Is OSHA Rear View Mirror Enforcement?

OSHA Assistant Secretary David Michaels addressed the staff of Public Citizen Jan. 18 to commemorate the organization's 40th anniversary. Michaels said, "OSHA is not working to kill jobs; we're here to stop jobs from killing workers."

02/28/2011


     OSHA Assistant Secretary David Michaels addressed the staff of Public Citizen Jan. 18 to commemorate the organization's 40th anniversary. Michaels said,"OSHA is not working to kill jobs; we're here to stop job from killing workers."

Logo for U.S. Occupational Safety and Health Administration includes the OSHA web address, www.osha.gov.

     On December 30, 1970, President Nixon signed the Occupational Safety and Health Act and on April 28, 1971 the Occupational Safety and Health Administration was born. Many of the original 29CFR regulations for machine safety came about by OSHA’s adoption (in whole or in part) of the existing ANSI B11 Machine Tool standards. History reflects that OSHA’s consistent focus has been on work place safety which is too also say that the “product” being manufactured in the work place was not OSHA’s focus.

     I have heard some people say that this focused approach actually allows a manufacturer to build and ship an unsafe machine. I believe we have “other” protections like liability, best practices, and doing what’s right when companies manufacture machines for sale in the U.S. However, does this focus approach by OSHA mean that their enforcement is enacted after the machine is commissioned for production? Is this a “rear view mirror” approach?

     In comparison, take Europe for example. OSHA is the law in the U.S. and the Machinery Directive is the law in Europe. The Machinery Directive covers the design, build, test, and safety certification of various categories and types of machines. These standards are driven to the machinery OEM’s and engineering firms. The same standards are also used by the end users who ultimately own and operate the machines. This scenario is somewhat oversimplified, but, you can quickly surmise that enforcement in Europe is directed at the OEM. So, wouldn’t it be appropriate to say that it probably isn’t permissible to build and ship an unsafe machine in Europe?

     Isn’t our OSHA approach for machine safety (in comparison to Europe) somewhat analogous to the cow that got out of the barn? In my opinion, given our rear view mirror approach, end users in the U.S. need to be vigilant in their purchase orders to push compliance requirements up stream to the OEM’s and engineering firms.

     INTEGRATED SAFETY COULD BE YOUR OPPORTUNITY – CONSIDER IT!

Submit your ideas, experiences, and challenges on this subject in the comments section below. Click on the following text if you don't see a comments box, then scroll down: Is OSHA Rear View Mirror Enforcement?

Related articles:

Assistant Secretary David Michaels Remarks

How To Integrate Safety

Contact: www.jbtitus.com for “Solutions for Machine Safety”.



No comments
The Top Plant program honors outstanding manufacturing facilities in North America. View the 2013 Top Plant.
The Product of the Year program recognizes products newly released in the manufacturing industries.
The Leaders Under 40 program features outstanding young people who are making a difference in manufacturing. View the 2013 Leaders here.
The new control room: It's got all the bells and whistles - and alarms, too; Remote maintenance; Specifying VFDs
2014 forecast issue: To serve and to manufacture - Veterans will bring skill and discipline to the plant floor if we can find a way to get them there.
2013 Top Plant: Lincoln Electric Company, Cleveland, Ohio
Case Study Database

Case Study Database

Get more exposure for your case study by uploading it to the Plant Engineering case study database, where end-users can identify relevant solutions and explore what the experts are doing to effectively implement a variety of technology and productivity related projects.

These case studies provide examples of how knowledgeable solution providers have used technology, processes and people to create effective and successful implementations in real-world situations. Case studies can be completed by filling out a simple online form where you can outline the project title, abstract, and full story in 1500 words or less; upload photos, videos and a logo.

Click here to visit the Case Study Database and upload your case study.

Bring focus to PLC programming: 5 things to avoid in putting your system together; Managing the DCS upgrade; PLM upgrade: a step-by-step approach
Balancing the bagging triangle; PID tuning improves process efficiency; Standardizing control room HMIs
Commissioning electrical systems in mission critical facilities; Anticipating the Smart Grid; Mitigating arc flash hazards in medium-voltage switchgear; Comparing generator sizing software

Annual Salary Survey

Participate in the 2013 Salary Survey

In a year when manufacturing continued to lead the economic rebound, it makes sense that plant manager bonuses rebounded. Plant Engineering’s annual Salary Survey shows both wages and bonuses rose in 2012 after a retreat the year before.

Average salary across all job titles for plant floor management rose 3.5% to $95,446, and bonus compensation jumped to $15,162, a 4.2% increase from the 2010 level and double the 2011 total, which showed a sharp drop in bonus.

2012 Salary Survey Analysis

2012 Salary Survey Results

Maintenance and reliability tips and best practices from the maintenance and reliability coaches at Allied Reliability Group.
The One Voice for Manufacturing blog reports on federal public policy issues impacting the manufacturing sector. One Voice is a joint effort by the National Tooling and Machining...
The Society for Maintenance and Reliability Professionals an organization devoted...
Join this ongoing discussion of machine guarding topics, including solutions assessments, regulatory compliance, gap analysis...
IMS Research, recently acquired by IHS Inc., is a leading independent supplier of market research and consultancy to the global electronics industry.
Maintenance is not optional in manufacturing. It’s a profit center, driving productivity and uptime while reducing overall repair costs.
The Lachance on CMMS blog is about current maintenance topics. Blogger Paul Lachance is president and chief technology officer for Smartware Group.