Machine Safety - Am I Responsible?

Case examples cross my desk almost weekly asking, “am I responsible” or liable for for machine safety? These questions come from end users, OEMs, systems integrators, and suppliers. Initially, OSHA provides an answer, but beyond that...


J.B. TitusAm I responsible for machine safety? How would you answer this question?

     In the U.S. we have to initially answer this question from the regulatory (OSHA) perspective. Therefore, we have the OSHA General Care and Duty clause OSHA that requires “each employer shall furnish to each of his employees, employment and a place of employment free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees”. In addition, consensus standards over the past decade have been consistently adding clarification to end user and supplier responsibilities for machine safety. Additionally, there are scores of local regulations, state regulations, and company policy’s that also influence the regulation side.

     With all of this “clarification," why does the confusion of who’s responsible seem to never go away?

     In my opinion, one reason is the liability side of the equation. Case examples cross my desk almost weekly asking, “am I responsible”? These questions come from end users, OEM’s, systems integrators, and suppliers. The scenarios range from an end user who contracted for an older machine retrofit adding an automated feeder system over eight years ago to another end user who moved a machine to another State where it was re-installed without touching any controls or electrical on the machine.

     The advice in all of these situations begins with and is not limited to:

  • Always check all applicable OSHA regulations, local codes & regulations, international standards,and domestic consensus standards
  • Check all terms and conditions in purchase agreements and contracts
  • Check all company policy’s involved in the project
  • And, this is just the beginning......

     There is no way to thoroughly and properly cover this topic in a short blog because the answer is most often different in every case. However, what is consistent is the simple fact that due diligence will always be the order for the day. There are far too many variables on the liability side for a simple and quick answer. Possibly the clearest example of this involves the discussion over “touching the machine.” Many interpretations of touching the machine means that having done so “you” are obligated to bring the machine to current code. So, by moving a machine are you obligated to bring the control system and machine guarding to compliance with current standards and regulations?

     Does anyone have a very clear answer?

     Does anyone have a definition for “touching the machine”?   

     In my opinion, these factors and many more collectively indicate that machine safety is everyone’s responsibility. What’s your opinion? Leave a comment below.

     DANGER - This energy source has been locked out - proper machine safety methods save life and limb, says the Control Engineering Machine Safety blog.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: Machine Safety – Am I Responsible?

Related articles:  

Machine Safety and Who’s Responsible?

Machine Safety And Your Safety Culture

Updating Minds About Machine Guarding

Contact: 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 Engineering Leaders Under 40 program identifies and gives recognition to young engineers who...
A cool solution: Collaboration, chemistry leads to foundry coat product development; See the 2015 Product of the Year Finalists
Raising the standard: What's new with NFPA 70E; A global view of manufacturing; Maintenance data; Fit bearings properly
Sister act: Building on their father's legacy, a new generation moves Bales Metal Surface Solutions forward; Meet the 2015 Engineering Leaders Under 40
Cyber security cost-efficient for industrial control systems; Extracting full value from operational data; Managing cyber security risks
Drilling for Big Data: Managing the flow of information; Big data drilldown series: Challenge and opportunity; OT to IT: Creating a circle of improvement; Industry loses best workers, again
Pipeline vulnerabilities? Securing hydrocarbon transit; Predictive analytics hit the mainstream; Dirty pipelines decrease flow, production—pig your line; Ensuring pipeline physical and cyber security
Upgrading secondary control systems; Keeping enclosures conditioned; Diagnostics increase equipment uptime; Mechatronics simplifies machine design
Designing positive-energy buildings; Ensuring power quality; Complying with NFPA 110; Minimizing arc flash hazards
Building high availability into industrial computers; Of key metrics and myth busting; The truth about five common VFD myths

Annual Salary Survey

After almost a decade of uncertainty, the confidence of plant floor managers is soaring. Even with a number of challenges and while implementing new technologies, there is a renewed sense of optimism among plant managers about their business and their future.

The respondents to the 2014 Plant Engineering Salary Survey come from throughout the U.S. and serve a variety of industries, but they are uniform in their optimism about manufacturing. This year’s survey found 79% consider manufacturing a secure career. That’s up from 75% in 2013 and significantly higher than the 63% figure when Plant Engineering first started asking that question a decade ago.

Read more: 2014 Salary Survey: Confidence rises amid the challenges

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.