In brief
Maintenance technicians see a machine at its most dangerous; guards removed, interlocks disabled, and production waiting to restart as soon as possible. A significant share of accidents happen not during planned maintenance but during a "two-minute" breakdown repair. Applying the energy isolation rule without exception, tying live fault-finding to a separate procedure and limiting lone working are the three basic measures for a maintenance team.
Why is maintenance staff safety addressed separately?
A production operator uses a machine the same way every day, with guards in place and interlocks working. A maintenance technician, on the other hand, meets the same machine with its guard removed, its panel open, its hydraulic line under pressure and, often, an unexpected fault. That is why maintenance staff safety is not a sub-heading of operator safety but a separate area with its own rules.
The Regulation on Health and Safety Requirements for the Use of Work Equipment draws the framework clearly. Under Annex I 2.13, maintenance work may only be carried out when the work equipment is shut down, its energy supply disconnected, all its movements stopped and it is not running; if this is not possible, the necessary measures are taken or the work is done outside the danger zone. Annex I 2.14 requires the means of isolating energy sources to be easily visible and recognisable, and reconnection not to create a hazard for workers. Repair, maintenance and inspection of equipment posing a specific risk are carried out by persons specifically assigned to this work (Art. 8).
In metal and machinery businesses in Bursa and the surrounding provinces, maintenance teams are often small: a few people, several lines and shifts. This structure magnifies the three risks below.
Production pressure: the "two-minute job" trap
The biggest enemy of breakdown repair safety is time. The line has stopped, a shipment is waiting, the shift supervisor is standing over you. In this atmosphere, the most frequently heard sentences are familiar: "I'll just wipe the sensor", "I'll take the part out and close it straight away", "No need for a lock, I'm right here." A significant share of maintenance accidents happen in exactly these short interventions, because a short job is the easiest excuse to skip the procedure.
Leaving this pressure to the technician's attention alone does not work. Management needs to state three things clearly in writing:
- There is no time exception. The energy isolation and lockout rule applies regardless of how many minutes the job will take.
- The authority to stop lies with the technician. A technician who stops the line for a safe intervention is not questioned for that decision.
- A recurring fault is a maintenance issue. If the same sensor has to be wiped every shift, the problem lies not with the technician but with the design; a permanent solution is planned.
Working without isolating energy: what energy remains?
Switching off the main isolator is often not enough to make a machine safe. A significant share of maintenance and repair risks come from the energy remaining in the system after it has been switched off:
| Type of energy | Hazard that may remain after isolation | How is it verified? |
|---|---|---|
| Electrical | Secondary supply, capacitor charge, uninterruptible power supply | Testing for absence of voltage with a suitable instrument |
| Hydraulic | Pressure in the accumulator, a cylinder held up | Pressure gauge at zero, accumulator discharged |
| Pneumatic | Air remaining in the tank and lines, cylinder movement | Dump valve open, pressure gauge at zero |
| Gravity | A die, ram or raised table falling | Mechanical safety block or pin |
| Springs and tension | Tensioned belts, springs, a jammed conveyor | Releasing tension in a controlled way |
| Inertia | Flywheel, rotor or saw that keeps turning | Seeing the full stop with your own eyes |
| Heat and fluids | Hot surfaces, steam, pressurised fluid | Closing valves, draining, cooling time |
For each machine, these energy sources and isolation points should be identified in advance and shown in an instruction posted on or next to the machine. For the steps of lock and tag application, see our article on lockout and tagout (LOTO); for electrical work, see the five rules of electrical safety.
Live fault-finding: when, and under what conditions?
Some faults cannot be found with the energy isolated: to see whether a sensor is sending a signal or exactly when a valve opens, the machine needs to be energised. The regulation requires the necessary measures to be taken in such cases where working with the energy isolated is not possible. These measures should be set out in a written procedure:
- Fault-finding and repair are separated. Live work is only for locating the fault; once the repair begins, the energy is isolated and locked out.
- The machine's own setting mode is used. If the manufacturer provides reduced speed, hold-to-run control or a setting mode, the work is done in that mode. Bridging a door interlock or taping over a light curtain does not replace this mode.
- Only a competent person works. Live fault-finding is done by a technician assigned to this work who knows the machine and the circuit diagram.
- A second person stands by the emergency stop. If the work is close to the danger zone, one person stands at the emergency stop button.
- A work permit is issued. A short permit form is used for high-risk fault-finding; see permit-to-work system.
Removing guards and disabled interlocks
Annex I 2.8.1 requires guards to be designed so that they cannot easily be removed or rendered ineffective, and maintenance to be possible as far as possible without removing guards. On site, however, the most common situation is a guard removed for maintenance not being refitted. The operator on the next shift uses the machine with its guard missing, assuming "that's how it works".
Cables and keys used to bridge interlocks should not be left freely in the maintenance cabinet; their use should be recorded and restricted. For guard types and selection, see our article on machine guards.
Lone working and night shifts
On the night shift, the maintenance team is often one person. When a technician working alone gets trapped, falls or receives an electric shock, it can take a long time for anyone to notice. Lone working should be addressed as a separate heading in the risk assessment, and jobs should be divided into three groups:
- Jobs not to be done alone: confined space entry, work on live electrical panels, work at height and work under suspended loads. For confined spaces, see our article on working in confined spaces.
- Jobs that can be done alone with communication: status reports by radio or phone at set intervals, informing the shift supervisor at the start and end of the job.
- Routine jobs: low-hazard inspection and observation rounds.
External service technicians need particular attention. A technician from the machine manufacturer or a maintenance company does not know the workplace's isolation points, emergency arrangements or the other work on the line. A short briefing should be given before work begins, they should use their own lock and tag, and the machine should be taken back under the handover rule above when the job is finished. For the division of responsibilities in contractor work, see our article on subcontractor OHS responsibility.
The fatigue effect of night shifts should not be forgotten either. The risk of error increases in complex interventions in the early hours of the morning; where possible, schedule major maintenance work on the day shift. For other effects of shift work, see our article on night shifts.
Planned maintenance is part of OHS
From an OHS perspective, planned maintenance is also the most effective measure: the fewer breakdown repairs, the less work done under pressure. The OHS side of planned maintenance has three headings:
- Maintenance log: for machines with a maintenance log, maintenance operations are entered into the log as they happen (Annex I 2.13.1).
- Testing safety functions: emergency stops, door interlocks, light curtains and two-hand controls are written into the maintenance plan as separate items.
- Separation from periodic inspection: maintenance does not replace periodic inspection. Under the regulation, the person who maintains a piece of equipment may not carry out the periodic inspection of the same equipment (Art. 14/A).
Recurring faults and near misses feed into the maintenance plan. For recording the events a technician describes as "that was close", see our article on a near-miss reporting system; for finding the root cause, see root cause analysis.
In its OHS specialist service, Bursa Sistemer OSGB treats maintenance work as a separate activity group in the risk assessment, and prepares energy isolation instructions and lone working rules together with the maintenance team. Other risks in the sector are on our metal and machinery page. You can track periodic inspection and training dates with the OHS calendar tool.
Frequently Asked Questions
Is lockout needed even for a short intervention?
Yes. The regulation requires maintenance to be carried out with the energy supply disconnected and movements stopped; it makes no exception based on how long the job takes. A short intervention is the moment when lockout is most often skipped and accidents most often happen.
Can a machine be run live for fault-finding?
For fault-finding that cannot be done with the energy isolated, it can be done with measures such as the machine's setting mode, a competent person, a second person standing by the emergency stop and a work permit. Once the repair begins, the energy is isolated and locked out.
Can a maintenance technician carry out periodic inspections?
The person who maintains a piece of equipment may not carry out the periodic inspection of the same equipment. Periodic inspections are carried out by authorised persons registered on EKIPNET, the Ministry's online register of periodic inspectors.
Is one maintenance technician enough on the night shift?
It may be for routine jobs, but jobs such as confined space entry, live panel work and work at height should not be done alone. A regular means of communicating with a technician working alone should be defined in the risk assessment.
A certified specialist matched to your hazard class: site inspections, approved logbook, training plan, annual plan and report follow-up.
Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.