The mid-20th century in the United Kingdom, like many industrialized nations, was characterized by significant advancements in manufacturing processes, which unfortunately were often accompanied by a high incidence of industrial accidents. Factories were bustling with machinery, and while productivity soared, the human cost in terms of injuries and fatalities remained a pressing concern. Among the most dangerous machines in use were power presses, devices capable of exerting immense force to cut, shape, or form metal and other materials. The inherent power and repetitive nature of these machines, combined with inadequate guarding and safe systems of work, led to a disproportionately high number of severe injuries, particularly crush injuries to hands and fingers, often resulting in amputation.
Recognizing the specific and severe hazards posed by power presses, the British government enacted the Power Presses Regulations 1965. This legislation was not merely an amendment to existing factory laws but a dedicated and highly prescriptive set of rules aimed squarely at mitigating the risks associated with these powerful machines. It represented a significant step forward in workplace safety, moving beyond general provisions to address the unique operational characteristics and injury potential of power presses. The regulations mandated stringent safety measures, placing clear responsibilities on employers and laying the groundwork for a more robust safety culture within the manufacturing sector.
Historical Context and the Impetus for Regulation
Before delving into the specifics of the 1965 Regulations, it is crucial to understand the environment that necessitated their introduction. The Factories Act 1961 was the overarching legislation governing safety in factories, consolidating previous acts. While it contained general provisions for the guarding of machinery, these were often insufficient to address the complex and dynamic hazards of power presses. These machines, which range from small bench-mounted presses to massive presses capable of forming car body panels, operate by a ram descending rapidly under immense force, often hundreds of tonnes, into a die to perform a specific task like blanking, piercing, bending, or deep drawing. The danger zones are primarily at the point of operation, where the ram meets the die, and other moving parts like crankshafts and flywheels.
Accidents on power presses were disturbingly common and frequently severe. Operators, often working at high speed and under repetitive strain, could inadvertently place their hands or fingers into the trapping zone during the ram’s descent. Malfunctions in the control system, accidental cycling, or inadequate guarding were also major contributors. The injuries were typically crush injuries, amputations, or severe lacerations, leading to permanent disability and significant human suffering. The economic cost, in terms of lost productivity, medical expenses, and compensation, was also substantial. The high rate of these specific, preventable injuries provided a clear and urgent mandate for targeted legislation.
Key Provisions of the Power Presses Regulations 1965
The Power Presses Regulations 1965 comprised a series of detailed requirements designed to ensure the safe operation, maintenance, and guarding of power presses. The regulations applied to any power press, which was broadly defined as a machine that performs an operation by means of a tool or dies carried on a ram or slide which is moved towards or away from a stationary bed or table. This definition encompassed various types of presses, including mechanical, hydraulic, and pneumatic presses, and also included press brakes, which are used for bending sheet metal.
Guarding of Power Presses (Regulation 1)
At the heart of the 1965 Regulations was the stringent requirement for effective guarding. Regulation 1 mandated that a power press must not be used unless it is “effectively guarded.” This seemingly simple phrase carried immense weight and necessitated specific engineering solutions. The regulations detailed various types of guards and safety devices deemed acceptable, emphasizing that guards must prevent access to the dangerous parts of the machinery while it is in motion or capable of being put into motion.
- Interlocking Guards: These were perhaps the most significant requirement. An interlocking guard ensures that the press cannot operate unless the guard is in the closed and safe position, and conversely, the guard cannot be opened while the press is operating or in a dangerous state (e.g., ram descending). This typically involved electrical or mechanical interlocks that broke the control circuit if the guard was opened. The regulations required these interlocks to be robust and not easily defeated or bypassed.
- Automatic Guards (Sweep-Away Guards): These guards are designed to physically push the operator’s hands away from the trapping area as the ram descends. While less preferred than interlocking guards for primary protection due to their reliance on operator discipline and potential for entanglement, they were considered acceptable in certain applications where interlocking guards were impractical, provided they met specific design and performance criteria.
- Fixed Guards: For parts of the press that did not require frequent access (e.g., flywheels, gears, crankshafts), fixed guards were mandated. These are permanent barriers that prevent access to dangerous moving parts. They must be securely fixed and only removable with tools.
- Distance Guards: In some cases, safety could be achieved by maintaining a safe distance from the dangerous parts. This might involve barriers that ensure the operator cannot reach the point of operation while the press is active.
- Two-Hand Control Devices: These require the operator to use both hands to initiate the press cycle, thus ensuring that their hands are away from the danger zone. Critically, the controls must be spaced far enough apart to prevent one-handed operation and must require simultaneous activation.
- Photo-electric Safety Devices (Light Curtains): While less common at the time of the 1965 regulations’ initial drafting, these advanced sensing devices became increasingly accepted. They create a “curtain” of light beams across the opening to the press. If any part of the operator’s body breaks these beams, the press immediately stops or is prevented from starting. The regulations allowed for their use provided they met stringent reliability and fail-safe criteria.
The regulations stipulated that the guards must be of substantial construction, securely fitted, and maintained in an efficient state, in good repair, and in proper working order. This placed a continuous obligation on employers to ensure the integrity and functionality of safety devices.
Inspection and Testing by a Competent Person (Regulation 2)
Beyond initial guarding, the regulations introduced a groundbreaking requirement for regular and thorough examination of power presses and their safety devices by a “competent person.” This was a pivotal aspect of the legislation, moving from a reactive approach to a proactive, preventative one.
- Definition of Competent Person: A “competent person” was defined as someone possessing the necessary practical and theoretical knowledge and experience of the power press and its safety devices to enable them to carry out the required examination and test properly. This often meant specialist engineers, either internal to the company or external consultants.
- Frequency of Examination:
- Power Press Examination: Every power press had to be thoroughly examined by a competent person at least once every 12 months. This examination covered the structural integrity of the press, its clutch, brake, and other essential mechanical and electrical components, ensuring they were in safe working order.
- Guard and Safety Device Examination: The most frequent requirement was for the thorough examination and testing of the guard or other safety device every 6 months. This higher frequency underscored the critical role of these devices in preventing injury.
- After Major Repair/Modification: An additional examination was required after any substantial alteration, repair, or modification that might affect the safety of the press or its guard.
- Record Keeping: Following each thorough examination, the competent person was required to provide a written report or certificate, stating the findings, any defects found, and confirming that the press and/or its safety devices were safe to operate. These certificates had to be kept available for inspection by Factory Inspectors for a specified period. This documentation was crucial for demonstrating compliance and for accident investigation.
Die-Setting Operations (Regulation 3)
The regulations recognized that a significant number of accidents occurred not during routine operation but during the process of setting or changing dies. This is a hazardous period where the ram may be moved manually or under power, and operators often need to place their hands within the point of operation. Regulation 3 specifically addressed these risks:
- Prevention of Accidental Ram Descent: During die-setting, the regulations mandated that effective measures be taken to prevent the ram from accidentally falling or being inadvertently operated. This often involved the use of props, chocks, or safety blocks placed between the ram and the bolster, or the physical locking out of the power supply (lock-out/tag-out procedures).
- Safe System of Work: The regulation implicitly required a safe system of work for die-setting, involving the isolation of power, verification of isolation, the use of appropriate tools and safety devices, and clear procedures for all personnel involved.
Training and Instruction (Regulation 4)
While engineering controls were paramount, the regulations also acknowledged the critical role of human factors. Regulation 4 required that no person should be employed at a power press unless they had received adequate training and instruction in safe working practices.
- Competent Operators: Operators had to be thoroughly instructed on how to operate the press safely, how to use and check the guards, and what to do if they suspected a defect or malfunction.
- Supervision: Adequate supervision was also required to ensure that operators adhered to the prescribed safe working procedures and utilized the safety devices correctly. This meant not only initial training but also ongoing reinforcement of safe practices.
Maintenance and Repair (Regulation 5)
The upkeep of power presses and their safety systems was crucial for their continued safe operation. Regulation 5 mandated that maintenance, repair, and adjustment operations must only be carried out by “competent persons” who were adequately trained and authorized for such tasks.
- Isolation Procedures: Crucially, the regulations required that the power press be isolated from its power source (e.g., electrical or pneumatic) and rendered safe before any maintenance or repair work began. This reinforced the principle of “lock-out/tag-out” to prevent unexpected start-up.
- Verification After Repair: After any maintenance or repair that could affect safety, the press and its safety devices had to be thoroughly checked and tested by a competent person before being returned to service.
Reporting of Defects (Regulation 6)
Regulation 6 placed a responsibility on anyone who discovered a defect in a power press or its safety device that might endanger safety to report it immediately to their employer or supervisor. Correspondingly, employers had a duty to ensure that such defects were rectified promptly and that the press was not used until it was safe.
Exemptions and Certificates of Exemption
The regulations allowed for the possibility of exemptions under specific circumstances. The Chief Inspector of Factories could issue a certificate of exemption from certain provisions if it was demonstrated that alternative measures provided an equivalent level of safety, or if compliance was impracticable due to the nature of the work. These exemptions were rare and typically granted only after rigorous assessment.
Enforcement, Impact, and Legacy
The Power Presses Regulations 1965 were enforced by Her Majesty’s Factory Inspectorate (which later became part of the Health and Safety Executive, HSE, after the Health and Safety at Work etc. Act 1974). Inspectors had the power to visit factories, examine records, inspect machinery, and issue improvement or prohibition notices. Non-compliance could lead to prosecution, significant fines, and in severe cases, imprisonment.
The impact of the 1965 Regulations was profound and immediate. There was a significant and measurable reduction in the number and severity of accidents involving power presses. The prescriptive nature of the regulations forced employers to invest in better guarding, regular maintenance, and proper training. It drove innovation in safety technology for presses and led to a greater awareness of the specific risks involved. The regulations established a clear benchmark for power press safety and fostered a more proactive approach to risk management in this area.
The 1965 Regulations were a landmark piece of legislation because they moved beyond general requirements to provide highly specific and enforceable rules for a particular type of hazardous machinery. This approach proved highly effective in tackling a persistent problem. It demonstrated the power of detailed statutory instruments in improving workplace safety outcomes.
Evolution and Subsequent Legislation
While highly effective, the Power Presses Regulations 1965 did not remain in isolation. The UK’s approach to health and safety evolved significantly with the enactment of the Health and Safety at Work etc. Act 1974 (HSWA). The HSWA introduced a more holistic, goal-setting, and risk-based approach to health and safety, placing general duties on employers, employees, and others. It laid the foundation for a shift from prescriptive, industry-specific regulations to broader, performance-based ones.
The most significant change affecting the 1965 Regulations came with the implementation of European Union directives on workplace safety, particularly the Provision and Use of Work Equipment Regulations (PUWER), first introduced in 1992 and subsequently updated in 1998 (PUWER 1998). PUWER is a comprehensive set of regulations that applies to virtually all work equipment, not just power presses. It requires that equipment provided for use at work is:
- Suitable for the purpose for which it is used or provided.
- Safe for use, maintained in a safe condition, and inspected to ensure it is correctly installed and safe to use.
- Used only by people who have received adequate information, instruction, and training.
- Accompanied by appropriate safety measures, such as guards, emergency stop buttons, and warning devices.
PUWER 1998 largely superseded the Power Presses Regulations 1965. While the specific 1965 regulations were technically revoked, their fundamental principles and requirements were effectively absorbed and broadened within PUWER. For instance, the requirements for competent person examination, guarding, safe systems of work for maintenance and die-setting, and training are all central to PUWER. What was specific to power presses in 1965 became a general requirement for all work equipment under PUWER. This shift reflected a move towards a more harmonized and integrated approach to safety across various industries and types of machinery.
Even with the advent of PUWER, the legacy of the 1965 Power Presses Regulations remains indelible. They served as a blueprint for how to effectively regulate specific high-hazard machinery. The principles of thorough examination, the need for robust interlocking guards, the focus on safe systems of work during non-routine operations like die-setting, and the emphasis on competent personnel were all pioneered or significantly strengthened by these regulations. These principles are still fundamental to modern health and safety management, particularly for machinery with significant trapping or crushing hazards.
The Power Presses Regulations 1965 stand as a testament to the effectiveness of targeted legislation in addressing specific industrial hazards. Born out of a clear need to curb a high rate of severe injuries, they introduced a comprehensive framework for the safe design, operation, and maintenance of power presses. By mandating stringent guarding, regular expert inspections, and safe working practices, the regulations profoundly improved safety outcomes in factories across the UK.
While the specific 1965 regulations have been superseded by broader and more encompassing legislation such as PUWER, their core principles and the safety culture they helped to foster remain highly relevant. The emphasis on preventing access to dangerous moving parts, the critical role of competent persons in examination and maintenance, and the importance of clear procedures for hazardous tasks like die-setting are now embedded within general work equipment safety standards. The Regulations demonstrated that proactive, prescriptive measures, coupled with rigorous enforcement, could dramatically reduce industrial accidents and enhance the well-being of the workforce, leaving a lasting legacy on the evolution of occupational safety.