Machine safety: Are most machines are intrinsically safe by design?

It is odd to think that anyone in the U.S. believes most machines are intrinsically safe by design. Yet, only three weeks ago I heard this comment spoken in a conference room. Honestly, this kind of statement needs a lot of scrutiny to understand the intended validity.

04/21/2013


Can anyone in the U.S. believes most machines are intrinsically safe by design? Just three weeks ago I heard this comment spoken in a conference room. Honestly, this kind of statement needs a lot of scrutiny to understand the intended validity.

 

It’s important to lift the covers, look around, ask some questions, and make some assessments. For example, this room was filled with representatives of machinery manufacturers from around the world. As such, it’s also important to have some understanding of the global country/regional regulatory and enforcement environments. Case in point – the above individual was an engineer from the United Kingdom. Knowing this if he were talking about machines built and installed in the UK he would be mostly correct. So, why is this statement country specific? Since we have international standards co-written by all countries aren’t we all treated the same?

 

NO! And the reason is that we all have country/region specific enforcement requirements and methodologies, interpretations, legal systems, resources and capabilities. I believe the broadest way to explain this dilemma is to focus on the enforcement side. In the case above the OEM is located in the UK and is therefore subject to the Machinery Directive. The Machinery Directive encompasses all of the countries that form the European Union and is considered the “law” for enforcement purposes. As international standards (like ISO 13849-1: 2006) become adopted and listed under the Machinery Directive, then conformance to that standard is considered as a legal requirement. Furthermore, since adopted and listed standards in the EU are written with a focus on designers and builders of machinery they are in fact requiring compliance by OEMs. Therefore, the statement above by the engineer in the UK could be judged mostly correct because it would be understood that an OEM in the UK would not be allowed to manufacture a machine without being compliant to machine safety standards listed by the Machinery Directive.

 

Conversely, if the engineer making that statement worked for an OEM located in the US and the ultimate customer is also located in the US then his statement could not be assumed to be mostly correct. Enforcement in the US is the responsibility of OSHA and OSHA places compliance to standards on end users of machinery. At the same time OSHA enforces “a safe working environment” on both end users and OEM’s but in doing so they do not inspect a machine under construction by an OEM. In both cases the OEM in the UK and the OEM in the US could well use ISO 13849-1 for safety compliance during the design and build of the machine. However, for enforcement purposes the OEM in the US may or may not have built his machine in compliance to ISO 13849-1 because he is not required under enforcement to have built a safe machine. OEM’s in the US will “likely” build a safe machine because; they follow best practices, customer specifications, competition, or possibilities of costly legal proceedings.

 

In my opinion in the US one cannot assume that machines are intrinsically safe by design.       

 

In summary, I advise that it’s generally important to have some understanding of the global country/regional regulatory and enforcement environments to understand the level of machine safety by design.

 

Has this presented you with any new perspectives? Add your comments or thoughts to the discussion by submitting your ideas, experiences, and challenges in the comments section below. 

 

J.B. Titus, CFSERelated articles:

Inside Machines: Does adopting ISO 13849-1:2006 change the U.S. model for compliance and enforcement?

 

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



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