phrase 'legal requirement' are you having difficulty in understanding?

But like many other threads where one gets dragged by Jacob into trying to nail jelly to a tree. I promise this is my last contribution to this thread in response to Jacob.

 

[Jacob]

.... I promise this is my last contribution to this thread.

Promises promises! :roll:

 

[James-1986]

"legal requirement"

If they give me 20 grand I'll be able to comply, otherwise they can mind their own damned business :wink:

 

[RogerS]

Just to clarify, chip limiting tooling is required for both hand feeding and power feeding on a vertical spindle moulder. Of course this is the requirement in a business with employees..........

Robin, this question cropped up over on WoodworkUK as the general consensus was as you suggest...ie PUWER (which is the Act in question ) only applies to those businesses that employ people. It does not. PUWER equally applies to self-employed people as well (even one-man bands) and I got clarification of this from HS & E. A big surprise, I must say.

James...either you've got the world's largest collection of cutters (without limiters) or you need to find a cheaper supplier !! :lol:

 

[Jacob]

"This leaflet contains notes on good practice which are not compulsory but which you may find helpful in considering what you need to do. "
If you cause an accident by not following "good practice" then you could be liable for the damages. Fair enough, but it remains open to interpretation and circumstances. And there will certainly be good practices which are not detailed in any of the pamphlets.
Let us know when you are making you last post Roger - you keep promising!

Here's the tune

 

[RogerS]

Do I smell a troll in here ?

 

[Jacob]

Is that it then?

 

[James-1986]

James...either you've got the world's largest collection of cutters (without limiters) or you need to find a cheaper supplier !! :lol:

:lol:

I DO have quite a big bucket of HSS cutters!

However I would also want a tilting spindle to replace my EQ, a profile grinder, a setting stand, moulding blocks, rebate blocks, cill blocks, scribing blocks, big bucket of shaped cutters as well as blanks AND a nice T handle hex key to do up all the bolts

 

[RobinBHM]

Just to clarify, chip limiting tooling is required for both hand feeding and power feeding on a vertical spindle moulder. Of course this is the requirement in a business with employees..........

Robin, this question cropped up over on WoodworkUK as the general consensus was as you suggest...ie PUWER (which is the Act in question ) only applies to those businesses that employ people. It does not. PUWER equally applies to self-employed people as well (even one-man bands) and I got clarification of this from HS & E. A big surprise, I must say.

James...either you've got the world's largest collection of cutters (without limiters) or you need to find a cheaper supplier !! :lol:

Hi Roger, thanks for clarifying my clarification -I have to admit to assuming it doesnt apply to self employed people rather than actually having checked it out. In reality, it seems unlikely HSE would prosecute a one man band for injuring himself.............

Nevertheless, a self employed woodworker can easily have an injury that could end his career and thus income, so it is wise to be risk adverse. One can argue the details, but the regulations for woodworking, overall make a safer environment and if tooling etc is compliant then risk is reduced along with the temptation to take risky shortcuts.

The recent thread about ladders shows how tempting it is to take shortcuts to get the job done.

 

[Jacob]

...... In reality, it seems unlikely HSE would prosecute a one man band for injuring himself.................

You'd have to prosecute yourself - with help from HSE.

 

[Jacob]

I must be the first person on this forum to read Woodworking Information Sheet No 18 (Revised) right to the end as nobody else seems to have noticed the footnote;

"This leaflet contains notes on good practice which are not compulsory but which you may find helpful in considering what you need to do"

It's advisory rather than compulsory.

In the event of an accident you would of course be culpable if you hadn't followed recommended safety advice or set up other sensible safety procedures. No one could argue with that.

There is masses of other material such as http://www.hse.gov.uk/pubns/books/l114.htm but the emphasis is on guidance and recommendations.

It makes sense of course to treat the good practice info as the default standard and to all intents and purposes obligatory, particularly where third parties are involved.

But there remains leeway for other ways of doing things.

 

[Peter Sefton]

I must be the first person on this forum to read Woodworking Information Sheet No 18 (Revised) right to the end as nobody else seems to have noticed the footnote;

"This leaflet contains notes on good practice which are not compulsory but which you may find helpful in considering what you need to do"

It's advisory rather than compulsory.

In the event of an accident you would of course be culpable if you hadn't followed recommended safety advice or set up other sensible safety procedures. No one could argue with that.

There is masses of other material such as http://www.hse.gov.uk/pubns/books/l114.htm but the emphasis is on guidance and recommendations.

It makes sense of course to treat the good practice info as the default standard and to all intents and purposes obligatory, particularly where third parties are involved.

But there remains leeway for other ways of doing things.

Well done for spotting something written 13 years ago Jacob (thanks for bringing it to our attention) :mrgreen: , but I think you have a bit more reading to do before they ask you to join the advisory committee!
You may also need to read all the legislation to get the full picture. The revised publication you highlighted has been with us since 1998. This is what the rest of the professional industry has been working on since then. If you do care to read on you will find the regulation apply to employers and the self employed - you may cut your fingers off in your time proven ways but you can be prosecuted and then charged the costs for the prosecution. You can go to court and fight against the legislation but if you have not used the ACOPs you will not win.

I know you will continue in your own way, but my main concern is that this forum is a venue to help new and improving woodworkers and your personal practices and mis-information may end up seriously injuring someone else!

I do hope this does not come to fruition and some common sense prevails.

The blocks being advertised and then recommended by yourself as seen on Wealdon are only to be used on machines with interlocking guards, not hand fed spindle moulders including those fitted with power feeds or people using push sticks.

 

[Jacob]

So - what/where are the legally obligatory rules, word for word, rather than advice and recommendations? Which are the correct ACOPs? At which point does an ACOP become a legal obligation?

If the law is unclear (it is) then it's bad law. Is the HSE publishing material which is out of date? I downloaded the PDF today. Should they be prosecuted for distributing misleading and incorrect information?

I'm working with the best information I can obtain. In what way is it mis-information? How could I know, or be responsible, if the information is wrong?

One thing is certain - if you and the professional industry are "working on it", you are making a very bad job of clarifying issues and distributing information.

PS or to put it another way - The highway code is largely compulsory - there is little "should" it's all "must" and an offence not to obey.
As I understand it the HSE rules are not largely compulsory - by their own account on their website today ("This leaflet contains notes on good practice which are not compulsory but which you may find helpful in considering what you need to do"). There is no "must" but in the event of an accident you could be responsible for inadequate safety provision.
Have the HSE got it wrong?

 

[doctor Bob]

Go on Jacob, one more whack..........

 

[Jacob]

I want to know what the law is. Not what Roger or Peter think it is. I don't think either of them know. That's all!

 

[Jacob]

NB see last para;

"This guidance is issued by the Health and Safety
Executive. Following the guidance is not compulsory,
unless specifically stated, and you are free to take
other action. But if you do follow the guidance you
will normally be doing enough to comply with the law.
Health and safety inspectors seek to secure compliance
with the law and may refer to this guidance."

It's advisory not compulsory. Not that I'd argue with it particularly, but it's not against the law, per se, to use other set ups.

Just to clarify, chip limiting tooling is required for both hand feeding and power feeding on a vertical spindle moulder. Of course this is the requirement in a business with employees, although as mentioned further up the thread, self employed people will likely have insurance which will almost certainly require compliance.

full pdf here: http://www.hse.gov.uk/pubns/wis37.pdf .......

 

[RobinBHM]

The key here is 'unless specifically stated':

on page 1 of the guide notes it says:
Limited cutter projection tooling should be designed
and constructed to meet BS EN 847-1.

It isnt as clear as it could be, like a lot of these sorts of documents. I suppose because it covers so many different situations and sectors of woodworking industry, the regulations cant be as explicit as they really should be.

The point about self employed, which I hadnt realised, is actually clearly mentioned in PUWER here:
Who has duties under PUWER?
18 PUWER places duties on:
• employers;
• the self-employed;
• people who have control of work equipment.


http://www.iosh.co.uk/~/media/Documents ... 0L114.ashx

 

[RogerS]

"Where possible to fit them, there has been a requirement to use limited cutter projection tooling on hand-fed machines since 5 December 2003.2 The term ‘hand-fed’ includes the use of demountable power feed units and hand-operated carriages on which the workpiece is placed manually or clamped."

"Requirement" ....noun
a thing that is needed or wanted: choose the type of window that suits your requirements best.
• a thing that is compulsory; a necessary condition: applicants must satisfy the normal entry requirements.

That seems pretty clear to me.

 

[Peter Sefton]

I attended one of the HSE training days back in the late 90's when the ACOPs and PUWER were produced, part of the legislation that superseded the 1974 regs put the onus for employees to write risk assessments and safe systems of work for their own work places. These need to be based on the ACOPs to show how you will comply.

Below is a small exert from the ACOP

Approved Code of Practice
This Code has been approved by the Health and Safety Executive, with the consent of the Secretary of State. It gives practical advice on how to comply with the law. If you follow the advice you will be doing enough to comply with the law in respect of those specific matters on which the Code gives advice. You may use alternative methods to those set out in the Code in order to comply with the law.
However, the Code has a special legal status. If you are prosecuted for breach of health and safety law, and it is proved that you did not follow the relevant provisions of the Code, you will need to show that you have complied with the law in some other way or a Court will find you at fault.

You may also find the updated information on chip limited tooling of interest.

http://www.hse.gov.uk/pubns/wis37.pdf

The way people usually find out if they have complied is after the accident has happened and they attend court. At this time they don't have a leg to stand on or a finger to point the blame with (depending on the severity of the accident)

The courts will not except either ignorance or lack of cash as reasons for non compliance. It is the duty of all to to understand and comply to the regs.

This maybe like the British tax system, not straight forward or possibly fair but the law of the land.