Machine safety: Incorporating functional safety as part of your machine safety plan, Part 3
When considering “functional safety,” look at what differs compared to other safety initiatives, consider U.S. versus international standards, examine conformance responsibilities, and think about what changes are needed, if any, as a manufacturer. Part 3 of 4 looks at international safety emphasis and impact with OSHA.
Four questions related to functional safety follow.
3. Do the international standards place primary conformance responsibility on manufacturers like with OSHA? (Part 3)
4. Do we have to change our machine safety program as a manufacturer in order to meet the compliance requirements? (Part 4)
The third point is addressed here in Part 3 of this four-part post on functional safety.
Definition from IEC 61508-1 - Functional safety is “part of the overall safety relating to the equipment under control and the equipment under control’s control system which depends on the correct functioning of the Electrical/Electronic/Programmable Electronic safety-related systems, other technology safety-related systems and external risk reduction facilities”.
Do the international standards place primary conformance responsibility on manufacturers like with OSHA?
Note – in this discussion the term “manufacturer” is very broad and includes; end users, OEMs and systems integrators, for example. As such it is strongly advised that the reader understand some granularity and interpret accordingly.
Most folks in the US understand that OSHA represents enforcement and the law. It is also generally understood that under the General Duty clause (29 U.S.C. § 654, 5(a)1): “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees." By our system in the US it can be argued that any single international standard will therefore place primary conformance responsibility on any place of employment and in our case every manufacturer. However, this argument is not interpreted or applied the same way in every country. For example, an international standard listed by the Machinery Directive in Europe will likely place primary compliance responsibility for machine safety on OEM’s and systems integrators.
It’s also my understanding that OSHA primarily requires conformance to OSHA’s regulations and domestic consensus standards. In some cases they have and/or will state non-compliance to an international standard during a citation. So far to my knowledge OSHA has not openly stated a compliance requirement to an international standard. With that said, looking at the Scope clause of most international machine safety standards you will likely find words like – “this standard provides safety requirements and guidance on the design and integration of safety-related parts of the control system, including the design of software”. In the US this scope generally defaults to the OEM or systems integrator (aka, supplier) and not to the end user. Therefore, its generally understood that international standards place primary conformance responsibility on designers, integrators, and builders of machines and controls systems. And, the same standard will also likely state a requirement that if an end user performs this scope of work in house he will have become the supplier and must comply with the requirements.
Have you found difficulty understanding any of these issues? Add your comments or thoughts to the discussion by submitting your ideas, experiences, and challenges in the comments section below.
Machine Safety – incorporating “Functional Safety” as part of your machine safety plan – Part 1
Machine Safety – incorporating “Functional Safety” as part of your machine safety plan – Part 2
Contact: http://www.jbtitus.com for “Solutions for Machine Safety”.
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