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JICOSH Home > Guidelines > Guidelines on the Disclosure of Machinery Usage Information to Ensure Safety 82001)
Guideline

Guidelines on the Disclosure of Machinery Usage Information
to Ensure Safety (2001)


(Source : Technology Institution of Industrial Safety)


While the majority of occupational accidents involving machinery and equipment are often attributable to unsafe behaviors and/or operations by workers, it should be noted that one reason for this circumstance is the lack of adequate provision by manufacturers to end users of the information required to ensure safe machine operations.

The Ministry of Health, Labour and Welfare, in an effort to further reduce the number of occupational accidents involving machinery and equipment, published a notification, entitled "Guidelines for Comprehensive Safety Standards of Machinery" in June 2001. The Guidelines contain instructions for machinery and equipment manufacturers with respect to identifying hazard through risk assessment, making machinery intrinsically safe, implementing protective measures through the use of safety devices, etc., disclosing usage information, and other such matters. Unlike conventional measures that focused on safety measures implemented by business owners, the Guidelines introduce a global approach to preventing occupational accidents.

The present Guidelines are intended to supplement the usage information provided in the Guidelines for Comprehensive Safety Standards of Machinery of the Ministry of Health, Labour and Welfare.

1.   General

1.1 Purpose

      These Guidelines establish the "machinery usage information (hereinafter referred to as 'usage information')" that should be disclosed by machinery manufacturers and provided by machinery suppliers to users of machinery in order to prevent occupational hazards involving machinery.

1.2 Scope of application

      These Guidelines apply to machinery used in all industries, and cover all aspects of manufacturing, shipping, use, dismantling, and disposal of machinery.

2.   Basic approach to usage information

2.1 Usage information

      Usage information clarifies the intended use of machinery with the objective of preventing occupational accidents involving machinery, and it includes the information and instructions that manufacturers and suppliers of machinery must provide to users of machinery in order for them to use the machinery safely and correctly.

2.2 Basic requirements concerning usage information

      Usage information does not compensate for design deficiencies and it includes the following matters:

1)   General information that a machine user requires to use the machine correctly.

(1)  Original intended use and usage instructions for the machine.

(2)  Information on machine specifications.

(3)  Information that should be displayed on the machine body.

(4)  Information for safe handling of the machine with respect to packaging, transport, storage, assembly, installation, and commissioning.

(5)  Information for safe handling of the machine with respect to use, operation, detection of defects, and maintenance.

(6)  Information for safe handling of the machine with respect to discontinuing use, removal, dismantling, and disposal.

2)   The following safety measures and their effects taken by the machine manufacturer in designing the machine:

(1)  Information on safety related design prerequisites of the machine.

(2)  Hazard identified during risk assessment and the severity of associated risk.

(3)  Hazard and associated risk that were eliminated or reduced through design.

(4)  Risks that could not be eliminated or reduced (remaining risk) through design and associated safeguarding measures.

(5)  Residual risk that remains despite the adoption of safeguarding measures to address remaining risk.

(6)  Additional preventative measures.

3)   Warnings about foreseeable misuse and unintended applications with respect to residual risk.

2.3 Parties disclosing and providing usage information

      The party disclosing usage information shall be the machine manufacturer. The party providing usage information shall be the machine supplier. The following apply according to the circumstances of the machine transaction:

1)   In the case of designing and manufacturing the machine, the party disclosing usage information shall be the machine manufacturer.

2)   In the case of supplying the machine by way of import sale, lease agreement, rental agreement, used sale, etc., the provider of usage information shall be the supplier of the machine, be they an importer, domestic dealer, systems integrator, leasing agent, rental agent, or used machinery seller.

3)   In the case of a machine user transferring the machine to a third party, the provider of usage information shall be the party transferring the machine (user). In such a case, the party transferring the machine is required to provide retained usage information and records of the machine's history.

4)   In the case of the machine user requesting a third party to dispose of or remove the machine, the provider of usage information shall be the party that disposes of the machine (user).

2.4 Recipient of usage information

1)   Concerning the recipient of usage information, the following apply according to the circumstances of the machine transaction:

(1)  In the case of purchasing the machine from the manufacturer, the recipient shall be the employer purchasing the machine.

(2)  In the case of transferring a used machine, the recipient shall be the party receiving the transfer of the used machine.

(3)  In the case of disposing of the machine, the recipient shall be the party handling the disposal of the machine.

2)   The party that actually requires the usage information is the worker engaged in the transport, installation, adjustment, operation, maintenance, cleaning, repair, disposal, etc., of the machine. Therefore, the recipient of the usage information is required to reliably pass on the obtained usage information to workers, and to disclose to workers any independently implemented safety measures, safeguarding measures, and residual risk from not being able to take appropriate safety measures, and additionally, to take necessary measures such as the provision of education and training.

3.   Means and content for providing usage information

3.1 Basic requirements concerning information provision means

      The means for providing usage information shall be determined based on considerations of the content of the usage information, including the disclosed hazard and residual risk, the risk of misuse and unintended application, etc., Select the most appropriate single or combination of communications means. Specific examples include displays, signs (pictographs) or warning labels, signals or warning devices, accompanying documents (instruction manual, safety manual, etc.), education and training on machine handling, and so forth. Satisfy the following conditions in this process:

1)   Place displays and warning labels in appropriate locations such as the machine interior, the side and top of the machine body, etc.

2)   Place signals and warning devices in appropriate locations such as the machine interior, the side and top of the machine body, etc.

3)   Provide accompanying documents at the time of machine delivery or at an appropriate time prior to delivery. In the case of a user requesting the information again after machine delivery due to loss or other reason, give consideration to either the machine manufacturer or supplier having the ability to supply the information again.

3.2 Content of displays

Displays for machinery shall, at a minimum, contain the following content, and shall be clearly legible throughout the life of the machine:

1)   Displays for the purpose of individually and clearly identifying the machine. For example, a nameplate showing the name and address of the manufacturer, the series name, model name, and serial number of the machine, and so forth.

2)   Displays and marks required by laws and regulations.

3)   Information required to use the machine safely.

3.3 Content of signs (pictographs) and warning labels

      Signs (pictographs) and warning labels shall, at a minimum, contain the following content, and shall be clearly legible throughout the life of the machine:

1)   Signs and warning labels do not simply indicate a hazard, but also explain the type and details of the hazard.

2)   The explanation of the type and details of the hazard shall clearly instruct on what should and should not be done.

3.4 Content of signals and warning devices

      Signals and warning devices shall contain the following content:

1)   Visual signals such as flashing lights and audible signals such as sirens that are used to warn of an impending hazardous event such as machine startup or excessive speed shall meet the following requirements.

(1)  Produced prior to the occurrence of the hazardous event.

(2)  Be clearly recognizable by workers and not ambiguous.

(3)  Be reliably perceived and differentiated from all other signals.

(4)  Be aware of the risk of "sensorial saturation" and take steps to address this risk.

2)   Design and install warning devices so they can be easily checked. Additionally, mandate periodic checks of warning devices in the instruction manual.

3.5 Content of accompanying documents

      Include the following information required for the safe use of machinery:

1)   Information on laws, regulations, and standards related to the machine.

2)   Information on the transport, handling, and storage of the machine.

3)   Information on starting the machine. For example:

(1) Requirements for anchoring/installing (including information on dampening vibration, etc.).

(2)  Conditions for assembly and mounting.

(3)  Space required for use and maintenance work.

(4)  Permissible environmental conditions (temperature, humidity, vibration, electromagnetic radiation, etc.).

(5)  Instructions for connecting to the machine's power source (especially instructions for protecting against electrical overload).

(6)  Advice on removing and disposing of waste materials.

(7)  Recommendations for preventative measures that users should adopt (protective equipment, safe distance, safety signs, signals, etc.).

4)   Information on the machine itself. For example:

(1)  Detailed explanations about the machine, mounted equipment, guards and/or safety devices.

(2)  Intended and prohibited usage of the machine.

(3)  Technical drawings (especially conceptual diagrams of safety functions).

(4)  Information on noise and vibrations produced by the machine.

(5)  Information on radiation, gas, vapour, dust, etc., produced by the machine.

(6)  Information on electrical equipment.

(7)  Written documentation showing that the machine complies with essential requirements.

5)   Information on machine use. For example:

(1)  Description of manual control equipment.

(2)  Instructions on making settings (setup, etc.) and adjustments.

(3)  Mode and means for stopping (especially emergency stop).

(4)  Hazard identified through risk assessment.

(5)  Information on risk that the designer could not eliminate with safety measures.

(6)  Information on special risk that could arise with specific applications or mounted tools, and on specific safeguards required for such applications.

(7)  Information on prohibited applications and usage.

(8)  Instructions for restart after identifying, repairing, and intervening (emergency stop, etc.) with error locations.

(9)  Instructions on recommended personal protective equipment and necessary training.

6)   Information on maintenance For example:

(1)  Characteristics and frequency of checks.

(2)  Instructions on maintenance work that requires special technical knowledge and special skills and should be performed by experienced personnel ( maintenance personnel and specialized personnel ).

(3)  Instructions on maintenance work that >can be performed by users (workers) without special skill s. Clearly differentiate between instructions given to experience d p ersonnel and to inexperienced personnel .

7)   Information on stopping use and disposal (storing, dismantling, disposal, etc.) in terms of decommissioning and safety.

8)   Information on emergency situations. For example:

(1)  Measures to extinguish fire.

(2)  Warnings about the potential emission and leakage of harmful substances, and when possible, means for dealing with such situations.

3.6 Types of education and training

1)   Education and training provided by manufacturers and suppliers of machinery for machinery users.

2)   Education and training provided by employers that purchase, etc., machinery for workers that actually use the machinery.

4.   Considerations in preparing and compiling usage information and the means of provision

4.1 Considerations in preparing usage information

Consider the following points when preparing usage information:

1)   The machine manufacturer or supplier shall select a single or combination of displays, warning labels, signals, warning devices, accompanying documents, education, training, etc., based on considerations of the purpose of the usage information, usage period, provision location, provision method, etc.

2)   Usage information shall be as clear and concise as possible and use consistent terminology and units.

3)   The means for providing usage information shall be durable.

4.2 Considerations in preparing markings

Consider the following points when preparing markings.

1)   Information marked directly on the machine shall be permanent and remain legible throughout the life of the machine. In other words, the information shall be clearly visible on a continuous basis from the machine's shipping until the machine's disposal.

2)   Displays shall be easy to understand and not ambiguous.

4.3 Considerations in preparing signs (pictographs) and warning labels

      Consider the following points when preparing signs (pictographs) and warning labels.

1)   Limit to important passages and diagrams.

2)   Use a particularly noticeable warning location, content, and style.

3)   Display warnings, to the extent possible, on the machine body. Place warnings where the warning text is certain to be visible to workers while using the machine.

4)   Clearly use terminology such as hazard, warning, caution, mandatory, prohibited, important, etc.

5)   Signs and warning labels shall be unambiguous and immediately understandable upon seeing.

6)   Prioritize the use of signs (pictographs), diagrams, and clear phrases.

7)   Use language that is understandable to users (workers, etc.).

8)   Signs and warning labels shall conform to recognized specifications.

9)   Be clearly legible throughout the life of the machine.

4.4 Considerations in installing signals and warnings devices

Consider the following points when installing signals and warning devices:

1)   Machine manufacturers and suppliers shall make arrangements in advance with the machine user with respect to the signals and warning devices employed as safety measures.

2)   Warning devices shall be designed and installed so as to be easy to check. A self-check function for breakdowns is preferable.

3)   Accompanying documents shall provide an account of the details, methods, precautions, etc., of the periodic checks for warning devices.

4.5 Considerations in preparing accompanying documents

      Prepare and compile accompanying documents in accordance with the following principles, policies, and considerations:

1)   Principles in preparing and compiling accompanying documents

(1)  Prepare for each machine model.

(2)  Clearly indicate warnings, etc., that are particularly important for using the machine safely by placing them in a prominent position such as at the outset of accompanying documents, by using noticeable colors, printing them with symbols and large letters, etc.

(3)  When personal protective equipment is required for using the machine safely, indicate this clearly in the accompanying documents. Moreover, emphasize the requirement on the machine packaging and elsewhere.

(4)  Clearly indicate the necessity of reading the instruction manual, safety manual, etc.

(5)  Clearly indicate the necessity of education for using the machine safely.

2)   Policies in preparing accompanying documents

(1)  Prepare accompanying documents based on assumed questions from the standpoint of actual users and workers.

(2)  Make an effort to use terminology and units consistently, provide easy to understand explanations of uncommon technical terms, and write in a clear and concise manner.

(3)  The writing style should be unambiguous and use an active voice and assertively imperative tone.

3)   Considerations in preparing accompanying documents

(1)  When the accompanying documents are long, prepare tables of contents and indexes.

(2)  Prepare documents that are easy to read for the machine user (including other workers). Write explanations with easily understandable words and phrases.

(3)  In the case of importing and selling the machine, do not provide a literal translation of the accompanying documents performed by the machine supplier (import seller, etc.), but rather documents that have been rewritten to be easily understood by machine users and workers.

(4)  In the case of a machine that is expected to be used by non-specialized workers, use plain and easy to understand language for technical sections and apply the following considerations to make instructions and explanations easy to understand for non-specialized workers:

  1. Explanations shall be a combination of text and diagrams, tables, sketches, etc., and to the extent possible, supplement explanations with pictures, explanatory drawings, illustrations, etc.

  2. Express data, etc., in table format and place explanatory drawings, tables, etc., near the explanatory text.

(5)  Use a clear type font to make accompanying documents legible. Additionally, make the document easy to understand by changing the font color and type, changing the paper color, and so forth.

(6)  Documents shall remain legible through to the removal, dismantling, and disposal of the machine. For this purpose, use paper that can withstand storage for long periods and use a durable binding.

(7)  Concerning storage, clearly indicate the following:

  1. Store in a location that can be easily accessed by machine users (especially workers).

  2. Accompanying documents must be stored by the user until the machine's removal, dismantling, and disposal.

4.6 Considerations in conducting education and training

1)   Machine manufacturers and suppliers shall observe the following in conducting education and training:

(1)  Mention all the basic requirements (section 2.2) with respect to usage information.

(2)  Provide systematic explanation about the means and details of providing the usage information.

(3)  It is desirable to anticipate and accept questions from machine workers.

2)   Employers that purchase, etc., machinery shall observe the following in conducting education and training:

(1)  Reliably convey to machine workers all of the usage information obtained from the machine manufacturer or supplier.

(2)  Provide full disclosure to workers about risk that remains despite safety measures, safeguarding measures, and countermeasures taken by the employer that purchased, etc., the machine.

(3)  For all levels of machine workers that receive this information, repeat the education and training until workers gain a sufficient understanding.

(4)  Until machine workers are able to gain a sufficient understanding of the usage information, the supervisor, etc., in charge of the machine shall remain on location to provide safety instructions to machine workers.




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