Machine Safety: Do not tell employees that a safety compliant machine is safe
Just because you were particularly careful to purchase a new machine compliant to the latest machine safety standards and delivered with all the usual mandatory conformity marks like CE, UL, etc., you cannot tell employees they are working on a safe machine. Listen to OSHA and ANSI.
Purchasing a new machine compliant to the latest machine safety standards and delivered with all the usual mandatory conformity marks (CE, UL, etc.) does not mean that you should tell employees they are working on a safe machine.
As a business owner (these responsibilities are frequently delegated) you have a due diligent responsibility to understand the world of regulation (OSHA), industry standards, and your regional/local requirements. That said, quite often machines are marketed and purchased with the complete understanding that they are fully compliant with latest issue of a particular machine safety standard. But does this mean that the operator is automatically safe? Not on your life!
OSHA and ANSI advice
Aside from risk assessment requirements for an installed machine called out by OSHA and a regional safety standard like ANSI B11.0-2010, a business owner needs to understand the differences between a machine safety (design and build) standard versus a general machine guarding (application) standard. Let’s look at an example machine.
A metal forming machine manufactured in the U.S. will very likely acknowledge full compliance with ANSI B11.1-2009, Safety Requirements for Mechanical Power Presses (a machine safety design and build standard). This is great news for a new machine because all safety hazards should be acknowledged and mitigated to “safe” levels from the factory. The new machine should also be compliant with regulation OSHA 1910.217 for Mechanical Power Presses. This regulation will be used by the original equipment manufacturer (OEM), and it will also cover some of the installation safety related issues. But, due diligence knowledge also reveals that OSHA itself claims that its regulations are the bare minimum requirements.
Therefore, another ANSI safety standard, ANSI B11.0-2010, Safety of Machinery – General Requirements and Risk Assessment, is needed to:
1. Identify all hazards of the installed machine, and
2. Identify/choose all safeguarding steps required to mitigate each identified hazard.
Then, another safety standard, ANSI B11.19-2010, Performance Criteria for Safeguarding, can be incorporated into the compliance requirements because it leads users through the application of those chosen safeguarding methodologies. Some of those methodologies could include; fixed guards, safeguarding devices, awareness barriers, safety labels, safe work procedures or complementary equipment, to mention a few.
Additionally, some manufacturers also bring other machine safety standards into safety culture requirements to have added assurance that they are providing safe working environments for employees. One of these machine safety standards is NFPA 79, Electrical Standard for Industrial Machinery-2012. In fact, these standards will call out a normative (required) or informative (optional) reference to each other which tends to simplify your search for choosing machine safety standards applicable for your business.
Doesn’t it make sense that a new “out of the box” safety compliant machine does not mean that the same installed machine is automatically safeguarded for your employees?
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ASSE - Professional Safety Journal- Near-Miss Reporting, May 2013
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