Date First Published on SafetySmart Compliance: November 9th, 2012
As with any other set of hazards or equipment, controlling machine hazards starts with an assessment of the hazards involved. Here’s an overview of how to conduct such a hazard assessment for machine guarding.
What the OSHA Standard Says—and Doesn’t Say
As a general matter, OSHA requires that employers proactively perform hazard assessments to assure that the workplace is free from recognized safety and health hazards. Machine guarding requirements are more specific than other requirements. Whereas OSHA’s typical address is to lay out broad measures for employers to implement based on the hazards and particular situations involved, Machine Guarding removes much of the assessment and discretionary element.
Machine guard measures are based on the kinds of machines in the workplace and don’t leave a lot of room for flexibility. Accordingly, hazard assessment isn’t directly addressed in the machinery guarding sub-chapter.
Conducting Machine Hazard Assessments
However, hazard assessments do have to be performed to account for the particular hazards posed by the unique site conditions of your workplace and your application of machinery, e.g., machine configuration, equipment used, number of operators, etc. Hazard assessment should be performed:
- When the machine is first installed;
- When the machine is moved from one place to another in your facility;
- At intervals recommended by the manufacturer or if no recommendations can be located, at least monthly;
- Before being placed back into service following preventative maintenance or repairs; and
- Following the report an incident that injures an employee, potentially injures an employee; or
- When the machine malfunctions.
Consider the type of machinery, the manufacturer, where and when it was purchased, the location of the machinery, preventative maintenance requirements. You should also look at how many employees operate the machinery and what type of training program currently exist to train new employees. Here are some other questions that you should be asking while you are completing your hazard assessment:
- What are the hazards associated with the machine?
- What are the guards and how do they work?
- How do you use the guards?
- How and under what circumstances and by whom may guards be removed?
- What should you do if a safeguard is missing, damaged or ineffective?
Action Items for Hazard Assessment
Here’s a basic game plan listing the actions you can take:
- Gather a small working group consisting of any dedicated safety employees in your organization, at least one production/process supervisor, one member if the Maintenance Department and one or two line staff. If you have a Safety Committee, they can be responsible for the tasks in part or entirely. In addition, you could add Management staff, HR staff and representatives of other major departments in your organization.
- Spend at least the first meeting talking about what hazards you have and what existing written programs are already in place. Consider how well guarded your machinery is and whether or not you think employees routinely bypass guards or take them off for repairs and don’t put them back on. Think about how many of your employees work with hazardous machinery and how you train new employees on the tasks.
- Develop a basic Machine Safety Program that lists the rules in your workplace for working with machines as well as the requirements for the use of guards. It should also include procedures for inspecting machinery, training workers on machine safety and other elements as necessary.
- Develop a list of machines in your workspace that are not properly guarded as well as an Action Plan for obtaining the necessary guards.