Like many global organizations Gillette has found itself needing to address the requirements of the various European Union directives which are being introduced in order to create a single European market. Several of the directives affect our operations, particularly the Machinery Directive, which was implemented through our Machinery Safety Design &; Review Process.
One stipulation of the Machinery Directive is that a manufacturer must (in order)
Eliminate or reduce risks by designing them out
Implement protection measures against risks that can't be eliminated
Inform users of residual risks which remain
To document this the directive requires a technical file containing amongst other things "a description of methods adopted to eliminate hazards presented by the machinery."1 We achieve this by risk assessment and by using a checklist of the directive's Essential Health &; Safety Requirements.
One of the fundamental standards under the directive, EN292, states "Initial risk assessment should be carried out by the designer at the design stage"2. This leads to the need for a structured methodology for identifying and quantifying the risks present. Gillette begins this work in phase 3 of our Machinery Safety Design &; Review Process, the design phase. It then continues for the remainder of the process in order to ensure that the physical machine is compliant and that the final engineering countermeasures have replaced any administrative controls used during debug.
How does Gillette ensure that our approach to risk assessment is sufficiently thorough? European Standards provide guidance. EN1050 lays out the general approach that one should take to risk assessment and defines risk assessment as "a series of logical steps to enable, in a systematic way, the examination of the hazards associated with machinery"3. In Annex B, for information only, the standard mentions eight different techniques that are commonly used. At the recommendation of Laidler Associates, a British consulting group, Gillette has settled upon an adaptation of Preliminary Hazard Analysis derived from the book Reliability, Safety and Risk Management4. We have found it to be simple enough to be learned quickly, yet powerful enough to act as a useful tool to ensure safety through design for the types of machinery we manufacture.
It is important to appreciate that even when historical accident data is available, the assessment of degree of risk is an inherently subjective process. EN1050 advises us that a good historical safety record shouldn't be presumed to definitively indicate low risk. In fact we are usually estimating rather than measuring risk. Selecting the type and quantity of personnel who undertake the assessment is therefore an important consideration that we will return to later.
