Machine Safety: Does a risk assessment need to be updated for a minor machine modification?
"We’ve made some minor changes to several machines over the past six months but none of these modifications included the safety system. Our engineer said that there was no change in operator safety. Do we have to update the risk assessments anyway?"
The long and short answer is – yes! This is one of the most frequently asked questions at Machine Safety seminars. Just think about the consequences for a moment. Let’s say a modification was made to the protective fencing moving a man entry gate six feet. The modification was simple enough and the existing door interlock switch continues to work just fine after being re-wired. The operator is unaffected by this change because he/she is not required to access this door. So, operator safety is unaffected as the engineer had said.
However, if the new door location is now six feet closer to a hazard point the time distance calculations may reflect the need to raise the hazard level from Cat 3 to Cat 4. This will undoubtedly require different hazard mitigation techniques to reach the same reduced level of hazard (acceptable risk). And, how would we discover that this simple modification resulted in a serious change to overall machine safety? An updated risk assessment! This is why any modification to a machine requires that the risk assessment must be updated.
In my opinion, referring to ANSI B11.0 – 2010 Safety of Machinery – General Requirements and Risk Assessment will answer this question in Clause 4.11 (page 27) as follows:
4.11 Modifying and/or rebuilding a machine
Non-standard uses or modifications of the machine, machine control system or the safeguarding can create additional hazards. A modifier and/or rebuilder of machinery shall use the risk assessment process to ensure that risks are reduced to an acceptable level. Modifiers and/or rebuilders shall, where practicable, solicit the original supplier’s recommendations regarding any proposed modification to a machine that may affect the safe operation prior to making any such changes.
Where modifications are made to the machine/system (for example, intended use, tasks, hardware, and software), a risk assessment / risk reduction process shall be repeated for those parts of the machine/system being modified or affected.
Within the United States I strongly recommend that manufacturers use ANSI B11.0 as one of your core industry standards for machine safety compliance. Also, it’s actually recommended by OSHA.
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