|
SAFETY SOLUTIONS: OSHA & Machine Safeguarding
Machine safeguarding or the lack of it, on machinery
still tops the OSHA top ten list of serious citations.
In our experience over 90% of machines
on the factory floor are not guarded in accordance with relevant
regulations and standards. To safeguard a machine
correctly and ensure the existing safeguards are adequate
requires a documented machine safeguarding assessment.
A proper assessment helps ensure that your machine
remains productive after the guarding is installed.
A documented machine safeguarding assessment provides
a clear plan to reduce risk and bring machines into
compliance. The report should contain a high level
overview and machine-specific risk reduction recommendations
based on the identified risk level of the equipment
as used in your facility. The report helps communicate the
current status of your machine safeguarding program to
all levels of your organization.
A documented assessment helps create priorities for
safeguarding while taking into account measures that are
currently working. This helps target funds where the most
benefit will be realized while also planning for future
upgrades. The assessment document can also be used to
ensure machines remain in compliance by comparing the
existing guarding system with the detailed guarding recommendations
and drawings. This allows any deviations
to be identified and addressed.
How long has the subject of machine safeguarding been
discussed? Years! Were you aware that all of your machinery,
since OSHA was enacted in 1971, had to meet the
minimum safety standards? These standards/regulations
come from the American National Standards Institute
(ANSI). OSHA has three main standards that they use.
These standards are:
1910.212(a)(1) Types of guarding. One or more methods
of machine guarding shall be provided to protect the
operator and other employees in the machine area from
hazards such as those created by point of operation, ingoing
nip points, rotating parts, flying chips and sparks.
Examples of guarding methods are-barrier guards, twohand
tripping devices, electronic safety devices, etc.
1910.212(a)(2) General requirements for machine
guards. Guards shall be affixed to the machine where possible
and secured elsewhere if for any reason attachment
to the machine is not possible. The guard shall be such
that it does not offer an accident hazard in itself.
1910.212(a)(3) (III) The point of operation of
machines whose operation exposes an employee to injury,
shall be guarded. The guarding device shall be in conformity
with any appropriate standards therefore, or, in the
absence of applicable specific standards, shall be so
designed and constructed as to prevent the operator from
having any part of his body in the danger zone during the
operating cycle.
OSHA also uses the American National Standards
Institute (ANSI) as a guide to cite employers when their
machines are not guarded according to these safety standards.
How is it that ANSI standards became part of the
OSHA regulations? In the early 1970s, when OSHA was
issuing new workplace safety regulations, it would often
use what was available either as the basis for its new regulations,
or incorporate by reference an existing standard.
In either case, the ANSI voluntary standards would fill the
bill, as they were considered best practices at the time and
they are still used today for OSHA enforcement activities.
ANSI standards can also be interpreted as implicit regulations
through our American legal system. The standards
make a wonderful reference on how a machine
should be, or more likely in the case of a trial, should have
been guarded. Employers or manufacturers who do not
comply have a potential liability exposure if an ANSI standard
indicates a method of machine design, operation or
safeguarding that may have prevented an injury. It would
be difficult to persuade a jury that a particular document
is “just a voluntary standard” while the opposing lawyer
advocates it is really the Holy Grail of safeguarding.
Guarding of machinery to prevent injury is not a new
concept. The first design to guard against a mechanical
hazard is lost in antiquity. The first patent in this country
for a machine guard was an interlocking guard for a
machine used to bottle carbonated beverages granted to
Henry Carse of Pittsburgh, Pennsylvania in l868. In his
patent Mr. Carse cites prior guarding technology and his
improvement upon it.
To have a properly designed guard, the guarding device
must meet OSHA 29 CFR 1910.212 federal safety regulations
and the following OSHA criteria:
- The guard must provide positive protection.
-
Must prevent all access to the danger zone during
operation.
- Cause the operator no discomfort nor inconvenience.
- Not interfere with operation.
- Operate automatically or with minimum effort.
- Be designed for the job and the machine.
- Preferably be a built-in feature.
- Provide for machine oiling, inspection, adjustment
and repair.
- Withstand long use with minimum maintenance.
- Resist normal wear and shock.
- Be durable, fire and corrosion-resistant and easily
repaired.
- Not constitute a hazard itself (without splinters, sharp
corners, rough-edges or other sources of injury).
- Protect against any contingency, not merely against
normal operations.
- Conform with the provisions of American Standards
Association codes
Our company has been guarding
machinery for the last 38 years.
Should you decide to hire a consultant
to come to your facility here are
a few items that you should know:
The consultant should have extensive
experience conducting machine
safeguarding risk level assessments
in accordance with all applicable
standards
The consultant should be willing to
provide you with a sample assessment
report
The consultant should be able to
provide a reference list of companies
and contacts where machine safeguarding
assessments were conducted
in the last 2 years and equivalent
in scope to your requirements
The consultant should be able to
provide proof of Professional
Liability or Errors & Omissions insurance
Provide a written report of the
assessment findings to include identified
risk levels that validate the
detailed risk reduction strategies
Be an active member of various
trade organizations and participate
on various industry consensus standard
committees
In closing, OSHA is only going to
get tougher. If you are attending this
year’s woodworking show and are
thinking about buying a machine,
please give us a call and we will offer
compliance guidance.
For more information, click on the author link at the top of the page.
|
