Common Functional Safety Myths

Agenda
• Omron & Safety Expertise

• Common Functional Safety Myths

Introduction
• Michael Joaquin, P.Eng.
• Over 19 years of career experience
• Professional Engineer, with a practice focused on
safety engineering
• Technical Committee for CSA Z432 Safeguarding of
Machinery
• Conducted Risk Assessments, HAZOPs, PSRs, MGR,
arc flash analyses, fire code compliance audits, etc.
• Experience in virtually all types of industries across
Canada, from F&B to pharma to construction to
water/wastewater to R&D
• Taught occupational health and safety-related
courses
Who is Omron?
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Over 35,000 employees globally

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productivity with complete machine and process
safeguarding solutions:

• Door switches
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Myth #1: Machine Safety is
something you can just take care
of once and then forget about
“We check our machines
when we buy them and
that is good ‘nough”
Fact: Machine Safety is an ongoing requirement
Changes happen through seemingly innocuous actions, for example
planned and unplanned maintenance downtime, process
improvement initiatives, etc.

Companies must have regular risk assessments performed on their

machines to ensure that they meet the most recent safety standards

Under most circumstances, whenever equipment is moved, a new

risk assessment is required

Annual Stop Time Measurement (STM) analysis ensure equipment

hazardous motion has ceased within intended design parameters
Myth #2:

Administrative controls and

comprehensive employee safety
training can replace good
engineering
“We keep training until operators stop
getting injured”
 RISK REDUCTION
MEASURE
EXAMPLES CLASSIFICATION Fact: Protective measure shall be
Most
Effective
•

•
Redesign the process to eliminate
or reduce human interaction
Automated material handling
determined by risk assessment
Elimination Design Out
(robots, conveyors, etc.)
or • Intrinsically safe design (Energy
Containment)
Specialized training alone shall not be used as a means
Substitution
•
•
Reduce energy
Substitute hazardous with less
of reducing the probability of a hazardous event if it
hazardous chemicals etc.. cannot be assured that all individuals exposed to the
hazard will have that level of training/knowledge
Safeguarding
•
•
Barriers/Interlocks
Presence sensing devices (light
(B11.0 – 6.6 (2015))
Technologies / curtains, safety mats, area Engineering
scanners, etc.)
Protective Devices Controls
• Two hand control and two hand
trip devices
Achieve the Highest level of reliability:
Awareness Means
•
•
Lights, beacons, and strobes
Computer warnings
1. Design out: Eliminate the hazard or substituting other
• Signs and labels materials, processes, or equipment
• Beepers, horns, and sirens
2. Implement engineering controls: install safety
Training and
•
•
Safe work procedures
Training Administrative technologies to protect the operator
• Lockout / Tagout / Tryout Controls
Procedures

Personal
Administrative Controls (PPE/Procedures) & training
• Safety glasses / face shields
Least Protective • Ear plugs & Gloves
Effective Equipment
(PPE)
•
•
Protective footwear
Respirators are the least effective, as they rely on worker action
and/or attentiveness in order to be effective
Fact: Protective measure shall be
determined by risk assessment
Specialized training alone shall not be used as a means
of reducing the probability of a hazardous event if it
cannot be assured that all individuals exposed to the
hazard will have that level of training/knowledge
(B11.0 – 6.6 (2015))

Achieve the Highest level of reliability:

1. Design out: Eliminate the hazard or substituting other
materials, processes, or equipment
2. Implement engineering controls: install safety
technologies to protect the operator

Administrative Controls (PPE/Procedures) & training

are the least effective, as they rely on worker action
and/or attentiveness in order to be effective
Myth #3:

Older machines are

“grandfathered in,” so
they don’t need
safeguarding
“That machine is so old,
no one cares”
Fact: No exemption for older machinery
• It is typical to think of applying safeguarding of
machinery to newly manufactured, rebuilt, and
redeployed machinery

• Existing machinery that is non-compliant must

be upgraded

• Employers have a legal duty to provide a safe

work environment—no matter how old the
equipment is
Myth #4:

An inspector can only cite

you for a violation on the
first review of a machine
“The inspector was just
here and did not say
anything about machine
safety-so I have no
worries”
Fact: You can cited at any time
• An inspector doesn’t need to pass judgement
on every single piece of equipment at a client
facility

• It’s possible that another inspector who arrives

later may issue orders for compliance on a
machine that the first inspector already
examined

• Many regulatory agencies do special

enforcement programs to re-inspect equipment
for specific requirements
Myth #5: The CSA and ANSI
standards are law
Fact: Standards are not the Law
A standard is a guideline that can be used to demonstrate
compliance with the law

Legislation is the law, and it can be imposed by enforcement officers

(i.e. inspectors)

Regulatory organizations will reference a standard as to what to do.

Myth #6:

If you have several

machines that are
identical, you only Picture

need to do a risk
assessment for one
of them.
Fact: Its Complicated
Depends on the complexity of the machine and the
location of installation

One risk assessment listing all of the unique identifiers

for each machine (i.e. serial numbers) can be
acceptable

Equipment must be identical in:

1. Design
2. Operation
3. Installation Parameters

Best practice is to do a risk assessments for all

machines
Myth #7:

There are machine

safeguarding exemptions for
smaller companies
“The Inspector only cares
about the big companies”
Fact: Safety regulations apply to all companies
• All companies are required to safeguard their machines properly
and protect the lives and safety of their employees

• OSHA, MOL & NOM: no exemptions for size of business or

number of employees

• Business size may only impact size of fine if the company is found
in violation of a safety regulation
Myth #8:

Performance requirements for

safety measures “stop at the
wire” Picture
Fact: Performance Requirements applies to all energy sources

• Many believe that safeguarding is only necessary when the

energy source is electrical

• All possible energy sources need to be “single fault tolerant” :

• Electrical
• Hydraulic
• Pneumatic

Other sources of energy can pose significant risks to workers

Myth #9:

The machine’s OEM is

responsible for doing the risk
assessment, so if a machine is
certified to be safe, nothing
more needs to be done
“It is a brand new
machine. It should be
compliant”
Fact: The end user has final responsibility
• The employer is responsible for ensuring worker
safety, whether or not an OEM has certified a
machine as safe

• Legislation attributes the obligation of worker

safety, in particular machine safeguarding, to the
employer

• Depending on your location, the OEM may not

install any safety devices or even provide a risk
assessment

• Even if the OEM provides a risk assessment, the

employer is still responsible for ensuring the
compliance of the equipment
Myth #10:

Using a padlock to prevent

access on a movable guard is an
acceptable and sufficient safety
measure.
“We are only in there twice per
shift and I keep the key in my
pocket”
Fact: Movable Guards Shall be Interlocked
ANSI B11.19
The user shall ensure that barrier guards that are frequently
removed or that have movable or hinged sections are
interlocked.
CSA Z432-04
Movable guards that provide protection against hazards
generated by moving transmission parts shall
• remain fixed to the machinery or other structure (generally by means
of hinges or guides) when open; and
• be interlocking guards with or without guard locking in order to
prevent moving parts starting up as long as these parts can be reached
and to give a stop command whenever they are no longer closed.
ISO 12100
Movable guards which provide protection against hazards
generated by moving transmission parts shall:
º as far as possible remain fixed to the machinery or other
structure (generally by means of hinges or guides) when open;
º be interlocking guards (with guard locking when necessary).
Myth #11:

Safety is more important for a

younger employee.

“I don’t have any millennials

working for me, so it is not a
problem ”
 Distribution of Non-Fatal Injuries by Age Group
2018*
30%

25%
Fact: Safety is important for all ages
20%
Workers younger than 25 do have non-fatal
15%

10%
injuries at slightly higher rates than older worker
5%

But workers older than 45 are 37% of the non-

0%
16 to 24 25 to 34 35 to 44 45 to 54 55 to 64 65 and over

fatal injuries in any given year

Distribution of Fatal Injuries by Age Group
2018*
25%
Fatal Injuries, however, increase significantly
20% with worker age
15%

10%

5% Workers older than 45 are approximately 62% of

0% the deaths in a given year
16-24 25-34 35-44 45-54 55-64 65 and over

*US Bureau of Labor and Statics-Dec 2019 Injuries and fatalities from
“Contact with objects and equipment”
Myth #12:

Safety is too expensive, and

it reduces productivity and
efficiency by adding extra
steps to key processes
Fact: Not addressing safety can be expensive
Cost of a Fatality:
• $991,027 Direct Costs (Center for Disease Control 2017: NIOSH Dataset SD-1002-2017-0)
• $2,100,977 Indirect Costs (National Safety Council, Injury Facts Sheet 2019)

Cost of an Amputation:
• $98,126 Direct Costs (National Safety Council, Injury Facts Sheet 2019)
• $208,027 Indirect Costs (National Safety Council, Injury Facts Sheet 2019)

ROI of Safeguarding Correctly :

• For every $1 invested, ROI of $2-$6 (National Safety Council, Injury Facts Sheet 2014)
Thank You!
Questions?
Michael Joaquin, P.Eng., Safety Services Specialist | (416) 320-1381 | michael.joaquin@omron.com
www.automation.omron.com