In August we published an article regarding the then recently published AS5327:2019 Earthmoving Machinery – Access Systems. Whilst there is no change to the approach that Plant Assessor is taking to this standard I should have included more detail in my article around the exact differences between ISO2867:2011 Earthmoving Machinery – Access Systems and AS5327:2019 Earthmoving Machinery – Access Systems.
Before we get into the details of this update there are a few points worth making –
It is important to note that AS5327 could be viewed as an intermediary standard as it is expected that ISO2867 will be reviewed in the next 2 to 3 years. That revision will influence future versions of AS5327.
The authors have attempted to be all things to all people in many ways as there is no other guidance as specific as this available.
This update is based on questions and feedback from readers of the first article.
AS5327 includes Appendix ZZ. This appendix contains the differences between the ISO version and the AS version. Interestingly, the draft version of AS5327 did not include such an appendix but rather replaced the ISO clauses with the Australian versions in the body of the standard. It is a matter of personal opinion as to whether you like this approach.
The clause at the centre of my previous article is 6.2.3.
Below is clause 6.2.3 as it appears in ISO2867, in the main body of AS5327 and in my article in August
Below is the version of clause 6.2.3 as it appears in AS5327 appendix ZZ –
The questions for us are, what is the difference and does it make a difference?
For me, there is in reality no difference. ISO2867 requires guardrails for all platforms above 3m and platforms above 2m where the platform is less than 1.5m from an edge 2m. It is extremely rare that a platform is greater than 1.5m from the edge of a machine. This means that in reality ISO2867 requires guardrails for all platforms above 2m as does AS5327.
AS5327 does add an additional requirement in NOTE 1. Note 1 states – For heights below 2m alternative protective measures should be implemented where a significant risk of fall exists.
I can see that the intention of this additional information in note 1 is to provide additional guidance, however in reality it is subjective, confusing and arguably misleading. Let me explain.
Firstly, the use of the word “should” not “shall’ means that the requirement is recommended but not mandatory.
Secondly, it requires designers, manufacturers, suppliers and users of machines to determine whether a “significant risk” exists and then to determine the alternative protective measure to be implemented. This is a very subjective process. One that Plant Assessor removes for our users every day.
Lastly, the use of the word “alternative” both states and implies that a guard rail should not be implemented below 2m. Under the Australian WHS laws and the risk assessment process there are times where a guardrail is the appropriate method of controlling the risk of falling.
As mentioned at the start, Plant Assessor will not be changing its approach to this requirement.
This update was to clarify in more detail the difference between ISO3867 and AS5327.
As always, Plant Assessor customers can ask me a question regarding standards or legislative obligations anytime, simply email your question to firstname.lastname@example.org and they will be answered in this section of the newsletter each month.
Disclaimer: This information is intended to provide general information on the subject matter. This is not intended as legal or expert advice for your specific situation. You should seek professional advice before acting or relying on the content of this information.