U.S. Machine Safeguarding Regulations – An Overview

U.S. Machine Safeguarding Regulations – An Overview
By Steve Dukich Sr. Commercial Engineer The purpose of this presentation is to provide a top down overview of safety regulations in the United States, and provide comparisons to the organization of regulations in the European Union. We start with OSHA, the law, moved to ANSI and finally discuss some specific standards of interest.

Copyright © 2006 Rockwell Automation, Inc. All rights reserved.
Agenda The OSHA Act Important OSHA Standards National Recognized Testing Labs ANSI U.S. Consensus Standards OSHA Citations Conclusion Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Occupational Safety and Health Act of 1970
OSHA Creation When Occupational Safety and Health Act of 1970 The OSHA act was passed by the U.S. Congress and signed into law by the President Nixon in This ACT has a function and objective similar to that of the Machinery Directive for the European Union. Find the act at this internet location: Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

OSHA Purpose Why 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… Section 2 (b) of the Act describes the purpose of OSHA. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

OSHA Purpose How 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; Section 2 (b) (3) also gives the authority to the Secretary of Labor to create a set of standards and a commission to carry out the functions necessary to satisfy the act. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

OSHA Applicability Where 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. Section 4 (a) states the locations that are covered by the act. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Article 5 What (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. Article 5 sets the basic requirements. Notice that the Act places the responsibility on both the employer and the employee. This is quite divergent from Machinery Directive, which requires suppliers to place machines on the market that are free from hazards. In other words, a supplier can sell a machine in the U.S. without any safeguarding. It is up to the user to make the machine safe. Although this was a common practice when the Act was approved, the trend is for suppliers to provide machines with the safeguarding. Standards are now attempting to get the supplier and user to communicate requirements for safeguarding so that machines are made not only safe but more productive. This article is often referenced in many citations issued by OSHA. If there are no specific standards that OSHA can reference, then the fallback position is simply the employer did not furnish a place free from hazards. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Section 6 Standards What (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. The Secretary of Labor must make known to the public the standards that it feels are required to meet the requirements of the act. This limits the Secretary to national consensus standards and established Federal standards. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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. The OSHA standards are published under Title 29 of the Code of Federal Regulations. These codes can be obtained from the internet, free of charge. This slide shows a picture of a hard copy of the code. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Part 1910 Occupational Safety and Health “Standards”
OSHA standards are available free of monetary charge. The safety and health standards can be found in Part 1910 of the 29 CFR. Common notation is 29 CFR 1910.xxx. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Part 1910 has 21 Subparts 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 This is a list of some of the more important subparts of 1910. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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. Source: page vi of the CFR 29 This is also stated in Subpart A under (a)(1) The standards of agencies of the U.S. Government, and organizations which are not agencies of the U.S. Government which are incorporated by reference in this part, have the same force and effect as other standards in this part. Only the mandatory provisions (i.e., provisions containing the word "shall" or other mandatory language) of standards incorporated by reference are adopted as standards under the Occupational Safety and Health Act. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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. 29 CFR covers the control of hazardous energy. This is commonly known as the Lockout/Tagout standard. The equivalent voluntary standard is ANSI Z Essentially, if you are going to perform service or maintenance on a machine, the power must be locked out. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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. The voluntary standard Z244.1 provides a better description of when the alternative measures can be used. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Subpart O - Machinery and Machine Guarding
Definitions General requirements for all machines Woodworking machinery Cooperage machinery Abrasive wheel machinery Mills and calendars – rubber and plastics Mechanical power presses Forging machines Mechanical power-transmission apparatus Subpart O is titled “Machinery and Machine Guarding”. This subpart lists the general requirements for all machines as well as requirements for some specific machines. OSHA adopted many existing ANSI standards in the 1970s. For example B11.1 for mechanical power presses was adopted as Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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

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

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

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. This point is emphasizing a basic OSHA premise – “hands out of die”. Operators must not have to put their hands in the point of operation. Guarding techniques must take this into account. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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

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 R provides federal standards for some selected industries. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Subpart S - Electrical Addresses electrical safety requirements that are necessary for the practical safeguarding of employees in their workplaces… Appendix A - Reference Documents NFPA (National Electric Code) many other reference documents Subpart S is titled “Electrical”. This is how the National Electric Code is linked to OSHA. Since OSHA calls it a reference document, every requirement (where the word shall is used) in the NEC is an OSHA requirement, Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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). Definitions for Subpart S can be found in 29 CFR NRTL requirements are stated in 29 CFR Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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. These two important definitions, found in , help clarify what falls into the requirements for Electrical devices and what it means to be “Listed”. A common term for products is the have the equipment “UL Listed”, the equipment has been tested by an NRTL, in this case, Underwriter’s Laboratories, and placed on UL’s list of approved equipment. OSHA does not maintain a list of approved equipment. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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) Here is a list of nationally recognized testing labs, as of July Each NRTL will have an approval mark that is registered with OSHA. This of NRTLs and their marks are available on the OSHA website. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Test by UL to meet Canadian and US requirements
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 In general, this agreement works well. On rare occasions, a UL inspector will not accept the CSA mark and vice-versa. From a machine safeguarding perspective, Canadian standards are a little more restrictive than U.S. standards. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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

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. ANSI votes for the U.S. on ISO and IEC standards. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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

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) - ASSE (American Society of Safety Engineers): NFPA (National Fire Prevention Association): PMMI (Packaging Machinery Manufacturer’s Institute): RIA (Robotics Industry Association): UL (Underwriter’s Laboratory) – and many more – see the ANSI website. There are many Standards Developing Organizations in the U.S. Most of these SDOs are not accredited by ANSI, and therefore do not develop national consensus standards. Only ANSI-accredited organizations develop national consensus standards. There are over 200 ASDs in the U.S. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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 Purchase national consensus standards Other purchase locations Global Engineering Documents: global.ihs.com the developing organization National consensus standards are identified by the ANSI mark. The document number is not always preceded by the acronym ANSI. This makes identifying ANSI standards a bit challenging. If you search on the ANSI webstore, consensus standards are identified by the mark. If you go to a popular website, like Global Engineering Documents, you will not always know whether the standard is an ANSI standard. For example, the robot standard is document number RIA R15.06; there is no mention of ANSI in its document number, nor its name. On the other hand, ANSI B11.19 uses the ANSI acronym in its document number. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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 Minor differences exist, so NFPA79 must be used for US machines. Next revision of NFPA 79:2007 will be issued in late 2006. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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 (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.” OSHA will provide interpretations. A person can write a letter to OSHA, and someone from OSHA will respond. These responses are published on OSHA’s website for all to see. The example on this slide was taken from the OSHA website. This interpretation shows that OSHA will use nationally recognized consensus standards to determine compliance to the OHSA Act. What exactly is a nationally recognized consensus standard? Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

ANSI Z244.1-2003 Lockout / Tagout
Published by the American Society of Safety Engineers Updated version of OSHA 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. The history of Z244.1 goes back to OSHA adopted Z244.1 as in The standard was reaffirmed many times. In 1997, Z244.1 began its latest revision process. It was released in The update takes into account many years of casualty data on the uncontrolled release of hazardous energy. It represents best practices in many industries and promotes the use of risk assessment to determine appropriate alternative methods to lockout or tagout. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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. Risk assessment is becoming the norm in the U.S. Many standards, that are undergoing revision, are including a section on risk assessment. B11.TR3, a technical report on risk assessment and risk reduction, is one of the best selling documents reported by ANSI. Although there are no OSHA requirements for risk assessment, U.S. industry is taking notice as it helps determine the most effective method of protecting workers, while also making machines more effective. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

User-Supplier Relationship
Risk Risk Assessment Protective measures taken by supplier design safeguards other protective measures User Input Supplier Input Protective measures taken by user additional safeguards organization training personal protective equipment This flow chart was first published in ANSI B11.TR It attempts to show that the risk is diminished as protective measures are added. It also attempts to show and encourage communication between the supplier and user to reduce risk. Higher levels of risk reduction and machine productivity can be achieved at the design stages of a machine rather than after the machine has been delivered and installed. This flow diagram has been adopted by ISO :2003 Residual Risk Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Universe Model of U.S. Machinery Standards
HS-1738 SAE Automotive Packaging Machines Cooperage B155.1 Printing B11.19 Safeguarding Z244.1 B65.1 B11.TR3 Risk Assessment Lockout/Tagout OSHA Act Woodworking B11.2 General Mfg Cells B11.20 Hydraulic Presses A Level 12100 The OSHA Act is the law created in the U.S. The green planets are OSHA standards. The grey planets are national consensus standards. ISO and -2 have been accepted by the Association of Manufacturing Technology to become nationally recognized standards (ANSI ISO and -2). ANSI B11.TR3 is a widely accepted technical report. In the U.S., standards are not officially classified in the levels of A, B and C, but the reality is that the standards pretty well fall into the same categories, as developed by the EN and ISO standards. Electrical NFPA79 B Level B11.1 C Level Mechanical Presses Forging R15.06 Robots Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Universe Model of EN Machinery Standards
For comparison purposes, the universe model can be applied to the European organization of standards. The Machinery Directive is similar to the OSHA Act. EN1050 (aka EN/ISO14119) is similar to B11.TR3; B155.1  EN415; Z244.1  EN1037, and so on. Many of the EN standards are being revised and replaced by their ISO equivalents. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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

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 OSHA 29 CFR 1904 requires employers to report incidents that require more than first aid. These incidents are compiled and transmitted to local offices and used as part of the inspection drivers. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Penalties Serious up to $7000 per violation Other than Serious discretionary but not more than $7000 Repeat up to $70,000 per violation Willful Violations resulting in death- further penalties Failure to abate $7000/day The penalty cost of violations increases as the seriousness increases, and jumps 10-fold when the violation is a repeated and willful. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

OSHA Top Citations in Manufacturing 10/2004-9/2005
Standard #Cited #Insp $Penalty Description Total 41677 6773 48,947,874 3560 1889 2,952,588 The control of hazardous energy (lockout/tagout). 3332 1730 736,035 Hazard Communication. 2660 2125 3,500,799 General requirements for all machines. 2476 1111 901,148 Respiratory Protection. 2085 1298 1,011,958 Wiring methods, components, and equipment for general use. 1882 1236 897,056 Powered industrial trucks. 1850 958 1,155,765 Mechanical power-transmission apparatus. 1515 1136 873,354 General requirements. 1140 555 594,668 Woodworking machinery requirements. 1123 681 473,381 Abrasive wheel machinery. 1032 760 639,288 990 324 1,142,507 Mechanical power presses. 977 480 863,489 Occupational noise exposure. 959 732 1,017,397 Guarding floor and wall openings and holes. The U.S. government fiscal year runs from Oct to Sept. For the year ending in Sept 2005, 41,677 citations were issued from 6773 inspections. The number 1 standard cited was control of hazardous energy. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

Conclusion OSHA places responsibility for a safe working environment on employers. Machine suppliers and users should apply voluntary consensus standards rather than the out-dated OSHA standards. Electrical equipment must be listed by a NRTL. Risk assessment is required by many ANSI voluntary standards, and is becoming the norm. Copyright © 2006 Rockwell Automation, Inc. All rights reserved.

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