An ongoing discussion of machine guarding topics, including solutions assessments, regulatory compliance, gap analysis, operating efficiencies and cost savings, as well as all relevant safety standards, such as those from NFPA, ANSI, RIA, IEC, ISO and OSHA. About J.B. Titus.
Is OSHA Rear View Mirror Enforcement?
February 28, 2011
OSHA Assistant Secretary David Michaels addressed the staff of Public Citizen Jan. 18 to commemorate the organization's 40th anniversary. Michaels said,"OSHA is not working to kill jobs; we're here to stop job from killing workers."
On December 30, 1970, President Nixon signed the Occupational Safety and Health Act and on April 28, 1971 the Occupational Safety and Health Administration was born. Many of the original 29CFR regulations for machine safety came about by OSHA’s adoption (in whole or in part) of the existing ANSI B11 Machine Tool standards. History reflects that OSHA’s consistent focus has been on work place safety which is too also say that the “product” being manufactured in the work place was not OSHA’s focus.
I have heard some people say that this focused approach actually allows a manufacturer to build and ship an unsafe machine. I believe we have “other” protections like liability, best practices, and doing what’s right when companies manufacture machines for sale in the U.S. However, does this focus approach by OSHA mean that their enforcement is enacted after the machine is commissioned for production? Is this a “rear view mirror” approach?
In comparison, take Europe for example. OSHA is the law in the U.S. and the Machinery Directive is the law in Europe. The Machinery Directive covers the design, build, test, and safety certification of various categories and types of machines. These standards are driven to the machinery OEM’s and engineering firms. The same standards are also used by the end users who ultimately own and operate the machines. This scenario is somewhat oversimplified, but, you can quickly surmise that enforcement in Europe is directed at the OEM. So, wouldn’t it be appropriate to say that it probably isn’t permissible to build and ship an unsafe machine in Europe?
Isn’t our OSHA approach for machine safety (in comparison to Europe) somewhat analogous to the cow that got out of the barn? In my opinion, given our rear view mirror approach, end users in the U.S. need to be vigilant in their purchase orders to push compliance requirements up stream to the OEM’s and engineering firms.
INTEGRATED SAFETY COULD BE YOUR OPPORTUNITY – CONSIDER IT!
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Contact: www.jbtitus.com for “Solutions for Machine Safety”.
For more than 30 years, J.B. Titus has advised a wide range of clients on machine functional safety solutions, including Johnson + Johnson, Siemens, General Motors, Disney, Rockwell Automation, Bridgestone Firestone, and Samsung Heavy Industries. He holds a Bachelor of Business Administration degree from Oklahoma University in industrial management and an MBA from Case Western Reserve University in marketing and finance. He is a professional member of the American Society of Safety Engineers and is OSHA-certified in machine guarding. Titus is also TUV-certified as a Functional Safety Expert and serves on several American National Standards Institute, National Fire Protection Association, and National Electrical Manufacturers Association national safety and health standards committees. Reach him at jb(at)jbtitus.com and via www.jbtitus.com.
Thursday, 10-03-11 10:21
JB - I always enjoy your articles and appreciate this particular OSHA article very much. I hope you and the members of the NFPA 79 Industrial Machinery committee is doing well.