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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Calculating a Safeguarding ROI

In the United States, workers operating or maintaining industrial machinery suffer more than 18,000 amputations, crushed fingers and other traumatic injuries each year. While these injuries vary greatly, the majority of cases do have one thing in common: the injury was largely preventable if machine safeguarding equipment had been in-place, or would have been far less severe.

Many employees, unions and worker advocates may well ask, “Why do we need a safeguarding business case?” “Don’t employers have a responsibility for providing a safe and healthful workplace for their employees?” Although U.S. organizations understand that machine safeguarding is the law and that protecting human life is socially responsible, each company must answer the return on investment (ROI) question their own way. Where does safeguarding fit into a business strategy? Can safeguarding be quantified by using cost-benefit financial analysis? To get to those answers we need to look at both sides of the ledger, comparing the cost of an accident versus the cost of preventing it.

WHAT DOES A MACHINE ACCIDENT COST?
Insurance studies indicate machine safeguarding provides an opportunity for businesses to reduce bottom-line operating costs by eliminating both the direct and indirect costs of an accident, while improving productivity and employee morale. But just how much can be saved? Liberty Mutual reported in its annual Workplace Safety Index that U.S. employers spent $48.6 billion for wage and productivity losses, medical expenses and administrative expenses for workers hurt on the job. This is roughly equivalent to the annual sales of Cisco, Pfizer or FedEx. A study by Colorado State University set the total direct and indirect cost of workplace injuries at a staggering $128 billion.

Safeguarded Press

Direct costs of an accident refer to out-of-pocket expenses like hospital and medical bills. They 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. Costs continue to cascade throughout the company with overtime required to make up the lost productivity and new workers who need to be hired and trained. The National Safety Council (NSC) estimates that lost time alone associated with the average injury costs nearly $30,000.

However, costs related to an injury do not end there, as an accident will influence indirect costs far outside company walls. Analysis of most accidents reveal that the actual total cost can range from four to ten times the visible, direct cost stated by an insurance company. For example, a single accident can result in OSHA fines up to $100,000 per machine or more if the violation is found to be willful. In 2010, 24 percent of OSHA’s Top 10 citations for manufacturing dealt with machine guarding violations, resulting in more than $6 million in proposed penalties. In addition, insurance rates can rise dramatically or coverage can be dropped entirely. Investments targeted for company growth may need to be diverted to cover the costs of the accident, while employee morale and productivity can experience a significant drop, and the company’s brand and reputation will likely be damaged by negative publicity. Finally, there are the legal fees, plus management time spent dealing with regulators and attorneys.

Safeguarded Mill Drill
And while it is not calculated as an indirect cost, a poor safety record can make the difference between a company winning and losing bids, especially with government contracts. A plant with a singularly bad reputation for safety may also find itself unable to attract workers at all or may have to pay wages well above market value to do so. Also, if the machine where a serious accident occurred is unique and 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.

DO THE MATH
OSHA’s $afety Pays website (www.osha.gov/dcsp/smallbusiness/safetypays) makes it easy for organizations to calculate direct and indirect costs of an accident. As an example, let’s assume a fictional company with annual sales of $5 million and an 8% pre-tax profit margin has an accident involving an employee whereby his hand was entangled in a drill press.

By using insurance company claims data, $afety Pays can calculate that the crushing accident will cost that company, on average:
• Direct Cost: $56,557
• Indirect Cost: $62,212
• Estimated Total Cost: $118,769

Safeguarded Lathe
By entering profit margin information, $afety Pays will also project the additional sales required to recover the costs of the injury. In this instance, additional sales revenue necessary to cover costs is $1,484,612 based on the 8% profit margin or approximately one third of annual sales. If pre-tax margins are less, the sales impact is even greater.
On the other side of the ledger is the cost to safeguard the machine involved in the accident. For the purpose of this discussion, let’s assume that the same fictional company had an onsite risk assessment performed by a reputable firm that surveyed ten machines on the plant floor at a cost of $5,000, or $500 per machine. Next, assume that the drill press had been safeguarded per OSHA regulations and ANSI standards at a total cost of $1,000. Adding in its prorated share of the risk assessment, total cost to safeguard the drill press would be $1,500, a figure that compares very favorably to the estimated $118,769 cost of the accident.

HUMAN CAPITAL AS ROI
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. And 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 positive return on their safety investment, more than half the machines in the United States 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 should 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.

CONCLUSION
Whether driven by the law or social responsibility or the need for a positive ROI, most organizations embark on a quest to make their workplaces safe. The business case for machine safeguarding is solid. By comparing the installation cost of safeguarding over the productive life of a machine versus the direct and indirect costs of even a single accident, it becomes clear that safeguarding makes sound business sense and should be a cornerstone of an organization’s safety goals and objectives.