U.S. Machine Safeguarding Regulations – An Overview By Steve Dukich Sr. Commercial Engineer.

U.S. Machine Safeguarding Regulations – An Overview

By Steve DukichSr. Commercial Engineer

2 Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Agenda

The OSHA Act The OSHA Act

ANSIANSI

U.S. Consensus Standards U.S. Consensus Standards

National Recognized Testing Labs National Recognized Testing Labs

Important OSHA Standards Important OSHA Standards

OSHA Citations OSHA Citations

Conclusion Conclusion


Occupational Safety and Health Act of 1970

http://www.osha.gov

OSHA Creation


OSHA Purpose

The Congress declares it to be its purpose and policy ... to assure so far as possible every working man and woman in the Nation safe and healthful working conditions and to preserve our human resources…


OSHA Purpose

By authorizing the Secretary of Labor to set mandatory occupational safety and health standards applicable to businesses affecting interstate commerce, and by creating an Occupational Safety and Health Review Commission for carrying out adjudicatory functions under the Act;


OSHA Applicability

This Act shall apply with respect to employment performed in a workplace in …– a State,– the District of Columbia,– the Commonwealth of Puerto Rico,– the Virgin Islands,– American Samoa, Guam, the Trust Territory of the

Pacific Islands, Wake Island, Outer Continental Shelf Lands defined in the Outer Continental Shelf Lands Act, Johnston Island, and the Canal Zone.


Article 5

(a) Each employer -(1) shall furnish to each of his employees employment and a

place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

(2) shall comply with occupational safety and health standards promulgated under this Act.

(b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.


Section 6 Standards

(a) “...the Secretary shall...by rule promulgate as an occupational safety or health standard– any national consensus standard, and– any established Federal standard,– unless he determines that the promulgation of such a

standard would not result in improved safety or health for specifically designated employees…”

– Initially, OSHA adopted many existing ANSI standards rather than create their own standards. Since then, these OSHA standards are not revised as quickly as voluntary standards.


29 CFR

• The OSHA standards are published under Title 29 of the Code of Federal Regulations

• These published standards are the law. – U.S. national consensus standards

are voluntary, and are used by OSHA as reference material when giving citations.


Agenda


ANSIANSI







Part 1910Occupational Safety and Health “Standards”


Some of the subparts• A - General• B - Adoption and Extension of Established Federal Standards• C - General Safety and Health Provisions• H - Hazardous Materials• I - Personal Protective Equipment• J - General Environmental Controls

– includes Lockout/Tagout

• O - Machinery and Machine Guarding• R - Special Industries• S - Electrical

Part 1910 has 21 Subparts


Incorporation By Reference

The legal effect of incorporation by reference is that the material is treated as if it were published in full in the Federal Register (5 U.S.C. 552(a)).

When a national consensus standard is incorporated by reference in one of the subparts, that standard is considered the law.


Lockout Tagout

• Subpart J covers control of hazardous energy

• This covers the servicing and maintenance of machines and equipment in which the unexpected energization or startup could cause injury to employees.

• Employers must establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start up or release of stored energy in order to prevent injury to employees.


Lockout Tagout Exception

• Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection.

• Alternative measures are safeguarding devices like light curtains, safety mats, gate interlocks and other similar devices connected to a safety system.

• See ANSI Z244.1 for the equivalent voluntary standard.


Subpart O - Machinery and Machine Guarding

• 1910.211 Definitions• 1910.212 General requirements for all machines• 1910.213 Woodworking machinery• 1910.214 Cooperage machinery• 1910.215 Abrasive wheel machinery• 1910.216 Mills and calendars – rubber and plastics• 1910.217 Mechanical power presses• 1910.218 Forging machines• 1910.219 Mechanical power-transmission apparatus


1910.212 General Requirements

One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by…

• point of operation• ingoing nip points• rotating parts• flying chips• and sparks.


General Requirements

• Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible.

• The guard shall be such that it does not offer an accident hazard in itself.


Point of Operation Guarding

• Point of operation is the area on a machine where work is actually performed upon the material being processed.

• The point of operation of machines whose operation exposes an employee to injury, shall be guarded.


Point of Operation Guarding

• The guarding device shall be in conformity with any appropriate standards therefore, or, in the absence of applicable specific standards, shall be so designed and constructed as to prevent the operator from having any part of his body in the danger zone during the operating cycle.


Types of Safeguards

• Guards– Fixed, Interlocked, Adjustable, Self-Adjusting

• Devices– Presence Sensing, Two-hand, tripwire, interlocks

• Location/Distance– Hazard located away from people

• Feeding and Ejection Methods– Operator does not have to put hands in point of operation

• Miscellaneous Aids– Awareness Barriers, Shields, Holding Tools


Subpart R

• Pulp, Paper and paperboard mills• Textiles• Bakery Equipment• Laundry machinery and operations• Sawmills• Logging Operations• Telecommunications• Electric Power Generation, transmission and distribution• Grain handling facilities


Subpart S - Electrical

• Addresses electrical safety requirements that are necessary for the practical safeguarding of employees in their workplaces…

• Appendix A - Reference Documents– NFPA 70-78 (National Electric Code)– many other reference documents


Agenda


ANSIANSI







29 CFR Subpart S - Electrical

• Acceptable and Approved. – An installation or equipment…– is acceptable to the Assistant Secretary of Labor, and

approved within the meaning of this Subpart S…– if it is accepted, or certified, or listed, or labeled, or

otherwise determined to be safe… – by a nationally recognized testing laboratory (NRTL).


Listed Equipment

• What is Equipment?– A general term including material, fittings, devices,

appliances, fixtures, apparatus, and the like, used as a part of, or in connection with, an electrical installation.

• What is Listed? – Equipment is "listed" if it is of a kind mentioned in a list

which, (a) is published by a nationally recognized laboratory which makes periodic inspection of the production of such equipment, and (b) states such equipment meets nationally recognized standards or has been tested and found safe for use in a specified manner.


NRTLs as of July 2006

• Applied Research Laboratories, Inc. (ARL) • Canadian Standards Association (CSA) • Communication Certification Laboratory, Inc. (CCL) • Curtis-Straus LLC (CSL) • Electrical Reliability Services, Inc. (ERS) • Entela, Inc. (ENT) • FM Global Technologies LLC (FM) • Intertek Testing Services NA, Inc. (ITSNA) • MET Laboratories, Inc. (MET) • NSF International (NSF) • National Technical Systems, Inc. (NTS) • SGS U.S. Testing Company, Inc. (SGSUS) • Southwest Research Institute (SWRI) • TUV America, Inc. (TUVAM) • TUV Product Services GmbH (TUVPSG) • TUV Rheinland of North America, Inc. (TUV) • Underwriters Laboratories Inc. (UL) • Wyle Laboratories, Inc. (WL)


UL and CSA

• UL and CSA have reciprocal agreements. UL inspectors are supposed to accept the CSA approved products and CSA is supposed to accept the UL approved products provided the products have the appropriate marks.

Test by UL to meet Canadian and US

requirements

Test by CSA to meet Canadian and US

requirements


OSHA State Plans

• Twenty-four states, Puerto Rico and the Virgin Islands have OSHA-approved State Plans and have adopted their own standards and enforcement policies.

• For the most part, these States adopt standards that are identical to Federal OSHA.

• However, some States have adopted different standards applicable to this topic or may have different enforcement policies.


Agenda


ANSIANSI







ANSI

• The American National Standards Institute (ANSI) coordinates the development and use of voluntary consensus standards in the United States and represents the needs and views of U.S. stakeholders in standardization forums around the globe.

• www.ansi.org


ANSI

• ANSI - American National Standards Institute is a publishing organization which releases the individual industry consensus standards.

• ANSI imposes restrictions on the make up of the consensus group to ensure balanced representation and standard practice guidelines to ensure complete documentation. The four principles are due process, openness, transparency and consensus.

• ANSI does not write standards or approve products.


U.S. Standards Development

• National consensus standards are developed by ANSI-accredited Standards Developers (ASD) that represent U.S. industries. They are also known as Standards Developing Organizations (SDO).

• Some ASD for machines…– AMT (Association For Manufacturing Technology) -

www.amtonline.org– ASSE (American Society of Safety Engineers): www.asse.org – NFPA (National Fire Prevention Association): www.nfpa.org– PMMI (Packaging Machinery Manufacturer’s Institute):

www.pmmi.org – RIA (Robotics Industry Association): www.roboticsonline.com– UL (Underwriter’s Laboratory) – www.ul.com– and many more – see the ANSI website.


ANSI Standards

• ANSI Standards can be identified by the following mark.

• Standards are not always prefaced with “ANSI”– ANSI B11.19 – ANSI standard for safeguarding– RIA R15.06 – ANSI standard for robots

• ANSI Online Store– http://webstore.ansi.org/ansidocstore/default.asp– Purchase national consensus standards

• Other purchase locations– Global Engineering Documents: global.ihs.com– the developing organization


Agenda


ANSIANSI







ANSI NFPA 79 - Safety of Machinery

• NFPA 79 is an ANSI Standard– Electrical standard for industrial

machinery.– But not specifically referenced by OSHA.

• Closely harmonized with IEC 60204-1– Minor differences exist, so NFPA79 must

be used for US machines.

• Next revision of NFPA 79:2007 will be issued in late 2006.


OSHA Standards Interpretations

“The machines which are not covered by specific OSHA standards are required under the Occupational Safety and Health Act (OSHA Act) and Section 29 CFR 1910.303(b)(1) to be free of recognized hazards which may cause death or serious injuries.”

“ These machines must be designed and maintained to meet or exceed the requirements of the applicable industry consensus standards. In such situations OSHA may apply standards published by the American National Standards Institute (ANSI), such as standards contained in ANSI/NFPA 79, Electrical Standard for Industrial Machinery, to cover hazards that are not covered by specific OSHA standards.”


ANSI Z244.1-2003 Lockout / Tagout

• Published by the American Society of Safety Engineers• Updated version of OSHA 1910.147• Why would we have a voluntary standard when a federal

standard already exists?– Voluntary consensus standard are updated much easier than OSHA

standards.– Z244.1 represents best practices for controlling hazardous energy

and addresses the need for greater flexibility through the use of alternative methods based on risk assessment and application of the hazard control hierarchy.

– When a discrepancy exists, OSHA will accept the implementation of a voluntary standard.


Risk Assessment

• Although there is no OSHA requirement for risk assessment, US industry organizations are requiring a risk assessment as the basis for achieving adequate risk reduction as well as making machine more productive.

• Risk assessment is becoming the norm in US industry.– B11.TR3 – a technical report issued by the AMT covering risk

assessment and risk reduction.– NFPA79 – Section 4 of electrical standard requires risk assessment.– PMMI B155.1 – Packing machine standard updated to include a risk

assessment section.– RIS R15.06 – Robotic standard includes prescribed changes or

allows risk assessment and risk reduction to achieve tolerable risk.


User-Supplier Relationship

Risk Assessment

Protective measures taken by supplierdesignsafeguardsother protective measures

Protective measures taken by useradditional safeguardsorganizationtrainingpersonal protective equipment

Residual Risk

User Input

Risk

Supplier Input


Universe Model of U.S. Machinery Standards

OSHAAct

A Level

C Level

B11.2

B65.1

HS-1738

B11.19

B11.20

R15.06

Electrical

1910.212

General

1910.213

Woodworking

1910.217

1910.214 Cooperage

1910.218

Forging

B Level

Safeguarding

SAEAutomotive

MechanicalPresses

Robots

HydraulicPresses

Mfg Cells

Printing

B11.1

Z244.1

1910.147

NFPA79

B155.1

Packaging Machines

B11.TR3Risk Assessment

12100

Lockout/Tagout


Universe Model of EN Machinery Standards


Use of standards

• In the U.S. as in Europe and the ISO world, the machine specific (i.e. Level C) standards take precedent over the more general (Level B and A) standards.


Agenda


ANSIANSI







Incident Information Flow

• Employers must report incident history to OSHA.• OSHA compiles incident rates and transmits info to local offices.• Inspection Drivers

– Imminent Danger– Catastrophes and Fatalities– Employee Complaint– High Hazardous Industries– Local Planned Inspections– Follow-up Inspections– National and Local Focus Programs


Penalties

• Serious– up to $7000 per violation

• Other than Serious– discretionary but not more than $7000

• Repeat– up to $70,000 per violation

• Willful– up to $70,000 per violation– Violations resulting in death- further penalties

• Failure to abate– $7000/day


OSHA Top Citations in Manufacturing 10/2004-9/2005

Standard #Cited #Insp $Penalty Description

Total 41677 6773 48,947,874

19100147 3560 1889 2,952,588 The control of hazardous energy (lockout/tagout).

19101200 3332 1730 736,035 Hazard Communication.

19100212 2660 2125 3,500,799 General requirements for all machines.

19100134 2476 1111 901,148 Respiratory Protection.

19100305 2085 1298 1,011,958Wiring methods, components, and equipment for

general use.

19100178 1882 1236 897,056 Powered industrial trucks.

19100219 1850 958 1,155,765 Mechanical power-transmission apparatus.

19100303 1515 1136 873,354 General requirements.

19100213 1140 555 594,668 Woodworking machinery requirements.

19100215 1123 681 473,381 Abrasive wheel machinery.

19100132 1032 760 639,288 General requirements.

19100217 990 324 1,142,507 Mechanical power presses.

19100095 977 480 863,489 Occupational noise exposure.

19100023 959 732 1,017,397 Guarding floor and wall openings and holes.


Agenda


ANSIANSI







Conclusion

1. OSHA places responsibility for a safe working environment on employers.

2. Machine suppliers and users should apply voluntary consensus standards rather than the out-dated OSHA standards.

3. Electrical equipment must be listed by a NRTL.4. Risk assessment is required by many ANSI voluntary

standards, and is becoming the norm.

Date post:	26-Mar-2015
Category:	Documents
Upload:	mason-kane
View:	233 times
Download:	7 times