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.
Machine Safety: Does OSHA reference consensus standards for compliance?
I have presented or been a presenter at literally scores of machine safety seminars over more than 10 years and absolutely the most asked question is, “Does OSHA reference consensus standards for compliance?”
Does OSHA reference consensus standards for compliance? I have presented or been a presenter at literally scores of machine safety seminars over the past 10-plus years and that is absolutely the most asked question.
The answer is yes, but in my opinion they don’t do it consistently and they don’t reference this “right” in the obvious places. First of all OSHA has their General Duty Clause right up front in SEC. 5. Duties:
(1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;
(2) shall comply with occupational safety and health standards promulgated under this Act.
29 USC 654
You would think that this is such a powerful “right” that they would make sure that it’s listed in an obvious place.
Secondly, you need to browse around the OSHA web site for a considerable amount of time until you find the eTools section as I did. Once there you will be able to find the below content, however, I’ve saved you the time by providing this link:
The basic regulation, in Section 1910.212, states that any machine that creates a hazard must be safeguarded to protect the operator and other employees. OSHA can also cite violations by referencing other standards such as the ANSI (American National Standards Institute) B11 series. The following is a list of each ANSI B11 Series Standard available at the printing of this publication.
Note: These are NOT OSHA regulations. However, they do provide guidance from their originating organizations related to worker protection.
B11.1 Mechanical Power Presses
B11.2 Hydraulic Presses
B11.3 Power Press Brakes
(Etc. through the entire B11 series)
Thirdly, in my years in the machine safety business I’ve not heard that this enforcement “right” is uniformly applied by all persons enforcing the OSHA regulations on industry. So, is this just one more of those dreaded issues that might or might not surface for any given manufacturer?
Has anyone found the OSHA directives to more clear on this issue than discussed above?
Your comments or suggestion are always welcome so please let us know your thoughts. Submit your ideas, experiences, and challenges on this subject in the comments section below. Click on the following text if you don't see a comments box, then scroll down: Machine Safety: Does OSHA reference consensus standards for compliance?
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.