§218 1.4.2.1.　固定ガード

Section 1.4.2.1 sets out three requirements for the first type of guards: fixed guards. The requirements set out in section 1.4.2.1 are complementary to the general requirements for guards and protective devices set out in section 1.4.1.

If the zone protected by a fixed guard does not need to be accessed or if the necessary access can be obtained by another route, fixed guards can be permanently fixed, for example, by welding, riveting or gluing. On the other hand, if it is necessary to open or remove a fixed guard, the first paragraph of section 1.4.2.1 requires that it must only be possible to open or remove the fixing systems with tools. This requirement aims to restrict the removal of fixed guards to competent or authorised persons by an intended action needing some thought and time. Fixed guards may thus be fixed, for example, by means of bolts, screws or other fasteners that can only be removed by using tools such as keys or wrenches. The choice of construction of fixed and movable guards.

fixing system and tools must be considered in light of the risk assessment. Fixings that can be quickly loosened or removed such as, for example, wing nuts, or quick- release fasteners, must not be used.

The second indent of section 1.4.2.1 requires the fixing systems for fixed guards to remain attached to the guards or to the machinery when the guards are removed. This requirement aims to reduce risks due to loss of one or more of the fixings when guards are removed, for example, for maintenance purposes. This can lead to the guards not being replaced, being only partially fixed in place or fixed with replacement fixings that do not have adequate strength, so that the guard cannot adequately perform its protective function, for example, where containment of ejected parts is necessary.

Application of this requirement depends on the manufacturer's assessment of the risk concerned. The requirement applies to any fixed guards that are liable to be removed by the user with a risk of loss of the fixings, for example, to fixed guards that are liable to be removed during routine cleaning, setting or maintenance operations carried out at the place of use. The requirement does not necessarily apply to fixed guards that are only liable to be removed, for example, when the machinery is completely overhauled, is subject to major repairs or is dismantled for transfer to another site. For the same reason, it may not be necessary to apply the requirement to the casings of machinery intended for use by consumers, where the manufacturer’s instructions specify that the repairs requiring removal of these casings are only to be carried out in a specialist repair workshop. In that case, fixing systems should be used that are not easy to remove.

The requirement set out in the third paragraph of section 1.4.2.1 aims to prevent the situation where the operators are unaware that a fixed guard has not been properly fixed in place or have failed to replace the guard correctly. Where possible, fixed guards should automatically come away from their fixed position when the fixings are loosened.

As a general rule, building structures (e.g. walls, pillars, etc.) where a machine is installed cannot be considered as guards (fences) of the machinery itself. However, their characteristics may be sufficient in order to prevent workers to access to dangerous parts of the machines or the dangerous areas. In these cases, the structures may replace the installation of additional guards.

For a particular machinery installation such structures can form part of the essential safety package for that installation provided that the machinery manufacturer:

has assessed that they are suitable for the application; and

recorded this in the machine’s technical file; and

indicated in the instructions that the installation is unique because of its reliance on building walls for safety; and

warned in the instructions of the risks that may arise if the building walls are modified, moved or removed, or the machinery is re-located, because the current configuration of the building walls is part of the safe machine layout; and

specifies in the instructions the fencing requirements for the safety of the machinery if it is moved to another location to ensure it meets the requirements of Directive 2009/104/EC when in use.