Research rigs
This guidance is in reference to products and equipment which have been designed and made/constructed at the University, such as research equipment and rigs (collectively known as research rigs), that are for workplace use only and are not intended to be sold or traded.
You have an obligation to make sure a product meets all of its essential health and safety requirements, even if it is only for your own use and you have no intention of supplying it to other parties. Regulations related to machinery safety do not apply to temporary research equipment, however vigilance for any products or equipment of this type is required to ensure that all such items meet the mandatory compliance standards. The Provision and Use of Work Equipment Regulations (PUWER) sets out minimum safety requirements which must be adhered to, and these apply to equipment including specially designed research rigs constructed ‘in-house’ for your own use ‘in-house’. Research rigs brought in by new or visiting researchers must also adhere to these regulations, which are retrospective regardless of the equipment’s age.
If parts or-sub-assemblies will be procured from suppliers, this must be undertaken in accordance with the steps outlined in
Declaration of Conformity
A Declaration of Conformity (DoC) is a formal written statement by the manufacturer or their authorised representative, stating that the product meets all relevant product supply legislation applicable to the product (occasionally there may be several DoCs, one for each regulation, although normally they should be combined into one document).
Declaration of Incorporation
A Declaration of Incorporation (DoI) is a formal written statement, very similar to a Declaration of Conformity but only currently exists under the Supply of Machinery (Safety) Regulations. However, the DoI states that 'the partly completed machinery must not be put into service until the final machinery into which it is to be incorporated has been declared in conformity with the provisions of this Regulation. The Declaration of Incorporation may only be issued for partly completed machinery, which cannot operate independently. It enables identification of the original manufacturer of the part and shows the customer that it complies, as far as it is able, with Supply of Machinery (Safety) Regulations. Instructions for the safe and correct assembly of partly completed machinery must be provided along with the DoI.
Considerations for Research Rigs
Safe design is critical to meeting the essential health and safety requirements for research rigs from the outset and this needs to be augmented with clear and accessible information about the production and use of research equipment /rigs including in any foreseeable abnormal situations. Set out below are the stages to be followed and the considerations that may be incorporated to completing each stage. Naturally these will take account of who may be harmed and how any harm would occur during the various stages of development and delivery.
Stage 1: Design
The Health and Safety at Work Act places a duty on any person who designs, manufactures, imports or supplies any article for use at work to ensure so far as is reasonably practicable that the article is designed and constructed that it will be safe and without risks to health. This means that you must consider the potential the equipment has to cause harm and the measures needed to mitigate this.
Early engagement of those with experience such as departmental technicians, senior academics or Heads of Department (HoDs) is recommended, with additional advice sought from your Health and Safety Adviser on our process and assessing health and safety risks.
You should consider the following as part of your design process:
- Where will the rig be located? Is the loading sufficient?
- How will it be supported? Has the weight and movement tolerance been factored?
- Does it need housing or containment?
- Will it be mobile or need securing in place?
- Is the size and/or weight accounted for?
- Are the materials and equipment to be used compatible?
- What parts may be required?
- Is access to water, electricity and/or compressed air of the right specification available?
- Is environmental management required e.g. temperature, humidity, sterilisation, extraction?
- Will fumes or dust be produced? Is specialist ventilation required?
- Will non-ionising radiation be incorporated e.g. lasers, EMF?
- Are hazardous substances /materials or compressed gases required? Will there be adequate access to safe and appropriate storage?
- If relevant, how will charging be achieved and will lithium-ion batteries be used?
- Have engineering controls and safety systems been assessed such as secure access, emergency stop controls, interlocks, lock tag out as well as barriers and guarding?
- How is access to the vicinity of the rig to be controlled?
- Is there assurance that it will no longer work if a safety element is compromised?
- What warning signs will be needed?
- Is an inspection schedule in place?
- What pre-use checks will be recorded?
- Have fire safety and DSEAR implications been assessed?
- Can all applicable standards be incorporated?
Stage 2: Preparation
The production of records allows us to demonstrate our commitment to meet the essential health and safety requirements for research rigs as constructed equipment. These must include:
- a risk assessment with appropriate sign off
- communication of any risks to all those using the equipment, including an understanding of the controls in place
- Technical File (see Stage 3)
- Operating procedures
- The process to ensure modifications are captured in review of the risk assessment
- The process for modifications to the equipment which impact its integrity to be notified to a competent person for approval
Stage 3: Technical File
Items to be included in the Technical File include:
- A clear identifying description of the equipment and location of its use
- An outline of its function(s)
- Circuit diagrams
- Test Reports
- Details of all critical operating parameters (speed, temperature, stability)
- Safety related devices
- Software information
- Quality control elements
- Records of risk assessments against the specific applicable standards
- Flowcharts and commissioning procedures
- Standard operating procedures for the system
- Detail equipment maintenance and appropriate frequencies – including electrical checks (PAT)
- Ensure suitable instructions and training documents are available
Stage 4: Safety checks
You must ensure the following are in place:
- Risk assessment
- Asset register listing
- Adequate technical file, environmental controls, attention to assembly, stability, control systems and devices, guarding and protective devices
- Correct design for handling and use of safe materials
- Consideration given to ergonomics, operating positions, seating, safe access for maintenance and cleaning
- Protection from: mechanical hazards, moving parts, sharp edges, potential for falling or ejected parts, being trapped, slipping, tripping or falling
- Protection against electrical, fire, radiation, explosion, extreme temperature noise, vibration, power failure, hazardous materials and emission hazards
- Safe access for maintenance and cleaning needs
- Safe operating procedures/instructions covering; maintenance and cleaning procedures, training programme and personal protective equipment
Machinery Modifications
The manufacturer's technical file must supply full instructions for the safe use of the product, as well as certain other information, such as the noise and vibration levels of the machinery, and how to combine the item with other products (if this is envisaged, for example with partly completed machinery).
If you are making modifications to machinery which had been marked with CE or UKCA marking, you need to ensure it is safe and continues to meet the PUWER requirements. Depending on the modifications, you may wish to get advice from the original manufacturer and will need sufficient engineering expertise for the type of modifications involved. Where this is not available, in or after consultation with Health and Safety, external advice should be sought.
Modifications which impact the integrity of the machinery must be notified to the competent person for approval with all risk assessments and documentation being updated accordingly. Examples include where the modifications:
- are so extensive that the item is basically a new machine
- affect the function of safety devices or systems
- introduce significant hazards that could not have been assessed in the original design, such as converting a manual machine to full computer control.
Further information and resources
HSE guidance:
- Safe Use of Work Equipment
- Provision and Use of Work Equipment Regulations 1998 (PUWER)
- Buying quiet equipment
- Safe use of lifting equipment
