Carrs Silver. (b) to stop the movement of any dangerous part of machinery or rotating stock-bar before any part of a person enters a danger zone.

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5 Carrs Silver Report Prepared by; Gary Waller CMIOSH Ranmoor Health and Safety Ltd, 237 Graham Rd, Sheffield, S10 3GS Report Prepared for; Martin Carr Carrs Silver Date; 20 th February 2017 Qualifications; Experience; Chartered Member of The Institution of Occupational Safety and Health (CMIOSH) NVQ 4 & 5 Management of Occupational Health and Safety Nebosh General Certificate Over 15-years experience in risk management, process and machinery risk assessments. Objective To review the 4 rolling mills to determine if additional safe guards can be taken to further reduce the residual risk and improve operator safety. Application of Legislation Provision and Use of Work Equipment Regulation 1998 (PUWER) Regulation 11 states: (1) Every employer shall ensure that measures are taken in accordance with paragraph (2) which are effective (a) to prevent access to any dangerous part of machinery or to any rotating stock-bar; or (b) to stop the movement of any dangerous part of machinery or rotating stock-bar before any part of a person enters a danger zone. (2) The measures required by paragraph (1) shall consist of (a) the provision of fixed guards enclosing every dangerous part or rotating stock-bar where and to the extent that it is practicable to do so, but where or to the extent that it is not, then (b) the provision of other guards or protection devices where and to the extent that it is practicable to do so, but where or to the extent that it is not, then (c) the provision of jigs, holders, push-sticks or similar protection appliances used in conjunction with the machinery where and to the extent that it is practicable to do so, and the provision of such information, instruction, training and supervision as is necessary.

General Operation All 4 Mills whilst slightly different fundamentally work in the same way, material is fed in by one operator then retrieved by a second operator, the thickness is adjusted after

The material is passed back to the infeed operator either on rollers to the side of the machine, over the top of the feed rollers, or in the case of the Finishing Mill retuned on coils.

6 General Operation All 4 Mills whilst slightly different fundamentally work in the same way, material is fed in by one operator then retrieved by a second operator, the thickness is adjusted after each pass until the desired finishing is achieved. The material is passed back to the infeed operator either on rollers to the side of the machine, over the top of the feed rollers, or in the case of the Finishing Mill retuned on coils. Jones Breaking Down Mill Run in direction trap point at infeed only Push stick used for shorted lengths of materials <16 Material length can vary from 16 to 20 ft E stops provided at both ends of the machine Short lengths are passed down the side of the roller track back to the infeed, longer lengths are passed over the top of the roller Roller infeed width varies along with finished size varies from 50 thou to 5 thou Danger Zone / Trap Point Finishing Mill One side feed Fed from coils through mill then back onto coil Coil returned to front to re-feed Additional pressure plate at the infeed Trap point is less accessible due to the pressure pad at the infeed. As material is fed in and out of the rollers via coils, operator interaction is less

Jones Sheet Mills (1) Generally used for smaller pieces of material Material passed over top of roller May have originally been used with coil feeders, hence screw points No infeed guides

Trap Point Jones Sheet Mills (2) Generally used for smaller pieces of material Material passed over top of roller May have originally been used with coil feeders No infeed guides Trap

7 Jones Sheet Mills (1) Generally used for smaller pieces of material Material passed over top of roller May have originally been used with coil feeders, hence screw points No infeed guides on these machines Use a push stick for smaller materials E stop to both ends of the machine Roller infeed width varies along with finished size varies from 50 thou to 5 thou Danger Zone / Trap Point Jones Sheet Mills (2) Generally used for smaller pieces of material Material passed over top of roller May have originally been used with coil feeders No infeed guides on these machines Use a push stick for smaller materials E stop to both ends of the machine Roller infeed width varies along with finished size varies from 50 thou to 5 thou Danger Zone / Trap Point

Conclusion Taking into account the current method of work and machinery set up versus the applicable legislation as detailed above, access to dangerous parts of moving equipment is possible, with

Recommendations Following the hierarchy of control measures and guarding selection detailed within PUWER 1998, my recommendation would be to trial a fixed guard on the infeed of both Sheets Mills.

8 Conclusion Taking into account the current method of work and machinery set up versus the applicable legislation as detailed above, access to dangerous parts of moving equipment is possible, with consequences that could result in serious personal injury. The 2 Sheet Mills are the higher risk as they are solely manual fed, typically with smaller components and used with no guide rails. Recommendations Following the hierarchy of control measures and guarding selection detailed within PUWER 1998, my recommendation would be to trial a fixed guard on the infeed of both Sheets Mills. From my discussion with the operators the only concern they raised was the possibility of material that sticks to the roller doubling up and feeding back around the roller, potentially damaging the material, it is my understanding that this can occur with material < 5 thou, however no detail of the number of occurrences was available. Below details the rough proposal for guarding on the two machines Mesh guard to allow visibility of the mill rollers, with a manual roller on the top to aid material being passed back to the infeed operator

9 Proposed Side Elevation Sketch This should be trialled initailly on the x 2 Sheet Mills as the infeed is more straight forward and instalation relatively easy. If deemed adequate from a user perspective, look to repeat in a simialr fashion on the other 2 Mills.

10 Additional Measures A detailed Safety System of Work should also be developed to cover key activities of operation, specifically to include; When to use a push stick Push stick specification When to transfer material down the side conveyor or over the top of the rollers Minimum / maximum material length and thickness PPE requirements, noted operators are wearing non steel toe cap trainers, generally you would expect to see safety footwear in an environment like this Specifcation of gloves, currently the operators are wearing loose fitting rigger gloves, these have the increased likelyhood of being pulled into moving parts of machinery.

11 Martin Carr From: Ray Palmer Sent: 23 May :46 To: 'Martin Carr Cc: Gary Waller Subject: Jones Large Rolling Mill Dear Martin I can confirm that following our visit and review of guarding yesterday the following is proposed in order to provide suitable guarding to prevent access to dangerous parts of the machine, e.g. in running nip in between input feed rollers: 2 Guards are proposed as follows: 1. Normal operations A hinged letter box guard fitted to the front of the machine is proposed at a distance of 900 mm to the letter box input. This will provide sufficient guarding to prevent access to the rollers from the front and the sides during normal operation in conjunction with guides and wedges on the machine. A distance of 900 mm from the rollers is the required standard. This guard will have the ability to be either hinged upwards or be removed for spread work where Guard No 2 will be fitted. 2. Spread work The machine is fully exposed during this work and given the shorter lengths of materials the operator is required to place hands in close proximity to the in feed rollers. The push sticks currently in use are not suitable as they are too short and not designed as a push stick, this increases the risk. A fixed guard is to be designed and bolted to the machine with sufficient height to pass material under to the input feed rollers whilst at the same time preventing access e.g. fingers hands coming into contact with the rollers. The guard should be robust enough to withstand materials curving and damaging the guard, pulling it off onto the rollers and ultimately causing significant damage to the rollers. This guard is to be similar to the newly fitted guards on other machines and is to be mounted by accessible bolts so that the guard can be positioned and removed following spread work. The top of the fixed guard is to have a continuous steel roller for the passage of longer material over the top. Dave your engineer will be making progress with Guard No 1 and following this I would ask that we are invited back in to review the guarding with Dave, the operators Paul & Martin and yourself. At this point we can check progress on guard No 2. Please provide Dave with a copy of this Kind regards Ray Ray Palmer Dip.2 OSH CMIOSH Chartered Safety and Health Practitioner Director 1

12 Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. Ranmoor Health and Safety Ltd Putting Safety First! Ranmoor House, 237 Graham Road, Sheffield, S10 3GS Tel (Ext 173) Mobile Fax Duty of Disclosure This /fax and any attachments contain confidential information intended for a specific individual, which is private and protected by law. Disclosure, copying, distribution, or other use of this information is strictly prohibited, except by the intended recipient. If you are not the intended recipient or have received this in error then you should not copy, forward or disclose it to any other person. Opinions and advice given in this /fax are not necessarily those of Ranmoor Health and Safety, and form no agreement, or commitment as such. All reasonable precautions have been taken to ensure no viruses are present in this /fax. Ranmoor Health and Safety cannot accept responsibility for loss or damage arising from the use of this /fax. Ranmoor Health and Safety Limited: Registered in England

17 Carrs of Sheffield Manufacturing Ltd (And Associated Companies) Safe Working Procedure H&S Ref: SWP 11 Procedure Metal Cutting Guillotine Mandatory Requirements Provision and Use of Work Equipment Regulations 1998 Introduction The incorrect use of plant and machinery can result in serious injury and sometimes permanent disablement. In order to prevent this, and also to comply with the Provision and Use of Work Equipment Regulations 1998, the following rules must be followed. Metal Cutting Guillotine (a) (b) (c) (d) (e) (f) (g) Operation of the guillotine is restricted to appointed employees only who have been suitably trained. The maximum rated thickness of material should never be exceeded. Sheared sheet should be removed from the bed, this is particularly important when cutting narrow gauge material. Ensure that no material is left on the bed when the guillotine is not in use. The blades are to be maintained in a sharp condition. The guarding and protection devices are to be thoroughly examined by an appointed competent person. Personal protective equipment must be worn, eg protective gloves, hearing protection Declaration I was given a copy of this SWP and the opportunity to ask questions relating to the SWP. I fully understand the requirements, and will perform my duties in accordance with the SWP. Name of employee: Signature of employee:.. Date.. I confirm the above named employee has been trained in all aspects relating to the SWP and fully understands the need to comply with the requirements of the SWP. Name of instructor:. Signature of instructor: Date. SWP 11 - Metal Cutting Guillotine Safety Page 1 of 1

20 Risk Assessment COS 01 Flattening Machine Flattening Sheet Metal Typical hazards associated with this activity Consequence Risk H M L 1. Contact with moving parts Cuts; bodily injury X 2. Entanglement Bodily injury X 3. Noise Noise induced hearing loss X 4. Slips, trips and falls Musculoskeletal injury / sprain / fracture X 5. Manual handling Musculoskeletal injury X 6. Maintenance Bodily injury X 1. Contact with moving parts 1.1 Only trained, authorised and competent persons use the machine. Two operatives carry out this work 1.2 A top roller guard is provided to the top of the machine 1.3 Emergency stop buttons are fitted at the input and output of the machine 1.4 Machine is operated at slow speeds 1.5 Operator s flatten the metal prior to feeding in, in order to (break its back) so as to prevent it from re-coiling 1.6 Long sections of sheet metal is placed on the floor 1.7 Smaller coils of metal is held by an operative whilst uncoiling at a safe distance away from the machine 1.8 Operatives are required to wear gloves when handling materials at a safe distance away from the machine 2. Entanglement 2.1 Operator is provided with company standard work wear e.g. jacket and trousers 2.2 Operator is not permitted to wear loose clothing, jewellery or have long hair 2.3 Operator awareness of moving parts and the need to keep hands away from moving parts 3. Noise 3.1 Noise output is not significant. Actions to Reduce the Risk 4. Slips, trips and falls 4.1 Operator is responsible for maintaining good housekeeping practices; including keeping the machine and surrounding area clean 4.2 Operator is provided with and is required to wear safety footwear 4.3 Floor area is painted and maintained in a good condition 5. Manual handling 5.1 Operators are provided with information and instruction in safe lifting techniques 5.2 Two persons to be utilised as required when uncoiling metal 5.3 Operator s awareness of coiled material re-coiling 5.4 Suitable height work benches and roller conveyors are provided 5.5 Operator is provided with protective gloves which must be worn 6. Maintenance 6.1 Day to day maintenance (greasing and lubrication), running and checking of the machine is carried out by trained and authorised operators 6.2 Break down and repairs are carried out by dedicated maintenance team 6.3 Operators are required to ensure that the machine is switched off during maintenance Having reviewed the above in the context of the activity you are assessing, use the space below to record any actions that are needed for safety * Also state if OK & no action needed 1. Investigate the use of an automatic uncoiler or some adaption to the machine, e.g. a conveyor roller with lid to house sheet metal in front of the feed rollers to the machine. Provide danger moving machinery sign if total guarding not possible Target date August & 2. Brief operators in the safe working procedure and obtain signatures August No further action required 4. No further action required 5. As in 2 6. No further action required Staff/Persons affected: Operatives x 2 Signature of persons involved in the risk assessment Ray Palmer; Martin Carr Date: 05/07/2013

21 Carrs of Sheffield Manufacturing Ltd (And Associated Companies) Safe Working Procedure H&S Ref: SWP 18 Procedure Flattening Machine Mandatory Requirements Provision and Use of Work Equipment Regulations 1998 Introduction The incorrect use of plant and machinery can result in serious injury and sometimes permanent disablement. In order to prevent this, and also to comply with the Provision and Use of Work Equipment Regulations 1998, the following rules must be followed. General Safety Rules: Never: Declaration (a) (b) (c) (d) (e) (f) (g) (h) (i) (a) (b) (c) (d) (e) (f) Carry out a visual check of the machine, any defects noted must be reported Check the emergency stop buttons positioned at each side of the machine Ensure that the fixed guards are in place and not damaged Ensure protective gloves are worn when handing sheet metal and when at a safe distance from the moving parts of the machine Carefully uncoil the coil, be aware of the coil, re-coiling. Break the back of the coil by flattening the material by hand Ensure that one operator is positioned at the feed in and the other operator at the feed output Feed the material into the machine to the nip point on the feed-in rollers Operate the machine Always maintain good housekeeping practices, do not leave material unattended on the floor Use a machine unless you are authorised and trained to do so Place hands in close proximity to the moving rollers or parts Attempt to clean or maintain the machine in motion - switch it off and un-plug it Use a machine or appliance which has a danger sign or tag attached. Danger signs should be removed only by an authorised person who is satisfied that the machine or process is safe Wear dangling chains, loose clothing, gloves rings or long hair which could get caught up in moving parts Distract people using machines I was given a copy of this SWP and the opportunity to ask questions relating to the SWP. I fully understand the requirements, and will perform my duties in accordance with the SWP. Name of employee: Signature of employee: Date: I confirm the above named employee has been trained in all aspects relating to the SWP and fully understands the need to comply with the requirements of the SWP. Name of instructor: Signature of instructor: Date: SWP 18 - Flattening Machine Page 1 of 1

PURPOSE OF THE PROCEDURE To minimize the incidence of employee injuries from machines and equipment as per OSHA

PURPOSE OF THE PROCEDURE To minimize the incidence of employee injuries from machines and equipment as per OSHA Title: Machine Guarding Procedure Effective Date: November 2005 Revision Date: January 13, 2017 Issuing Authority: Responsible Officer: VP, Facilities and Construction Management Director Environmental