Record keeping, Health & Safety bogeymen, daily checks, disposing of oil! It's a fair old rant this month from Terrain Aeration's David Green
Is it just me or is everyone getting bogged down in the ever increasing complexity of machine maintenance and the associated record keeping?
Following my acquisition of the C&P Soilcare machinery assets, I am currently battling with the consequences of the former "maintenance" men who, by the look of the machinery, clearly thought that you fill a grease nipple with a blob of grease applied by fingertip and that daily vehicle checks are just black and white patterns.
My capable staff, who have actually built all the equipment I need, are not, however, qualified as mechanics and, so, are not the "technically qualified competent persons" required to do the routine maintenance by our Health & Safety bogeyman. Even I, the designer of every bit of the machinery, am not qualified to be the competent person unless I document my experience.
How can I possibly document the accumulated mechanical knowledge of fifty years?
Can I say that my wife bought me a Hydraulics and Pneumatics text book for Christmas and I have read it until the print has worn off!
The H&S bogeyman is not satisfied with my latest certificate, top of the class with distinction on an NVQ course for Health and Safety, my membership of the Institute of Health and Safety as a technician, or the fact that I have been a qualified electrician for years.
None of these are relevant when it comes to installing or maintaining the custom built wiring I have designed for my machinery, despite the fact that I had to tell the manufacturers of the control system I used, that their wiring diagram was incorrect, and having them agree and write back thanking me for correcting their information!
I dare not let one of my guys touch any part of a road vehicle or trailer that is safety critical, brakes, steering etc. because, should he make a mistake that causes an accident, I will be guilty of allowing an "unqualified" person to do the maintenance on the vehicle that is not only subject to the road traffic requirements, but is also now the employees place of work and subject to much more stringent requirements under Health & Safety regulations.
As a result, my local garage has to do all the repairs. Even such minor things as adjusting the hand brake. Well, they are at least qualified experts and I can blame them if anything goes wrong ... wait a minute, does this allow me to discharge my duty of care? Not one bit, unless I can show that I have checked that the local garage is fully competent and maintained records to show those checks!
The daily check recording also gets me. There must be a complete record for the record to be acceptable. Complete? What, including weekends, holidays and times when the vehicle/machinery never turns a wheel? Well technically, yes, for how else can the H&S bogeyman know that the daily checks are being carried out daily?
So, that is fourteen machines, three vehicles, a forklift, a compressor etc. etc., all of which have the same time off at weekends and holidays that the operators do, and are, therefore, available for work on about 200 days a year.
My actual machine usage is 30%, so that is 165 plus 140 blank sheets per machine per year, and hidden in amongst this mass of over 300 empty sheets are just 60 that show a daily check actually being performed. The H&S inspector may never be found again if he returns and insists on this nonsense.
I am also stuck with the problem of waste oil disposal. I can only store a limited amount without expensive bunded tank provision but, on the other hand, the waste oil disposal companies will not accept small volumes.
What am I to do? Am I to accumulate the 1000 litres (about five years worth of oil changes) that the waste oil company wants and so become a registered waste producer with all the consequent costs, or is there another way to safely dispose of a few tens of litres of oil each year?
Do not suggest that I use the household waste site disposal facility for this is strictly illegal.