Machine Guarding: Protect Your Most Important Assets

The introduction to the primary OSHA Standard for Machinery and Machine Guarding (1910.212 General requirements for all machines) states very simply that, “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.” Simple as it sounds, Machine Guarding continues to place on OSHA’s Top 10 Most Frequently Cited Standards; for the 2014 fiscal year, it ranked number nine. That ranking (and many previous years’ rankings) makes it clear that, while one of the most critical concerns in a manufacturing facility, machine guarding isn’t as simple or easy as it sounds.

What Makes Machine Guarding So Difficult

The keys to adequate machine guarding rely heavily on safeguards (physical guards or other devices) that can do several things: prevent contact with a hazard, be secure so that it cannot be easily removed or modified, protect the machine from errant objects falling into the moving parts, create no new hazards, create no interference from performing a job quickly and easily, and allow for safe lubrication.

However, safeguards can only satisfy these requirements for the hazards that have been identified. What often makes machine guarding difficult is not in the actual guarding practice, though that can bring its fair share of complications to the table, but in the assessment and identification of the hazards each machine presents.

While it would be ideal if each piece of machinery, from component saws to multi-ton presses, arrived at a CM’s facility with a comprehensive safety system installed and a safety training manual to accompany it, the realities of this scenario are neither likely nor practical. Each piece of machinery needs to be assessed in situ to ensure that all hazards can be identified, including those presented by the area surrounding the space where the machine is installed.

Employer Responsibility

OSHA places the responsibility for machine guarding in the hands of the employer, rather than the equipment manufacturer. However, the majority of the safety equipment your new machinery will need should be and will be installed at the time it’s manufactured. New machines are often manufactured with safety in mind and are available with many of the proper safeguards installed. However, you are still responsible for a thorough risk assessment of all equipment, new and old alike, to ensure all machine and site-specific concerns are addressed.

If you currently own or have purchased older/used equipment, it’s likely you’ve encountered damaged or missing guards or devices. It’s possible they never existed, but that doesn’t mean they’re unwarranted and, thankfully, it doesn’t mean you can’t get the right guarding in place.

To repair or replace guards, you can usually purchase what you need from the original equipment manufacturer (OEM). OEM guards are often the best option because they were designed specifically for the form and function of the machine. On the downside, they can also be more expensive. Another option involves custom-made guards from an aftermarket manufacturer.

A third option is to build the guards yourself. In this case, the quality of the design and manufacture needs to be a priority and, especially for user-built guards, can also be reason for concern. On the plus side, you’ll be able to control costs while devising guards for machines that meet the legal requirements but also more readily meet your unique manufacturing needs.

It’s important to note that warning signs and labels should never be mistaken as an adequate means to abate a potential hazard. At best, they are useful reminders for machine operator(s) and visual hazard indicators to other employees in the area.

Think Outside the Guard

While a physical guarding solution for many hazards is obvious and straightforward (e.g., a shield, a hood, a bumper), there are plenty of other circumstances that don’t present a clear fix. In some cases, the physical guard causes a “greater hazard” to the operator; we wrote about this in the August 2007 article, “On Guard: A Closer Look at Safeguarding Your Manufacturing Equipment.” When a path to mitigation isn’t clear, creative solutions are in order. There are a number of new, exciting products on the market that do things like stop spinning saw blades in milliseconds. But there are also plenty of tried and true modern answers for complicated hazards. Devices, like light curtains, lasers, pressure sensitive safety mats, dual hand controls, palm buttons, foot switches and many more, provide additional options for eliminating or controlling hazards.

Training

Your machine guarding can only offer maximum protection if the people operating, maintaining and working near the equipment are properly trained and understand how it works. OSHA identifies several crucial factors for a thorough documentation and training program, including:

• Identifying the hazards and providing a description for each.
• Identifying each of the physical guards and/or devices and defining which hazards they protect against and how.
• How to appropriately use the safeguards.
• Who can remove the safeguards and why (maintenance, repair, etc.).
• Protocol when a guard is missing, damaged or malfunctioning.

Employee buy-in for machine guarding is also critical. Getting upfront input from the key people operating your equipment is vital as you look to update or enhance guarding to ensure solutions that are both safe and have a good dose of common sense attached. Going forward, guarding should be an integral part of your training.

Start the Process

In addition to 1910.212, there are several other OSHA standards and appendix references that apply specifically to machine guarding. All told, they hold hundreds of requirements. To complicate the subject, these same standards also refer to, and therefore also can enforce, requirements in numerous non-OSHA standards including 20-plus ANSI standards as well as NFPA 79, the Electrical Standard for Industrial Machinery.

It’s easy to see that this article is just the tip of the proverbial iceberg, but it’s important to have a baseline awareness of the issues that surround machine guarding. In 2015, SBCA’s Management Committee will review the issue of machine guarding and begin working with component manufacturers and equipment manufacturers across the country to gather and develop best practices.

Clearly, it’s not simple, but you have to start someplace. With nearly 6,000 occupational amputations reported in 2011 alone, one thing is clear—machine guarding is imperative. Even if you think you have a serious machine guarding puzzle, rest assured a solution can be found and you have several options for finding it.

Where to Begin?

• Get involved: Join the SBCA Management Committee and work with component and equipment manufacturers toward an industry-specific EquipmentSafety Standard.
• Roll up your sleeves: Utilize your safety committee or create an equipment safety task force to assess the equipment and put together recommendations.
• Call your workers compensation carrier: Their risk consultants will have tools and expertise you can use to drill down into the details and come up with some answers.

Your efforts just might save a finger, an arm, or even a life.