Keeping Safety up to Date During Market Changes

The value of a safety risk assessment

Modern safety starts and ends with a risk assessment to evaluate how people are interacting with machines and that the proper safety procedures and equipment are implemented and available.  Whenever equipment is new in a facility or has been modified, a risk assessment should be undertaken to evaluate what changes must be made to ensure that the machine is safe to operate and maintain.

A safety risk assessment identifies the tasks that are regularly performed while interacting with the machine. The safety consultant meets with the machine operator and anyone else who works with the equipment, including maintenance personnel and cleaners. The consultant will review the tasks the machine operator is performing on the machine, and the risk levels of those tasks. Are the interlock doors working effectively?  Is the operator bypassing machine guarding?  When they are adjusting a box that is out of position on a packaging line, are they putting their hands in harm’s way?  How likely is it that the machine could start running for some reason?  Is the air valve automatically purging air when the line is stopped to pick up a fallen part or product?  If not, the operator could pinch a finger. The safety consultant will check that the proper safeguards are in place. 

Certain tasks might be done more safely with the addition of safeguards like light curtains or interlock doors. For example, a light curtain is good for repetitive tasks.  But around a robot, you may want to consider hard guarding or physical barriers like an interlock door or fencing, to defend the space better.  What is the probability of a machine energizing, especially one that has no guarding in place?

Another factor the safety consultant studies is frequency of access.  When the interlock door opens, is the circuit robust enough to properly protect the person doing the task? If the door is interlock single channel without monitoring and the wire breaks, the machine won’t be able to sense whether the door is open or not. For a task done once per minute, a light curtain is a better choice than interlock doors.

If you’re not already convinced on its value, a safety assessment can identify any potential gaps in compliance and guarding and improve your bottom line. There may be improvement opportunities for how someone is doing the task. If machine safety and guarding can be robust enough, you don’t need lockout/tagout for those tasks.  The plant’s productivity and ROI is much better when you don’t need to shut down completely.  There is likely room for improvement and the consultant can provide feedback on the current setup and recommendations for what it should be.

It’s important to choose a safety partner that is properly certified by an industry-recognized safety organization to help you with your machine safety assessment, so that they are using the most current, international standards. They will break down the line into components and provide a quote for the number of pieces of equipment. The safety assessment also includes safety improvement recommendations, such as redesigning a machine to make it more accessible to do what the machine operator is trying to get it to do, without a total shutdown.

Are your lockout/tagout procedures up to date?

One of the first things that must be verified or created for new or modified equipment is the lockout/tagout procedure for the control of hazardous energy. Having an up-to-date and complete lockout/tagout procedure is critical to instruct maintenance employees how to put the machine in a zero-energy state so that there is no movement. It’s also required by OSHA for all equipment with multiple sources of hazardous energy.

Have you updated your LOTO procedure with changes in the production line? Are new employees trained on the procedure and are LOTO placards posted? Lockout/tagout procedures are a great way to help protect workers during heavy maintenance.  For routine tasks, however, LOTO is not always the most practical solution. In fact, OSHA allows alternative protective measures for certain routine tasks.

Take advantage of minor servicing exceptions

Risk assessments can be used to identify tasks that meet the qualifications of OSHA’s minor servicing exception to the lockout/tagout regulation.  The risk assessment will then also determine how robust your alternative safety measures must be to protect the employees interacting with the machine.  With the proper safety guards in place, routine tasks such as loading and unloading, tool changes, setup or minor cleaning may be able to be completed without lockout/tagout. Taking advantage of this minor servicing exception will result in less downtime, while making it less likely for employees to take short cuts that can lead to injuries. 

A checklist for whether your safety procedures have kept up

You may wonder where to start to determine whether your safety procedures have kept up with production changes. This manufacturing safety checklist will help you quickly evaluate if your safety procedures have kept up with change or not.

1. Do you have documented LOTO procedures? Do they extend to minor servicing procedures? This can help keep production running without a total lockout of the equipment.
2. Review the age of your LOTO procedures - are they several years old? If so, the rest of the safety program is probably outdated.  LOTO is the frontline of any safety program, and yet every year it’s in the top 10 most cited OSHA violations.
3.  If your machinery is older, then you probably don’t have safety system components with which you can use the minor servicing exception.
   
4. Do you have warning signs identifying confined spaces, and a confined space inventory?  The signage should specify if the space is designated as permit required, no permit required or no entry. Best practice is to have evaluations or entry procedures documenting the hazards associated with it, so that no one becomes engulfed or entrapped. Do you have a designated emergency responder on-site and in the community? Examples of confined spaces can include siloes, hoppers, air handlers and tanks.
5. Only authorized employees should perform servicing and maintenance tasks. Do you have documentation detailing who can perform certain tasks, for example a machine operator vs. a maintenance technician?  Best practice is to communicate and document this clearly, even though this is not required by OSHA.
6. Have you offered lockout/tagout training to employees using equipment they are not familiar with, or new equipment?  The hardware installer generally offers training after the equipment has been installed.

Safety, much like a production process, is a lifecycle and should be continuously reevaluated to make sure it is the best that it can be.  Manufacturing safety should not be overlooked. Investing in safety can be used to help upgrade production capabilities so that your machines are up and running more, with less time offline. 

If you need help with your safety program or have questions, Rockwell Automation can help you make sure that you have everything you need for a productive and safe work environment.  Reach out to RACSMSAFETY@ra.rockwell.com and our TÜV Rheinland-certified safety experts will put you on the right path.