American industry can be proud of the many advances in occupational safety and health that have evolved during OSHA’s 40-year reign. While industry has made laudable gains, there are some fundamental areas where progress has been surprisingly – and depressingly – slow. Machine and equipment guarding is one area where problems still exist.
Here are some facts about machine and equipment guarding from an OSHA enforcement perspective (federal agency data only):
- Of the hundreds of enforceable standards for general industry, only seven deal directly with guarding of fixed machinery or equipment.
- Compared to many other standards (e.g., process safety management, HAZWOPER, confined space entry, asbestos), these seven guarding standards seem easy to understand and apply.
- Compared to some other topics, machine guarding requirements have not changed much in the 40 years of OSHA’s existence, even though other complex regulatory topics have been introduced or changed during this period (e.g., arc flash, hazard communication) and writers of consensus standards – including standards dealing with machine guarding topics – continued their periodic revisions to keep pace with technological advances.
- Machine guard violations remain consequential in today’s world. During FY 2010, 24 percent of OSHA’s Top 10 citations for manufacturing dealt with machine guarding violations. Those violations resulted in more than $6 million in proposed penalties. Most of the violations were judged as serious violations, which can carry a penalty of up to $7,000 per instance. Repeated or willful violations can result in penalties of up to $70,000 per instance.
While OSHA’s penalties for machine guarding violations don’t tell the whole story, they illustrate how much work remains in dealing with this “simple” problem with a scope that remains difficult to define. There’s no doubt about it: Machine and equipment guarding continues to challenge American industry.
Unfortunately, the most common way to learn of a machine or equipment guarding shortcoming is when an injury occurs. Furthermore, accidents associated with improperly or inadequately guarded machines or equipment often produce more severe injuries.
The Bureau of Labor Statistics presents more disappointing data. Despite improvements during recent years, nearly 6,000 occupational amputations were recorded in the United States during 2009. Many of these amputations are products of improperly guarded machines or equipment or lockout violations.
Ignorance is No Defense
While it is unknown how many of the referenced machine guarding injuries or violations were detected after the employer had taken action to adequately guard the equipment in question, the existence of such cases is well documented. For example:
- An operator of a hydraulic press was crushed to death when he reached inside of the press to unload an assembly. The press was equipped with light curtains and fixed guards, and the employer had contracted design and installation of the guarding. The press utilized presence-sensing device initiation (PSDI) to automatically cycle the machine when the area protected by the light curtain was cleared. The press operator, who had a slight build, unintentionally moved inside of the light curtain, which signaled the press to cycle. The guarding was judged to be inadequate and improperly installed.
- An operator of a machining center with integrated robotics incurred a crushing injury that resulted in a leg amputation. The equipment had been used safely for many years and seemed totally enclosed by fencing and failsafe, interlocked gates. The guarding arrangement was designed by the machining center manufacturer and installed by a plant maintenance crew. Parts were fed through an opening in the fenced enclosure by a powered work-holding fixture (pallet). The operator crawled through this small fence opening to make a “quick” adjustment when he sustained the injury. Prior to the incident, the fence opening was not considered as a viable means of ingress. Remedial action included installation of strategically placed light curtains around the fence opening.
Impact of Improperly Guarded Equipment
While injured workers are the ultimate victims of accidents, their employers don’t escape unscathed, either. The business impacts of accidents and injury are both tangible and intangible. Cost leads the way in terms of tangible impacts, including increased workers’ compensation costs, OSHA penalties and legal fees.
Less intangible impacts can have even greater impacts, however. When a worker suffers a serious injury, plants can expect:
- Costly down time while the investigation is completed. In some cases, investigations can take days or weeks before affected equipment can be returned to service following any required remediation. Downtown also can result in missed shipments and disappointed customers.
- Increased overtime costs.
- Diversion of resources to address crises caused by the accident.
- Decreased employee morale or worker unrest.
- Negative publicity.
- Damaged reputation to the business – even recruiting efforts can be impaired.
Obviously, businesses don’t want to their workers to be hurt, endure enforcement actions or bear additional cost. So why do machine guarding problems persist? Perhaps the topic is not as easy to understand as it may seem. Consider the following:
- One has to consider a myriad of variables in defining the proper machine guarding solutions. First, the equipment not only has to be properly guarded, but it also must continue to serve its production demands. Proper guarding strategies must consider all variables – production, set-up, tool changes, inspection, maintenance and abnormal or upset conditions.
- Over the last 4 decades, machine guarding has progressed from largely a mechanical undertaking to one that is more electronically focused. Much of the manual machinery that was being used 40 years ago has been replaced by highly automated, computer-controlled equipment. The number of interlocks and interfaces associated with properly guarding automated equipment is not easy to understand.
- Newer equipment is sophisticated and is produced by a growing number of global companies. Too many purchasers of newer equipment incorrectly believe that the equipment manufacturer is responsible for proper machine guarding. Purchasers also can gain a false sense of confidence through requirements that equipment “must be guarded in accordance with OSHA standards.” The fact that an equipment manufacturer accepts this requirement does not mean that they understand how to properly guard the equipment.
- Machine guarding is like other technical functions – new products, approaches and requirements continuously are introduced. Few people have the time – or the ability – to keep pace. While OSHA does not approve equipment, approval by third parties (e.g., UL, ANSI and NFPA) is required or recommended for many machine guarding components.
Or maybe it’s a resource issue:
- When manufacturing operations struggle with limited resources, they may assign machine guarding functions to whoever is available whenever they can fit it into their schedules. In some cases, this means that the workers assigned responsibility don’t have the technical backgrounds needed to understand and apply the proper technology. It also can mean significant delays in completing the guarding task while waiting for an opening in the schedule, researching options and the trials and errors of installation. Unfortunately, even after going through this process, there is no guarantee that the work will be properly completed.
- Even manufacturing companies with broad and deep engineering resources may find it difficult to divert their technical resources away from core functions.
- Machine guarding is a niche specialty. Even the most competent of internal engineers face a learning curve to understand the complexity of the OSHA standards and application of the many consensus standards that are involved.
Alternatively, the root problem might be an accountability issue:
- Many companies take a hybrid approach to machine guarding. It’s not uncommon for an internal employee to identify the guarding need through an informal review. That person then may work with a local industrial equipment firm to specify guarding hardware and software. Design may be contracted or handled by other internal or external resources, while yet another contractor or internal maintenance team may complete the installation.
- In this case, it can be difficult to identify the accountable party in the event of a question or problem. If no member of the ad hoc team has deep knowledge of machine guarding technologies and requirements, it’s also possible the original project objectives of properly guarding the equipment while maintaining optimum productivity will be lost.
The Holistic Solution
Over the past 2 decades, American industry has discovered the efficiency of outsourcing for niche services and expertise. Outsourcing helps reduce risks and costs while providing focused technical expertise. Through a single agreement, businesses can hold their contractors accountable for solving problems.
Common examples of outsourcing include:
- Project engineering firms tapped for plant expansions or installation of new, specialty equipment.
- Maintenance contractors retained for both common (e.g., HVAC, security systems), and specialty equipment (e.g., high voltage electrical distribution systems, process control equipment).
- Environmental consultants who assess risks, recommend equipment options, overview installation and provide appropriate documentation needed to satisfy regulatory requirements and liability prevention needs.
- Businesses regulated by OSHA’s Process Safety Management standard who retain consultants to help them assess risk through Process Hazard Assessments and to design and install the equipment necessary for resultant corrective actions.
This outsourcing model has equal relevance for machine guarding. Until recently, few businesses identified or sought external firms that can provide turn-key or “holistic” machine guarding services to effectively help manage this risk.
Holistic machine guarding services include:
- Conducting professional risk assessments on a machine-by-machine basis. The guarding needs, including safety circuits, for each piece of equipment are specified in accordance with the most recent standards. Sizes, types and locations of recommended guards and devices clearly are illustrated. In addition, a quantifiable risk index is calculated for each piece of equipment to help the business owner prioritize the work. This risk index and its accompanying cost estimate also are useful for budgeting purposes.
- Working with customer engineers, safety professionals, supervisors and workers to design an approach that fully satisfies all guarding requirements while meeting production needs.
- Specifying hardware and software solutions. At minimum, holistic machine guarding firms will specify only equipment that is listed by third parties and certified to relevant standards. These holistic firms manufacture many of their own guarding devices and have a broad, deep knowledge of the market and evolving standards.
- Installation of guarding solutions by teams that are experienced with virtually every type of guarding application from the point of operation for presses, brakes and shears to perimeter guarding of manufacturing system cells. Installation typically is more efficient with less down time.
- Commissioning guarding solutions in collaboration with the customer’s project team. Commissioning includes training for operators and maintenance personnel. Complete documentation is provided and all documentation and training is presented in the local language. Deep involvement by customer teams assures long-term satisfaction.
Using a holistic firm on a turn-key basis eliminates accountability questions. Additionally, holistic firms are capable of dividing the work in accordance with customer wishes and can provide detailed installation instructions for use by internal maintenance or contractor installation teams.
While the concept of holistic machine guarding may be new to some parties, it offers proven cost effectiveness. Liberty Mutual has estimated this approach provides a 3:1 cost benefit advantage; OSHA estimates a 6:1 ratio.
Speaking of cost, anyone seeking goods or services would be well advised to heed the words of English author John Ruskin from over a century ago:
“It is unwise to pay too much, but worse to pay too little. When you pay too much, you lose a little money – that is all. When you pay too little, you sometimes lose everything, because the thing you bought was incapable of doing the thing it was bought to do. The common law of business balance prohibits paying a little and getting a lot – it can’t be done. If you deal with the lowest bidder, it is well to add something for the risk that you run.”
What to Look For
There are many attributes to seek in selecting a holistic machine guarding firm, but two stand above the others. The first and foremost is customer satisfaction. Be sure to check recent references and ask the candidate firms to identify references where the work didn’t go exactly as planned. Follow up with these references to learn how the firm handled problems and variables.
Next, determine that the firm truly is holistic – can they fill the role as a one-stop shop for machine guarding? To do so, they must demonstrate expertise in performing machine guarding assessments; delivering safety products; designing, installing and validating safety systems; and delivering machine safety training.
Other considerations in choosing a holistic firm include:
- Has the firm been recognized by third-party awards?
- Is the firm well established and financially viable?
- Is its work warranted?
- Has the firm worked in an industry similar to yours?
- Is the firm involved in the consensus standards process?
- Is follow-up service available?
- How quickly can services be delivered and how flexible is the firm in dealing with novel work schedules?
- Is a user-friendly Web site available?
Thus far, this paper has addressed basic needs when it comes to machine guarding. Companies with top-notch safety performance, multi-site operations and multinationals, meanwhile, can enjoy additional benefits from working with holistic machine guarding firms. These benefits include:
- The comprehensive approach to machine guarding is useful when converting “zero injury” philosophies into reality.
- The documented, machine-by-machine guarding risk assessments and the employee involvement fostered by the assessments directly support OSHA VPP recognition and OHSAS 18001 (Occupational Health and Safety Management System) registration efforts.
- Holistic firms can work with equipment manufacturers to review and sanction guarding approaches for new equipment before it is shipped to the holistic firm’s customer.
- Guarding designs and approaches can be used for identical pieces of equipment that may reside in multiple locations.
- Machine guarding risk assessments can be used to qualify equipment for transfer from one country to another where different standards may be observed. Many emerging countries require such documentation before imported equipment can be sanctioned for use.
- Consistent approaches to machine guarding results in better operation/maintenance and requires fewer spare parts in inventory. This is similar to the Southwest Airlines model of flying only Boeing 737s.
Holistic machine guarding providers can provide one final advantage to customers regardless of the company’s size or sophistication – the peace of mind of knowing that the job was done correctly and that workers are protected.
Ron Allen’s professional career began 37 years ago when he was appointed administrator, technical services, for the American Society of Safety Engineers. He has worked in plant, division, group and corporate environmental health and safety leadership positions with FMC Corp., Monsanto Co., Emerson Electric and Eaton Corp. He joined Imperial Sugar Co. as senior director of environmental, health, safety, quality and food safety in March 2009, a year after the company experienced a tragic combustible dust explosion that claimed the lives of 14 employees. He departed following the company’s successful settlement negotiations with OSHA and has since founded his own firm, Turnaround Safety Services. Allen holds an M.S. in safety management from West Virginia University and is a certified safety professional, registered professional engineer, certified professional environmental auditor and a registered environmental management systems auditor.