Page 20 - OHS, March 2022

MACHINE GUARDING
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BY JOSEPH GASPARINO & STEVE MISURACA
Machine guarding is in the OSHA Top 10 Most Frequently Cited Violations each year. Perhaps your organization had a significant machine injury, maybe you have machine guarding risk concerns at
your site(s), or you simply feel your organization’s culture needs to move towards engineered solutions on the Hierarchy of Controls. Where do you start? We have compiled machine guarding best practices into three categories: Data Gathering, Assessments and Solutions.
Data Gathering
Data gathering is important as it sets the tone for the entire machine guarding assessment process. Most organizations defer to their Computerized Maintenance Management System (CMMS) for a detailed machine asset list. A CMMS is a software package that maintains a computer database of information about an organization’s maintenance assets, including a detailed machinery list. It is recommended to do a validity check and make sure that all obsolete equipment is removed, and newer equipment is on the list. It would also be recommended that the list includes the asset name, asset number, description and location as these would assist in work scope execution.
For those that are managing multiple sites, there will be additional steps to the process. Locations could vary in size and not have a CMMS system; in which, you may need to defer to the accounting asset list. For each location, it is recommended that the location name, location point of contact (as well as their contact information), city, state, country, number of buildings, number of assets and approximate square footage of the facility be noted.
Now that the data is gathered, you should determine the expected work scope and output of this initiative. Do you need a risk assessment? Would you like a guarding inventory? Will the assessment be per OSHA or ANSI standard? Do you want to capture best practices during the process? Once these considerations are clear, you will need to determine if this is an internal initiative or if external support is required.
To determine if this can be executed with internal labor, it would be important to calculate the expected workload in hours. Based on our experience, you can assess approximately 25 machines per day in a manual assessment process, which will then take approximately 10 days to organize notes and images into a usable standardized reporting format.
Internal Labor Calculation (ILC): Estimated Working Days = (Total number of machines/25) + (Total number of machines/25 x 10).
Example for a location with 450 machines: (450/25) + (450/25 x 10) = 198 working days.
With 200 working days in a year, this would be a full-time job. This is perhaps the biggest mistake we see when undergoing these initiatives internally. The amount of assessment time is
underestimated and when distractions occur, details are missed and/or it becomes a lost initiative. At this point, you may want to consider outside services.
There are machine guarding assessment companies that have developed internal software to increase the number of machines inspected and eliminate the data documentation time. Thus, comparing it to a manual process, it will significantly reduce time to implementation and your overall project costs.
With these thoughts in mind, it is now time to establish the team. Establishing duties and responsibilities for the site point of contacts and support team is recommended. This team should be brought in to discuss and develop the startup processes and project timeline. To develop an impactful team, the members equipment experience and knowledge of the machine guarding standards are important. Team alignment on how risk will be assigned to each machine component must be standardized.
We see many organizations start the assessment process but never get to the solutions. Mostly because they overlook the estimated costs of this endeavor. What is this initiative going to cost? For a general rule of thumb, we recommend using $2,500 per day of assessment labor and per machine solution.
Machine Guarding Improvement Budget (MGIB): MGIB = (number of assessment days x $2,500) + (number of machines x $2,500).
Using the example from earlier of 450 machines at a rate of 25 assessments per day: (450/25) x $2,500) + (450 x $2,500) = $1,170,000.
Why is this important to know up front? Because too many organizations start this initiative and don’t anticipate the total costs. Thus, we recommend performing a quantitative risk assessment with the machine guarding assessment. During this assessment we also recommend coming up with estimated budgetary solutions. Your leadership’s primary language is typically data and financially driven. Understanding financial diminishing returns is necessary to successfully present and obtain budget approval.
Assessments
Once the data gathering is complete, you can begin the machine
16 Occupational Health & Safety | MARCH 2022
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