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: Thinking of bypassing an e-stop? Have you talked to an attorney?
Is it ever permissible to install a bypass switch or to disable an e-stop? For some reason, some Internet “safety forums” have had this continuing discussion. See the one requirement consistently missing from these international discussions. And ask these 4 questions.
Is it ever permissible to install a bypass switch or to disable an e-stop? For some reason, a few “safety forums” on the Internet have had this discussion going for months. These are international discussions, yet one requirement in the analysis is missing consistently.
On this subject, can you actually imagine several engineers corroborating and contributing argumentation on how to install and why not to install a bypass switch on an e-stop circuit. The discussions veer off into SIL levels, PL (Performance Levels), MTTFd (Mean Time To Fail dangerous), B10 values, and more. Sometimes there’s even a brief discussion about the Machinery Directive or different standards like IEC 61508-1, IEC 62061, ISO 13849-1, and IEC 60204-1, and different ways to derive calculations based on different interpretations.
Just when it looks like the discussion is about to arrive at a conclusion someone asks something like, "Well, just what is it you’re trying to accomplish? And, why is this question on the table?" Then a strategy discussion launches on why and how a safety function can be bypassed.
So, what is the one requirement not even hinted at so far? That’s right, the risk assessment!
Why is it that these discussions can go on for months back and forth and no one interjects the "risk assessment" discussion?
4 questions to ask if you're thinking of bypassing an e-stop
Here are some of the questions I can think of related to this topic:
1. Does the current risk assessment allow for a given hazard to become unmitigated?
2. Does your company safety policy allow for a given hazard to become unmitigated?
3. Do machine safety application standards like IEC 60204-1, ISO 13849-1, or in the U.S. – NFPA 79 allow e-stops to be by-passed or disabled?
4. Is there any established and documented compliant basis whereby it is okay to bypass an e-stop?
Well, if the answers to these questions are generally, "NO," then, why would anyone even consider designing and engineering an e-stop bypass?
Additionally, I’d want to know if the individual asking the original question is talking about an application based on international standards or domestic U.S. standards. The answer to that question might then promote discussions involving risk assessment, that is: ISO 12100 versus ANSI B10.0. I’m sure you get the point!
Has this presented you with any new perspectives? Do you have some specific topic or interest that we could cover in future blog posts? Add your comments or thoughts to the discussion by submitting your ideas, experiences, and challenges in the comments section below.
Also see additional posts linked at the bottom of this article.
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.