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

“We have reviewed all of our machine safety hazards and have applied mitigation solutions to every hazard. Will OSHA agree with the mitigated 'acceptable' risk levels we’ve achieved?”

J.B. Titus

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“We have reviewed all of our machine safety hazards and have applied mitigation solutions to every hazard. Will OSHA agree with the mitigated “acceptable” risk levels we’ve achieved?”

In my 40-plus years in manufacturing I’ve never seen OSHA agree with any level of applied machine guarding and administrative solutions. On the other hand, I have seen OSHA agree with an employee who has complained to OSHA about an unsafe situation. With that said, there are plenty of information resources that can help you (in manufacturing) understand all of the mitigation techniques available for each identified hazard. Some of these sources include; OSHA’s 29 CFR 1910.XXXX, and consensus standards like the ones listed as related reading the bottom.

(Photo courtesy of JB TITUS & ASSOCIATES)

After completing a risk assessment, the five levels of hazard mitigation described in machine guarding standards are:

1) Eliminate the hazard – design it out

2) Isolate the hazard with hard guarding

3) Add additional engineering, guards, devices, or layers of safety (controls or systems)

4) Administrative controls like – training, signage, assessments, etc.

5) Personal protective equipment (PPE) like - goggles, gloves, outer clothing, shields, etc.

All five levels are fully acceptable risk mitigation solutions to achieve that “acceptable” level of mitigated risk. In my opinion, that acceptable level of risk for a given hazard is intentionally left undefined because you are the one who defines the tolerable level of risk you or your company is willing to accept. It’s been my experience that you are in the best position possible as long as you’ve documented your complete process for each identified hazard including the steps of mitigation taken to achieve that “acceptable” level of mitigated risk. And, furthermore, that you have consistently met the periodic OSHA requirements for employee training and documentation. Lastly, have I mentioned documentation?

Having completed all of this – OSHA still will not openly agree, in my experience. What has your experience been? Please let us know if you agree or disagree?

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

Related reading and articles:

ANSI B11.19-2010, Performance Criteria for Safeguarding

NFPA 79 – 2012, Electrical Standard for Industrial Machinery

Safe or Safe Enough by John M. Piampiano and Steven M. Rizzo, Professional Safety, Jan., 2012

Machine Guarding & The Hierarchy of Measures for Hazard Mitigation

Machine Safety – how safe is safe enough?

Contact: www.jbtitus.com for “Solutions for Machine Safety”.