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.

Safeguarding press brakes without sacrificing productivity

Technology advances can keep the operator safe and the press brake running

Even though the U.S. has some very strict machine guarding regulations, the U.S. Department of Labor reports that press brake operators in this country suffer more than 350 amputations per year—and these are only the reported injuries. The question is why?

For one, by their design, press brakes are very dangerous machines, much more so without proper safeguarding equipment. Injuries result because of unguarded access to the point of operation at the front of the machine and the operator’s ability to reach around the safety device to get to the point of operation at the side or back of the machine. Also, the back-gauge system creates pinch points and poses a risk to the operator with its hazardous motion. Although rare, operators also can experience blunt force trauma after being struck by ejected materials.

But perhaps the greatest threat linked to running press brakes is having the operator’s hand trapped between the part being bent and the frame of the machine (see Figure 1). If the force is great enough or the part is sharp enough, impalement or an amputation can occur.

Another factor contributing to the dangers of press brakes is the metal fabricator’s failure to perform an upfront risk assessment. This type of assessment is the critical first step in any safeguarding project and, unfortunately, seldom completed. An overall risk assessment considers hazard severity, frequency of exposure, and probability of injury, as suggested by ANSI B11.0-2015. Risk or machine safeguarding assessments should be done before commissioning any new machinery, after upgrading existing machinery, after changing the work area, and after any accident or serious incident.

Yet another dynamic contributing to press brake injuries is lack of press brake maintenance, in particular testing safety devices to ensure they are working properly and in the correct position. An unmaintained press brake, especially one with damaged tooling, can put both the machine and operator at risk for serious injury.

All of these issues can be addressed in a few moments. It is time well spent to ensure that the machine is safe to operate. Having said that, not all shops will commit to that type of preparedness and maintenance. So it’s not a question of if an operator will get hurt by a press brake; it’s a question of when.

What Are the Safety Standards?
The Occupational Safety and Health Administration (OSHA) does not specifically address mechanical or hydraulic press brakes, but the machines are commonly cited under the general duty clause 1910.212, which covers failure to provide adequate protection for plant employees from known machine hazards. Most commonly, the industry follows the ANSI standard for press brakes, ANSI B11.3, for safeguarding method guidance and then ANSI B11.19 for design criteria.

The original B11.3 standard was approved in 1973 and revised in 1982 and again in 2002. The current 2012 standard, ANSI B11.2-2012, includes the new topics of close proximity point of operation, active opto-electronic protective devices (AOPD), and a safeguarding means called safe speed.

Safe speed is protection for the operator when safeguarding is not provided by a light curtain, such as after the optical system is muted for the bending operation to occur. Safe speed must be monitored automatically, so the press brake ram does not exceed 10 mm/s and for the machine closing movement to be stopped if this limit is exceeded. To insert these new safe speed requirements into B11.3, the committee drew on experience with this requirement in Europe and its corresponding EN 12622 standard.

Does Safeguarding Hinder Productivity?
A widespread misconception in the industry is that safeguarding a press brake prevents or hinders employees from making production quotas. However, an Aberdeen Group research study (“Integrated Safety Systems: Ensuring Safety and Operational Productivity”) concluded that companies that have taken steps to invest in safeguarding not only improve plant safety, but realize superior operational performance and overall equipment effectiveness (OEE). The 20 percent of best-in-class companies that had the highest OEE also had the lowest safety incident rate. The top companies typically had an OEE on average of 90 percent and an injury incident rate of 0.05 percent, while the bottom 20 percent of companies had an OEE of 76 percent and an injury frequency rate of 3 percent, which is 60 times higher. Top manufacturers were also able to achieve a 2 percent unscheduled asset downtime rate, versus a 14 percent rate for the laggard group in the study.

Figure 1
When it comes to older bending machinery, nothing really acts as a barrier between the press brake and the machine’s operator.

What makes these statistics possible is modern safeguarding tools. Some of these options are awareness and barrier guards, light curtains, two-hand controls, and laser AOPD.

First, however, a word or two about retrofitting. When retrofitting older machines, installers must take great caution to ensure that the new technology does not decrease the safety of the machine or add new hazards. Sometimes an older machine simply cannot be brought up to today’s standards. At that point the installer must evaluate the situation and ensure the full machine installation becomes safer overall than its original state with the new safeguarding. If not, he needs to step back and consider the options. ANSI B11.3-2012 gives direction on this topic.

Awareness Barrier. The backs of press brakes cannot be left wide open. Two hazards often lurk here: reaching the dies from the back and the possibility of a multi-axis back gauge moving and creating pinch points. As to exactly what is required on the back of equipment often depends on local OSHA interpretation. At the very least, an awareness barrier, like a railing, chain, or cable with a “danger” or “warning” sign complete with pictographs, not just verbiage, should be installed. Awareness barriers are bare-minimum methods in reducing risk.

Barrier Guards. Although not versatile, barrier guards on the ends of most press brakes are effective when used in conjunction with other safeguarding devices (see Figure 2). They also can be used to mount/support light curtains, adding to their value. Barriers can have openings for material to be fed into the die area, but do not allow for hands into that area.

Barrier guards reduce the risk of the operator getting his hands pinched when he reaches between the punch and die from either side of the press brake or reaches between the back-gauge system and tool. By OSHA’s definition, a guard must prevent people from reaching over, under, through, or around it. Guards must meet one of two measurement scales—the OSHA guard opening scale or the ANSI/CSA guard opening scale—to ensure that a small hand can’t reach far enough through any opening to get hurt.

Barrier guards can be fixed or interlocked. The interlocked design prevents misuse and is required to be either electrically interlocked or fixed in place using a fastener that requires a tool for removal. They’re often hinged or sliding to allow easy access to the point of operation for machine setup (access to limit switches or other levers and dials), tool change, or maintenance tasks.

Light Curtains. These safeguarding tools have been around since the mid-1950s. They consist of a vertically mounted transmitter and receiver with closely spaced beams of laser creating a flat sensing field. When fingers, hands, or arms reach through that sensing field, the press cycle is prevented or stopped to avoid operator injury.

One of the reasons that press brakes make a good application for light curtains is that they can be stopped midcycle very quickly. Hydraulic press brakes stop quickly if maintained properly. Mechanical press brakes may not. Air clutch machines have reasonable stop times, but mechanical friction clutch (MFC) machines are known for stopping very slowly. Quite often light curtains can’t be used on MFC press brakes because the safety distance can end up being 2 to 3 feet.

Like any safeguarding device, light curtains should be “function-tested” before every operating shift to ensure that they are continuing to provide protection. Make/model-specific function-test procedures are usually available on each light curtain manufacturer’s website.

Two-Hand Controls. These controls are considered a safer means of cycling a press than a footswitch because both hands must be in a safe position to use them. When a press is cycled with a footswitch, hands can be anywhere. It’s possible to use a two-hand control as a safeguarding device as well during press brake operation.

Figure 2
The barriers on the side of this press brake have light curtains attached to them, providing the press brake operator with two layers of protection.

Most operations require that the part be held when bending, so two-hand control is rarely used to cycle a press brake or used as the point-of-operation safeguard. The part would have to be fixtured and supported by a backgauge to use a two-hand control.

Laser AOPD. The newest entry into the press brake safety category is the laser AOPD (see Figure 3). Inclusion of laser AOPD technology in the B11.3-2012 is a welcome addition to the standard that now gives press brake manufacturers, dealers, and users a clear guideline to implementing this technology safely for retrofit applications (B11.3 subclause 8.8.7 —Close Proximity Point of Operation AOPD Safeguarding Device).

It is important to note here that AOPDs are an acceptable method of safeguarding hydraulic press brakes only per ANSI B11.3 and also following most manufacturers’ specifications.

A unique feature of AOPDs is that they are designed to be mounted with zero safety distance, unlike light curtains that must be mounted at a calculated safety distance (see Figure 4), as outlined in ANSI B11.3. Safe speed safeguarding is based on a ram speed of 10 mm/s or less, providing that speed is carefully monitored. Again, this new method of protection can be applied only to hydraulic press brakes (and potentially servo-drive press brakes). Because of their close proximity point of operation, AOPD systems are best-suited for applications such as box bending, bending with flanges, or where light curtain effectiveness is diminished due to excessive blanking or muting.

Press brakes are very dangerous machines, much more so without proper safeguarding equipment. When safeguarding equipment is engineered, installed, and operated correctly, it provides positive, business-enhancing benefits while mitigating risks and reducing insurance and energy costs. Metal fabricators also should recognize the payback of reducing costs associated with accidents, medical expenses, and regulatory noncompliance.

For more information about safeguarding press brakes, please contact us at 1-800-922-7533.

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

SAFETY IN NUMBERS: Stop Time Measurements

Stop-Time Measurements Keep Safeguarding Equipment in Peak Performance

We’ve all heard the phrase “what a difference a day makes,” yet when it comes to industrial safeguarding, the concern isn’t days, hours or even minutes. It is the milliseconds it takes for a machine operation to stop. That fraction of a second can make the difference between a life-changing injury or a safe machine cycle, the difference between a valued employee going home or being taken to the emergency room.

How can we assure the right outcome? How do we determine if a machine will stop in time?

The answer is specialized equipment called “Stop-Time Measurement” devices (STM). An STM is used to determine the total response time from the triggering of a machine’s operating control or a safeguarding device… to the exact moment when a dangerous movement comes to a halt. Take, for example, the time it takes for a press brake cycle to stop when a finger or hand enters the point-of-operation zone, or the time between when a light curtain is activated and when the machine comes to a complete standstill.

Once the stop-time data is captured by an STM in either milliseconds or inches, it is applied to an established formula to calculate the minimum safety distance required to install safety devices. A record of the measurement can be printed out, or alternatively, the device can be plugged into a PC where the measurements can be recorded and documented.

Doing the Math
According to OSHA, the majority of machine-related accidents happen as a result of a reflex action or when the operator is not paying attention. For example, a machine operator may instinctively reach into the machine when there is an issue. Or they will be so focused on a task that they’ll cross the threshold into a hazardous area without being aware of it. In these events, it is critical that a machine’s safety devices stop operations before the hazard is reached. In addition, accidents may not be the fault of the operator at all. There are instances where integrators do not program the field of coverage — the area being monitored by the light curtain, for instance — at the proper safety distance and puts the operator unknowingly at danger.

So what is the correct distance? The basic calculation for ‘safety distance’ comprises approach speed, overall stop time and penetration depth factor.

The standard formula is below:
DS = K (T) + DPF
where:
DS = the safety distance
K = the maximum speed that an individual can approach the hazard
T = the total time to stop the hazardous motion
DPF = the depth penetration factor of the safeguarding device

There are other variations on this calculation; for example, where a light curtain is in operation, the calculation requires both the resolution and the response time of the light curtain to be factored. Most STM devices perform calculations internally so the operator doesn’t need to concern themselves with all the details of the math, only the results to act upon.

In the United States there are two formulas that are used to properly calculate the safety distance. The first, the OSHA formula, is the minimum requirement for the calculation of the safety distance. The second is the ANSI formula, which incorporates additional factors to be considered when calculating the safety distance. Rockford Systems recommends the use of the ANSI system since it is the more comprehensive of the two. The formula is included in ANSI standards B11.19-2010 and Robotic Industries Association (RIA) R15.06-1999 (R2009), as well as CSA Z142-10, Z432-04 and Z434-03.

Stop-Time Measurement Service
For all linear and rotating motion equipment, Rockford Systems offers STM service for newly installed safety devices as well as for the periodic validation of existing safety devices. Periodic safety distance validation with an STM is required for AOPD systems, light curtains, 2-hand control systems, emergency stop devices, pressure-sensitive protective strips or mats, interlocking guards, doors and gates, as well as other safety devices and controls equipment used during production. This is necessary since factors like maintenance, brake wear, and alterations can increase the machine’s stopping time. If a machine stops slower than it did when it was originally commissioned then components will need to be adjusted to continue providing the correct level of safety. Stop time measurement is able to detect changes at an early stage, so that appropriate action can then be taken. For these and other reasons it is important to perform at least an annual stop time analysis. Rockford Systems STM services are mainly employed on reciprocating (stroking or cycling) machines, such as mechanical or hydraulic presses and press brakes, but can also be used on machines that rotate, such as lathes, mills, and drills.

Location of a safety component, whether hard guarding or electronic, is based upon the machine’s stopping time. Simply stated, a safety component should be placed far enough away from the risk area that it is not possible to reach the hazard before the machine has stopped. Safety devices are then installed using the minimum safe distance. Reference our OSHA Safety Distance Guide Slide Chart.

Regularly checking shop machinery with Stop-Time Measurements and maintaining a log of the results empowers a company to be proactive in establishing a safety maintenance program. It ensures that safeguarding equipment on machinery works as designed to achieve greater worker safety, productivity and profits.

Press Brake Safeguarding To Prevent Injuries

Including In-Depth Analysis of Light Curtains vs. Laser AOPD

Press brakes are unforgiving machines and a common source of workplace amputations of hands, fingers and arms. United States Department of Labor statistics indicate an average of 368 instances of amputations annually from press brake accidents. And these are only the reported accidents.

WHY ARE PRESS BRAKES SO DANGEROUS?
The primary reasons are access to the point of operation at the front of the machine, as well as reaching around the safety device to get to the point of operation at the ends of the machine. In addition, there are pinch points and hazardous motion created by the back-gauge system.

But the dangers don’t stop there. However well intentioned, fabricators often employ lower cost, used or refurbished press brakes where the primary controls and/or condition of the machine and safety system may be suspect. Plus, original equipment manufacturers (OEM’s) generally consider the point of operation aspect of the press brake safety system to be the end-user’s responsibility. The end-user may assure, incorrectly, that the machinery arrived into the shop ready for commissioning. Lastly, press brakes have always been operator intensive, sometimes involving multiple operators, and operator behavior is not always predictable. That is why it is good practice to make one operator the leader of the crew.

OSHA/ANSI SAFETY REGULATIONS
OSHA’s machinery and machine guarding regulations (29 CFR 1910 Subpart O) require one or more guarding methods to protect employees from exposure to hazardous machine energy during the operation of press brakes. There isn’t a great deal of detail to the OSHA regulations so fabricators in search of answers would be better served by turning to ANSI B11.3-2012 which covers safeguarding of power press brakes. The B11.3 adopted EN 12622 (European standard), giving it even more specific instructions to follow and minimizing any vague, grey areas.

ANSI B11.3 is the only safety system standard specifically applicable to power press brakes used in America, and it excludes mechanical power presses; hydraulic power presses, hand brakes; tangent benders; apron brakes; and other similar types of metal bending machines. It discusses hazards associated with the point of operation at length and identifies alternative guards and devices. For example, the ‘close proximity point of operation AOPD’ safeguarding devices, which we will discuss later in this blog, and a means of safeguarding referred to as ‘Safe Speed.’ We should note that ANSI B11.0-2015 recommends risk assessments of press brakes among other equipment, offered by Rockford Systems.

PRESS BRAKE PROTECTION OPTIONS
Today, there several ways to safeguard a press brake, some better than others. All have advantages and drawbacks.

The most basic type of safeguarding is a fixed and interlocked barrier guard coupled with two-hand controls. This is not a functional solution for fabricators as a work piece is hand held in close proximity to the point of operation during the braking process and can potentially whip up as bending is taking place.

Another approach are pull backs and restraints. Both are restrictive and have limitations and for that reason, operators dislike them. Both devices shackle the operator to a machine and restricts mobility. Yet another approach is the two-hand down/foot-through device. In some cases, this will work. However, this method raises ergonomic issues and it is very slow. Not what you want in a busy, production-driven fabrication shop.

SHEDDING LIGHT ON SAFETY
A modern light curtain is a photoelectric presence-sensing device that protects against access into hazardous points and areas of the press brake. They can range from very compact to larger, more robust and resistant models that can withstand demanding ambient conditions. We should note that a stop-time measurement (STM) device is needed to calculate the safety distance on a regular basis, just as it is needed with two-hand controls.

Safety Light Curtains safeguard personnel using an LED transmitter and receiver. Any interruption of the plane of light by an object equal to/or larger than the “minimum object sensitivity” initiates an output signal. That could be a hand or a finger or a misplaced tool that will either cause the machine to stop or prevent a cycle until the blockage is removed. The operator must be outside the protected area through the entire stroke of the press brake ram. The safety distance between the light curtain and the machine depends on the application, the type of light curtain, and the machine’s stopping performance.

OSHA has a set of regulations for light curtains that are listed here:
1. The machine must be able to stop the movement of the ram anywhere in the stroke.
2. The stopping time of the ram must be known.
3. The stopping time of the ram must be monitored for deviation in stopping time on each stroke.
4. The minimum distance the light curtains can be located to the pinch point must be known.
5. The light curtains must be control reliable.
6. The machine stop circuit with which the light curtains are interfaced, must be control reliable.
7. The light curtains must be self checking for proper operation on each stroke.
8. There should be no easy way to disable the safety system without special tools.
9. If the safety system is disabled there should be a clear indication that it is disabled.
10. The operator and setup person should be properly trained in the operation of the safety system.

LASER FOCUSED ON SAFETY
The newest entry into the press brake safety category is probably its most revolutionary, the Laser Active Optic Protective Device, more commonly referred to as the AOPD. Four manufacturers now make AOPD systems including LazerSafe™ a partner of Rockford Systems. Inclusion of Laser AOPD technology in the B11.3 is a welcome addition to the standard that now gives press brake manufacturers, dealers and users a clear guideline to implementing this technology safely. (B11.3 sub-clause 8.8.7 – Close Proximity Point of Operation AOPD Safeguarding Device)

The biggest advantage of AODP is that operators can hand-hold piece parts up close to the dies, while using a foot-switch to actuate the machine-cycle, which is almost impossible to safely accomplish using a light curtain. Another advantage is for larger piece parts with tall side-legs that would be difficult when using a vertically mounted light curtain for safeguarding. For those familiar with using light curtains, those two situations often require excessive “Channel Blanking” which “yes” allows for production of those parts, but often lets the hands and fingers to reach too close to the dies.

LIGHT CURTAINS or AODP?
Laser AOPD protects the point of hazard whereas light curtain systems restrict operator access to the point of hazard. Operators can hand-hold piece parts up close to the dies with AOPD, while using a foot-switch to actuate the machine-cycle. This is virtually impossible to safely accomplish using a Light Curtain. But that doesn’t make AODP perfect for every application. AOPD systems are well suited for applications such as box bending, bending with flanges, or where light curtain effectiveness is diminished due to excessive blanking or muting.

There are advantages and drawbacks to both systems. And we would stress that it is not an “either-or” situation between light curtains and AODP. The two can be used, and often are, on the same machine. Light curtains provide for die configurations that the AODP won’t handle like compound bends, for instance. This is done to ensure that safeguarding is provided for all die setups. For die setups where neither light curtains or AOPD can offer effective safeguarding, but the part can be fixture in place, that is it does not require hand-support, a two-hand control can be used for safeguarding.

The diagram below sums up the two systems.

The Alternative Universe of Lockout/Tagout

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

Simple, right? Wrong.

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

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

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

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

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

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

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

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

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

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

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.

Most Common Reasons To Upgrade Machine Safeguarding

Hydraulic press with a light curtain and two-hand control device as the point-of-operation safeguard. Also has a hydraulic control with control reliability.
Hydraulic press with a light curtain and two-hand control device as the point-of-operation safeguard. Also has a hydraulic control with control reliability.

People often wonder what motivates companies to make improvements in their machine safeguarding. As a supplier of this equipment, we often find that four things influence these decisions.

First, serious accidents are sometimes the reason. Unfortunately, machine safeguarding may be a back burner issue until something catastrophic occurs.

Second, inspections by insurance companies who write worker’s compensation policies often uncover issues involving unguarded machines. This prompts them to throw a company into the insurance “pool” for high risk accounts resulting in higher premiums.

Third, state or federal OSHA inspections may reveal similar problems with incomplete machine guarding, resulting in fines, along with the costs of abatements/corrections.

Fourth, some larger companies invoke their own machine safeguarding rules that go “above and beyond” OSHA regulations and ANSI safety standards.

In any case, Rockford Systems, LLC offers machine safety surveys where one of our machine safety specialists will visit your plant to conduct a detailed inspection of either specific machines in question, or of all your machines if you wish.

Do I Really Need to Safeguard My Machines?

Unguarded Lathe

Yes, you really do need to safeguard machines in your workplace. But to what extent can be a matter of interpretation based on minimum safety requirements (OSHA regulations), or best safety practices (ANSI standards).

Most employers are familiar with OSHA (Occupational Safety & Health Administration) and the enabled OSH Act of 1970. Under the OSH Act, employers are responsible for providing a safe and healthful workplace. Employers must comply with all applicable OSHA standards. Employers must also comply with the General Duty Clause of the OSH Act, which requires employers to keep their workplace free of serious recognized hazards.

By law, employers are legally required to follow OSHA regulations. That means an OSHA inspector will issue citations for noncompliance to their CFR (Code of Federal Regulations). OSHA’s CFR SubPart O—Machinery and Machine Guarding has six (6) machine specific safeguarding regulations which are:

1910.213 Woodworking Machinery
1910.214 Cooperage Machinery

1910.215 Abrasive Wheel Machinery
1910.216 Mills and Calendars
1910.217 Mechanical Power Presses

1910.218 Forging Machines

safeguarded lathe

OSHA regulations for safeguarding most other machines falls under 1910.212 General Requirements For All Machines which specifies that the operator and others in the machine area be protected from exposure to hazards.

However, ANSI’s B11-Series Safety Standards (which has 24 machine categories) are often used to fill in the details for specific safeguarding and can be used as reference material by OSHA inspectors. Even though ANSI safety standards are voluntary, they could become legally mandatory if an OSHA citation mentions specific ANSI standard for you to comply to.

The bottom line is that all employers should strive to exceed minimum requirements and abide by the best safety practices found in the ANSI B11 standards. The key to employee safety is to observe best safety practices at all times. After all, it could be a matter of life and death!