Loureiro notes a trend with respect to the enforcement of machine guarding regulations. During a routine audit, an inspector will view guarding requirements in the context of OSHA standards. But in the unfortunate event of an accident, OSHA has established a precedent of enforcing against the stricter ANSI Standards. Industries may be under the impression that they have adequately guarded their machines as often OSHA chooses not to apply the ANSI Standards during routine site visits and inspections. The lack of comment or enforcement by OSHA during the routine audit can lull a facility into a false sense of confidence that they have done everything necessary from a machine guarding standpoint as the ANSI standard may apply if there is a problem.
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The OSHA standard requiring machine guarding assessments and the guarding of powered machine tools has been around for decades. Moving machine parts can cause severe workplace injuries including crushed fingers or hands, amputations, burns, or blindness. Safeguards including machine guarding are essential for protecting workers from these preventable injuries. Any machine part, function, or process that may cause injury must be safeguarded. Summarizing the standard, when the potential exists for inadvertent contact with the point of operation of a machine or accidental contact could injure the operator or others in the vicinity, the hazards must be eliminated or controlled. In addition to the point of operation, one must also guard power generation devices such as drive belts and rotating shafts that may be associated with the machine’s operation but not associated with the operator’s routine activities.
All powered machine tools must be assessed and guarded in accordance with OSHA Standards. But the OSHA standards lack specificity and are much less stringent than the more recent ANSI Standards. Meeting the ANSI Standards requires a much higher level of effort as ANSI goes well beyond barrier guarding and strives to ”mistake-proof” the inadvertent access to all machine hazards. Such guarding can be accomplished through electronic sensing of the presence of the operator, electronic sensors that immediately shut a machine off or sensors that cause the movement of the machine to cease immediately.
Loureiro performs machine guarding assessments, designs the guarding systems and installs the guards. We also work closely throughout the process with our clients’ operators to ensure the final product meets all essential needs. Some of our clients have older often more difficult machines to guard. We have worked with clients to overcome software programming and other electronic issues involved with the guard/machine interface. Sometimes (depending on the severity of the hazard) redundant guarding systems are required.
An essential ingredient in designing a successful machine guarding program is involving those who will actually use the equipment. Involvement of the operators throughout the process greatly increases the probability that the ultimate guard will be not only effective for the purpose of minimizing hazards but will also allow the operator to accomplish the necessary tasks with the machine. Failing to actively engage the operator during the design and installation process can result in hazards not being recognized and addressed, the operator not being able to accomplish their task and the operator’s unwillingness to embrace the need for the guard.
Loureiro recommends that our clients not be lulled into a false sense of security when an internal or external OSHA inspection indicates compliance with or remains silent on whether your guarding meets the intent of OSHA regulations. We recommend that clients reviewing their machine guarding needs evaluate compliance with OSHA as a starting point but attempt to achieve the ANSI standards. In the unfortunate and, hopefully, unlikely event of an injury associated with machine operation experience indicates you should expect to be held to the higher ANSI standard.
Be on your guard.
Loureiro Engineering Associates, Inc.
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