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 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

Ten Most Reported Worker’s Compensation Injuries

Last year in America 2.9 million employees (U.S Bureau of Labor Statistics) suffered a workplace injury from which they never recover, at a cost to business of nearly $60 billion (Liberty Mutual Insurance). These statistics are staggering. To help gain a better perspective on the realities of workplace danger, we have compiled a list of the ten most reported worker’s compensation injuries, as reported by a leading insurance company.

By raising awareness of these dangers, we hope we can help you identify hazards in your workplace and take measures to control the risks preferably by eliminating them – but if that is not possible, by reducing them as far as possible.

1. Overexertion– These are injuries due to excessive physical effort such as lifting, pulling, pushing, turning, wielding, holding, carrying or throwing. The Liberty Mutual Workplace Safety Index, which is compiled using Bureau of Labor Statistics (BLS) data, workers’ compensation claims reported to the National Academy of Social Insurance and compensation benefits paid by Liberty Mutual, indicates that overexertion accounts for more than 25 percent of direct workers’ compensation costs paid out annually.

2. Slips – Slipping accidents are the second leading cause of workers’ compensation claims and the top cause of workplace injuries for workers 55 and older, as reported by the National Flooring Safety Institute. In a hard fall, a worker may sustain injuries to the knee or ankle, wrist or elbow, back or shoulder, hip or head. Employers need safety guidelines to ensure spills are promptly cleaned and no debris is present which can be dangerous.

3. Falling – In 2013, 595 workers died in elevated falls, and 47,120 were injured badly enough to require days off of work. A worker doesn’t have to fall from a high level to suffer fatal injuries. While half of all fatal falls in 2016 occurred from 20 feet or lower, 11% were from less than 6 feet. Not surprisingly, construction workers are most at risk for fatal falls from height – more than seven times the rate of other industries. These types of accidents can be reduced by the use of proper personal protection gear, training and employee diligence.

4. Bodily Reaction– Coming in at number four are reaction injuries caused by slipping and tripping without falling, often leading to muscle injuries, body trauma, and a variety of other medical issues. Although these injuries may sound non-serious, insurance companies paid out $3.89 billion in workers’ compensation in 2016 for bodily reaction incidences (Liberty Mutual Insurance).

5. Falling Object Injuries – There are more than 50,000 “struck by falling object” injuries every year in the United States, says the Bureau of Labor Statistics. That’s one injury caused by a dropped object every 10 minutes. How serious is the danger? Consider this: an eight-pound wrench dropped 200 feet would hit with a force of 2,833 pounds per square inch – the equivalent of a small car hitting a one-square-inch area. Proper personal protection gear usage, such as a hard hat, can be instrumental in keeping the employee safe.

6. Distracted Walking Injuries – They may seem funny in slapstick comedies, but distracted walking injuries in the workplace were recently labeled a “significant safety threat” by the National Safety Council. These injuries occur when a person accidentally runs into walls, doors, cabinets, glass windows, tables, chairs or other people. Head, knee, neck, and foot injuries are common results. As with distracted driving accidents, it is difficult to track the number of occupational injuries caused by distracted walking, since workers might be reluctant to admit they were looking down at their cell phones when they were injured.

7. Vehicle Accidents – Accidents are common in workplace environments using cranes, trailers and trucks. According to the Bureau of Labor Statistics more than 1,700 deaths a year result from occupational transportation incidents. Employee Safe Driver training courses are likely to reduce vehicle accidents that may injure employees. Managers are required to conduct routine vehicle maintenance to ensure vehicles are operating safely and properly.

8. Machinery Accidents – Machines used in the workplace are often operated without safety guards and devices, exposing their operators and others to serious injury. Common injuries involve clothing or hair becoming caught in moving parts. Many of the amputations that occur on machinery can be prevented by updating machines with appropriate safeguarding. Electrical updates for magnetic motor-starters, main power disconnects, and emergency-stops, also help to prevent injury. OSHA regulations and ANSI safety standards spell out safety modifications that can prevent needless accidents. Learn more about how Rockford Systems, a leader in machine safeguarding, will help you create a safer workplace with their extensive line of innovative safeguarding solutions.

9. Repetitive Motion Injuries – Thousands of employees suffer from injuries that occur gradually and make it difficult to do daily tasks, such as typing, twisting wires, using hand tools, or bending over to lift objects. These are called repetitive motion injuries and strain muscles and tendons. Over time it will lead to back pain, lumbar injuries, tendonitis, bursitis, vision problems, or carpal tunnel syndrome. Repetitive motion injuries may be temporary or permanent. Employee training and the use of proper ergonomic tools can help keep these incidents low.

10. Workplace Violence – According to OSHA, workplace violence is any act or threat of physical violence, harassment, intimidation, or other threatening disruptive behavior that occurs at the work site. It ranges from threats and verbal abuse to physical assaults and even homicide. Nearly 2 million American workers report having been victims of workplace violence each year. Unfortunately, many more cases go unreported. Workplace violence employee training and employee diligence in watching out for suspicious activities can help keep these incidents at bay. One of the best protections employers can offer their workers is to establish a zero-tolerance policy toward workplace violence.

Workplace injuries can leave the lives of employees and their families shattered. Employers have legal obligations to ensure a safe workplace for their employees – and also for anyone else who may visit the workplace such as customers, contractors and members of the public.

Work Safety Topics

Did you know that June is National Safety Month? Rockford Systems has partnered with the National Safety Council to promote safety to our valued customers!

Nearly 13,000 American workers are injured each day, and each injury is preventable. Here are some of the safety topics NSC is focusing on.

Fatigue
Adults need seven to nine hours of sleep each day to reach peak performance, but nearly one-third report averaging less than six hours. The effects of fatigue are far-reaching and can have an adverse impact in all areas of our lives.
· Safety performance decreases as employees become tired
· You are three times more likely to be in a car crash if you are fatigued
· Chronic sleep-deprivation causes depression, obesity, cardiovascular disease and other illnesses

Drugs at Work
Drug use at work is a safety topic that is gaining attention. Lost time, job turnover, re-training and healthcare costs are three of the primary implications of drug use regularly confronted by employers. The typical worker with a substance use disorder misses about two work weeks (10.5 days) for illness, injury or reasons other than vacations and holidays.
· Workers with substance use disorders miss 50% more days than their peers, averaging 14.8 days a year
· Workers with pain medication use disorders miss nearly three times as many days – 29 days
· Workers in recovery who report receiving substance use treatment miss the fewest days of any group – 9.5

Driving
Many employers have adopted safe driving policies that include bans on cell phone while driving and on the job. NSC has created a Safe Driving Kit with materials to build leadership support for a cell phone policy and tools to communicate with employees.

Workplace Violence
Every year, 2 million American workers report having been victims of workplace violence. This violence fits into four categories: criminal intent, customer/client, worker-on-worker and personal relationship (most involving women).
The deadliest situations involve an active shooter.

Every organization needs to address workplace violence through policy, training and the development of emergency action plans. While there is no way to predict an attack, you can be aware of warning signals that might signal future violence.

Slips, Trips and Falls
You might be surprised to learn that falls account for the third-highest total unintentional deaths every year in the United States. Fatalities as a result of falls are surpassed only by poisoning (including deaths from drugs and medicines) and motor vehicle crashes.

Fall safety should be a top priority. Construction workers are at the most risk for fatal falls from height, but falls can happen anywhere, and it is important to recognize potential hazards, both on the job and off. Plan ahead and use the right equipment.

Ergonomics and Overexertion
Overexertion causes 35% of all work-related injuries and is the No. 1 reason for lost work days. Regular exercise, stretching and strength training can prevent injury. Likewise, ergonomic assessments can ward off ergonomics injuries, often caused by excessive lifting, lowering, pushing, pulling, reaching or stretching.

Struck by Objects
While employers are responsible for providing a safe work environment, employees can take steps to protect themselves at work. Paying attention is vitally important for those operating machinery as well as those working around power tools and motor vehicles.

Source: National Safety Council