On guards: Keeping workers safe around machines and moving parts
Machine guarding is a perennial fixture on OSHA’s annual list of the Top 10 most frequently cited workplace safety violations. It ranked ninth in fiscal year 2018 after coming in at No. 8 in FY 2017 – accounting for more than 4,000 violations over both years.
It’s on a similar list in Michael Brodzik’s home state of Michigan. However, neither list reveals the full scope of the hazard, he claims.
“There are specific machine guarding requirements that are frequently cited and wouldn’t be captured in the Top 10,” said Brodzik, a senior occupational safety consultant for the Michigan Occupational Safety and Health Administration’s Consultation Education and Training Division.
The incidents that earn machine guarding a spot on federal OSHA’s annual Top 10 list violate the general requirements in the standard’s general industry section (29 CFR 1910.212). But the standard also has sections for construction (29 CFR 1926), agriculture (1928), longshoring (1918) and marine terminals (1917). Then, within the general industry requirements is Subpart R, which covers textiles, bakery equipment and telecommunications.
“There is an almost limitless possibility of machines [that] form, process, manufacture, move and/or manipulate something,” Brodzik said.
What to do
Machinery-related hazards include not only the risk of amputation or body parts and clothing getting caught in equipment, but also workers being hit by flying chips of material and sparks.
To make the wide-ranging aspects of this less overwhelming, a National Safety Council training program document – “Machine Safeguarding – Module 12” – breaks down the OSHA requirements for protecting workers into three main parts:
- Point of operation (where work is performed)
- Power transmission equipment
- Any other moving parts
Linda Martin, president of the Board of Certified Safety Professionals’ board of directors and lead editor of the NSC “Supervisors’ Safety Manual,” said employers should prioritize their safeguarding efforts based on “probability and severity” of risks, and risk assessment should be used for the purchase and design of new equipment as well as any audits of older machines.
The hazard analysis also should include observing operators and getting their input.
“From the moment they start to operate the machine, you look at the design and you think, ‘Well, could someone potentially get hurt because of a moving part of a machine?’ If the answer is yes, then you have to guard against it,” said Namir George, senior safety consultant and manager of international consulting services at NSC.
The four general types of guards, according to OSHA, are fixed, interlocked, adjustable and self-adjusting. These guards should:
- Conform to or surpass applicable regulations.
- Prevent worker body parts from making contact with the point of operation, “danger zones” or any other hazardous moving parts.
- Be a permanent part of the machine (not easily removed or tampered with).
- Be strong and durable.
- Not interfere with the operation of a machine, or weaken its structure or other equipment.
- Be properly designed for the machine and the job.
- Not create additional hazards, such as sharp or jagged edges.
- Ensure objects can’t fall into moving parts.
- Be resistant to corrosion and fire.
An operator should be able to turn off the power “without leaving his position at the point of operation,” OSHA says on its Machine Guarding eTool website.
Securing management buy-in for machine guarding is vital, because adding proper guards might mean a little more cost.
“Machine safeguarding is not as simple, and generally is not cheap, to implement,” said Linda Martin, lead editor of the National Safety Council “Supervisors’ Safety Manual” and president of the Board of Certified Safety Professionals’ board of directors. “Management has to be committed.”
Employers who look to buy older (and less expensive) machines might find the proper guards are missing because they weren’t required when the equipment was manufactured.
Some employers may have misconceptions, Martin said, that these machines are exempt from OSHA regulations, and that new machines “automatically come from the factory completely compliant.”
Sometimes, machines may come from another country where guarding regulations are not as stringent or, as Michael Brodzik, a senior occupational safety consultant for the Michigan Occupational Safety and Health Administration’s Consultation Education and Training Division, points out, are bought at an auction without all of the proper parts.
Namir George, senior safety consultant and manager of international consulting services at NSC, advises double-checking guards to ensure they comply with any applicable standards, even if the manufacturer claims its safeguarding equipment complies with regulations.
The best safeguards are the ones built by machine or safeguard manufacturers, NSC states.
Operators and workers who maintain machines suffer an estimated 800 deaths and 18,000 amputations, lacerations, crushing injuries or abrasions every year, according to OSHA. The contributing factors, experts note, are some of the usual culprits: putting time and cost concerns ahead of safety, subpar maintenance and repair, and inadequate training.
Concerns regarding time or complacency can lead to shortcuts, and those can include workers removing guards because they think it’s a faster or more efficient way to get the task done – especially when there’s inadequate supervision.
“People have done the same job for several years,” George said, “and they know they can do it without the guards. And they know they can get away with it.”
Sometimes, workers remove guards to perform maintenance (e.g., lubricating a machine) and forget to put them back on when they’re done.
“If possible, one should be able to lubricate the machine without removing the safeguards,” OSHA states. An applicable solution, the agency adds, is placing oil reservoirs outside the guard with a line that leads into the “lubrication point.” This will reduce the frequency of workers having to reach into the dangerous area.
Instructing workers on the importance of safeguards is vital, and OSHA recommends education or hands-on training cover:
- Descriptions and identification of the hazards associated with certain machines.
- How the safeguards function and protect workers from specific hazards.
- How to use the guards.
- Who is authorized to remove safeguards and under what circumstances.
- What to do if a guard is damaged, missing or cannot provide adequate protection.
Workers should understand “the importance of hazardous energy control and release of stored energy,” Martin said, adding “they might remove the guards for maintenance, or to clear jams or fix other malfunctions, and think that ‘not moving’ means that a machine or point of operation is safe.”
The NSC training document recommends enforcing safeguard use as one of its five steps in a systematic approach, along with identifying hazards and assessing risks. The other two are finding solutions to guarding problems and supervision. Supervision includes checking that guards are in place before work begins and incorporating these reviews in normal safety and health inspections. Along with workers, supervisors should do their part to alert the proper personnel that a guard is missing or needs replacing.
“Everybody needs to make sure that people are empowered, that everybody follows the rules, including supervisors and management,” George said.
An effective safeguarding program also involves supervisors and other managers setting good examples by ensuring guards are used correctly.
“If they watch their supervisor (work without the safeguard), then that’s the message” employees are receiving, George said.
Consult the experts
If you’re unclear where to start or how to improve your organization’s safeguarding program, Brodzik suggests taking advantage of free consultation – either from OSHA via its On-Site Consultation Program or your state.
Insurance companies also provide consulting services, and some trade organizations may have resources as well, Brodzik said.
“You need to go beyond compliance,” George said. “What can we do to try to protect employees from hazards associated with moving parts of a machine? That’s the question you should always ask.”