If a machine shop hasn't had an incident or employee injury for 10 years, is that result of an excellent safety culture or simply great luck? Are “hope” and “lack of attention” proactive business strategies?

J.B. Titus

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“We run an excellent shop because we haven’t had an incident or employee injury for the past ten years!” Are statements like this the result of an excellent safety culture or simply ten years of great luck? Are “hope” or “lack of attention” proactive business strategies?

I would expect your answer to be – NO!

It basic nature that businesses don’t want incidents to occur.  And, at the same time employees don’t want to be hurt. Businesses generally, some only when confronted, don’t wish for exposure to unneeded regulation, un-scheduled machine downtime, employee injuries, costly liabilities or the cost burdens associated with these issues. Yet, in my opinion, these are some of the negative results a business can expect as consequences of avoiding the required risk assessments for their machinery operations.

Some of the potential liabilities of exposure (avoidable consequences) might be:

- Timing – Too many businesses still avoid the issue of compliance to the risk assessment requirement which extends to existing, new or modified equipment. The sooner the better to meet compliance requirements and avoid citations.

- Miss-applied devices – quite often safety devices are provided but are miss-applied because a hazard level was not properly assessed. For example, a Cat 4 hazard could require a control reliable solution involving a Cat 4 safety rated switch with redundant contacts. A miss-applied device in this example could include; a single standard interlock switch, safety rated devices below Cat 4, or an application which is not control reliable.

- Foreseeable misuse – a properly conducted machine guarding risk assessment will typically uncover misuse situations like; equipment malfunction, unauthorized process material, operating tooling beyond its useful life, unexpected loss of power, and reach over – under – around - or through guarding.

- Miss-applied procedure – Lockout/Tagout (LOTO) is frequently misunderstood and/or not always followed as prescribed by OSHA. LOTO incidents are preventable via frequent training, documenting procedures, not permitting shortcuts, and by establishing employee penalties for non compliance.

- Unidentified modes – all modes of operation and their related tasks need to be identified in order to reveal their related hazards. Unidentified modes include; setup, cleanup and preventive maintenance.

Have you seen any of these potential liabilities? Can you add any additional potential consequences?

The advice of industry experts is to not become aware of the importance of risk assessments only after a serious incident and the resulting OSHA citation, or the legal engagement, or the sever financial expenses which fall directly to your bottom line. “Hope” is not an effective strategy – proactive engaged machine safety leadership is!  

Your comments or suggestion are always welcome so please let us know your thoughts. 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: Consequences of not performing risk assessments!

Related articles:

OSHA – 29 CFR 1910.147, Lockout/Tagout

Machine Safety – does a risk assessment need to be updated for a minor modification to a machine?

Machine Guarding & The Hierarchy of Measures for Hazard Mitigation

Machine Safety: Is OSHA okay with my 'acceptable' risk mitigation?

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