SAFETY SOLUTIONS: OSHA & Machine Safeguarding
It is 2015 and we are still hearing about workers being
seriously injured or killed by machinery that is located in
the workplace. An extremely important area of the
Occupational Safety & Health Act of 1970 are the Federal
and State OSHA standards, which protects a machine operator
from hazards associated with machinery and its operations.
However, too frequently, the purpose of machine safeguarding
is misunderstood in that it is thought to concern
itself with the point of operation hazards only.
The definition of Point of Operation is: “The area on a
machine at which work is performed on the material being
processed”. Too many times the positioning of electrical
controls, separate & properly installed emergency stops,
guarding of belts and pulleys,
non-slip walking surfaces,
protection from flying
chips and sparks, and proper
color-coding of machine
guards and parts are often
neglected when manufactures
are building equipment
or when safety professionals
inspections of machinery.
Specifically, machine safeguarding
and prevents injury from
the following sources:
- Direct contact with the
moving parts of a
- Splashing of hot metal or
chemicals and chips from
machine tool operations.
- Mechanical and electrical
failures. (Power outage
- Human failure, resulting
from human traits such
as curiosity, distraction,
fatigue, worry, anger, illness,
as well as deliberate
An effective machine safety program must begin with a
thorough analysis of the potential hazards created by the
machines used in the facility. The specific hazards both
mechanical and non-mechanical are identified. On the
basis of this analysis, a determination will be made on the
best way to reduce or eliminate identified hazards.
Machine hazard analysis consists of four elements:
1. Determine the steps in operating the machine. For
- What hazard(s) is the operator exposed to when he /
she is setting up or starting up the machine?
- What hazard(s) is the operator exposed to when performing
a particular job?
- What hazard(s) are present when the operator or
maintenance person must make adjustments on the
- What hazard(s) are present when performing cleaning
or clearing of the machine?
2. Identify existing or potential hazards for each operating
step. For each step there may be one or more existing
or potential hazards associated with whatever actions the
operator is taking. Example: is the worker wearing clothing
or jewelry, or does the operator have long hair that could
get caught in the machine?
Or is the worker positioned
to the machine in a way that
is potentially dangerous?
3. Evaluate the cause of
the hazard. Once you have
examined the various steps
a machine operator takes to
perform the job, you need to
determine the cause of the
hazard so that preventive
measures can be taken.
4. Choose the most effective
measures to prevent
accidents and injuries. When
the reasons workers are
exposed to hazards become
clear, effective steps can be
taken to abate the hazards.
At this stage, it is best to
review the hazards with the
operator(s) and decide
together how the job can be
performed to eliminate the
Guarding of machinery is
required to prevent injury to
the operator and other people in the machine area. It is presumed
that machine designers strive to produce machinery,
which will perform the intended function without damage to
itself and without causing injury to the operator.
Today, many well-known machine manufacturers still
fabricate and sell their equipment without the necessary
safeguards and electrical controls required by OSHA,
national consensus standards and various safety regulations
to protect people from hazards not associated with
the point of operation.
Many of these manufacturers never warn the person buying their equipment that safety devices are missing. Would
you want to purchase their equipment for your family, or
employees to use without it being equipped with the proper
safety equipment? Would you like to be cited by OSHA
and penalized for not having the proper safeguarding
equipment that is required to be installed by the manufacturer?
Well chances are, you are at risk for this potential
everyday. Today, many of these hazards are missed or overlooked
by most inspectors and they end up in your shop.
Machine safety standards have been in place for the last
thirty years. A good example of this statement is that
according to the most recent safety regulation, machinery
must not be able to restart by itself after a power failure.
Federal OSHA requires and they state in 29CFR 1910.213
(b)(3) the following: “On applications where injury to the
operator might result if motors were to restart after power
failures, provision shall be made to prevent machines from
automatically restarting upon restoration of power”. This
standard is specific to woodworking machinery, but what
about plastic working machinery?
Product Safety Issues
Designing machine safety also has product liability
implications. A product liability “state of the art design” is
established by case law and social expectations that
demand a high level of safety for the users and
bystanders. If a machine is defective and its use results in
injury, the injured party may seek compensation through
Another type of hazard that has not been the subject of
a major recall yet, but one is expected in the near future,
is the hazard of power outage protection. Power outage
protection, an important safety device, is missing from
most low cost equipment. Many unsuspecting employers
have purchased machinery like grinders, drill presses, band
saws, scroll saws, sanding equipment, and other types of
machinery, where leading manufacturer’s or the employer
has never installed these electrical safety controls.
Many devices can be added to machinery to protect
operators from this hazard. Some of these devices are not
Underwriters Laboratories Listed or use Underwriter
Recognized Parts (UR) and do not carry the UL listed
marking. State electrical codes require that most equipment
be UL listed, thus employers could be wasting their
money by installing the wrong electrical devices. Major
machine safeguarding suppliers and other places sell
these products to unsuspecting employers and these
devices can injure people and also catch on fire. Also if you
install these devices on your machinery and you do not go
back to an authorized testing laboratory, you have then
violated the UL listing of that piece of equipment. If it
catches fire and burns your facility down, your insurance
carrier may not cover the loss.
To check if your machines has this sleeping hazard conduct
the following test:
- After ensuring that the machine is safe to start, and
wearing the proper protective equipment, start the
machine and let it come to operating speed.
- Shut down the machine by unplugging it from the wall,
if cord connected, or turning it off at the main breaker.
- When the machine comes to a stop, turn the breaker
back on or plug the machine back into the wall.
- Did the machine restart? If the answer is yes, then the
machine was not properly designed and power outage
protection needs to be installed.
What can you do?
Optimum machine safeguarding can only be achieved by
using an approach that combines safe equipment with safe
operation. Following the portion of the OSHA standard
related to your work activity will never reduce all potential
accidental loss, many of these OSHA standards are outdated
and many times are in conflict with one another. A
machine-guarding program that does not address each
potential hazard (task/risk analysis) including ergonomics
and education can never be a successful program.
Practicality and common sense can be relied on to govern
decisions, especially when these are tempered by a
sincere desire to protect human life and limb. Should you
ever need information on how to properly guard a
machine, please feel free to contact me at jpodojil@podojilconsulting.
- From Industrial Accident Prevention written in 1941
by the grandfather of the safety movement H.W.
Heinrich, Assistant Superintendent Engineering and
Inspection for the Travelers Insurance Company.
For more information, click on the author biography at the top of the page.