Web Exclusive Feature: Machine Guarding Made Easy

American industry can be proud of the many advances in occupational safety and health that have evolved during OSHA’s 40-year reign. While industry has made laudable gains, there are some fundamental areas where progress has been surprisingly – and depressingly – slow. Machine and equipment guarding is one area where problems still exist.

Here are some facts about machine and equipment guarding from an OSHA enforcement perspective (federal agency data only):

• Of the hundreds of enforceable standards for general industry, only seven deal directly with guarding of fixed machinery or equipment.
• Compared to many other standards (e.g., process safety management, HAZWOPER, confined space entry, asbestos), these seven guarding standards seem easy to understand and apply.
• Compared to some other topics, machine guarding requirements have not changed much in the 40 years of OSHA’s existence, even though other complex regulatory topics have been introduced or changed during this period (e.g., arc flash, hazard communication) and writers of consensus standards – including standards dealing with machine guarding topics – continued their periodic revisions to keep pace with technological advances.
• Machine guard violations remain consequential in today’s world. During FY 2010, 24 percent of OSHA’s Top 10 citations for manufacturing dealt with machine guarding violations. Those violations resulted in more than $6 million in proposed penalties. Most of the violations were judged as serious violations, which can carry a penalty of up to $7,000 per instance. Repeated or willful violations can result in penalties of up to $70,000 per instance.

While OSHA’s penalties for machine guarding violations don’t tell the whole story, they illustrate how much work remains in dealing with this “simple” problem with a scope that remains difficult to define. There’s no doubt about it: Machine and equipment guarding continues to challenge American industry.

Unfortunately, the most common way to learn of a machine or equipment guarding shortcoming is when an injury occurs. Furthermore, accidents associated with improperly or inadequately guarded machines or equipment often produce more severe injuries.

The Bureau of Labor Statistics presents more disappointing data. Despite improvements during recent years, nearly 6,000 occupational amputations were recorded in the United States during 2009. Many of these amputations are products of improperly guarded machines or equipment or lockout violations. 

Ignorance is No Defense

While it is unknown how many of the referenced machine guarding injuries or violations were detected after the employer had taken action to adequately guard the equipment in question, the existence of such cases is well documented. For example:

• An operator of a hydraulic press was crushed to death when he reached inside of the press to unload an assembly. The press was equipped with light curtains and fixed guards, and the employer had contracted design and installation of the guarding. The press utilized presence-sensing device initiation (PSDI) to automatically cycle the machine when the area protected by the light curtain was cleared. The press operator, who had a slight build, unintentionally moved inside of the light curtain, which signaled the press to cycle. The guarding was judged to be inadequate and improperly installed.
• An operator of a machining center with integrated robotics incurred a crushing injury that resulted in a leg amputation. The equipment had been used safely for many years and seemed totally enclosed by fencing and failsafe, interlocked gates. The guarding arrangement was designed by the machining center manufacturer and installed by a plant maintenance crew. Parts were fed through an opening in the fenced enclosure by a powered work-holding fixture (pallet). The operator crawled through this small fence opening to make a “quick” adjustment when he sustained the injury. Prior to the incident, the fence opening was not considered as a viable means of ingress. Remedial action included installation of strategically placed light curtains around the fence opening.

Impact of Improperly Guarded Equipment

While injured workers are the ultimate victims of accidents, their employers don’t escape unscathed, either. The business impacts of accidents and injury are both tangible and intangible. Cost leads the way in terms of tangible impacts, including increased workers’ compensation costs, OSHA penalties and legal fees.