I know exactly what a “chip extractor” is.
You might consider it silly, but it’s the law.
Emergency stop functions are no longer considered a primary means if safeguarding.
They are primarily for the protection of the equipment and prevention of “collateral” damage.
The regulations prevent nothing.
They merely require that the modifications are done in a suitable manner.
This is absolutely no difference to what is required by Building Regulations, BS7671 & the competent person schemes.
It is merely the requirements differ because the hazards are different and the requirements of the legislation and standards differ.
The term “emergency stop” is a specific term which invokes the requirements of a safety function.
If the machinery doesn’t have any emergency stops then you will not have to implement them. However if it does then you need to continue that with the modifications.
A simple off switch cannot act as an emergency stop or means of emergency isolation unless it meets the requirements for such.
The standards are very clear on that.
This discussion would not be happening if the work was covered BS 7671, everyone would be supporting compliant work. Just because there is additional legislation and different standards, it is thought to be nonsense.
I believe that if the HSE enforcement archive is checked, then many more actions regarding PUWER and machinery legislation will be found than BS7671/EAWR/Building Regulations.
If you are unsure of the hazards posed then please look up the Essential Health and Safety Requirements in the SMSR, and then refer to the product standard for the chip extraction here: