February 7, 2017

Debunking theTop 4 Mythsof Machine

Safeguarding

Introduction

Rockford Systems delivers innovative machine safeguarding solutions for organizations working with industrial machinery.

Pervasive Lack of Machine SafeguardingMachine Guarding = OSHA’s Top 10 Most Cited Violations

– According to OSHA, workers who operate and maintain machinery suffer approximately 18,000 amputations, lacerations, crushing injuries, abrasions and more than 800 deaths per year.

– In 2016 alone, 88% of the total number of OSHA Machine Guarding violations were classified as “Serious.”

Pervasive Lack of Machine Safeguarding

• Rockford Systems estimates that an alarming 50% or more of metal fabricating machinery in the United States does not comply with the critical safety requirements for guarding outlined by OSHA and ANSI.

Majority of Metal Fabrication Machines are NOT Guarded

Top 4 Machine Safeguarding Myths

1. New machines are safe (good to go) because their manufacturers sold them as fully compliant with OSHA regulations and other Safety Standards

2. Older machines are exempt from OSHA’s machine safety regulations because they are “grandfathered-

in”3) Automation cells containing Industrial Robots are

always properly safeguarded by the robot supplier

4) OSHA regulations are only guidelines, not the law.

MYTH ONE

New machines are safe because their manufacturers built them to meet up-to-date safety standards and regulations

• REALITY: May not be trueThis depends on the country where the machines were built and

the safety standards that the machine manufacturer used as a guideline for designing, building and installing; control systems, electrical components (NFPA 79-2015), and safeguarding.

It also depends on:1) Machine Safeguarding EXPERTISE of the equipment OEM.2) OEM’s reluctance to add Safeguarding to the project’s COST.3) OEM’s concern about the LIABILITY of providing Safeguarding

New machines are safe because their manufacturers built them to meet up-to-date safety standards and regulations

• REALITY: May not be true (continued)

It's very important for the buyer of new machines to specify the Safety Related Parts of Machine Controls SRP/CS for which this equipment must comply (see ANSI B11.19-2010 as one example). The buyer should not hesitate to spell out the clause numbers from ANSI Standards, European Standards, and even OSHA Regulations, although those are usually older and limited to less machines.

Remember that Safety Standards from European Machinery Guarding Standards (EU) and Canadian Standards Association (CSA) offer higher levels of protection than US ANSI Standards provide.

Example: New Drill Press

Example: New Combination Mill/Drill

OSHA 1910.212 (a)(1) One or more methodsof machine guarding shall be provided to

protect the operator and other employeesin the machine area from hazards such as…

point of operation, ingoing nip points,rotating parts, flying chips, sparks…

Chip/Coolant Hazards

Hinged Chuck Shieldwith built-in Interlock

Example: Engine Lathe with two Shields

Interlock

Chip/Coolant Shieldwith built-in Interlock

www.centryco.comwww.buww.com

Telescopic stainless-steelsleeves cover horizontal

rotating componentsof this Engine Lathe

Example: New “Stamping” Presses

“Servo-Drive”Gap-frame Press

Straight-sideMechanicalPower Press

Two-handControl

AdjustableSide Guards

InterlockedSafety Block

Two Sets ofLight Curtains

Three Sets ofLight Curtains

Fourth in Back?

InterlockedSafety Block

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Vertical Light Curtain

AOPD Laser Device

Back to Back2-Hand Control

Hinged Corner Guards

Sliding Interlocked Vertical Guard in back

MYTH TWONow that we’ve completed MYTH ONE let’s move on to:

Older machines are "grandfathered-in" since they were manufactured before Safety Standards and Regs. existed

REALITY: Not trueAll machines, regardless of age, must at very least, meet minimum OSHA regulations. (since OSHA was “promulgated” back in 1970)

For companies wanting to meet a higher safety benchmark, the series of 24 ANSI B11 Safety Standards offer the best available guidelines for metal processing machines used here in the U.S.

ANSI B11 standards are regularly updated. Writing Committees must do one of 3 things every 5 years; (re-write, re-affirm, drop/combine)

Machine Safety Compliance that exceeds minimum OSHA Regulations to achieve “Best Safety Practice” (like ANSI B11 Safety Standards) also helps your company meet “due diligence” in case there is ever litigation after a serious machine accident.

There are no OSHAGrandfather

Clauses

Examples: Old Mechanical Power Press, Shear, Lathe

for Older Machines

Belt Cover Open

Belt Cover Closed

On pre-1957 J-headBridgeport VerticalMilling Machines

ANSI B11 Safety Standards for Metalworking Machine ToolsB11.0 Safety of Machinery . . . and Risk AssessmentB11.1 Mechanical Power Presses (1910.217 OSHA) B11.2 Hydraulic Power PressesB11.3 Power Press BrakesB11.4 ShearsB11.5 Iron WorkersB11.6 LathesB11.7 Cold Headers and FormersB11.8 Drilling, Milling, and BoringB11.9 Grinding (1910.215 OSHA) B11.10 SawingB11.11 Gear CuttingB11.12 Roll Forming and Roll BendingB11.13 Automatic Screw/Bar and ChuckingB11.14 Coil Slitting

B11.15 Pipe, Tube, and Shape BendingB11.16 Metal Powder CompactingB11.17 Horizontal Hydraulic Extrusion PressesB11.18 Coil Processing SystemsB11.19 Safeguarding MethodsB11.20 Integrated Manufacturing SystemsB11.21 Machine Tools using LasersB11.22 CNC TurningB11.23 Machining CentersB11.24 Transfer MachinesANSI/RIA R15.06 Robot Safeguarding (both 1999 and 2012)

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TR 1 - 2004TR 2 - 1997TR 3 - 2000TR 4 - 2004TR 5 - 2006TR 7 - 2007

Ergonomics Mist ControlRisk AssessmentPLC/PESNoise MeasurementLean Manufacturing

ANSI B11Technical

Reports

All 24 refer to B11.19

Example: Bench (Pedestal) Grinder

Red Curved Direction Arrow1/4” maximum opening

Covered spindle end/nut1/8” maximum opening

1/8” maximum opening for Work Rest#1 OSHA Machine Safeguarding

violation in every state in the U.S.OSHA 1910.215 (a)(4)

#1

ANSI B11.9-2010ANSI B7.1-2000Also see

“Ring-testing” the wheel before mounting it is required by OSHA

OSHA 1910.215 (b)(3) Abrasive Wheels - Figure 0-6,7 65° from the horizontal plane to the top of opening

and 90° maximum wheel cover opening

1/4”

1/8”Work Rest

TongueGuard

MYTH THREENow that we’ve completed MYTH TWO let’s move on to:

REALITY: May not be trueSome OEMs providesafeguarding andsome don’t

Automation cells containing Industrial Robots are always properly safeguarded by the robot supplier

See our Blog Poston Robots fromearly January

Category 1 well-tried safety components andprinciples

Category B safety-related parts of machineand safeguards – componentswithstand environment

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Category 2 components monitored beforemachine start-up and periodically(mats, drop probe, R/F)

Category 3 dual/monitored system of criticalcomponents – single fault does notlead to loss of safety function

(better guard interlocks)

Category 4 dual/monitored system with allforeseeable faults detected( light curtains)

EN 954-1 Safety-Related Parts of Control Systems(European)

reprinted with permission SICK Inc.

Area Laser Scanner can be programmed on the shop floorwith a laptop for both “Fault Zone” and “Warning Zone”and can be re-programmed if/when parameters change

Perimeter Guarding Heights6 inch sweep, 72 inch height (CSA-2003)

12 inch sweep - 60 inch height (ANSI/RIA-R15.06 1999)

Output Signal Switching Device

Vertical Light Curtain

InterlockedGuard Door

3 EmergencyStop Buttons

MYTH FOURNow that we’ve completed MYTH three let’s move on to:

OSHA Regulations are only safety guidelines for manufacturers but are not really the law

• REALITY: Not trueWilliams/Steiger Act of 12/29/70 (which established OSHA); General Duty Clause 5(a)(1) “Employers to provide a place of employment free from recognized hazards likely to cause death or serious physical harm to employees” (a.k.a. safe and healthful workplace) This applies to states under Federal OSHA supervision, as well as those under State OSHA supervision.

OSHA's Machine Guarding Regulations have changed very little since 1975, therefore lack what employers need to know about current machine safety options. OSHA regs. have always been considered as a starting point only.

By law, employers are legally required to follow OSHA regulations. “COSHOs” (Compliance Safety/Health Officers) issue citations for compliance to their Code of Federal Regulations; CFR SubPart O; Machinery/Machine Guarding

OSHA 1910.212 General Requirements for all machines says the operator and others in machine area must be protected from exposure to hazards. (using Guards, Devices, Methods, or some combination of these three)

OSHA Regulations are only safety guidelines for manufacturers but are not really the law

Once a manufacturer is cited for a violation, whether for new machinery or or old, the best place to turn for advice is the ANSI B11 series of consensus standards that identify accepted options for safeguarding machinery.One of them, ANSI B11.19-2010 entitled; “Performance Criteria for

Safeguarding”, is an "umbrella standard" for all machines in the B11 series. Its primary objective is to establish requirements for the design, construction, installation, operation, and maintenance of safeguarding.

In earlier years, each ANSI B11 Standard had it’s own “Safeguarding Section” which required users to buy copies of ALL the B11 Standards for which they had an interest. In B11.19 -2010, the safeguarding sections of each of the 25 ANSI B11 Standards were consolidated into one (umbrella) standard for user convenience, and to prevent having to buy all of them.

B11.19 is the one to reference for learning about the five Safeguarding alternatives: 1) Guards, 2) Devices, 3) Distance, 4) Location, 5) Opening, regardless of the type of machine that they are applied to.

5(b) EMPLOYEES shall comply with OSHAstandards, rules, regulations, and orders

applicable to their own actions and conduct

EMPLOYERS to furnish a place of employmentfree from recognized hazards likely to causedeath or serious physical harm to employees

OSHA 5(a)(1) General Duty Clause

OSHA 1910.212 General Requirements (a)(1)protect operator & other employees

in the machine area from hazards

• point of operation (Guards, Devices, Methods)• ingoing nip points (Covers, Guards, Shields)• rotating parts (Covers up to 7’ or 8’ from floor)• flying chips & sparks (Chip/Coolant Shields)

examples of safeguarding methods: barrier guards,two-hand actuators, electronic safety devices, etc.

NOT complete list of hazards or safeguarding

General Requirementsfor All Machines

OSHA 1910.212 (a)(3)(ii) . . . The guardingdevice shall be in conformity with any“appropriate standards” . . .

. . . like for instance ANSI B11 Safety Standards,since that is where many OSHA Regulationscame from to begin with (with limitations)?

Code of Federal Regulations OSHA Sub-Part OMachinery and Machine Safeguarding

Verti

cal =

spec

ific1910.213 Woodworking machinery (ANSI 01.1)

1910.214 Cooperage machinery (whiskey barrels)

1910.215 Abrasive wheel machinery

1910.216 Mills and calendars (rubber and plastics)

1910.217 Mechanical Power Presses (ANSI B11.1)

1910.218 Forging machines (presses and hammers)

ANSI B11.9 ANSI B7.1

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1910.219 Mechanical power transmission apparatus

1910.211 Definitions1910.212 General requirements for all machines

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• Myth #1: New machines are safe because theirmanufacturers designed and built them to

meet up-to-date safety standards/regulations

– REALITY: Not necessarily, always conduct an Onsite Risk Assessment and/or Machine Survey to identify OSHA 1910.212 “General Requirements for Machines” violations and identify how to bring machines into compliance. ANSI, Canadian and European standards often provide “Best Practices.”

Myt

h Su

mm

ary Myth #2: Older machines are "grandfathered

in“since they were designed and manufactured before safety standards and regulations existed

– REALITY: False, there are no grandfathering laws in effect. All machines must meet minimum OSHA regulations. For companies wanting to meet a higher safety benchmark, ANSI B11 Safety Standards offer the best available guidelines for metal processing machines.

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h Su

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• Myth #3: Automation cells containing Industrial Robot are always properly safeguarded by the robot supplier

- REALITY: May not be true some OEM’s provide this and some don’t

• Myth #4: OSHA regulations are onlysafety guidelines but are not the law

- REALITY: False, by law, employers are legally required to follow OSHA regulations, meaning that an OSHA

inspector will issue citations for compliance to the Code of Federal Regulations.

Onsite Machine Risk Assessmentsand Machine Surveys are Critical

Onsite Risk Assessments and Machine Surveys are the critical first step in proper machine safeguarding to help identify the tasks and associated

hazards on a machine shop's equipment.

Risk Assessment based on ANSI B11.0-2015 provides:hazard score with the risk level for each machine suggestions to lower the hazard leveldetailed documentation to outline the results

Machine Survey based on ANSI B11 Stds. and OSHA Regs.each machine is audited for compliance to OSHA Regs. and ANSI Stds.customized proposals with specific products, services to bring the machines into full compliance to OSHA and to “Best Safety Practices”

ANSI B11.0-2015 Table 1Risk Assessment Scoring System

Probability ofOccurrence

of HarmCatastrophic Serious Moderate Minor

Very Likely High High High Medium

Likely High High Medium Low

Unlikely Medium Medium Low Negligible

Remote Low Low Negligible Negligible

Severity of Harm

SUMMARY

Questions & Answers

• Type your question into the chat box

• Email your question to:

matt.brenner@rockfordsystems.com

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