Key decisions
Use competent, site-specific assessment and controlled change
- Review the supplied machine information alongside the employer’s duties for safe work equipment and the real site process.
- Identify mechanical, electrical, pneumatic, pressure, product, chemical, fire, explosion, ergonomic and contamination hazards.
- Assess normal production, set-up, refill, sampling, cleaning, unjamming, maintenance, fault recovery and foreseeable misuse.
- Define isolation, access, competence, supervision and verification for every task that crosses a protective boundary.
- Reassess changes to product, pack, layout, controls, guarding, speed, tooling or adjacent machinery before use.
Distinguish machine supply from the user’s work system
The supplier provides information and protective measures for the machine and agreed scope. The employer still needs to ensure the equipment is suitable for the intended use, installed correctly, maintained and used by trained people within a safe system of work. Adjacent conveyors, bulk product supply, cleaning services and site modifications may introduce hazards outside the original machine boundary.
The Health and Safety Executive provides official guidance on PUWER and work equipment, including suitability, guarding, controls, maintenance, inspection and training. This page is general project guidance and does not replace the machine instructions, legal advice or a competent site assessment.
| Task or condition | Questions for the assessment | Evidence / control to define |
|---|---|---|
| Normal production | Where are moving parts, pinch points, pressure, hot surfaces, spills and product exposure? | Guarding, interlocks, controls, safe distances, containment and operator procedure. |
| Set-up and changeover | Which adjustments need power or access, and how is the correct format verified? | Safe adjustment method, reduced-risk mode where designed, tooling control and first-off check. |
| Cleaning and unjamming | What energy, pressure, chemical and contamination hazards remain after stopping? | Isolation, release/drain, access, PPE, tools, cleaning method and authorised restart. |
| Maintenance and fault finding | Who is competent, what isolation is required, and how is testing performed safely? | Permit or safe system, lock-off, test method, guarding restoration and return-to-service record. |
| Line interfaces | How do emergency stops, permissives and restart commands behave across machines? | Documented boundary, validated signals, stop categories where applicable and controlled recovery. |
| Change or modification | Does the change affect safety functions, access, intended use or hazardous substances? | Engineering review, updated assessment/documentation and revalidation before production. |
Include product and hazardous-substance risks
Product information can change the required materials, containment, ventilation, drainage, electrical equipment, PPE and emergency arrangements. Review safety data sheets and the process by which vapour, mist, dust, pressure or static may be generated. Corrosive products also create exposure and material-compatibility risks during connection, filling, leaks and maintenance.
Where dangerous substances could create fire or explosion risk, the employer must obtain competent assessment under the applicable requirements. HSE’s official DSEAR guidance explains the duty to assess and control those risks. Do not label a general filler suitable for a hazardous area without the required project-specific classification and evidence.
Assess every operating mode and intervention
Many incidents occur during cleaning, blockage removal, adjustment or maintenance rather than steady production. List every intervention: loading packs, topping up product, sampling, clearing a fallen container, removing a nozzle, changing seals, washing parts and recovering after a line fault. Identify the energy and hazard state for each one.
Emergency stopping is not a normal isolation method. The procedure should define how electrical, pneumatic, hydraulic, pressure, gravity and stored mechanical energy are isolated or otherwise controlled for the task. Only competent people should perform work requiring access beyond the defined operator procedure.
Verify guarding, controls and line behaviour after installation
Installation and integration can change access and control boundaries. Check that guards can close, interlocks operate, emergency stops reach the agreed equipment, reset does not create unexpected movement, and restart requires the intended deliberate action. Confirm safe response to loss and restoration of power or air.
Use the FAT and SAT guide to turn these requirements into documented tests. The site should retain inspection, training, maintenance and modification records appropriate to its duties and the machine’s supplied instructions.
Control modifications throughout the machine life
Changes to guards, software, speed, nozzles, product feed, containers, conveyors or adjacent equipment can alter the original risk profile. Do not treat a production improvement as purely operational when it changes access, timing, pressure, intended use or safety functions.
Record the proposed change, competent review, updated drawings or instructions, test evidence and authorisation before use. Where the legal status of a substantial modification is uncertain, obtain specialist advice. Preserve the approved software and settings so the changed state is identifiable and recoverable.
Safety information to prepare for a filling-machine project
- Product safety data, hazards, temperatures, vapour/dust and spill behaviour.
- All operator, cleaning, refill, sampling, unjamming and maintenance tasks.
- Site layout, access, adjacent machinery and control/emergency-stop boundaries.
- Electrical, pneumatic, pressure, lifting, drainage, extraction and environmental conditions.
- Competence, training, supervision and safe-isolation responsibilities.
- Required guarding, access, verification and abnormal-state tests.
- Installation, inspection, maintenance and modification-control arrangements.
- Named competent persons for site risk, hazardous substances and legal/compliance decisions.