April 2014 newsletter
- Does OSHA Understand its Own Machine and Equipment Guarding Directive?
- Journey to Risk Elimination
- FDRsafety enhances recruiting services
Does OSHA Understand its Own Machine and Equipment Guarding Directive?
By Jim Stanley and Mike Taubitz
Machine and equipment guarding by location or position is a topic the two of us have discussed many times in recent months. Over the past several years, OSHA has increased citations to employers for failure to guard or adequately guard machinery and equipment, which suggests that the agency has forgotten or pays no attention to its previous guidance.
First some background: FDRsafety continues to have clients contact us about OSHA citations/violations for not guarding or improperly guarding shafts, belts and other power transmission equipment and/or machinery. In many cases, the moving parts of machinery and/or equipment are located in areas where there are no workers, except those who perform service and maintenance on the machinery and/or equipment using (hopefully) lockout/tagout. It would appear that OSHA believes that all machinery/equipment with moving parts requires guarding regardless of its location or position. OSHA’s position is just wrong.
OSHA STD 01-12-014, which is a clarification of 29 CFR 1910.219, states in part:
In some instances, the application of “enclosed” and “fully enclosed” has been interpreted to mean that all four sides of a power transmission belt must be covered by an enclosure. This application has been enforced even when guarding by location has been accomplished by the belts running close enough to walls and other objects to present no exposure to employees.
What that means is that when there is no employee exposure to power transmission belts because they are naturally guarded by location, then no enclosure or guarding is required.
ASME B 20.1 – 2012, which is the safety standard for conveyors and related equipment, has more on this topic:
Where necessary for the protection of personnel from hazards, all exposed moving machinery parts that present a hazard to personnel at workstations or operators’ stations shall be mechanically or electrically guarded or guarded by location or position.
Remoteness from frequent presence of employed personnel shall constitute guarding by location.
The key is this: Where there is no exposure, there is no hazard. Just because machinery or equipment is moving does not mean it requires a guard.
If you believe that you are required to have a guard around all moving machinery and equipment in your facility, perhaps you should considering consulting with a safety professional.
Jim Stanley is a former Deputy Assistant Secretary of Labor for OSHA. Mike Taubitz, a senior advisor at FDRsafety, is a former Global Safety Director for General Motors.
For questions about this article, contact them at info@fdrsafety.com or (888) 755-8010.
Journey to Risk Elimination
To start the process of creating a world-class safety program, answer these two questions:
- Will your organization pass the test of today’s increased regulatory review by OSHA?
- Do you have an integrated system to ensure that the training, controls and programs in place today will sustain themselves and allow senior management to monitor occupational safety and health performance as they do any other facet of the business?
If the answer to #1 or #2 is “no” or “uncertain” you may wish to consider FDRsafety’s Journey to Risk Elimination approach to drive continuous improvement in your organization.
FDRsafety can help reduce uncertainty while:
- Improving occupational safety and health operational performance,
- Integrating occupational safety and health into company processes,
- Teaching your employees how to carry on the Journey to Risk Elimination as part of their job,
- Linking occupational safety and health to long-term initiatives like sustainability and corporate social responsibility,
- Leveraging your occupational safety and health program to create a competitive advantage.
We offer a three-step approach to help company leaders identify systemic occupational safety and health issues and create a tailored approach to the organization’s problems and concerns.
- Determine your current state (onsite assessment):
- Determine key concerns of senior management and stakeholders
- Obtain input from key personnel
- Review processes
- Empirically measure the progress of the occupational safety and health program
- Analyze information and review options to deal with problems/issues
- Prepare a report for leadership’s review and consideration of next steps that may include:
- Risk assessments, education and training, safety awareness classes and services related to the integration of occupational safety and health into the business and creation of a roadmap for a risk elimination culture
- Guidance on occupational safety and health standard work elements to meet OSHA requirements
- Establishment of an occupational safety and health assessment program
Journey to Risk Elimination Seminars
A key to establishing the right culture is the Journey to Risk Elimination Seminars that are tailored to your industry and company. The object of the seminars is to establish a culture of ownership by all employees. This training uses principles of operational excellence to drive a culture of risk elimination.
- Sessions begin with the leadership team and then cascade through the entire organization.
- Through the use of illustrations in the classroom and field exercises, employees are taught to see risk elimination as a journey rather than a destination.
- The course heightens employees’ awareness of risks and supports the development of a culture of eliminating them – a culture that goes beyond occupational safety and health and reduces risks in other disciplines.
- The system fosters a holistic approach to occupational safety and reinforces the concept that safety is a 24/7 lifestyle.
Through real life examples and illustrations from their workplace, managers and employees are taught to identify occupational safety and health risks and eliminate them before they result in incidents or exposures. Tools are provided to identify risks and track corrective and preventative actions to eliminate them.
For more information, contact FDRsafety at info@fdrsafety.com or (888) 755-8010
FDRsafety enhances recruiting services
We are excited to announce that FDRsafety’s recruiting services have been enhanced with an expanded team dedicated to finding the permanent safety professional best suited to meet your company’s unique safety and health needs.
Advantages of utilizing FDRsafety recruiting include:
We are safety professionals recruiting safety professionals – FDRsafety is well-connected in the industry, which enables us to keep a full database of qualified candidates. Because this is our area of expertise, FDRsafety exclusively recruits safety professionals for our clients.
We save you time and money. Candidates we present you are well qualified – not just names an agency gathered from an internet ad. FDRsafety pre-screens all candidates through performing interviews and reference checks. This allows us to expedite the process of hiring a permanent safety professional, from your initial request to the fulfillment of the position. FDRsafety is an economical solution to filling your organization’s open safety positions.
We guarantee our work. If you hire one of our candidates and you are not completely satisfied within the first six months, we will recruit a replacement at no additional charge.
For more information, contact FDRsafety at info@fdrsafety.com or (888) 755-8010
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