SAFETY SOLUTIONS: Are Your Machines Safe to Operate?
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, 2017 through July 10, 2018 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 repetitions. 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 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:
Q: Why did the manufacturer build it that way?
A: 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 standards or National Electrical Codes (NEC).
Q: Why did the purchasing department buy it that way?
A: 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.
Q: Why didn’t the facility or maintenance group inspect the machine before installing it, or why wasn’t it caught during routine maintenance?
A: Many companies do not have the owners/operator’s manuals and thus may not have seen that the point of operation guard is usually considered an accessory to the machine.
Q: 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?
A: 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.
Q: The best one is this statement: “Well, OSHA has been or was here and they did not cite the machine”.
A: 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 craftspeople. Think SAFETY the next time you operate powered machinery. If you have any questions, you can e-mail me at email@example.com.
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