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SAFETY SOLUTIONS:Machine Safety – Are Your Machines Safe to Operate?
Trade shows are starting to come around again this
year and many of our readers will be attending the
National Shows, the International Woodworking
Show or the Metal and Plastic Industry Shows. Many who
will be attending these conferences will be searching for
new machinery. For this reason, I would like to concentrate
on machinery once again.
For the first time in the history of OSHA, the citing of
machinery for not having proper safeguarding, which
would include items like emergency stops (red in color
with a yellow background), power outage protection,
machine guards that use fasteners not readily removed by
the operators and other items like training and machine
maintenance have now received a special emphasis from
the government.
According to OSHA statistics for calendar year October
1, 2001 through September 30, 2002, OSHA cited the
following:
- Hazard Communication Standard (lock out written program)
— 1,994 citations
- Machine Safeguarding, type of guarding — 1501 citations
- Hazard Communication - information — 863 citations
- Machine Guarding - point of operation guarding — 839
citations
- First aid emergency eye wash and showers — 826 citations
-
Guarding floor openings, platforms and runways —
760 citations
-
Hazard Communication - lack of training — 759 citations
-
Electrical Wiring methods and equipment — 726 citations
-
Lockout and Tagout - establishment of an energy control
program — 721 citations
-
Lockout and Tagout - written energy training program
— 672 citations
Is machine safeguarding a new issue with the regulatory
agencies? No, however, one of the main problems in
machine safety is that many old machines were built without
adequate guards and these machines are still in existence
and utilized on a daily basis. Does a manufacturer
have a responsibility to go back and find these machines
and repair them? Many think they do. Does the owner of
the machine have the expertise to properly guard a
machine? Some do, most do not.
Too many times employers try and do the right thing by
trying to save a little money and assign an employee to
design, build and guard a machine. Although these
employees believe that they have the expertise in the field
of machine safeguarding, many do not. Therefore they
design guards that create an additional hazard in themselves
or do not eliminate the hazard. This ends up exposing
the company to higher liabilities and a waste of company
resources (people), materials and money.
Accidents involving machinery with poor or non-existent
guards are common because of human nature. When accidents
occur, the manufacturers, owners, supervisors and
other employees that were not injured by the machine, say
that the employee knew or should have known not to stick
their hand in the work area; that it was dangerous, that it
was hazardous. They say it was the operator’s own fault,
and that the guard reduces the utility of the machine - that
the guard diminishes safety because the operators rely on
it for protection. Many times you hear this statement
when trying to have a guard put on a machine:
“I have operated that machine for the last 20 years
(always in increments of 5) and I have not been injured
yet.”
Operator error? Rarely was the injury to the employee
caused by operator error alone. By using proper accident
investigation techniques the investigator will uncover that
the real cause of the accident had many contributing factors
and unless these are eliminated this accident can and
probably will occur again and again.
As students of human behavior, we know that the
employee did not stick their hand in the machine for the
first 10,000 repetitions, but only on the 10,001 repetition.
At this time the employee was not as quick, was
thinking of something else or lost their balance and fell
into the machine losing their hand or several fingers.
Repetitious activity soon breeds inattention and a
dulling of the obvious and vicious nature of the hazard.
Inattention, familiarity, distraction and poor design are
some causes of accidents. The best employee in the world
will, on occasion, be day-dreaming or worrying about
something at home and put their hand where it shouldn’t
be. This is the purpose of the guard. It must prevent the
injury on this one occasion. If it is properly designed, it will
do so.
In today’s world, we use electronic devices to protect
operators from the hazard of reaching into the danger
zone. We have a tendency to say that the machine is now
properly guarded. In reality, if there is a remote possibility
that a part or fixture can break and fly out of the
machine and strike someone, then the machine was not
properly guarded. If a person can reach over, under,
around or through, then the machine was not properly
guarded. If a person can remove a guard because it did
not use the proper fasteners in its design or was not interlocked
to prevent or limit the machine motion, then this
machine was not properly guarded. If the guard uses fasteners
that are easily removed by the operator without
the authorized person using a special tool, then it was not
the right guarding design.
If we base safety of the operator on OSHA machine
guarding regulations, then we have potentially exposed
an employee to an undesirable risk. An example of this
statement is the use of a belt or disc sanding machine to
grind or finish metal.
This machine was designed by the manufacturer to
be used to finish a wood product. It was designed using
an American National Standards Institute standard
titled O1.1 safety requirement for woodworking
machinery. This machine is recognized in the OSHA
standard 29 CFR 1910.213 as specific for woodworking
machinery and even here one can find a conflict with
OSHA’s own standard.
OSHA states that the unused portion of the sanding
belt must be guarded but in the sanding disc portion of
the same set of 29 CFR 1910.213 standards, OSHA
states the revolving disc above the table does not have to
be guarded. Confusing? Yes, in reality there is only one
OSHA regulation for machinery. This standard is the
catchall for all machinery. 29 CFR 1910.212 (a)(1) states
the following: “One or more methods of machine guarding
shall be used to protect the operator and other employees
ees in the machine area from hazards created by point of
operation, ingoing nip points, rotating parts, flying chips
and sparks.” To ensure that your machine is safe to operate
conduct a risk assessment to identify and eliminate
the potential for injury.
Machine Guarding Questions
Like many other problems identified by audits, first
comes the shock factor:
- Why did the manufacturer built it that way?
Answer: Many manufacturers today are not trained in
all the regulations that apply to machinery. Many
manufacturers of machinery do not follow American
National Standards Institute (ANSI) consensus standardsor National Electrical Codes (NEC).
- Why did the purchasing department buy it that way?
Answer: Many people who purchase equipment do
not know the regulations themselves and usually there
is no program in place to inspect the machinery prior
to having it shipped to the location. Then it is too late.
The success of a machine-guarding program is in the
heart of good bid specifications.
- Why didn’t the facility or maintenance group inspect
the machine before installing it, or why wasn’t it
caught during routine maintenance?
Answer: Many companies do not have the owners /
operators manuals and thus may not have seen that
the point of operation guard is usually considered an
accessory to the machine.
- Why didn’t the safety professional or the person
responsible for ensuring that the machine met the
intent of the standards prior to purchasing the
machine see the potential problems?
Answer: Many do not have the expertise in machine
safety or in conducting risk assessments and just
sign off on the documents without trying to contact
anyone to ensure that it meets the standards. A
good example of this statement is purchasing a small
piece of machinery that does not have power outage
protection.
- The best one is this statement: “Well, OSHA has been
or was here and they did not cite the machine”.
Answer: Believe it or not, even OSHA inspectors may
not possess the required expertise to inspect the
machine. Many inspectors have only received a one
week course in machine safeguarding and they too
walk by hazards allowing some poor operator to be
completely exposed to a serious injury. In today’s
world of potential litigation, OSHA inspectors can and
have been sued for not bringing the hazard to the
employer’s attention if an employee was injured.
To find out more about what OSHA requires or how they
interpret an OSHA machine guarding standard, visit
OSHA’s website at www.OSHA.gov then research the documents
located in the Directive section of that website.
OSHA has also established a training program on this
subject and it can be found in the E-tools section of the
site.
Machine safeguarding is a paramount issue for employers,
employees and home wood and metal craftspeople.
Think SAFETY the next time you operate powered
machinery.
For more information, click on the Author Biography link at the top of this page.
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