Frequently asked questions - Printing industry safety

Yes. Paper-cutting guillotines are high-risk machines which have caused many accidents over the years. HSE guidance The guide to the safe use of power-operated paper-cutting guillotines.  sets out what training is required in Part 2 paragraphs 71-93 and 101.

Essentially, guillotine operators must be competent and trained to understand: 

• the risks arising from the use of the machine including specific operations such as  knife changing and knife cleaning, etc;
• the operation of controls and safeguards;
• the importance of safe working practices;
• how to carry out daily checks on the machine.

Find out more

Health and safety training: A brief guide

No. All new and substantially refurbished machinery manufactured, supplied and imported since 1st January 1995 should be CE marked. CE marking is one of several requirements of The Supply of Machinery (Safety) Regulations 2008.

SMR does not apply to machinery supplied or manufactured before 1st January 1995 or second-hand machinery.

SMR intends to protect users of machinery. However, never assume CE marked machinery is safe. Users of machinery must still check it is suitable and safe as required by the Provision and Use of Work Equipment Regulations 1998.

Find out more

• Buying new machinery: a short guide  

It is often necessary to remove guards for cleaning, maintenance etc. Failure to replace guards is a major cause of accidents in the printing industry. All safety-related features should be checked to make sure they are in good condition and working properly at regular intervals. The frequency of checks may be specified in user manuals or other standards or you may have to determine this as part of your risk assessment. Your assessment should consider; how often equipment is used, the operating environment, the variety of operations and the risks to health and safety from malfunction or failure. If you routinely find guards missing / not replaced, you will need to review and improve your system. You should provide a formal system of planned-preventative or condition-based maintenance where safety critical parts could fail making guards or other protection devices inoperable. If you have a maintenance log make sure you keep it up to date.

Find out more

• The guide to the safe use of power-operated paper-cutting guillotines
• Safety requirements for using hand-fed platen (die-cutting) machines 
• The printers guide to health and safety

Health surveillance is about systematically watching out for early signs of work-related ill health in employees exposed to health risks. The provision of health surveillance should be determined by your risk assessment. It is important to share your risk assessment with a competent occupational health professional who will advise on the health risks, develop your health surveillance programme and where necessary train others  ie responsible person.

In your industry employees may be exposed to UV-curable inks, isocyanates and other chemicals which have the potential to cause respiratory and skin problems. These products labelled R42 'May cause sensitisation by inhalation', R42/43 'May cause sensitisation by inhalation and skin contact' or R43 'May cause sensitisation by skin contact'.

Health surveillance for workers using isocyanates or other respiratory sensitisers may include:

• assessing workers respiratory health before a worker starts a relevant job
• introducing annual surveillance, or as advised by your competent occupational health professional. This may involve further questionnaires and lung function tests
• keeping a health record
• monitoring sickness absence

Health surveillance for skin problems may include:

• assessing workers skin condition as soon as possible after starting work
• examining the skin (usually hands and forearms) regularly
• asking workers about their skin condition;
• keeping a record.

Find out more

• Health surveillance
• COSHH G402 Health surveillance for occupational asthma
• COSHH Essentials

I use gloves for handling inks and solvents- what is the correct way to put them on and take them off?

Even the best gloves won't protect you from hazardous chemicals unless you put them on and take them off properly. Advice on how to do so is available in the following posters:

• Correct removal of gloves - Reusable gloves (chemically resistant) poster
• Correct removal of gloves - Single use gloves (splash resistant) poster

Can I sign a disclaimer not to wear PPE?

No. Employers must provide personal protective equipment (PPE) when health and safety risks cannot be adequately controlled in other ways.  Since PPE is a 'last resort', it is important that you wear it all the time you are exposed to the risk. No exemptions should be allowed for those jobs which take 'just a few minutes'.

The PPE needs to be:

• suitable
• maintained and stored properly;
• provided with instructions on how to use it safely; and
• used correctly by employees.

Employees should receive information, instruction and training on why PPE is needed, when to use it, how to use it, as well as instructions for repair/ replacement and the limitations of it. Employers need to make sure employees are using it properly.

Find out more

• Personal Protective Equipment at Work
• COSHH basics - Personal protective equipment (PPE)
• Do employers have to provide PPE?
• Personal protective equipment at work (Second edition)

What is REACH and what do I have to do if my employees use inks and solvents?

REACH (Registration, Evaluation, Authorisation and restriction of Chemicals) is the current system for controlling chemicals in Europe. It applies to substances manufactured, imported supplied or used in the EU.

REACH does not replace the COSHH Regulations which place duties on employers to control employees exposure to hazardous substances in the workplace.

REACH dutyholders (The roles of dutyholders) are:

• Manufacturers/importers
• Downstream users
• Others in Supply Chain

All printing companies are downstream users of chemicals and have a duty to use them in a safe way, and according to the information on risk management measures that should be passed down the supply chain in safety data sheets. Users should check safety sheets received from suppliers to review existing COSHH assessments to ensure that appropriate risk management measures are being taken for the chemicals used. Companies can pass information about use back to registrants so that this can be taken account of when assessing the risks of chemical used. Companies may also need to supply risk assessment and risk management measures to the European Chemicals Agency if they don't want their supplier to know about how they use the chemicals.

Some users may also be importers and have a duty to register.

Find out more about REACH

Anyone with a specific question on REACH can contact [email protected].

The following FAQs support Printing Information Sheet 18 Safety requirements for handfed platen (die cutting) machines and should be read in conjunction with this document. 

Some of the answers refer to British or European Standards. HSE is not able to provide copies of these standards, although you may be able to obtain them from your local library. Alternatively, you should consult your machinery/guard supplier who should have access to them.

I don't use the 'dwell' (timer) mode and have decided to wire it out. Do I still have to fit laser scanners or photo-electric guards to safeguard access at the front of the machine?

No – dwell is the highest risk mode.  Once dwell (and continuous mode) are removed, operators have to initiate each stroke manually and the risk is greatly reduced.

If I wire out the dwell, can I keep the continuous mode?

No – if you wire out the dwell, you should also wire out the continuous mode. If you wish to keep the continuous mode, you must fit the additional safeguards described in the information sheet.

Control circuits

Do I have to retrofit 'dual-circuit cross-monitored' (DCCM) control circuits to my platen? 

No – taking into account the cost and technical implications, as well as the range of additional control measures that you should be taking (as set out in the Information Sheet), HSE does not consider retro-fitting of DCCM systems to be reasonably practicable in most instances.

However, the minimum requirement is dual-channel control circuits ie two circuits but without a cross monitoring function. In this case, the pre-start checks and periodic inspections are vital to ensure the continuing integrity of safety critical parts of the platen, and hence ensure the safety of operators.

The current European Standard EN 1010-5 allows pressure sensitive mats (PSMs) to be used as side protection.  Is this still acceptable?

Yes. PSMs are allowed by the Printer's Guide to Health and Safety. However, PSMs are easily damaged and should only be used where they are unlikely to be subject to damage eg from passing forklift trucks etc. Their functionality should be checked as part of the routine daily/shift checks, as well as the periodic inspection carried out by a competent person – see the relevant section in Printing Information Sheet 18. Where existing mats do not meet the formula S=KT+C set out in HSG 180 "Application of electro-sensitive protective equipment using light curtains and light beam devices to machinery", you may need to consider further measures such as a barrier at the edge of the mat to prevent access into the danger area between the platens.

Are fixed tables still acceptable or do I have to use interlocked enclosures or interlocked side tables?

Side tables (both fixed and moveable interlocked), are still acceptable provided they are sufficiently high and wide to prevent operators gaining access to the moving parts at the side of the press as well as access between the platens themselves ie the danger area. The height and the width are interdependent eg a lower height would allow an operator to reach over further and the width would need to be increased as a result. As such, it is not possible to give specific figures. Further information can found in Table 2 (for high hazard applications) in BS EN ISO 13857:2008 "Safety of Machinery – Safety distances to prevent hazard zones being reached by upper and lower limbs". 

However, interlocked enclosures are the preferred option. This is because unlike a table, there is no 'top', which could allow access onto the platen. It also means that it is simple to access the side of the machine if necessary eg to adjust the clamping pressure. 

Are 'hold-to-run' devices such as two-hand controls acceptable as a means of safeguarding my platen?

Hold-to-run devices can only be used where the platen operates in single cycle mode ie dwell and continuous mode have been wired out. However, in this case they offer no safety advantage so there is little benefit to be gained in their use.

Pressure sensitive mats (PSM) can be configured as hold-to-run devices ie they are installed where the operator stands and will only allow the platen to cycle when it detects the operator's weight. This is only acceptable where they are used in addition to the other safeguards described in Printing Information Sheet 18. This is because they are only suitable for ensuring the protection of a single operator and are easy to defeat.  

We use a platform at the front of the platen for the operator to stand on – are these still acceptable?

Yes – platforms are widely used in the industry and many firms provide them for medium and larger machines to allow operators better reach between the platens and ensure more comfortable working. Platforms are still acceptable, provided they don't increase the risk of the operator accidentally falling or being tipped into the platen. 

The isolator for my platen is at the rear of the machine. Do I have to move it closer to the operating position?

Not necessarily – this will depend on the way the machine is being used, exactly where the isolator is, how easy the isolator is to get to, what your isolation procedures are and how rigorously you enforce them. Research shows that operators tend not to isolate the machine if the isolation point is too far away or not easily accessible.  Your aim should always be to make it as easy as possible for employees to do the right thing ie follow the laid down isolation procedure. It is important that you consult with platen operators when you are devising a suitable isolation procedure.

My platen requires the power to the machine to be 'on' in order to operate the electric chase when changing the cutting tools. Do I need to fit a separate power supply to the chase to be able to isolate the main controls whilst changing the tooling?

Yes. Hand-fed platens are high-risk machines and must be capable of being isolated when anyone (including contractors or service engineers) needs to work in the danger area between the platens.  As such, you will need a main isolator which isolates the whole machine and a further isolator which isolates the whole machine except for the power supply to the chase. Your isolation procedures should reflect this arrangement.

Regular maintenance and inspection is vital to ensure the safety of your hand-fed platen. The best way to do this is through a combination of daily/shift checks, routine maintenance and repair and periodic inspection.

Hand-fed platens have many similarities to guillotines in terms of how they operate (particularly the clutch/flywheel mechanism), how they are guarded (eg where lasers or other electro-sensitive protective devices are fitted) and how they should be inspected and maintained. HSE guidance Safe use of power-operated paper-cutting guillotines (C50) contains more information relevant to these questions. This is free to download.

Printing Information Sheet 18 refers to daily/shift checks - what are these?

For small platens, less than 1 metre wide which use traditional safeguarding (see PIS 18), the tests set out in the Printer's guide to health and safety (pages 126-7) are still relevant. For larger machines fitted with additional safeguards such as laser arrays, further checks will be necessary – your supplier or competent person should be able to advise you.

Daily/shift checks should be primarily visual/functional; to verify that safety devices perform correctly. They should include:

Where clutch and brake systems do not include dual-channel actuation, or fail-safe mechanisms, the pre-start checks and periodic inspections are all the more important to ensure the integrity of safety critical parts of the platen.

Who should carry out daily/shift checks?

They should be carried out by operators or supervisors who have had sufficient training to recognise faults which may affect the safe use of the machine. Any check sheets used for daily/shift checks should be clearly designed to show what needs inspecting and what a pass or fail looks like in each case. Check sheets incorporating photographs can be very useful in this respect. Monitoring should take place to ensure checks are carried out.

What should be covered in routine maintenance?

Routine maintenance should include an assessment of previous daily/shift checks, breakdown history and 6-monthly/12-monthly inspection reports to develop an overall picture of the machine condition. Electrical components such as interlock switches should be inspected closely, to verify that devices have not been bypassed or defeated, that they have not deteriorated through wear, and that there are no signs of fatigue or electrical cable damage eg to the outer sheathing. HSE guidance Safe use of power-operated paper-cutting guillotines (C50) may also be useful as this details maintenance with respect to flywheel/clutch systems used elsewhere in the printing industry.

What should be looked at in the 6 and 12 monthly periodic inspections?

Periodic inspection (PI) allows faults or declining performance to be detected in sufficient time to allow remedial action to be taken. It should give you the confidence that your platen is working safely. It should be carried out by a competent person (see question below).

PI should consider how the safety devices interact with the hand-fed platen, in particular the drive and braking mechanisms. It should also take into account the risks which could arise from the failure of any component, as this will determine where the inspection needs to be targeted. The competent person will determine the level of thorough inspection required based on an assessment of the risks.

It should be carried out at least once a year as recommended by the PIAC document Printer's Guide to health and safety, whilst machines fitted with Electro-sensitive protective equipment (ESPE) such as lasers or photoelectric curtains should be inspected every 6 months. Particular areas that should be looked at include:

Further information is available in HSE guidance Safe use of power-operated paper-cutting guillotines (C50) paragraphs 94-96, 103-112 and 146-147. For lasers and other electro-sensitive protective equipment (ESPE), pages 36 to 42 of HSG 180 Application of electro-sensitive protective equipment using light curtains and light beam devices to machinery are relevant.

Who is a 'competent person' (to carry out periodic inspection)?

Periodic inspection should be carried out by a competent person ie someone with relevant electrical and mechanical qualifications, together with suitable and sufficient knowledge and experience of handfed platens.  This will enable them to correctly identify any faults and determine whether or not the platen is safe to use.  Paragraphs 103 to 105 of HSE guidance Safe use of power-operated paper-cutting guillotines (C50) give more details about competence and relevant qualifications.

What happens if my platen fails its periodic inspection?

If your handfed platen fails a performance tests/check or does not comply with the guidance contained in Printing Information Sheet 18, your competent person should advise you in writing. The inspection/test certificate should explain what the faults or shortcomings are and what action needs to be taken to rectify them.  You should not use the machine until you have taken the necessary remedial action.