Technical and legal framework
This service sits within a framework of statutory duties, technical rulebooks and operational practice. The distinction matters because it determines who is responsible for what.
- The machine remains a machine electrically
- A live control cabinet or machine is not treated with water or wet media. For work with electrical installations and equipment, DGUV Vorschrift 3 applies as an accident prevention regulation – binding for member businesses. The Industrial Safety and Health Ordinance additionally obliges the operator to carry out maintenance and recurring inspections. The practical consequence: cleaning and electrical work follow the same lock-off procedure, and responsibility for isolating lies with the operator.
- The circuit is a chemistry problem, not a visual one
- A machine can look clean and the circuit still be unusable. After flushing, the freshly made-up emulsion has to reach its parameters again: concentration, pH value and microbiological load. Residues of cleaning agents can destabilise a new emulsion, cause it to turn or form foam. TRGS 611 is a binding Technical Rule for Hazardous Substances with presumption effect under the Hazardous Substances Ordinance: whoever complies with it may assume that the Ordinance is met. In addition, DGUV Regel 109-003 describes the recognised state of the art for activities with metalworking fluids – it is not a legal norm, but becomes relevant through practice, supervision and insurance effect. For TRGS 611 the following applies: professional review of the rule in its full text is required.
- Dry ice is a gas method with side effects
- Carbon dioxide is heavier than air and collects in pits, trays, sumps and confined machine rooms. Work there requires ventilation, measurement and a clear rule on who enters when. Dry ice blasting also creates a very dry environment; in professional practice, electrostatic charging is controlled by earthing and suitable measures. Both belong in the risk assessment, not in a footnote.
- Manufacturer specifications take effect contractually
- Specifications of the machine and module manufacturer on cleaning – permissible agents, pressure, temperature, areas that must not be opened – are not a legal norm, but take effect through the purchase contract, through maintenance contracts and through the manufacturer's warranty terms. Anyone who disregards them risks claims. The manufacturer's documentation therefore belongs in the planning, not in the follow-up.
- Waste water and disposal
- Waste water containing oil or emulsion from cleaning is subject to water law. WHG and AwSV are legally binding; discharge requires an official permit and technical separation. Used emulsion, swarf, sludges and cleaning waste water must be routed to an orderly disposal path. Who keeps the evidence and whether the in-house acceptance point or an external facility is used belongs in the quotation. For the water law requirements the following applies: professional review of the standard in its full text is required.
- The boundary with maintenance
- Cleaning is not the replacement of wear parts, not repair and not inspection. Conspicuous findings – scoring on slideways, imbalance, leakage, condition of the seals – are passed on to maintenance, not silently dealt with as part of the job. This boundary belongs expressly in the quotation, so that responsibility for the condition of the machine does not blur.
The rulebooks named here describe requirements for how the work is carried out – they are not a certification held by BREREI. VDI and DIN normative texts are chargeable and were not available in full; where a statement touches the normative detail, this is noted in place.