Page 28 - Occupational Health & Safety, February 2017

MACHINE GUARDING
furnished with a compliant emergency stop button (OSHA 1910.212, ANSI B11.8 and NFPA 79), and not furnished with a plug lockout device (OSHA 1910.47). Any one of these violations would render the ma- chine unsafe to operate new out of the box and subject to OSHA citations and mods.
For both new and old machines, a ma- chine survey will identify OSHA machine guarding violations, along with recom- mended products and services to bring those machines into full compliance. In the case of the mill drill, a combination discon- nect/starter device with remote operator station, an electrically interlocked shield, and a lockout plug were added to bring the machine into compliance, and all motors tied into the machine’s main emergency stop circuit. In the case of the drill stand, a motor starter device with emergency-stop button, an electrically interlocked shield, and a lockout plug were added to bring the machine into compliance.
To underscore the dangers of non-com- pliant new machines, we displayed both the drill press and mill drill at the FABTECH 2016 trade show in Las Vegas. The major- ity of FABTECH attendees were unaware of the violations, even those who had exten- sive backgrounds in machine tools.
Myth Two: Older machines are “grand- fathered in” because they were manufac- tured before safety standards and regula- tions existed.
Reality: Up until the late 1970s, OSHA did have a small number of grandfather clauses in its regulations, but these have long since expired. In order to be in compli- ance today, machines must meet minimum OSHA regulations. For companies want- ing to meet a higher safety benchmark, ANSI B11 Safety Standards (series of 24) offer the best available guidelines for metal processing machines. These standards are updated on a regular basis, typically every five years. For example, the ANSI standard for “sweeps,” which specifies the maximum amount of space allowed between the floor and the bottom of a perimeter guard, only recently was set at 12 inches. However, a rash of serious injuries prompted a change, reducing the allowed 12 inches to 6 inches.
Myth Three: OSHA regulations only act as safety guidelines for manufacturers and are not the law.
Reality: Under the Occupational Safety & Health Act of 1970 (OSH) all employ-
On-site risk assessments and machine surveys are the critical first step in proper machine safeguarding; they help to identify the tasks and associated hazards on a machine shop’s equipment.
24 Occupational Health & Safety | FEBRUARY 2017
www.ohsonline.com
ers are responsible for providing a safe, healthful workplace. Employers must comply with applicable OSHA standards and the General Duty Clause of the OSH Act, which requires employers to keep the workplace free of serious recognized haz- ards. By law, employers are legally required to follow OSHA regulations, meaning that an OSHA inspector will issue citations for compliance to the Code of Federal Regula- tions. Specifically, OSHA 1910.212 General Requirements for Machines states the op- erator and others in the machine area must be protected from exposure to hazards.
Once a manufacturer is cited for a vio- lation, whether for new machinery or old, the best place to turn for advice is ANSI B11 series consensus standards that iden- tify accepted options for safeguarding ma- chinery. The series consists of nearly three dozen different documents that deal with machine safety and specify requirements for both the manufacturers and users of the machines. The majority of the ANSI B11 standards are machine-specific, offer- ing “best safety practices” for one category of equipment only. One standard, however, ANSI B11.19-2010, entitled Performance Criteria for Safeguarding, serves as an “um- brella standard” for all machines in the B11 series. Its primary objective is to establish
requirements for the design, construction, installation, operation, and maintenance of safeguarding.
OSHA’s machine guarding regulations have not changed since 1975 and therefore lack what employers need to know about current machine safety options. OSHA regulations have always been considered as a starting point only.
Machine Risk Assessments and Surveys Are Critical
On-site risk assessments and machine surveys are the critical first step in proper machine safeguarding; they help to iden- tify the tasks and associated hazards on a machine shop’s equipment. In a risk as- sessment, each machine receives a hazard score indicating the risk level using the ANSI B11.0-2015 safety standard methods. As part of the machine risk assessment, we provide suggestions to lower the hazard level and detailed documentation that will outline the results. In a machine survey, each machine is audited for compliance to current safety standards and customized proposals outline the specific products, services, and integrated design engineering solutions that are required to bring the ma- chines into full compliance.
Take the recent example of a major