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Debunking the Top Three Myths About Industrial Machine Safeguarding
Machine guarding is one of OSHA's Top 10 most cited violations year after year, despite tough regulations and fines that attempt to quell the machine safety crisis. Injuries stemming from a lack of machine safeguarding significantly increase metal fabricators' workers' compensation premiums and mods. In addition, they can lead to expensive Occupational Safety and Health Administration (OSHA) citations, a figure that reached $6.8 million in 2015 for violations of Machine Guarding Standard 1910.212.
The actual price tag for an injury is much higher than simply the OSHA citation because indirect costs must be taken into account, such as damaged facilities or equipment, medical expenses, lawsuits, lost productivity, and replacement personnel. Worst of all, these accidents can cause extremely severe, potentially life-changing injuries to employees or even death. It is estimated that workers who operate and maintain machinery suffer approximately 18,000 amputations, lacerations, crushing injuries, abrasions, and more than 800 deaths per year.
According to Rockford Systems, LLC, a premier provider of machine safeguarding products and services, the reasons for this continuing machine safety crisis are multifold, but three mistaken beliefs stand out:
1. New machines are safe because their manufacturers sold them fully compliant with OSHA regulations.
2. Older machines are exempt from OSHA machine safety regulations.
3. OSHA regulations are only guidelines, not the law.
Machine Safeguarding Myths
Myth One: New machines are safe because their manufacturers built them to meet up-to-date safety standards and regulations.
Reality: This depends on the country where the machines were built and the safety standards that the machine manufacturer used as a guideline for control systems, electrical components, and safeguarding. It's important for the buyer of new machines to specify the Safety Related Parts of Machine Controls SRP/CS that this equipment must comply with (see ANSI B11.19-2010). The buyer should not hesitate to spell out the clause numbers from either ANSI standards or from European standards where applicable. Remember that safety standards from European Union (EU) countries offer the highest levels of protection.
As part of ongoing market research, we recently purchased a new mill drill and drill press from leading machine manufacturers. After undergoing machine surveys, both machines were found to be in dire non-compliance new out of the box. Both the mill drill and the drill stand did not meet OSHA machine guarding compliance in four key areas: not furnished with a safety shield (OSHA 1910.212 and ANSI B11.8), not furnished with drop-out protection for all motors (OSHA 1910.212, ANSI B11.8 and NFPA 79), not furnished with a compliant emergency stop button (OSHA 1910.212, ANSI B11.8 and NFPA 79), and not furnished with a plug lockout device (OSHA 1910.47). Any one of these violations would render the machine unsafe to operate new out of the box and subject to OSHA citations and mods.
For both new and old machines, a machine survey will identify OSHA machine guarding violations, along with recommended products and services to bring those machines into full compliance. In the case of the mill drill, a combination disconnect/starter device with remote operator station, an electrically interlocked shield, and a lockout plug were added to bring the machine into compliance, and all motors tied into the machine’s main emergency stop circuit. In the case of the drill stand, a motor starter device with emergency-stop button, an electrically interlocked shield, and a lockout plug were added to bring the machine into compliance.
To underscore the dangers of non-compliant new machines, we displayed both the drill press and mill drill at the FABTECH 2016 trade show in Las Vegas. The majority of FABTECH attendees were unaware of the violations, even those who had extensive backgrounds in machine tools.
Myth Two: Older machines are "grandfathered in" because they were manufactured before safety standards and regulations existed.
Reality: Up until the late 1970s, OSHA did have a small number of grandfather clauses in its regulations, but these have long since expired. In order to be in compliance today, machines must meet minimum OSHA regulations. For companies wanting to meet a higher safety benchmark, ANSI B11 Safety Standards (series of 24) offer the best available guidelines for metal processing machines. These standards are updated on a regular basis, typically every five years. For example, the ANSI standard for "sweeps," which specifies the maximum amount of space allowed between the floor and the bottom of a perimeter guard, only recently was set at 12 inches. However, a rash of serious injuries prompted a change, reducing the allowed 12 inches to 6 inches.
Myth Three: OSHA regulations only act as safety guidelines for manufacturers and are not the law.
Reality: Under the Occupational Safety & Health Act of 1970 (OSH) all employers are responsible for providing a safe, healthful workplace. Employers must comply with applicable OSHA standards and the General Duty Clause of the OSH Act, which requires employers to keep the workplace free of serious recognized hazards. By law, employers are legally required to follow OSHA regulations, meaning that an OSHA inspector will issue citations for compliance to the Code of Federal Regulations. Specifically, OSHA 1910.212 General Requirements for Machines states the operator and others in the machine area must be protected from exposure to hazards.
Once a manufacturer is cited for a violation, whether for new machinery or old, the best place to turn for advice is ANSI B11 series consensus standards that identify accepted options for safeguarding machinery. The series consists of nearly three dozen different documents that deal with machine safety and specify requirements for both the manufacturers and users of the machines. The majority of the ANSI B11 standards are machine-specific, offering "best safety practices" for one category of equipment only. One standard, however, ANSI B11.19-2010, entitled Performance Criteria for Safeguarding, serves as an "umbrella standard" for all machines in the B11 series. Its primary objective is to establish requirements for the design, construction, installation, operation, and maintenance of safeguarding.
OSHA's machine guarding regulations have not changed since 1975 and therefore lack what employers need to know about current machine safety options. OSHA regulations have always been considered as a starting point only.
Machine Risk Assessments and Surveys Are Critical
On-site risk assessments and machine surveys are the critical first step in proper machine safeguarding; they help to identify the tasks and associated hazards on a machine shop’s equipment. In a risk assessment, each machine receives a hazard score indicating the risk level using the ANSI B11.0-2015 safety standard methods. As part of the machine risk assessment, we provide suggestions to lower the hazard level and detailed documentation that will outline the results. In a machine survey, each machine is audited for compliance to current safety standards and customized proposals outline the specific products, services, and integrated design engineering solutions that are required to bring the machines into full compliance.
Take the recent example of a major consumer products manufacturer located in the Southwest. The company, which has a history of making employee safety a top priority, runs the plant 24/7 with multiple production lines operating simultaneously. While this around-the-clock schedule meets output requirements, it also raises the possibility of an employee accident. Recognizing this danger, the employee health & safety manager decided to conduct a risk assessment of the plant's equipment.
The plant's manager said the company promotes a safety-focused culture where employees are always put first, and a new corporate directive targeted the injury-prevention value of machine guarding, with several vendors bidding for the job. The resulting program was conducted over a five-day period during which more than 20 risk assessments were conducted on the machine lines. Each of these lines is comprised of more than 100 pieces of equipment ranging from simple mechanical equipment to highly complex automation systems. Two vendor employees were responsible for the risk assessment: the company’s risk assessment manager and an electrical engineer well-versed in the National Electrical Code who assisted in analyzing electrical controls.
"We were very impressed by [the vendor]'s team. We had our initial findings within two weeks and a final report in less than three weeks, showing not only where safety could be improved but outlining a roadmap on how it can be done," said the safety manager. "The report prioritized potential areas of concern on the plant floor broken down in a matrix graphically depicting each piece of equipment's risk ranking. We were able to see how machines with a safety rating of 12, for example, could be brought to a 4 with the addition of safeguarding."
He said the vendor company "did the impossible. We gave them the task of assessing a massive manufacturing plant containing a variety of equipment, all in a short amount of time, and they got it done. . . . They are a great resource who remain highly receptive in sharing their knowledge."
This article originally appeared in the February 2017 issue of Occupational Health & Safety.