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Risk Assessment Compliance
Site Review Recommended Spare Parts
Operator Manual
Maintenance
M i t Manual
M l
Why Safeguard?
Acceptable Maintenance Practices?
Why should you Safeguard?
Because it hurts if you don’t……
Circuit Performance:
• Light Curtains wired into Machine Stop
Circuit
• Category
g y B per
p ISO 13849
• No Force‐Guided Relays (Safety Rated)
• Category B per ISO 13849
• No Redundancy
• Category B per ISO 13849
• No Monitoring of output circuit
• Category B per ISO 13849
What does this mean?
• Current Safeguards are
providing the illusion of
“providing
safety”
• Current Safeguards are a
waste of time and money
• Unable to claim
compliance to any
national or international
safety standards.
In America, are employers
REQUIRED to Safeguard?
What about Machine Builders?
It Depends…..
What does it depend on?
1. Where is the machine going?
Part 1902:
PartPart
24: Procedures
70: Production PartPart 1903:
70: Production
PartPart
24: Procedures
1910: PartPart 24: Procedures
70: Production
PartPart
24: Procedures
70: Production
Part 70A:Part State
1901:Plans forPart
Protection the 70A: Protection
PartPart
70A:70A:
Protection
Protection
PartPart
70A:70A:
Protection
Protection
for the
or Disclosure
Handling ofof Inspection,
or Disclosure
Citations,
for the
of
Occupational
Handling of
for
Safety
the
or Disclosure
Handling ofoffor the
or Disclosure
Handling ofof
Part 1919:
of Individual Development
PartProcedures
Privacy
1900: Reserved and
for State
of Individual of
Privacy
Individual
of Individual
Privacy
Privacy
of Individual
of Individual
Privacy
Privacy
Retaliation
Information or and Information
ProposedRetaliation
orand Health Retaliation
Information orRetaliation
Information
Gear Certification
or
in Records
Agreements
Enforcement of in State
Records in Records
in Records in Recordsin Records
Complains
Materials Penalties
Materials Complains
Standards Complains
Materials Complains
Materials
Standards
PartPart
24: Procedures
70: Production
PartPart
24: Procedures
70: Production
PartPart
24: Procedures
70: Production
PartPart
24: Procedures
70: Production
PartPart
24: Procedures
70: Production
PartPart
24: Procedures
70:
PartProduction
2400:
Part 70A: Protection
Part 70A: Protection
Part 70A: Protection
PartPart
70A:70A:
Protection
Protection
PartPart
70A:70A:
Protection
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f the
for th
or Disclosure
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R ldli l tiofof
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of Individual Privacy
of Individual Privacy
of Individual Privacy
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of Individual
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of Individual
of Individual
Privacy
Privacy
Retaliation
InformationRetaliation
orInformation Retaliation
orInformation Retaliation
orInformation orRetaliation
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Implementing
or the
in Records in Records in Records in Records in Records in Records in Records
Complains
Materials Complains
Materials Complains
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Materials Complains
Materials
Privacy Act
THE LAW
Part 1910:
Occupational
Safety and Health
Standards
S b
Subpart A
A: General S b
Subpart H
H: Hazardous S b
Subpart O
O: Machinery and S b
Subpart V
V: Reserved
Materials Machine Guarding
Subpart B: Adoption and Subpart I: Personal Subpart P: Hand and Subpart W: Reserved
Extension of Established Protective Equipment Portable Powered Tools
Subpart
Federal C: Adoption and
Standards Subpart J: General Subpart Q: Welding, Subpart X: Reserved
E t i off Established
Extension E t bli h d E i
Environmental
t lC
Controls
t l C tti and
Cutting, d Brazing
B i
Subpart
Federal D: Walking‐
Standards Subpart K: Medical and Subpart R: Special Subpart Y: Reserved
Working Surfaces First Aid Industries
Subpart C: Means of Subpart L: Fire Protection Subpart S: Electrical Subpart Z: Toxic and
Egress Hazardous Substances
Subpart F: Powered Subpart
p M: Compressed
p Subpart
p T: Commercial
Gas and Compressed Air Diving Operations
Platforms, Manlifts, and
Subpart G: Occupational
Work Platforms EquipmentN: Materials
Subpart Subpart U: Reserved
Health and Environment Handling and Storage
1910.211‐1910.219
1910.211: Definitions
1910.213: Woodworking machinery requirements All cracked saws shall be removed from service.
1910.218: Forging Machines A pad with a nonslip contact area shall be firmly
attached to the pedal.
1910.219: Mechanical power‐transmission
apparatus
For those hard of seeing:
$19,064338
JUST manufacturing
Machine
S f
Safeguarding
di
Fine
OSHA General Duty Clause
1910.212 (a)(1):
One or more methods of machine guarding shall be provided to protect the
operator and other employees in the machine area from hazards such as
those
h createdd by
b point
i off operation,
i iingoing
i nip
i points,
i rotating
i parts,
flying chips, and sparks.
1910.212(a)(3):
1910 212(a)(3):
The guarding device shall be in conformity with any appropriate standards
therefor, or, in the absence of applicable specific standards, shall be so
designed and constructed as to prevent the operator from having any part
of his body in the danger zone during the operating cycle
What happens if I don’t follow?
• Serious
– up to $7000 per violation
• Other than Serious
– discretionary but not more than $7000
• Repeat
– up to $70,000 per violation
• Willful
– up to $70,000 per violation
– Violations resulting in death‐
death further
penalties
• Failure to abate
– $7000/day
What actually happens?
The Problem with OSHA…..
Find X. A2+B2=C2
X
3cm
4cm
How do you PROVE you are Safe?
If OSHA ddetermines
i that
h compliance
li
‐ But OSHA does say how with the voluntary standard would
they EXPECT employers have prevented or lessened the
severity of an injury, OSHA may cite
to use the discretion
the
h employer’s
l ’ failure
f il to follow
f ll theh
provided by the standard standard as a violation of the
general duty clause.
Types of Voluntary Standards
– Horizontal standards – apply to ALL machine
types
– Vertical
V ti l standards
t d d – apply l only
l to
t specific
ifi
machine types
? Machinery
European
Union (EU)
Directive
Wh t’ the
What’s th Biggest
Bi t Difference?
Diff ?
Employer
LIABILITY OEM
Machinery
2006/42/EC
Directive
A Harmonized B Standards C
• Risk Reduction
– The application of protective measures
to reduce the risk to a tolerable level
Why do a risk Assessment?
• To create a safer working environment for employees (as required by OSHA)
• To reduce costs
• To comply with national and international consensus standards, including:
ANSI B11.TR3‐2000 – Risk Assessment and Risk Reduction – A Guide to Estimate,, Evaluate and Reduce Risks
Associated with Machine Tools
ANSI/RIA R15.06‐1999 – For Industrial Robots and Robot Systems – Safety Requirements
ANSI/NFPA 79‐2007 – Electrical Standard for Industrial Machinery
ANSI/ASSE Z244.1‐2003 – Control of Hazardous Energy – Lockout/Tagout and Alternative Methods
ANSI/PMMI B155.1‐2006 – Standard for Packaging Machinery and Packaging‐Related Converting Machinery –
S f t R
Safety Requirements
i t ffor C
Construction,
t ti C
Care, and
dUUse
CSA Z432‐04 – Safeguarding of Machinery – Occupational Health and Safety
CSA Z434‐03 – Industrial Robots and Robot Systems – General Safety Requirements
CSA Z460‐05 – Control of Hazardous Energy – Lockout and Other Methods
EN 1050:1996 / ISO 14121:1999 – Safety of machinery – Principles of risk assessment
EN 954‐1:2000
954 1:2000 / ISO 13849‐1:1999
13849 1:1999 – Safety of machinery – Safety‐related
Safety related parts of control systems – Part 1:
General principles of design
ISO 12100‐1:2003 – Safety of machinery – Basic Concepts, general principles for design – Part 1: Basic
terminology, methodology
ISO 12100‐2:2003 – Safety of machinery – Basic Concepts, general principles for design – Part 2: Technical
principles
How do I do it?
• Pick a standard to follow
– ANSI,
ANSI CSA
CSA, ISO
• You can create your own process, as long as
it’ss based on industry best practices
it
• You can conduct the process in house,
request iti ffrom your OEM
OEM, or contract an
outside service provider
Gather the Proper Personnel
• EHS manager
• Operators
• Maintenance personnel
• Engineers
• Electricians
• Production managers
• Specialists
Risk Assessment Process Per ISO 12100‐1
Risk Assessment Matrix
from ANSI/RIA
/ R15.06‐1999
Table 2
Severity of Exposure Exposure Avoidance Risk Reduction Category
E2 Frequent A2 Not Likely R1
S2 Serious Injury
Exposure A1 Likely R2A
More than
E1 Infrequent A2 Not Likely R2B
Fi t id
First-aid
Exposure A1 Likely R2B
E2 Frequent A2 Not Likely R2C
S1 Slight Injury Exposure A1 Likely R3A
First-aid E1 Infrequent A2 Not Likely R3B
Exposure A1 Likely R4
Table 2 - Risk reduction decision matrix prior to safeguard selection
Risk Reduction Measures
from ANSI/RIA
/ R15.06‐1999
Table 3
Category SafeGuard Performance Circuit Performance
Hazard Elimination or hazard substitution
Control Reliable (4
(4.5.4)
5 4)
R1 (9.5.1)
Engineering controls preventing acess to Control Reliable (4.5.4)
R2A
the hazard, or stopping the hazard (9.5.2),
e g interlocked barrier guards
e.g. guards, light Single Channel with monitoring (4
(4.5.3)
5 3)
R2B
curtains, safety mats, or other presence
sensing devices (10.4) Single Channel (4.5.2)
R2C
Si l Ch
Single Channell (4
(4.5.2)
5 2)
R3A Non interlocked barriers, clearance,
procedures and equipment (9.5.3)
Simple (4.5.1)
R3B
Awareness means (9.5.4) Simple (4.5.1)
R4
Table 3 - Safeguard Selection Matrix
Sample Risk Assessment per RIA 15.06
Sample Risk Assessment per ANSI B11.TR3
If there are hazards, their MUST be risk reduction
PROTECTIVE MEASURE EXAMPLES
Barriers
Engineering Controls Interlocks
(Safeguarding Technology / Presence sensing devices (light curtains, safety mats, area scanners, etc.)
Protective Devices) Two hand control and two hand trip devices
So what is the
Awareness Means
Lights, beacons, and strobes
Computer warnings
these 3 sections?
Training and Procedures on human
Safe work procedures
Safety equipment inspections
(Administrative Controls) Training
Lockout / Tagout / Tryout
behavior!
Safety glasses and face shields
Personal Protective Equipment Ear plugs
((PPE)) Gloves
Protective footwear
Least Effective Respirators
Hierarchy of Control
If there are hazards, their MUST be risk reduction
PROTECTIVE MEASURE EXAMPLES
Barriers
Engineering Controls Interlocks
(Safeguarding Technology / Presence sensing devices (light curtains, safety mats, area scanners, etc.)
Protective Devices) Two hand control and two hand trip devices
Ds = K(Ts) + Dpf
Hand Speed Depth
Safe Mounting Constant Penetration
Distance 63 inc/sec Factor
ANSI B11.19‐2010
Depth Penetration Factors
Depth Penetration Factors
NEW!
EN 954‐1
Page 15
Five Categories are Defined
• Category B
– The use of basic safety principles ( i.e. expected operating stresses )
– Reliability should be taken into account for given application
Single Channel
– Measures in addition to safety related controls may be needed
• Category 1
– All requirements for Category B apply
g Channel
Single
– Higher Reliability components for Safety functions: Using well‐tried components and principles.
– Decrease likelihood of faults
• Category 2
– All requirements for Category B apply Single Channel with limited Testing
– Higher Reliability components for Safety functions
– Safety function should be checked at suitable intervals by the machine control system
– The occurrence of a fault can lead to the loss of a safety function between checking intervals
• Category 3
– All requirements for Category B apply Dual Channel to tolerate Single Fault
– A Single fault shall not cause the loss of the Safety Function (need for redundancy)
– When reasonably practical, safety critical faults detected at or before the next demand upon the Safety Function
– Accumulation of Faults may lead to loss of Safety Function
• Category 4
– All requirements for Category B apply Dual Channel with testing for multiple faults
– Safety Critical Faults detected at or before the next demand upon the Safety Function
– Accumulation of Faults may not lead to loss of Safety Function
– Pulse Testing may be used to achieve this level of detection
Examples of products Control system category
1
Periodically
tested Safety Relay
required? 2
Redundant
Inputs & Outputs
Category
C t 3+
3
Monitoring
Self-monitoring 4
circuits
Function Block Diagram (Category 3)
How Safety Circuits Work (Category 3)
SIMPLE CIRCUIT INTERFACE – EXAMPLE ONLY
PLC OUT
LIGHT OUTPUT 1 MPCE 1
CURTAIN
PLC
or other
Safety OUTPUT 2 PLC OUT
Device
MPCE 2
MPCE 1
PLC
LIGHT MPCE 2
AUX. OUT MPCE Mon
CURTAIN
or other Safety
Device Safety OUTPUT 1
ALTERNATE APPROACH
APPROACH:
Device
OUTPUT 2 LC safety outputs are tied in series
with the PLC outputs
Things change
• Control systems became increasingly more
sophisticated utilizing complex integrated
circuits, microprocessors and firmware
• Control circuits became so complex that it was
no longer practical to define all possible
failure modes at the component level
• A more practical way to evaluate the safety related performance of control
systems was to analyze them at the black box or functional level
Elements of Functional Safety
Software
IEC 62061
Electronic
components
ISO 13849
13849-1
1 2006
Electromechanical EN954-1
components (ISO13849-1:1999)
a 10-5 to 10-4
b 3×10-6 to 10-5
c 10-6 to 3×10-6
d 10-7 to 10-6
e 10-8 to 10-7
EN ISO 13849‐1
PLr PL
B 1 2 3 4 Category
S: Severity of injury
L M H L M H L M H H MTTFd
F: Frequency and/or exposure to hazard
n n L M L M L M L M L M L M H DCavg
P: Possibility
P P ibilit off avoiding
idi
hazard or limiting harm
- 65 or higher CCF
Possible
1 a combinat
ions
1 2
1 1
b
2
2
1
c
2 1 2
d
2 1
2
e
n: none L: Low M: Medium H: High
Lets start with making Categories Simple
• Safety control systems have different architectures (structures)
depending on a machine’s purpose, the degree of hazard, the
machine's size, etc. Categories as referred to in safety control
systems
y refer to basic classifications of architecture like this:
Architecture of Each Category
Making MTTFd simple
• MTTFd refers to an average amount of time
th t it ttakes
that k ththe safety
f t control
t l system
t to
t
encounter a dangerous failure.
MTTFd
DCavg
g
None DC<60%
Low 60% DC 90%
Medium 90% DC 99%
High 99% DC
Making CCF Simple
Must
4 Assessment/analysis
Whether the results of the failure mode and the effectiveness analysis are utilized to 5
avertt failures
f il that
th t frequently
f tl occur from
f the
th designing
d i i perspective
ti
5 Ability/training
Whether the designer is trained to understand the cause and effect of failures that 5
Be > 65
frequently occur
6 Environment
6.1 Electromagnetic compatibility (EMC) for CCF based on contamination prevention and 25
appropriate standards
6.2 Other effects 10
Whether the system is designed to meet the requirements for resistance against all
relevant environmental effects such as temperature, shock, vibration, humidity, etc,
as specified in applicable standards
Total 100 max
Table F.1 - Estimation of the measures against CCF
What do you need to know?
• How to use ISO 13849 to determine the
performance level of safety functions
• How to assess the safety integrity of a
p
complete machine control system,
y , and
gather the reliability data for each of the
safetyy components
p and subsystems
y that
is required to do the calculations
Protective Stop Vs. Emergency Stop
Stop Basics ( per NFPA‐79:2010 )
• Stop Categories
– There are three categories
g of stopp functions as follows:
• Category 0 is an uncontrolled stop by immediately
removing power to the machine actuators.
• Category 1 is a controlled stop with power to the machine
actuators available to achieve the stop then remove power
when the stop is achieved.
• Category
C t 2 is
i a controlled
t ll d stop
t withith power lleft
ft available
il bl to
t
the machine actuators.
Emergency Stop Actuators
• 10.7.3 Actuators for emergency stop devices shall be colored RED.
• The background immediately around pushbuttons and disconnect
switch actuators used as emergency stop devices shall be colored
YELLOW.
• The RED/YELLOW combination is reserved exclusively for the
emergency stop and emergency switching off applications.
Emergency Stop PUSHBUTTON Requirements (Hardware)
• The emergency stop
pushbutton device shall
remain unguarded.
– For pushbutton type of devices 60mm (or less)
OSHA does not require risk assessments; however, they do require a safe
place of employment. The easiest way to demonstrate that an employer is
providing a safe place of employment is to follow national and/or
international consensus standards (Such as ANSI or ISO). Most of these
standards do require a risk assessment to determine the appropriate level of
safeguarding and circuit performance. For example, if a company chooses to
follow ANSI B11.19 Performance Criteria for Safeguarding to demonstrate
compliance to OSHA, this standard requires a Risk Assessment is performed.
In Short, it’s highly advised to conduct a risk assessment
Quiz Answers – Question 2
Is OSHA a federal or state program?
a) Federal
b) State
c)) Federal
F d l andd eachh state has
h their
h i own OSHA program
d) Federal and some of the states have their own OSHA programs
OSHA covers most private sector employers and their workers in all 50 states, the
District of Columbia, and other U.S. jurisdictions either directly through Federal OSHA
or through an OSHA‐approved state program.
Twenty‐five states, Puerto Rico and the Virgin Islands have OSHA‐approved State Plans
and have adopted their own standards and enforcement policies. For the most part,
these States adopt standards that are identical to Federal OSHA. However, some States
have adopted different standards applicable to this topic or may have different
enforcement policies.
Quiz Answers – Question 3
Are ANSI standards enforceable by OSHA?
a) Yes, all ANSI standards are enforceable.
b) Only ANSI B11.19 (Performance Criteria for Safeguarding)
c)) Yes,, onlyy the ANSI B11 Group
p of Standards
d) Yes, but only the standards “incorporated through reference”
e) No
One area of confusion for safety professionals, design engineers, machine builders and
users involved with the implementation of the ANSI documents revolves around the
enforceability of these consensus standards. After all, these are just voluntary
standards, right? Well, the real answer is yes – and no. Technically, ANSI standards are
considered voluntary consensus standards and are not written as laws or regulations.
In fact, the subcommittees that create the standards have no enforcement authority,
much to the relief, I am sure, of the subcommittee members! Yet the standards
themselves are widely recognized in industry as an excellent source of reference
material, often with an easier‐to‐understand format than that of OSHA.
Quiz Answers – Question 3 Continued
• The voluntary status of the standards can change significantly when
OSHA adopts ANSI standards by reference. This is the case, for
example, with OSHA 1910.215, Abrasive Wheel Machinery. The
section, 1910.215(b)(12), requires abrasive wheel machinery guards
to conform to the ANSI B7.1‐1970 standard on abrasive wheels. By
specifically incorporating the B7.1 standard in its regulations, OSHA
has converted a voluntary standard into a federal requirement.
Various state safety agencies may follow the same process as OSHA,
OSHA
and incorporate ANSI standard references in their respective state
regulations, especially when taking the lead from OSHA. For
example, California, Oregon and South Carolina all have similar
rulings on the abrasive wheel machinery.
Quiz Answers – Question 4
What safeguard
Wh f d technologies
h l i would ld b
be subject
bj to the
h SSafe
f MMounting
i
Distance Calculation according to ANSI standards?
a) Hard Guards
b) Movable/Removable Guards (Interlocked)
c) Light Curtains
d) Laser Scanners
e) Two‐Hand Control
f) C+D
g) C+D+E
h) All of the above
In Short, all safeguarding devices are subject to some form of a Safe Mounting Distance
Calculation.
IIn order
d ffor presence sensing
i d devices
i tto b
be effective,
ff ti th they mustt either
ith preventt th
the start
t t of,f or
stop hazardous motion (or situation) when an individual is exposed to the hazard. For the devices
to accomplish this requirement, they must be located at a distance from the hazard such that
hazardous motion (or situation) is prevented, completed or stopped before the individual can be
harmed. However, Guards and movable barrier devices with various openings are located at a
position
iti away from
f the
th hazard
h d zone based
b d on the th ability
bilit off the
th operator
t to
t reachh through
th h the
th
opening.
Quiz Answers – Question 4 Continued
According to Annex D (Safety Distance) of ANSI B11.19:2010:
One of the most important criteria for proper use of a safety light curtain for machine
guarding involves the minimum safe distance. A light curtain must be mounted far
enough away from the point of hazardous operation so the machine will stop before
the operator
operator’ss hand or other body part can reach this hazardous point. If the safety
light curtain is mounted too close to the point of operation hazard, the machine may
not stop in time to prevent an operator injury.
Quiz Answers – Question 7 Continued
In America, the employer is the one responsible for providing a safe place of
employment. The employer typically will reference a well‐recognized
safety standard to demonstrate they are indeed providing a safe working
environment. A few examples of well recognized safety standards to
address
dd Safe
f Mounting Distance off safety
f light
l h curtains are ANSI B11.19‐
2010, ISO 13855, and CSA 432‐04. The employer is not required to follow
one of these standards; however, it would be highly unadvised. In the
event of an accident, the employer would need to justify how their
safeguards
f d ddid
d in ffact provide
d a safe
f place
l off employment.
l Without
h
following a well‐recognized standard this justification (to OSHA and /or a
judge) can be quite difficult.
NOTE: Answers A, B, and D are simply false and do not exist as part of any
consensus standard or OSHA regulation.
Quiz Answers – Question 8
Can a Safety Mat, used in a safety application, be used to initiate
machine motion by detecting the presence of an operator?
a) Yes
b) No
N
According to Section 8.5.2.9 of ANSI B11.19‐2010 A safety mat device shall not be used to
allow or enable the initiation or continuation of hazardous machine motion by indicating
that an individual is in a safe position related to the hazard.
NOTE: The safety mat device is designed to detect intrusion and to affect a safe shutdown.
Th
There are th
three primary
i reasons why
h it is
i nott to
t be
b used d as an enable
bl signal:
i l
Placement of a weighted object on the safety mat bypasses the intended safety function;
The failure of the safety mat controllers could result in a false enable signal;
Only one individual standing on the mat can enable hazardous motion. Other individuals
may be exposed to the hazard.
.
Quiz Answers – Question 9
What is the highest category you can achieve by wiring
conventional safety “Reed Style” switches in series?
a) B
b) 1
c) 2
d)) 3
e) 4
This figure shows a widely used approach for connecting multiple devices to a
monitoring safety relay. Each device contains two normally closed direct
opening action contacts. These devices can be a mix of interlocks or e‐stop
buttons. This approach saves wiring costs as the input devices are daisy‐
chained. Assume a short circuit fault occurs across one of the contacts at
Sw2 as shown. Can this fault be detected?
Quiz Answers – Question 10
What iis the
Wh h difference
diff between
b wiring
i i safeguarding
f di devices
d i in
i
parallel or “OR‐ing” safeguards in a Safety controller?
a) There is no difference in functionality or safety
performance
b) There
Th is
i no difference
diff in
i functionality,
f i li but
b parallel
ll l circuits
i i
have a lower circuit performance rating
c) Functionality is different, but safety performance is the
same
d) Functionality
F i li iis diff
different and
d safety
f performance
f h
has a
lower circuit rating
IIn Sh
Short,
t Laser
L S
Scanners h
have diff
differentt Depth
D th PPenetration
t ti ffactors
t depending
d di on ththeir
i orientation.
i t ti Th
The
Depth Penetration factor also needs to consider the minimum object resolution.
Dpf = 1200mm (48 in) for horizontal sensing field applications without vertical sensing for ground level
devices that can be reached over (30° or less).
Dpf = 900 mm (36 in) for reach through applications for object sensitivities greater than 64 mm (2.5
inches)