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 are conducting inspections of machinery.

Specifically, machine safeguarding protects against and prevents injury from the following sources:

• Direct contact with the moving parts of a machine.
• Splashing of hot metal or chemicals and chips from machine tool operations.
• Mechanical and electrical failures. (Power outage protection).
• Human failure, resulting from human traits such as curiosity, distraction, fatigue, worry, anger, illness, as well as deliberate chance taking.

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 example:

• 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 machine?
• 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 hazard.

The Problem

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 product liability.

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. com.

• 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.

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