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:

1. The guard must provide positive protection.
2. Must prevent all access to the danger zone during operation.
3. Cause the operator no discomfort nor inconvenience.
4. Not interfere with operation.
5. Operate automatically or with minimum effort.
6. Be designed for the job and the machine.
7. Preferably be a built-in feature.
8. Provide for machine oiling, inspection, adjustment and repair.
9. Withstand long use with minimum maintenance.
10. Resist normal wear and shock.
11. Be durable, fire and corrosion-resistant and easily repaired.
12. Not constitute a hazard itself (without splinters, sharp corners, rough-edges or other sources of injury).
13. Protect against any contingency, not merely against normal operations.
14. Conform with the provisions of American Standards Association codes

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.

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