Machine Risk Assessment vs. Safeguarding Assessment? Start 2020 off on the right safety foot.

When it comes to accidents, manufacturing ranks second highest of all industries. That comes despite OSHA regulations and American National Standards Institute (ANSI) standards. A key culprit is unguarded hazardous machinery.

Year after year, OSHA issues thousands of citations and levies millions of dollars in fines for machine safeguarding violations in an attempt to prevent injuries and save lives OSHA 1910.212(a)(1) is the most common section citation, whereby “one or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards” followed by OSHA 1910.212(a)(3)(ii) whereby “the point of operation of machines whose operation exposes an employee to injury shall be guarded.

Why the disregard?

Why is this so? Often facility safety managers are lulled into a false sense of security because a serious accident has not yet occurred or because accidents are rare in their facility. Other managers might wrongly suppose that their newly purchased machinery arrives fully compliant, not realizing that OEMs are typically concerned with new machinery price competitiveness, not necessarily guarding compliance. Still other managers may wrongly assume that older machines are “grandfathered in” before OSHA was formed.

For whatever reason, approximately HALF of industrial machinery has not been properly safeguarded.

That is the bad news.

The good news is there is a way to determine compliance through an assessment of the machinery on the plant floor, as outlined by ANSI B11.0. There are two types of assessments that reign supreme: the Risk Assessment and the Safeguarding Assessment. This article will address both methods and how they help an organization better protect the people operating the machines and reduce the risk at the facility.

Risk assessments should be conducted annually, including whenever a new machine is installed or a major change to an existing machine or production line has taken place. Additionally, in an ideal world, a pre- and post-assessment would be done to verify that the hazards identified in the assessment were properly mitigated.

Risk assessment

What a risk assessment is comprised of is outlined in ANSI B11 Series Standards for Industrial Machinery, ANSI/RIA R15.06-2012 Safety Standards for Industrial Robots, and the National Fire Protection Association (NFPA) 79-2015 Electrical Standard for Industrial Machinery.

The overarching goal of a task-based risk assessment is to identify hazards associated with machinery or robots. This requires an on-site visit by a risk assessment professional who audits and assigns each machine a risk rating based on three considerations: Severity of Injury, Exposure Frequency, and Avoidance Likelihood, which produces a Risk Level. Today’s risk assessment specialists use software-based tools that can make the process quicker than working through a pen-and-paper risk assessment form.

In advance of the facility visit and based upon project scope, the risk assessment specialist will need to review a comprehensive machine list and potentially other documentation such as: corporate safety standards, lockout/tagout (LOTO) procedures, electrical and mechanical drawings, floor-plan layout and equipment manuals.

The scope of assessing a piece of machinery for risk begins with reviewing its operational states with functionality tests performed to help identify potential hazards during machine start-up, cycle, and stopping. The risk assessment specialist may perform a Stop-Time Measurement (STM) test to determine the machine’s reaction time after receiving a stop signal to ensure proper safety distance of safeguarding devices. The specialist will also establish if a passerby or other employees in the area could be hurt if an incident occurs, in addition to the operator.

Along with assessing the production risks of the machine, the risk assessment specialist must analyze the tasks performed by the machine operator as they relate to interacting with the machine, loading and unloading materials, planned and unplanned maintenance methods, frequency of tool changes, and general housekeeping.

During the risk assessment, the specialist will photograph machines and generate a final hazard report documenting their assessment findings and risk levels. The hazardous findings of each machine are broken down into the following ranked classifications:

Critical: There is an imminent life-threatening or dismemberment hazard and immediate action is needed to reduce risk and improve operator safety
Mandatory: There is an imminent hazard that creates potential for injury and action is required to reduce risk, improve operator safety and to comply with OSHA/ANSI standards
Compliant: There is not a recognized hazard that creates potential for injury and no action is required.

Safeguarding assessment

While a risk assessment helps to identify a problem, it does not provide specific safety solutions nor cost estimates. For that, a safeguarding assessment is needed.

During the safeguarding assessment, a specialist will visit the site and conduct an intensive audit of each machine and identify compliance in five guarding areas: safeguards, controls, disconnects, starters and covers. The safeguarding specialist may request copies of electrical, pneumatic or hydraulic schematics, operator manuals and ask for control panel access so that engineers can review the control circuit for electrical compatibility of any proposed safeguarding solutions and to verify reliability of the control circuit to determine the interfacing requirements of suggested equipment. Then the safeguarding specialist will focus on risk reduction using this basic methodology:

– Eliminate Access — A good safeguarding system eliminates the possibility of the operator or other workers placing parts of their bodies near hazardous moving parts.
Reduction in Exposure — A machine safeguard should not be able to be removed, bypassed or tampered with by the operator. To minimize risk exposure, all guards and devices must be securely mounted at the point-of-operation and durable enough to withstand industrial environments, vandalism and heavy usage.
– Create No New Hazards — A safeguard defeats its own purpose if it creates a hazard of its own such as a shear point, a jagged edge, or an unfinished surface which can cause a laceration. The edges of guards, for instance, should be rolled or bolted in such a way that they eliminate sharp edges.
– Create No Interference — Any safeguard which impedes a worker from performing a job quickly and comfortably might soon be overridden or disregarded. Proper safeguarding can actually enhance efficiency since it can relieve the worker’s apprehensions about injury.
– Allow Safe Lubrication — Locating oil reservoirs outside the guard, with a line leading to the lubrication point, will reduce the need for the worker to enter the hazardous area.
Administrative Controls — Without administrative oversight and supervisory control, a machine safeguarding program will fail. Training is key to establishing a safety culture. Operators need to trained to follow the Standard Operating Procedures provided by the machine manufacturer in order to reduce hazards and related risks.

Uncovering gaps in protection

Unlike a risk assessment, a safeguarding assessment recognizes both the problem and the solution. A final compliance report and safeguarding project proposal is issued to facility management which identifies deficiencies or gaps where each machine is not in compliance with current or specified regulations and standards. When not in compliance, the proposal offers standard and customized safeguarding solutions, along with associated costs and timelines to help bring machines into compliance and reduce risk. Each proposed solution is carefully weighed against factors such as risk-reduction benefit, productivity, technological feasibility, economic impact, and maintainability.

In this way, a machine safeguarding assessment follows the OSHA/ANSI approach to controlling machine hazards: eliminate the hazard by design; or control the hazard by guarding, posted warnings, personal protective equipment, and employee training.

Risk reduction strategies

When evaluating risk reduction solutions to address identified hazards, consider each machine and its unique risks. Three basic methods are available.
– Eliminating or reducing risks to a “tolerable” level by installing a new, inherently safe machine. Please note that what constitutes “tolerable” to one company is not necessarily tolerable to another.
– Installing the necessary safeguarding equipment on an existing machine to minimize risks that cannot be eliminated. Fixed enclosing guards, protective devices such as light curtains, palm buttons or presence sensing mats, and training on the safe working methods of the machine are all necessary to reduce injury risks.
– Changing the production process to eliminate the hazard. Perhaps the operator performs actions that increase his exposure to serious hazards? Or recent changes upstream have created a more dangerous environment? Even a small change in procedures can make for a safer, more efficient operation.

Conclusion

Both risk assessments and/or the safeguarding assessments are critical first steps in any machine or robot safeguarding project as outlined in ANSI B11 Series Standards for Metalworking, OSHA 1910.212 General Requirements, ANSI/RIA R15.06-2012 Safety Standards for Industrial Robots and NFPA 79. These standards pave the way for risk-reduction measures that are both effective and economical. Machine risk assessments provide a comprehensive hazard analysis with a risk ranking; machine safeguarding assessments identify safeguarding solutions and provide cost estimates for implementation. Which one is right for an organization depends upon the specific needs of the organization, the organization’s objectives, desired outputs and risk levels.

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The Alternative Universe of Lockout/Tagout

On the surface, at least, machine lockout/tagout (LOTO) appears simple: Identify and isolate energy sources, lock and tag, and perform the procedure that needs to get done.

Simple, right? Wrong.

When energy is required to complete machine diagnostics or set-up work, or when a minor maintenance job is going to throw production hours behind schedule, LOTO becomes something far more complex than a textbook explanation.

Once you understand its intricacies, it is understandable why LOTO, as outlined in OSHA standard 29 CFR 1910.147 ”The Control of Hazardous Energy (Lockout/Tagout), has become an everyday struggle for many safety personnel. And why LOTO ranks among OSHA’s top ten violations, year after year. It is also understandable why industry is fast embracing the concept of “Alternative Measures”.

OSHA REQUIREMENTS
OSHA 29 CFR 1910.147 requires employees to remove power sources to a machine that could otherwise result in personal injury if energy were unintentionally released during maintenance or service. It clearly states facilities are responsible for establishing a written program covering how required safety measures will be applied. This includes provisions for developing machine-specific energy control procedures, training authorized workers to protect themselves with lockout/tagout, and for periodic inspections of the adequacy of the written procedures, along with the performance of personnel applying them.

As comprehensive as LOTO may be, it can be very time-intensive, often requiring longer than is required to finish the actual maintenance task on the machine. Production comes to a halt, resulting in the day’s production numbers potentially being missed. This becomes even more frustrating when the maintenance task is one that must be implemented several times a day. Loss of time and profits create a strong incentive to bypass LOTO to carry out repetitive machine tasks. However, it still violates OSHA requirements and puts workers in serious danger.

Thankfully, OSHA 29 CFR 1910.147 also outlines “Alternative Protection Measure” (APM) procedures that can result in increased efficiency without compromising the safety of the operation. This exception is also referred to as the “minor servicing exception”. Designed for machine tasks that demand frequent repetitive access, i.e., clearing a jam on a conveyor or a minor tool change, Alternative Measures do not require that power sources be completely cut off. Examples of Alternative Methods technology may include key-controlled locks, control switches, interlocked guards, remote devices and disconnects. It can also mean locking out just a section of a piece of equipment, rather than the entire machine.

ANSI REQUIREMENTS
The newest ANSI standard, ANSI/ASSE Z244.1 (2016) The Control of Hazardous Energy – Lockout, Tagout and Alternative Methods, agrees with OSHA in that workers should be protected from injury due to unexpected equipment startup or release of potentially hazardous energy. However, the ANSI committee did not try to align fully with every historic OSHA compliance requirement. Instead, the new standard gives expanded guidance beyond OSHA’s regulatory limitation to tasks that are “routine, repetitive and integral to production operations”.

ANSI makes it very clear that LOTO shall be used unless the user can demonstrate that a well-established alternative method will provide effective protection. In situations where the task is not well understood or risk assessed, lockout shall be the default protective measure applied to control machinery or processes. Section 8.2.1 of ANSI/ASSE Z244.1 (2016) specifies that alternative methods shall only be used after hazards have been assessed and documented through the application of a Practicability (or Justification) Study to determine that the techniques used will result in a negligible risk or no risk for sudden start up. Following the Hierarchy of Control model, ANSI/ASSE Z244.1 (2016) provides detailed guidance on if, when, and how a range of alternative control methods can be applied to result in equal or improved protection for people performing specific tasks. In addition, alternative risk reduction methodology is covered in detail specific to a number of new technologies including the Packaging, Pharmaceutical, Plastics, Printing, and Steel Industries; Semiconductor and Robotic Applications and others challenged by the current regulatory limitations.

Since the two standards are somewhat conflicting it is best to review ANSI first to help identify discrepancies that may not meet federal minimum regulations.

At this point, it would be appropriate to underscore that LOTO provides the greatest level of protection and, whenever possible, it should be utilized to protect employees from hazardous energy. In other words, inconvenience alone is not an acceptable excuse to use alternative measures. In addition, CFR 1910.147 clearly states that an allowable alternative measure must provide the same or greater level of protection as LOTO. Otherwise, it is considered noncompliant and therefore insufficient to replace LOTO.

By using standard safety-rated devices, such as interlock gates and e-stop buttons, a plant manager can achieve safe, reliable machine access that replaces standard LOTO procedures without violating OSHA requirements. Implementing alternative procedures to ensure equivalent protection for specific tasks can enhance productivity without endangering employees. But those procedures — and their benefits — come with strings attached, requiring a thorough understanding of the latest OSHA and ANSI standards.