Machine Safety

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.

See all Machine Safety blogs and comments


 

Machine Safety: More on shared responsibilities

Broad responsibilities of designing and building a safe machine from the supplier perspective were detailed in a November Control Engineering article by Steve Wright. Issues beyond that include additional shared responsibilities.

December 18, 2012


In the November issue of Control Engineering, Steve Wright wrote a great article explaining the broad responsibilities of designing and building a safe machine. Steve is directly on point from the supplier perspective. Now, let’s take this discussion one step further.

 

I’ve often wondered, given the U.S. model for enforcement, why we write safety standards for machine design but enforce safety via OSHA who only looks at the users of machines? By default, I’ve heard several people state that machinery OEMs in the U.S. are not regulated (by OSHA) to build safe machines. It seems that OSHA will go into an original equipment manufacturer (OEM) facility and cite worker safety issues but they don’t evaluate the machine they’re manufacturing.  

 

Having said that, the reasons (in my opinion) that Steve’s article is so relevant is that OEMs need to build safe machines because:

  • Company policy
  • Industry best practices
  • It’s right to reduce points of hazard
  • Global compliance for export
  • Compliance to customer specifications
  • Potential fault in litigation

Flowchart on left shows the relatively straightforward European legal model for enforcement. On the right, the U.S. model is less straightforward. Courtesy: JB Titus & AssociatesThese are some of the points which can easily be realized by reviewing the model comparisons between Europe and the USA in the graph on the left. You can readily see that it’s considered illegal for an OEM to build an unsafe machine in Europe.

 

So, I believe the reason Steve’s article is so important here in the U.S. is for OEMs comply with the safety standards, which helps users purchasing safe machines to provide a safer place for employees to work. Additionally, OSHA’s enforcement of the user community for installed machines further helps to provide a safer environment for employees.

  

J.B. Titus, CFSE

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.

Related articles:

Machine safety: Shared responsibility

Inside Machines: Does adopting ISO 13849-1:2006 change the U.S. model for compliance and enforcement?

Machine Safety – does OSHA reference consensus standards for compliance?

Machine Safety: Is OSHA okay with my 'acceptable' risk mitigation?

  

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.