Page 30 - Occupational Health & Safety, February 2017

MACHINE GUARDING
Finding the Right Machine Safety Partner for Your Company
Here’s what EHS pros need to know about machine safeguarding.
BY JOHN PEABODY
As a safety professional, you work every day to ensure employees are safe and produc- tive. You provide the appropriate training, reinforce basic safety concepts, and provide necessary PPE. You are familiar with the requirements for confined space restrictions, forklift protocols, and even have taken classes to ensure that workplace vio- lence is prevented.
Then production calls you and says that the new safeguarding on a machine is preventing them from making quota. The wheels come off.
You’re not alone. EHS professionals are well schooled in virtually every aspect of health and safety except for the details of machine guarding. After all, the machine guarding section of OSHA is a tiny fraction of OSHA’s hundreds of rules. Nonetheless, year after year, two of the top 10 most-cited OSHA regulations are machine guarding related (Section 1910.212, the general machine guarding clause, and section 1910.147, lockout/tagout). Why is this crucial area of industrial safety so difficult to master?
OSHA addresses specific machine guarding for only a handful of machine types, those in most common usage in the 1960s. Nowhere in OSHA is there a reference to industrial robots or water-jet cutting machines. So the question is how today’s EHS professional can ensure machinery is guarded in compliance with current standards, while simultaneously allowing workers to run the machines productively.
The key is expertise. More perhaps than in any other discipline, the use of experts is necessary because OSHA requirements do not clearly address the machines in today’s facilities. The general machine guarding clause is simple. It states: “One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards.” Nothing to it. The challenge is how to protect the operator from machine hazards while still allowing him to be productive. How do you find the right solution for your machine safety needs when machine safeguarding is most likely not a core competency of your staff?
There are basically two parts to machine guarding. First is the hazard identification process, most commonly called a risk or machine guarding assessment. Second, and possibly the more important, is the Risk Reduction evaluation. The Risk Reduction part considers: How will the risk be mitigated, and what methods of guarding will be most appropriate for your machines?
26 Occupational Health & Safety | FEBRUARY 2017
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Evaluating Your Machine Safeguarding Services Vendor (Partner)
Questions and considerations for finding the right machine safety partner for your company follow:
1. What level of experience does the company have and specifically the person(s) who will do your risk assessment and possibly remediation? Are they familiar with the machines and processes that you have? Do they know and understand the applicable regulations and standards involved, such as OSHA, ANSI, or ISO?
2. Do they use a repeatable and recognized process? What standard does the process adhere to? It is best to use a standard like ANSI B11.0-2015 and not to reinvent the wheel. The assessment process in the most current version of ANSI B11.0 states the following steps:
a) Prepare for and set limits of the assessment (which machines to be assessed, who will be on the as- sessment team, how to document, what are the scope and limits for this assessment, how to score risk, how to prioritize, what is the acceptable risk level, etc.).
b) Identify tasks and hazards. (Define the tasks involved. Many machines that are identical can be used in different ways. Your specific uses are critical information. Machine operators and maintenance personnel should be involved with this process.)
c) Assess initial risk. (Use a repeatable and reliable scoring system to score risk for each identified hazard.)
d) Reduce risk. (Use the Hazard Control Hierarchy and apply risk reduction guarding concepts to reduce risk. It is very important to have operators, maintenance, and production personnel involved in the review and buy-in of the risk reduction guarding concept before it is actually installed.)
e) Assess residual risk level. (With the agreed- upon risk reduction concept in mind, determine whether acceptable risk has been achieved.)
f) Has acceptable (tolerable) risk been achieved? (If yes, implement the risk reduction measures and continue in the next step. If no, re-evaluate risk reduction measures and work to reduce risk.)
■ This issue of tolerable risk deserves significant reflection within your organization. Some companies define tolerable based on lost work day accidents, oth- ers rely on the guidance of their insurers, but with- out a clear understanding of what is tolerable to your company, there is no end to the risk reduction process. What is tolerable to one is not necessarily tolerable to another. It behooves you to ensure that your defini- tion of tolerable risk is clearly defined and understood