What to Do if You are Issued an OSHA Citation

The Occupational Health & Safety Administration (OSHA) is the federal agency responsible for overseeing workplace safety. On the federal level, OSHA conducted 24,333 inspections in 2021. Of these 24,333 inspections, 10,584 (about 43 percent) were programmed inspections that focused OSHA’s enforcement resources towards industries and operations where known hazards exist.

If a violation is discovered during the course of an inspection, a citation may be issued. Citations serve as warnings, signaling the employer to take action to resolve the violation. When an employer receives an OSHA Notice, they must either post it, or a copy of it, at or near the place where each violation occurred as to make employees aware of the hazards to which they may be exposed. The OSHA Notice must remain posted for 3 working days or until the hazard is abated, whichever is longer. (Saturdays, Sundays and Federal holidays are not counted as working days).

Enforcement of machine guarding regulations is part of OSHA’s mission. OSHA requires that “any machine part, function, or process that may cause injury” be addressed as to eliminate or reduce risk based on hazardous exposures. In addition to the primary hazardous point-of-operation exposure, different functions, componentry, and processes sometimes need to be addressed on a single machine, or within a single manufacturing process, as well.  OSHA may also require secondary safeguarding devices, such as lighted beacons, audible alarms, and perimeter-style barrier guarding in some instances.

Despite regulations outlined in OSHA 1910.212, and the serious dangers posed by industrial equipment, machine guarding violations remain one of the top ten most common OSHA citations. Machine guarding violations also holds the dubious distinction of making the list of OSHA’s largest monetary penalties.

In this blog, we will discuss what a citation is, and how Rockford Systems can assist you in the event you are issued one.

WHAT IS AN OSHA CITATION?

An OSHA citation is similar to a complaint filed in court. That means it contains allegations of a violation, not conclusive findings. And while an OSHA citation may certainly look like a final ruling, sometimes including an invoice and a notice of debt collection, it is not a final legal document. The citation only becomes final after the employer:

  • Agrees with the citation or some modification thereof through a settlement.
  • Fails to contest the citation within fifteen working days.
  • Contests the citation, but loses during the administrative litigation process.

By law, OSHA must conduct an investigation before issuing a citation, most likely after an OSHA Compliance Safety and Health Officer conducts an on-site inspection. An investigation file will likely exist that contains evidence that supports OSHA’s citation. Unless the employer contests the citation and proceeds to the administrative litigation process, it’s possible that they are unaware as to exactly what is in an investigation file.

An OSHA citation should never be ignored. If an employer is not sure if they want to contest the citation, they can schedule an informal conference with an OSHA area director, a practice that OSHA encourages. An extension of any amount of time beyond the fifteen working days will not be granted unless the employer submits a Petition for Modification of Abatement showing the steps it has taken to achieve compliance. If the employer fails to remedy the situation by the abatement date, the citation becomes final and its fines must be paid. Simply paying the fine, however, does not get the employer off the hook. An employer still must correct the violation or could be cited for either a repeat, or possibly even willful violation in the future. OSHA also has the right to shut down the worksite to protect employees.

Let’s now explore three words that are extremely important to an OSHA violation: repeat, willful and serious.

  • Repeat violations are where OSHA determines that there have been similar violations within the last three years.
  • Willful violations are committed voluntarily or with indifference or disregard to the law.
  • Serious violations refer to situations where an employer knows that there is a hazard present that could result in either injury or death. OSHA uses another term, “other-than-serious” violations, for situations that likely will not result in injury or death but still may compromise health.

Maximum penalty for a serious violation is currently $14,502 per violation, while willful or repeated violations can result in penalties up to $145,027 per violation. OSHA does not fine employees for workplace and jobsite safety violations, only employers whos’ duty it is to provide a safe working environment compliant with OSHA regulation. Any possible reduction in penalty is at the discretion of the OSHA Compliance Officer, and factors such as size of the company, safety history, and good faith of the employer can all weigh in as to penalties assessed.

CONTESTING A CITATION

If an employer agrees to the citation, they must pay the fine within fifteen days, along with correcting the violation by the abatement date indicated on the notice.

An employer has the right to contest part or all of any notice that they receive. If only part of the notice is contested — such as the abatement date, penalty amount, or certain violations listed in the citation — than the employer still must correct the corresponding violations and pay the fines for the other parts of a notice that they are not contesting.

In contesting a citation, it is highly recommended that you enlist an experienced, knowledgeable safety professional to join you at both the informal and formal administrative hearings. An outside expert can also help guide an employer’s on-site investigation, and conduct a machine safeguarding audit with specific recommendations as to corrective actions and equipment.

During an OSHA hearing the employer should be prepared to share:

  • A detailed, written safety policy that addresses common or uncommon machinery hazards an employee may encounter.
  • Accurate records of all workplace accidents, injuries, illnesses, and deaths.
  • Classroom and field training schedules that teach employees proper safety procedures for both everyday work and in case of an emergency.
  • Administrative records demonstrating enforcement of company safety rules.
  • Up to date machine safeguarding audit records and documented corrective actions taken, if any, since the citation was issued.

AVOIDING CITATIONS

OSHA fines can be costly, and the process of contesting a machine guarding citation can be lengthy. The best way to avoid having to spend both time and money on an OSHA citation is to prevent one in the first place. Rockford Systems offers several services that will keep your employees safe and your business, including:

  • Safeguarding Policy Development: After conducting a baseline compliance evaluation and report, Rockford Systems will create the written program with a strategy for implementing any shortcomings in machine safeguarding. Employee training, ongoing safeguarding improvements, and an annual audit program round out the policy.
  • Machine Risk Assessment: Leveraging an experienced team of safeguarding specialists, all of whom have dedicated OSHA regulation and ANSI/NFPA 79 standards expertise, a Risk Assessment may provide an organization with a thorough understanding of its machine hazards. It is a proven, methodical tool to identify and document the hazards, as well as quantify and prioritize risk reduction efforts according to an associated risk score. A risk assessment will help you to identify hazards, but may not necessarily lead you to a solution in eliminating or reducing hazard in all cases.
  • Machine Safeguarding Assessment: This style of assessment is designed for companies who need safeguarding solutions and associated costs. It uses an organization’s machine list, machine task and hazard data gathered during the assessment, electrical schematics and our proprietary RSXpress™ mobile inspection tool that allows our safety professionals to perform a full assessment in determining compliance with OSHA regulation and ANSI/NFPA 79 standards.
  • A Machine Safeguarding Assessment is delivered with a complete compliance report and machine safeguarding project proposal.

Finally, Rockford Systems offers an Emergency Response service that can be scheduled for the same or next business day following an unplanned downtime incident or employee accident, depending upon the severity of the situation. Upon completion of the Emergency Response Assessment, Rockford Systems provides customers with a quick-turn, high-quality, comprehensive safeguarding report and proposal that outlines findings, suggesting ways to reduce risk and become compliant. Professional recommendations are provided in the areas of guards, devices, awareness barriers/devices, safeguarding methods and safe work practices, all referencing applicable OSHA regulations and ANSI/NFPA standards. In some cases, OSHA officials may even grant companies time extensions if it has demonstrated “Good Faith” efforts, such as hiring an outside expert to conduct an emergency response assessment.

 

How Rockford Systems Light Curtains Can Brighten Employee Safety in Your Plant

At first glance, a simple beam of infrared light would seem ineffective protection against fast-moving, dangerous industrial machinery. After all, isn’t that what heavy-duty steel guards are for? Yet, these beams of infrared light, when utilized as a component of “safety light curtains,” have prevented thousands of employee injuries and saved countless lives. Unlike other types of more bulky safeguards, such as physical barriers, light curtains make it easier to access equipment while performing maintenance or semi-automatic processes that require human interaction. Whether they are used to reduce exposure to point-of-operation hazards, or as a perimeter guarding device, being lightweight and compact makes light curtains ideal for machinery, robots or areas that require frequent access for purposes of material feeding, maintenance, repair, setup or the need to be adapted quickly to layout changes on a plant floor.

Light curtains are defined as being presence-sensing optoelectronic devices, and are often used as a component within an overall safety system in meeting nationally recognized safety regulations and standards, such as OSHA or ANSI (B11.19-2019). The most common application of light curtains is to detect people or objects passing through a perimeter boundary, or close to protect from direct contact with a machine’s point-of-operation. “Point of Operation” in this instance refers to where production material is being positioned for punching, bending, cutting, machining or where any type of hazardous motion is present. This is why light curtains are installed onto power presses and metal forming machines to protect the operator’s hands or fingers from crush injuries.

Transmitters and Receivers

Although light curtains come in a wide variety of designs, the two common features that make them alike are a transmitter and receiver. Transmitters units have a series of LEDs that emit an array of synchronized, parallel infrared light beams to a separate receiver unit on the other end. The receiver has a corresponding array of photo-diodes that automatically synchronize with the transmitter LEDs, in effect, “receiving” the pulses. Receiver circuitry is designed to detect only the specific pulse and frequency designated for it, preventing external light sources from being sensed. These systems can be mounted vertically, horizontally, or on any angle depending on the application. The only requirement is that the transmitter must align with the receiver when installed.

It is important to note that light curtains differ from other photoelectric sensors in that they have self-monitoring circuitry. When photoelectric cells from the transmitter are interrupted by an opaque object, this event triggers an output signal that is typically fed to a safety relay device delivering redundant protection. For example, if a person steps into a prohibited zone, this safety relay would signal to the machine to stop anywhere in its cycle or stroke to prevent a potentially catastrophic accident. Light curtains should only be used on machinery that can be quickly stopped anywhere within the machine’s cycle, and should never be used on any machine with a full-revolution clutch.

Once tripped, a conscious action is required on behalf of the operator to re-start the machine cycle after the source of the light curtain interruption is addressed. Prior Action Stations must be located outside yet within view of the protected area to prevent the inadvertent automatic or continuous resumption of the machine. Depending on the light curtain and its application, a separate enclosure may hold various diagnostic indicators, power supply, user controls and control logics that cannot be installed within the receiver.

Another light curtain design worth noting is an “active passive system” consisting of two unique devices. One both emits and receives beams while the other device essentially acts as a mirror to deflect the beams back to the receiver. While this approach minimizes overall costs and wiring, an active passive system reduces the intensity of the light beam and therefore normally has a much shorter operating range than a standard system. Mirrors will reduce the operating range of a light curtain by up to 18% per mirror, depending on the type of mirror installed.

Blanking & Muting

As mentioned earlier, light curtains come in a wide variety of resolutions and IP ratings. Other more advanced features have to do with minimizing the disruption to factory flow caused by machinery being completely shutdown when light beams detect an obstruction. Two worth noting are “blanking” and “muting” — two terms that are frequently used interchangeably yet incorrectly. Muting is the temporary automatic suspension of the entire curtain while a non-hazardous portion of the machine cycle is being performed, for example, during a press’s up stroke. Blanking is more complex. Instead of muting the entire sensing field, blanking is the bypassing of only a portion of it, leaving the rest of the light curtain active. Blanking finds utility when material is fed through the sensing field while the machine is in motion. Obviously, care must be taken to ensure the operators hands, fingers or arms cannot fit through the blanked portion.

Minimum Safety Distance 

When utilizing a light curtain as a point-of hazard safeguarding device, it is important to know and understand the stopping time of your machine.  Both OSHA, ANSI, and ISO all provide formulas to calculate the safe mounting distance of a light curtain based on the stopping time of your machine.  OSHA’s formula is the base requirement, while ANSI and ISO formulas represent best safety practice, and generally result in more than a 10% increase in safe mounting distance.

Light Curtain Resolution

The resolution of a safety light curtain is its detection capability measured as the amount of separation between its laser beams. Higher resolution light curtains improve the detection capability that can sometimes allow for the light curtain to be safely mounted closer to a hazard. While a 14mm resolution is ideal for finger detection and can be deployed closer to the source of hazardous motion, a lower 25-30mm resolution is all that is required for hand detection.

Rockford Systems strongly recommends a risk assessment prior to any light curtain installation.

Status Indicator Lights

Light curtains often feature status indicators clearly visible from a distance, preventing close proximity to dangerous machinery. Red, green, and yellow lights conveniently display operating status, configuration error codes, and blocked beams.

Questions to consider when selecting a light curtain:

  • What is the stopping time of the machine or equipment? Is it sufficient to even consider a presence sensing device?
  • How large is the area needing to be protected, and are there two corners or four corners?
  • What is the required height of the protection field?
  • What is the required operating range?
  • What is the required resolution, usually measured in millimeters? The tighter the required spacing, the higher the resolution.
  • What are your mounting requirements?
  • What Performance Level (PL) is required?
  • What environmental challenges will the light curtain face, including excessive temperatures, moisture exposure, and shock/vibration that can damage the equipment? This is often measured in IP ratings.
  • What cabling and wiring is needed?

Finally, with so much on the line, it is essential to overall employee safety that you consult with an experienced machine safeguarding expert when specifying and installing a light curtain. Contact Rockford Systems to ensure that your safety needs are fully met.

 

 

What the Wave of Retiring Machinists Means to Plant Safety

Within the next decade approximately 2.7 million “Baby Boomers” (b. 1946-1964) will retire, thereby ensuring that tens of thousands of skilled, well-paid positions will become available without a ready supply of American workers to fill them. Statistics paint an especially gloomy picture for the manufacturing sector, a widening of the skills gap, and a possible dilution of existing training programs.

Compared to the rest of the economy, the impact on manufacturing of this generational shift is oversized owing to two factors:

  • One, despite increased efforts by colleges and vocational schools to train new manufacturing workers, available jobs still outpace qualified employees.
  • And two, the existing manufacturing workforce is considerably older than the national employee average of 42 years. Currently, the average age of highly skilled manufacturing employees is 56, and nearly a third of all manufacturing professionals are over 50. As they retire, knowledge goes out the door with them.

What are the implications of these trends for your plant’s productivity? How will it impact employee safety? What can you do to transfer knowledge from one generation to the next?

Safety Knowledge Gap

Besides having less experience operating machinery correctly, workers new to the job are often unsure about their safety rights and responsibilities, or might feel uncomfortable speaking out about a potential hazard. They may also not have the proper training, so they underestimate the risks involved with operating high-speed machinery. A recent survey of machinists in North America exposed that 70% couldn’t recall receiving any formal training when they were first hired on.

Equally troubling, the Millennials (b. 1980-1996), who are replacing baby boomers, are more apt to job hop — 90 percent expect to stay in a job for less than three years — leaving manufacturers with heightened turnover and a badly depleted knowledge base, especially when it comes to safety. The so-called “Great Resignation,” the unprecedented mass exit from the workforce spurred on by Covid-19, also has reduced the pool for skilled labor.

Given all this, it probably comes as little surprise that employees under the age of 25 are twice as likely to visit the emergency room for an occupational injury than those over 25. The dangers facing younger workers underscore the critical importance of machine safeguarding. The lathe, press or saw on the plant floor considered “safe” solely on the basis of being accident-free for many years is no guarantee that modern safety regulations and standards are being met. A machine mistakenly perceived as “safe” may be the most dangerous in your maintenance shop, or on your production floor.

Safeguarding Assessment

Faced with the wave of Baby Boomer retirements, many manufacturers are trying to hold on to their older workers, persuade some to return after retirement, or recruit those retired from other companies. Unfortunately, these steps only postpone the inevitable. A more meaningful first step is to conduct a thorough machine safeguarding assessment on your machinery.

A machine safeguarding assessment draws on the expertise and experience of an outside company to identify and address machine hazards before they cause accidents. Over the course of a machine safeguarding assessment, detailed information is collected concerning each machine, how the operator interacts with the machine, and the process it is tied to. Hazardous areas are pinpointed on the machine and a hazard level assigned to each machine. Evaluating this hazard level helps determine which safeguarding methods should be applied to each machine to make it safe. If a risk is not tolerable, safeguarding measures need to be applied that will reduce the risk to an acceptable level that is in accordance with applicable regulations and standards. The assessor should also accurately identify all costs associated with the final project. After installing safeguards, a follow-up assessment will be conducted to verify that risk levels have either been eliminated, or reduced to a tolerable level.

Transferring Tribal Knowledge

Retirees won’t leave behind every bit of knowledge they’ve gained over the years, but capturing a majority of the important operational details will be beneficial down the road. Your organization needs to find ways of both learning and sharing this “tribal” knowledge before experienced machinists retire.

One common way of doing so is implementing a structured training and mentoring program pairing young workers with senior people who are technically expert in complex machinery. Along with face-to-face training on the machinery, the experienced worker is there to answer questions about operating procedures, and to help the young worker learn how to operate the machinery correctly. Recognizing hazards and learning safe work practices must be a central part of training and mentoring programs so make sure they are given equal billing with productivity during conversations. Training and mentorship also play an important role in informing young workers about OSHA, every worker’s right to a safe workplace, as well as the right to refuse unsafe work. Once retired, the mentor can return on a part-time or as needed basis to continue training new hires.

Outside Training

While older machinists certainly have the experience and technical knowledge, they may not know how to teach because they aren’t professional trainers or they can’t communicate effectively with a younger generation. Others may feel that training is an additional obligation that has been hoisted upon them when they are already crunched for time.

Hiring an outside firm to teach your team about machine safety regulations and standards is another step toward overcoming dilution in training. Rockford Systems offers a variety of safety training courses, including Machine Safeguarding Seminars, Combustion Safety Training, NFPA 70E and other courses at its Training Center in Rockford, Illinois. The popular 2-day seminars combine classroom discussion with live demonstrations to give the hands-on experience that new employees need. Once the seminar is complete, the employee will be better able to interpret the OSHA 29 CRF and ANSI series standards as they relate to their specific machine applications and production requirements.

Can’t make it to Rockford? No problem. The seminars can be presented at your company and tailored to the types of machinery found at your plant.

Annual Audits

Rockford Systems also offers an Annual Verification Audit to verify that your properly safeguarded equipment is being used as intended to protect employees working in dangerous environments. Moreover, the audit ensures that your capital investment in providing a safe working environment is sustained and continues to be in compliance with OSHA regulation and ANSI B11 series standards, as well as meeting any internal safety policies that a company may have established.

The primary evaluation criteria for the audit are visual inspection and function testing of safeguarding, controls, disconnects, motor starters, and mechanical power transmission apparatus covers. Once an audit is completed, Rockford Systems identifies issues in a detailed report highlighting deficiencies or changes from the original project specifications and recommendations for corrective actions to bring the equipment back into compliance.

Final Thoughts

A perfect storm has formed, making it increasingly difficult for manufacturers to find and train labor. The retirement of tenured and experienced machinists only makes matters more challenging. To ensure plant productivity and safety needs are continuously met despite retirements, take proactive steps through working to develop and promote training and mentorship programs, properly safeguarding your machinery, and conducting annual verification audits to ensure that your safety program is being followed as intended.

For more information, visit www.rockfordsystems.com

 

Ten Tips for Safeguarding Your Shop’s Metal Lathes

Operators of lathes are one of the largest machine worker populations in the United States, estimated to account for over 140,000 machinists. Of this population, approximately 3,000 suffer lost-time injuries annually in the United States. Some of these are fatal. These accidents occur in large industrial settings and factories, as well as in much smaller machine shops. No lathe operator is immune from an accident.

Operating a manual metal lathe, in particular, presents a number of hazards. For one, the lathe’s rotating parts easily can catch hair, jewelry and clothing, entangling the operator and resulting in severe and life altering injuries. Entanglement is also a risk whenever lathe operators use emery paper to sand or polish a rotating shaft. Without warning, the paper may wrap itself around the shaft, entangling the operator’s gloved hand, hair or loose clothing at over 300 RPM. Second, flying hot metal chips and coolant present serious risks if the machine’s guards or the operator’s PPE does not protect them effectively. Other risks include a work piece kicking back at the operator, slip-and-fall accidents due to coolant spilled on the floor, and parts or materials, such as chuck keys or unsecured work pieces, being projected at high speed and striking the operator and nearby employees. There have been lathe accidents recorded due to something as minor as the flashing effect of fluorescent light that can make a spinning lathe appear to have stopped.

Research shows there are numerous factors that can lead to a lathe accident. At the top of the list are malfunctions due to defective machinery, the failure to install proper safeguarding, mistakes due to the lack of employee training, poor lighting, and not providing proper PPE.

What does a metal lathe do?
A manual metal lathe is a precision turning machine that rotates a metal rod or irregular-shaped material while a tool cuts into the material at a preset position. Similar to a wood lathe, the metal lathe normally consists of a headstock and base that houses one or more spindles on which a work holding device or “chuck” can drive the stock while cutting tools remove metal, producing mainly cylindrical and conical shapes.

Operator Training & PPE
First and foremost, lathe operators must be trained and held accountable for following safe work practices. This is essential in avoiding injury. Examples of lathe machine safety precautions include not wearing loose clothing, rings and other jewelry, keeping long hair pulled back while operating a lathe and keeping hands and fingers away from rotating parts. As mentioned earlier, these practices are important because rotating parts will catch loose or dangling items and pull the operator into the machine, causing serious injuries or death.

OSHA makes it the responsibility of the employer to provide training that addresses safe start-up and shutdown as well as proper machine operation, speed adjustments and work piece placement, control and support. Employers must also equip lathe operators with proper PPE that includes safety glasses or other suitable eye protection, earplugs, protective footwear, and close-fitting clothing.

Safeguarding Standards for Lathes
There are no OSHA regulations specifically for lathes. Instead, OSHA considers lathes to be a 1910.212 machine, saying to the employer, “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” … but 1910.212 requirements are vague because they cover such a wide variety of machinery. Therefore, a reference to something more detailed, like the “appropriate standard” ANSI B11.6-2001, Safety Requirements for the Construction, Care, and Use of Lathes, is required for specific safeguarding alternatives. Section 5 of this standard contains the safeguarding requirements on metalworking lathes.

An important standard that ANSI B11 standards reference is ANSI/NFPA 79, Electrical Requirements for Industrial Machinery. It provides detailed information for the application of electrical/electronic equipment, apparatuses, or systems supplied as part of industrial machinery, including lathes. This standard addresses such issues as requirements for operator controls, emergency-stop devices, disconnect switches, motor starters, and protective interlocks.

Of course, even properly installed safeguarding equipment can’t protect a machinist who “works around” the safeguarding, lifting a guard, for example, to accomplish a task. Thankfully, most shields can be interlocked with the machine’s electrical system to prevent operation when they are not in place. Swinging a shield from its protective position will break its electrical connection and cut the power, forcing a quick coast down.

A lathe has several points of operation that present hazards. Each requires specialized safeguarding equipment. Below we address each of these hazards and what can be done to avoid accidents.

1. Safeguarding the Chuck
The chuck area is by far the most dangerous area on a lathe. From a practical standpoint, a rotating chuck cannot be fully enclosed — unlike gears, sprockets, or chains that usually are completely covered, often by the OEM. However, that same lathe manufacturer may not provide safeguarding at or near the point of operation although, according to 6.21 of ANSI B11.6, manual lathes must be safeguarded with a chuck guard and chip and coolant splash shields as required. In this case the employer is responsible.

Hinged chuck-shields are one of the most common methods to protect lathe operators from the rotating work-holder. Their purpose is to prevent an operator from inadvertently coming in contact with the chuck, which often results in entanglement, serious bodily injury or even death. Chuck shields are commercially available from numerous providers. They may be constructed of metal, polycarbonate, or some combination of materials. When not in use, they need to be swung up out of the way, so most are hinged. Same for during set-up.

Although U.S. Safety Standards and Regulations do not require chuck-shields to be interlocked, some European and Canadian manufacturers offer that feature. With electrically interlocked shields, when the lathe chuck shield is lifted up, the positive contacts on the microswitch open, sending a stop signal to the machine control. The machine will not start up again until the emergency stop button has been reset.

A common complaint against chuck shields is that they limit visibility due to light reflecting off the shield, or that obstruct their view to the work piece. To overcome these problems a clip-on lamp is sometime installed yet these can easily overheat. A far better solution is newer shields featuring built-in bright LED lighting that yield better visibility without shadows or heat build-up.

2. Sanding Belt Holder
Hand sanding and polishing metal shafts on the lathe with an emery cloth has resulted in numerous injuries. Emery cloth and gloves can easily be caught on the shaft, pulling the operator’s hand and arm on the shaft. An automatic sanding belt holder enables lathe operators to sand, polish and debur hands-free, keeping them a safe operating distance away from the spinning shaft and preventing entanglement. It typically fixes to existing tool-case turrets.

3. E-Stops
American National Standards Institute (ANSI) standards state that an emergency-stop or “e-stop” is required on any machine that will tolerate a quick stop. Some lathes have a true e-stop built in to halt operation in less than a second, but most require several seconds to cease functions. An electronic motor brake can improve coast-down time, in some cases from 15 seconds to 3 seconds, which can make a significant difference in an emergency.

Per NFPA 79, the e-stop must be a red with a yellow background, and have a mushroom-shaped button with a manual latch that keeps it down once it is pushed to prevent machine operation by the regular controls. Once the e-stop is engaged, the latch keeps it down until a manual quarter-turn releases the latch and allows the machine’s controls to again command the machine’s actions. Kick plates or grab-wires that go across a machine can facilitate an emergency shutdown if there is potential for an operator’s hands to be caught.

E-stops need to be readily accessible. An e-stop button should be within easy reach at each location on the machine that requires operator interaction. When more than one individual is involved, each person should have his or her own e-stop.

4. Chip/Coolant Shields
The long stringy chips produced when turning steel can wreak havoc on an operation and production. Edges of the chips are scorching hot and extremely sharp putting the operator at risk for injury, as well. Chips can strike the operator in the upper body or accumulate on the floor creating a slip-trip hazard.

As protection against chips, coolants, lubricant and sparks, lathes should be equipped with a chip and coolant splash guard, also known as a carriage safety guard. This type of guard can be electrically interlocked like a chuck shield, and gives added protection to the operator from direct contact with rotating components. Coolants are often overlooked as a hazard yet workers often are exposed through inhalation, ingestion, skin contact, or absorption through the skin, leading to burns and irritations. Without a chip/coolant shield, operators can also be at risk of inhalation of airborne substances such as oil mist, metal fumes, solvents, and dust.

It is rare for an OEM to include this type of shield on a new lathe. Again, it is the responsibility of the employer to install it before the lathe is put into commission.

5. Chuck Wrench
According to feedback from OSHA Compliance Officers and Insurance Loss Control Inspectors, one of the most common lathe accidents results from the misuse of standard chuck wrenches furnished by lathe manufacturers. When the lathe is not being used, a typical – and very unsafe storage place for the chuck-wrench is in the chuck. At some point in time, the operator turns the lathe on without checking to see where the chuck wrench is located, which projects it across the shop floor. Spring-loaded, self-ejecting chuck wrenches are a solution to this problem because they won’t stay in the chuck by themselves, helping to prevent a potential ejection hazard at machine start-up.

7. Magnetic Motor Starters and Disconnects
When updating an older lathe it is required practice to bring it up to code with current electrical standards like NFPA 79. This will require the installation of a motor starter and disconnect those only locks in the OFF position. When adding a motor starter, ensure it is magnetic to provide drop-out or “anti-restart” protection.

8. Telescopic stainless-steel sleeves
Although slow moving, horizontal rotating components in a lathe can entangle an operator and crush body parts with their tremendous torque. Installing telescopic stainless-steel sleeves will seal off their pinch-points plus protect the components from metal chips and other destructive contaminants. Unfortunately, operators complain that these devices are time consuming to install, need to be removed and cleaned regularly, and cause a loss in carriage travel. However, when compared to preventing a life-changing injury, these complaints are trivial in comparison.

9. Other Precautions
As with any machine, provision for Lockout/Tagout is always important with lathes. Danger and warning signs, depicting specific hazards on lathes, are also strongly recommended.

10. Conduct Machine Safeguarding Assessments
Machine Safeguarding Assessments are a critical step in any machine safeguarding process as outlined by ANSI B11, especially for companies deploying older or refurbished lathes. It is not unusual for lathes built in the 1940s to still be in active service, having been resold several times over the decades.

Odds that an older lathe is up to today’s safety standards are highly unlikely. Employers are often lulled into a false sense of security because a serious accident hasn’t occurred, or they may simply assume that the lathe they purchased, whether new or used, came equipment with all necessary safeguarding. The only way to take the guesswork out of compliance issues in your shop is a machine safeguarding assessment conducted by a qualified third-party, to help keep operators safe, machines productive and processes online. They will assign each machine a Risk Rating of 1 to 27, with 27 being the worst, based on three considerations: Severity of Injury, Exposure Frequency, and Avoidance Likelihood. When conducted by professionals, your machine safeguarding assessment will be delivered with a compliance report and a safeguarding project proposal that will detail the timing, costs and specific equipment required to bring machinery up to current standards.

Shield Against Debris

When a machinist is cutting, drilling, shaping or milling raw materials, there are always inherent risks. Thankfully, proper and up-to-date safeguarding equipment drastically minimizes the risks that machines pose. In this article, we look at one of the most basic and most critical components in machine safeguarding: the safety shield.

Before we start, we need to clarify the terms “guard” and “shield.” These are often used interchangeably when referring to safeguarding equipment, yet the two categories are very different. OSHA 29 CFR 1910.217 defines a guard as an enclosure that prevents anyone from reaching over, under, around, or through to a hazard.

Guards are used when a machine risk assessment shows a high level of exposure to recognized hazards. Shields, on the other hand, are designed for lower levels of exposures to hazards, while providing visibility into the point of operation. Shields typically have a transparent plastic panel with rugged framing, while a guard is solid metal, although it should be noted that not (not all shields have a framework, and that many industrial guards use aluminum for framework.).

Flying debris protection
The purpose of safety shields is to protect the machinist and bystanders from moving parts, flying debris, coolant, sparks, and other potential safety hazards by enclosing the danger (shields don’t enclose a hazard, they providing a barrier between plant personnel and the hazard) behind a rugged, impact-resistant panel. Shields attach to machinery, either temporally or permanently, fitting over blades, drills, lathe chucks, grinding wheels and other dangerous components (blades, cutting tools, chucks, grinding stones and other hazardous rotating components.).

Perhaps the greatest danger shields protect against is flying debris, an all-too-common occurrence in machine shops with the potential to bring about serious injury to an operator’s eyes, face, or body. The costs of a flying debris injury can add up quickly. Costs may include workers’ compensation claims, medical expenses, lost production time, and the possibility of permanent scarring and blindness.

For instance, consider an abrasive wheel grinder. Grinders are one of the most common pieces of machinery in maintenance shops, wheel grinders are powerful and designed to operate at high speeds. Depending on the equipment, the wheels can revolve at an incredible 10,000 surface feet per minute, and can loosen sharp chips or particles that can fly into an operator’s eyes or face. If a grinding wheel shatters while in use, the fragments can travel at more than 300 miles per hour directly at the operator, more than fast enough to penetrate the skull and cause traumatic brain injury. In situations like this a safety shield is the last line of defense against tragedy. (Our shields do NOT provide protection from catastrophic machine failure, which I would consider an exploding grinding stone) Even if the operator is wearing proper personal protective equipment, flying chips can cause life-threatening injuries without a shield installed. A shield can make the difference between a day that ends successfully and a day one that ends in the hospital.

Safety standards
Given their critical importance to operator safety, it is not surprising that ANSI, OSHA and other standards governing machine safeguarding heavily rely upon shields. Specific requirements largely depend on the type of machinery being safeguarded. Before installing a new shield on any machine the safety manager must ensure that the shield conforms to the appropriate, up-to-date standard for that machine.

Besides grinders, shields are typically installed on drilling machines, lathes, milling machines, band saws (saws), belt sanders, and disc sanders (sanding machines), and boring machines.. TheseThe seven (eight) machines represent over 95 percent of all shielding applications. Different standards outline the type of shield design and size that is allowed on each. In some cases, more than one type of shield per machine may be necessary to provide protection.

Types of shields
Shields come in dozens of designs, sizes and shapes. In their most basic form they can be broken out into fixed, portable, adjustable and interlocked categories, or a mixture of these features.

Fixed/portable
The most obvious characteristic of a fixed shield is that it is a permanent part of the machine. Tools are needed for its removal making it difficult to bypass. It is also not dependent upon other moving parts to perform its intended function, further increasing the protection. In contrast, a portable shield can be removed from the machine when not in use. Often, smaller shields will feature a pull magnetic base that attaches to a flat surface on the machine being safeguarded. Being removable, portable shields can be set aside for maintenance or moved to a similar machine. There are also large freestanding portable shields used to protect the area between machines, along aisles, or the backside of a machine.

Adjustable
An adjustable shield can be positioned for maximum protection during operation and swung out of the way for easy access to the workpiece and tooling. Types of adjustable shields are those mounted on brackets that allow for slide adjustments to fit workpieces; on steel ball-and-socket arms for simple movements and adjustments; or on flexible spring-steel arms offering virtually unlimited adjustment possibilities and long-term holding power.

Interlocked
Although not required, (I don’t like saying “not required” fiIt is best practices that sshields featuring movable parts that can be opened without using tools should be interlocked with the machine control system. The interlock prevents machines from starting until the shield is positioned safely in front of the hazardous area. Additionally, if the shield is moved away from the hazardous area while the machine is running, the interlock will send a stop signal to turn the machine off.

This way the hazards covered by the shields will be effectively controlled if the shield is opened and the hazard is exposed. (Explain differently, this is confusing. Hazardous machine movement is prevented when the shield is opened) When an interlocked shield is opened or closed, a tripping mechanism automatically shuts off the power to disengage operations. The machine cannot cycle or be started until the shield is back in place. (Maybe wrap all three previous sentences into one statement. Sounds odd and non-technical)

Modern machines rely on electrical interlocks since they are already fitted with an electrical control system. The interlock is connected to the safety circuit of the machine and will prevent machine start-ups when the shield is swung open, even if the power switch is “ON”. It is only after the shield is closed that the machine can be restarted and normal operation resumed. Switches and sensors connected to these systems can be something as simple as a micro-switch or a reed switch, or as complex as a non-contact sensor with an electromagnetic locking device. Non-contact interlocking devices available today use coded RF signals or RF ID technologies to ensure that the interlock cannot be defeated by simple measures, like taping a magnet to a rA safety relay will monitor the interlock switch for failure, providing a notification if the interlock has been removed or is not functioning correctly.

Impact resistance
It goes without saying that Aa transparent shield needs to be highly impact resistant, along with providing an unobstructed and undistorted view. Impact resistance of a material can be measured in different ways, and the test method varies depending on the material being evaluated. In the United States, the notched Izod impact resistance test, as outlined in ASTM D256, is a common method of measuring the toughness of a plastic material.

It is important to note that increasing the thickness of a shield beyond a certain level does not always improve or increase impact resistance. A shield made of tougher material can be down-gauged to be thinner — and, therefore, more cost-effective — than one made from a more brittle material while still offering the same or superior level of protection for operators. Not sure the impact resistance data belongs in this article.

Innovations
Having lain dormant for decades, innovation has finally come to the safety shield business. Companies are bringing new materials and features to the product category that are enhancing operator safety yet making it less expensive for machine shops to be fully compliant with regulations.

An example of this new problem-solving advancement is the incorporation of bright LED lighting into the shield frame to yield higher visibility of the work area. Operators have often complained that shields limit visibility because of reflectivity or obstruction. Unlike an incandescent, LED lighting is not-reflective, cool and renders true colors. Besides the white lighting illuminating the work area while in operational mode, different LED colors can be programmed to act as visual indicators.

For example, when the shield is moved out of the safe work position, the white LED can switch off automatically and red LED can switch on to warn the operator. If you plan to purchase a shield with an LED be aware that the lighting must be manufactured to exacting IEC IP65 outdoor/wet locations standards to withstand splashes of coolant and lubricant from the machine.

Another innovation is modularity. Different machines require different shields, and one size rarely fits all. Shield manufacturers have embraced the modular design concept so that shield shape, size, mount, arm, offset, lighting, interlocking and safety monitoring can be configured to engineer the best solution for even the most unique challenge.. Available today are various mounting options, including opposite-hand mounting scenarios for left-handed operators. Left handed or not, handles for drills, mills, boring machines, etc are located on the right side of most machines. Opposite side mounting locations are selected based on available machine frame surface and/or other obstructions on a machine. Shields are vertically and horizontally adjustable to clear varying work setups and table heights.

Finally, there is the issue of operators bypassing shields, either by pushing them out of the way or tampering with the equipment.

Tamper-resistant interlock enclosures (switches) and redundant safety monitoring (monitoring does nothing for preventing tampering) go a long way towards stopping bypassing. However, a quality shield that doesn’t interfere with operation of a machine is a better answer. A shield defeats its purpose if it impedes a worker from performing a job quickly and comfortably. When properly installed and designed for a specific machine, a shield will actually enhance efficiency because it will relieve apprehensions about an injury.

Learn about Rockford Systems’ line of PROTECTOR Series Shields offering the highest level of safety on the market.

Steel Curtains Help Protect Against Flying Debris Ejected from Hydraulic Presses

The potential for catastrophic injury when operating a hydraulic press is great. Its operation requires a worker to feed, position and remove stock in the area under the powerful ram or near the bending point, exposing him or herself directly to danger. Each year an estimated 250,000 industrial workers are struck by ejected debris such as metal chips, nails, broken cutters, blades, tools and dislodged grinding wheels from a variety of different machines.

Because of the tremendous force of a press, parts ejected from it have led to countless serious eye, head, and bodily injuries. Metal fragments, slivers, piece parts and blocks can be dislodged and dispersed at great speed, striking the press operator or bystanders. These types of accidents typically occur when job parts are not aligned properly during setup. As a result the job part may be squeezed out or ejected when under tremendous load. Stock may also fracture, sending shrapnel into the work area, piercing skin and underlying tissues. Each year an estimated 250,000 industrial workers are struck by ejected debris such as metal chips, nails, broken cutters, blades, tools and dislodged grinding wheels from a variety of different machines.

ROLE OF EJECTION CURTAINS
Ejection Curtain

Steel mesh ejection curtains were originally intended to protect people in the vicinity of a bomb blast. Today they have become a safety solution for hydraulic presses, namely Arbor and H-Frame presses. Rather than having a work piece that fractures, slides, rolls or ejects to become a high-speed projectile, the curtain’s interlocking wire coils act as individual springs that absorb kinetic energy, expanding and stretching in a predictive and repeatable way. The holes in the material allow pressure to go through the mesh while stopping or slowing the flying debris by wrapping around it and dropping it to the floor without ricocheting back towards the press, thereby reducing the potential for striking the operator.

Ejection curtains have gained popularity since they offer access during normal operations, as well as for press maintenance. Being mesh, the curtains are flexible and simple to push out of the way during loading, positioning or removing work pieces, unlike with traditional fencing or solid metal barriers. Additionally, the mesh curtain allows visibility while the press is in operation. Curtains are typically secured at the top on a pipe suspension assembly and hang free at both sides and the bottom, providing easy access to the machine.

METHODS FOR RISK REDUCTION
Ejection Curtains Top

Although ejection curtains are not classified as guards, they do act as an awareness barrier for powered presses to reduce exposure to the point of operation and also act as a containment barrier to stop or slow projectiles ejected from the machine. For powered presses, this product meets the ANSI B11.2 ref 8.2.1. “flying objects” clause, pending results of the risk assessment to determine the likelihood and force potential for throwing objects (note, a “shield” does not need to be a hard guard).

Platen presses, stamping presses, transfer presses, and in some cases forging presses require barrier guards or devices, which prevent access to the point of operation Over, Under, Around, or Through the guard itself. For these applications, an ejection curtain does not meet these criteria as it is a movable barrier and does not have to be in place to operate the press.

For more information on ejection curtains, please visit our product page or call 1-800-922-7533 or customerservice@rockfordsystems.com.

Machine Risk Assessment vs. Safeguarding Assessment? Start 2021 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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Bye-Bye Boomers: What Retiring Machinists Mean to Plant Safety

Within the next decade approximately 2.7 million Baby Boomers (1946-1964) will retire, thereby ensuring that tens of thousands of positions will become available without a ready supply of American workers to fill them. Statistics paint an especially gloomy picture for the manufacturing sector, and the resulting widening of the skills gap as young replaces old.

Compared to the rest of the economy, the impact on manufacturing of this generational shift is over sized because of two reasons: One, despite increased efforts by colleges and vocational schools to train new manufacturing workers, available jobs still outpace qualified employees. And two, the existing manufacturing workforce is considerably older than the national employee average of 42 years. Currently, the average age of highly-skilled manufacturing employees is 56, and nearly a third of all manufacturing professionals are over 50. As they retire, knowledge goes out the door with them.

What are the implications of these trends for your plant’s productivity? How will it impact employee safety? What can you do to transfer knowledge from one generation to the next?

SAFETY KNOWLEDGE GAP
Besides having less experience operating machinery correctly, workers new to the job are often unsure about their safety rights and responsibilities, or might feel uncomfortable speaking out about a potential hazard. They may also not have the proper training, so they underestimate the risks involved with operating high-speed machinery. A recent survey of machinists in North America exposed that 70 percent could not recall receiving any formal training when they first hired on.

Equally troubling, the Millennials (1980-1996), who are replacing Baby Boomers, are more apt to job hop — 90 percent expect to stay in a job for less than three years, leaving manufacturers with heightened turnover and a badly depleted knowledge base, especially when it comes to safety.

Given all this, it probably comes as little surprise that employees under the age of 25 are twice as likely to visit the emergency room for an occupational injury than those over 25. The dangers facing younger workers underscore the critical importance of machine safeguarding. The lathe, press or saw on the plant floor considered “safe” solely on the basis of being accident free for many years is no guarantee that modern safety standards are being met. Seasoned machinists may have developed workarounds that prevented accidents. Worse yet, the machinist may have covered up small accidents they’d suffered, considering an occasional nick or scratch simply part of the job. Your “safe” machine may be the most dangerous on the floor.

Step One: Safeguarding
Faced with the wave of Baby Boomer retirements, many manufacturers are trying to hold on to their older workers, persuade some to return after retirement or recruit those retired from other companies. Unfortunately, these steps only postpone the inevitable. A more successful, long-term answer is having your plant’s machinery subject to a thorough risk assessment process.

A risk assessment draws on the expertise and experience of an outside company to identify machine hazards before they cause accidents. Over the course of the assessment, detailed information is collected concerning each machine, its operator and the process it is tied to. Hazardous areas are pinpointed on the machine with a risk level assigned to each potential danger. Evaluating this risk level helps determine if further safeguarding methods should be applied to the machine to make it safe. If a risk is not tolerable, safeguarding measures need to be applied that will reduce the risk to an acceptable level that is in accordance with national, regional and local regulations. The risk assessor should also accurately identify all costs associated with the final project. After installing safeguards, a follow-up assessment will be conducted to verify that risk levels have been reduced to a code-compliant, tolerable level that will not threaten the safety of less experienced employees.

Step Two: Transferring Tribal Knowledge

Retirees won’t leave behind every bit of knowledge they’ve gained over the years, but capturing a majority of the important nuggets will be beneficial down the road. Your organization needs to find ways of capturing this “tribal” knowledge before the machinist hangs up their hat and heads for the white sandy beaches of retirement. One common way of doing so is implementing a structured mentoring program pairing young workers with senior people who are technically expert in complex machinery. Along with face-to-face training on the machinery, the experienced worker is there to answer questions about operating procedures that are unclear or not understood, and to help the young worker learn the ropes of a new job. Recognizing hazards and learning safe work practices must be central part of mentoring programs so make sure they are given equal billing with productivity during conversations. Mentors can also play an important role in informing young workers of their OSHA rights to a safe workplace, as well as the right to refuse unsafe work. Once retired, the mentor can return on a part-time or as needed basis to continue training new hires.

TRAINING
While older machinists certainly have the experience and technical knowledge, they may not know how to teach because they aren’t professional trainers or they can’t communicate effectively with a younger generation. Others may feel that training is an additional obligation that has been hoisted upon them when they are already crunched for time.

Hiring an outside firm to teach young employees about machine safety overcomes those problems. Rockford Systems offers Machine Safeguarding Seminars at its Rockford Systems Training Center in Rockford, Illinois. The popular 2.5-day seminars combine classroom discussion with live demonstrations on fifteen machines set up to give the hands-on experience that new employees need. Once the seminar is complete, the employee will be enable to interpret the OSHA 29 CFR 1910 and ANSI B11 Series Standards as they relate to their specific machine applications and production requirements, perhaps better than the retired operator they are replacing.

AGAIN, IMPORTANCE OF RISK ASSESSMENTS & SAFEGUARDING
A perfect storm has formed, making it increasingly difficult for manufacturers to find and train labor. The retirement of the Baby Boom generation only makes matters more challenging. To ensure plant productivity and safety needs are continuously met despite retirements, take proactive steps by conducting a risk assessment of machines, work to promote the transfer of knowledge, and install code-compliant safeguarding equipment.

The good old days? Not for machine operators.

History of U.S. Machine Safeguarding

When manufacturing moved from small shops to factories during the Industrial Revolution, inexperienced, often very young workers were confronted with a confusing jumble of moving belts, pulleys and gears. While pre-industrial craftsmen faced risks from kilns and hand tools, industrialization introduced massive steam engines and fast-moving machines. Adults and children, some as young as four years old, operated unprotected machinery 12-16 hours a day under conditions unheard of today, with many losing their lives.

Safeguarding History

In America the use of labor saving machines was driven by a regulatory climate that discouraged employer’s interest in safety. As a result, manufacturers at the time developed machinery that was both highly productive and very dangerous. Overworked American factory workers in the 1900s faced life with missing limbs, damaged vision and hearing, lung infections, and severe burn injuries.

Child Worker Injury

Workers who were injured might sue employers for damages, yet winning proved difficult. If employers could show that the worker had assumed the risk, acted carelessly or had been injured by the actions of a fellow employee, courts would usually deny liability. Only about half of all workers fatally injured recovered anything and their average compensation amounted to only half a year’s pay. Because employee accidents were so cheap, industrial machinery was developed with little reference to safeguarding.

Not unexpectedly, reports from state labor bureaus were full of tragedies that struck the unlucky. These reports spurred the budding labor movement to call for factory safety. In 1877, Massachusetts passed the Nation’s first factory inspection law. It required guarding of belts, shafts and gears, protection on elevators, and adequate fire exits. Its passage prompted a flurry of state factory acts. By 1890, nine states provided for factory inspectors, 13 required machine safeguarding, and 21 made limited provision for health hazards.

Safeguarding HistoryOn the national level, Congress passed a federal employers’ liability law in 1908 that made it more expensive for companies to have a machine accident on their books. Thanks to the new law, worker injuries that once cost companies $200 to resolve now cost almost $2,000. In 1910, the state of New York created a workmen’s compensation law that forced companies to automatically compensate for workplace injuries, eliminating the need for families to take corporations to court. By 1921, 43 more states had followed New York’s lead and established their own compensation laws. Compensation laws and other liability costs suddenly made workplace injuries an expensive proposition for many employers.

What followed was a slow but steady increase in machine safeguarding. Manufacturing companies began to work to create safer production equipment, and managers began getting tasked with identifying machine dangers.

In 1913, the U.S. Bureau of Labor Statistics documented approximately 23,000 industrial deaths among a workforce of 38 million — a rate of about 61 deaths per 100,000 workers. Although the reporting system has changed over the years, the figure dropped to 37 deaths per 100,000 workers by 1933 and 3.5 per 100,000 full-time-equivalent workers in 2010. A major contributor to the trend in fewer deaths was machine safeguarding.

Safeguarding HistoryAfter WWII accidents declined as powerful labor unions played an increasingly important role in worker safety. Personnel Protective Equipment (PPE) became a requirement with gloves, masks and aprons given to workers. Posters were hung throughout the plant floor reminding workers of their responsibility to think and act in a safe manner. Basic guards and safety mats became common features around industrial machinery. Also, the American Standards Association published its “Safety Code for Mechanical Power Transmission Apparatus” in the 1940s. Very similar to OSHA 1910.218 it was written to serve as a guide for machine manufacturers in guarding systems. The National Safety Council found that the injury frequency rate dropped from 15 injuries per 100 full-time workers in 1941 to 9 in 1950. By 1956, it reached a decade low of 6 per 100 workers. As impressive as those numbers were, the on-the-job death toll in the 1950s remained a stubborn 13,000-16,000 workers annually.

Nixon Signs OSH ACTIn the 1960s economic expansion again led to rising injury rates with 14,000 workers dying each year. An additional 2.2 million workers were injured on the job. Resulting political pressures led Congress to establish the Occupational Safety and Health Administration (OSHA) in 1970. On December 29, 1970, President Richard Nixon signed into law the Williams-Steiger Occupational Safety and Health Act (OSH Act), which gave the Federal Government the authority to set and enforce safety and health standards for most of the country’s workers. This act was the result of a hard fought legislative battle that began in 1968 when President Lyndon Johnson unsuccessfully sought a similar measure.

In the House, Representative William A. Steiger worked for passage of his bill by saying: “In the last 25 years, more than 400,000 Americans were killed by work-related accidents and disease, and close to 50 million more suffered disabling injuries on the job. Not only has this resulted in incalculable pain and suffering for workers and their families, but such injuries have cost billions of dollars in lost wages and production.”

Machine Safeguarding AssessmentsWhen the agency opened for business in April 1971, OSHA covered 56 million workers at 3.5 million workplaces. Today, 105 million private-sector workers and employers at 6.9 million sites look to OSHA for guidance on workplace safety and health issues.

Safeguarding technology and requirements have come a long way since the industrial revolution. Advanced light curtains, interlocked guards, laser-guided systems and presence sensors are now commonplace. Despite this progress, the lack of machine guarding has been named to OSHA’S Top 10 Most Cited Violations List virtually every year since the list began. In 2018 OSHA handed out nearly 2,000 violations to companies for failing to have machines and equipment adequately guarded, underscoring how much work there is left to do.

In many respects, we take today’s focus on machine safety for granted. However, by reviewing history we can see how it has benefited society by radically reducing accidents and deaths.

Safeguarding History

Evaluating the Machine Guarding ROI

Insurance studies indicate machine safeguarding provides an excellent opportunity for businesses to reduce bottom-line operating costs by eliminating both the direct and indirect costs of accidents.

Consider this:According to the 2018 Liberty Mutual Workplace Safety Index, serious, non-fatal workplace injuries amounted to nearly $60 billion in direct U.S. worker compensation costs. This translates into more than one billion dollars a week spent by businesses on injuries. Another study, this one conducted by Colorado State University, set the total direct and indirect cost of workplace injuries at $128 billion. For its part, the National Safety Council (NSC) set the total cost to society of occupational injuries and deaths at $151.1 billion.

So how does an organization evaluate the machine guarding return on investment (ROI)?

DIRECT COSTS

First off, what are the direct costs of an accident? These refer to out-of-pocket expenses like hospital and medical bills, but may also include the loss of a worker’s time because of the accident, the lost productivity by the machine involved in the accident being idled or requiring repairs, as well as the other machines further down the production line being shut down. Direct costs continue to cascade throughout the company with overtime required to make up the lost productivity or new workers who need to be hired and trained.

The NSC estimates that cost per medically consulted injury, counting wage losses, medical expenses, administrative expenses and other direct employer costs, to be $32,000. This varies greatly by cause and nature of the injury, and which part of the body is impacted. For example, the average cost per worker compensation claims involving an amputation runs $95,204, while a crushing accident is $57,519. These two sorts of injuries are mentioned here because they are both very common in machinery-related accidents. The NSC also reports that an employee death resulting from an accident costs the company on average $1.2 million. Total medical cost to society annually from occupational injuries and deaths is $33.8 billion.

INDIRECT COSTS
Analysis reveals that the actual total cost of an accident ranges from four to ten times the direct cost stated by an insurance company once indirect costs are factored in. Indirect costs can include such things as workplace disruptions, loss of productivity, and increased insurance premiums. And of course, there are litigation and lawyer fees. Here, the sky is the limit. Lawsuits resulting from employee injuries or death, especially those involving a lack of machine safeguarding, often result in multi-million dollar settlements or verdicts. Investments targeted for company growth may need to be diverted to cover the costs of these settlements, putting the future of the company in jeopardy.

While it is not calculated as an indirect cost, a poor safety record can make the difference between a company winning or losing bids, especially with government contracts. A plant with a singularly bad reputation for safety may also find itself unable to attract qualified workers or may have to pay wages well above market value to do so. Also, if the machine is locked out for investigation or until the safeguarding deficiency is abated, the company may need to outsource the work at a much higher cost. It’s also possible that the work is so specialized that it’s impossible to outsource and therefore the company loses the business.

MANAGEMENT OPINIONS ON SAFETY
A poll by Liberty Mutual Group insurance showed that the majority of executives surveyed (61%) reported that for every one dollar spent on safety, three dollars is saved. Nearly all (95%) said workplace safety had a positive effect on financial performance. OSHA estimates a 6:1 ratio for saved dollars for every one dollar invested in safety, twice Liberty Mutual’s 3:1 ratio.

Of course, if a company could be guaranteed a huge return on their safety investment, more than half the machines in the U.S. today would not be operating unprotected. Convincing upper management to commit tens of thousands of dollars on machine safeguarding when a return may not be seen for years can be a hard sell. In this situation, safety professionals can stress that although cost savings are a motivator, safety’s biggest ROI comes in the form of human capital. Money savings from fewer injuries, increased productivity, and higher morale are all additional benefits.