OSHA's Position On Machine Guarding - Today
When in doubt, it's always best to go right to the source. That's what was done in a question and answer session with OHSA regarding machine guarding. The result should clear up many of your questions and concerns about machine guarding and provide those involved in designing, building, or operating machines with some guidance.
During the back-and-forth exchange that lead to these answers, some interesting items came up. OSHA, for instance, offers training and an on-site consultation program, two good things to know for anyone concerned about compliance. And, issues identified in the consultation program are not reported to the Compliance Department of OSHA.
Finally, every effort has been made to ensure that the information and web links are accurate, but, as with many other aspects of life in a risky world, there's no guarantee.
And now, on to the questions and answers.
1.) From OSHA's perspective, what is the difference between an OSHA standard and a consensus standard?
An Occupational Safety and Health Administration (OSHA) standard is defined under the Occupational Safety and Health Act (OSH Act) as "a standard which requires conditions, or the adoption or use of one or more practices, means, methods, operations, or processes, reasonably necessary or appropriate to provide safe or healthful employment and places of employment." These standards are promulgated following the public notice and comment provisions in Section 6(b) of the OSH Act.
The OSH Act also defines "national consensus standard" as "any occupational safety and health standard or modification thereof which (1), has been adopted and promulgated by a nationally recognized standards-producing organization under procedures whereby it can be determined by the Secretary that persons interested and affected by the scope or provisions of the standard have reached substantial agreement on its adoption, (2) was formulated in a manner which afforded an opportunity for diverse views to be considered and (3) has been designated as such a standard by the Secretary, after consultation with other appropriate Federal agencies."
Many of OSHA's safety standards are based on national consensus standards. For example, the Agency's electrical standards for general industry are based on National Fire Protection Association's Standard for Electrical Safety in the Workplace .
2.) What consensus standards does OSHA use to help guide industry in complying with machine safety regulations in order to provide a safe workplace?
The Agency has incorporated by reference or adopted provisions of national consensus standards for machine guarding for many types of machines. For example, the source standard for OSHA's mechanical power press standard in 29 CFR 1910.217 is American National Standard Institute B11.1 - 1971, Safety Standard for Construction, Care and Use of Mechanical Power Presses . A list of voluntary consensus standards developed by the American National Standard Institute and incorporated by reference in OSHA standards can be found in 29 CFR 1910.6.
3.) How should industry keep up with OSHA's changes to machine guarding regulations?
The industry may keep up with OSHA's changes to machine guarding rules in general by looking in the Federal Register. The Agency's plans to revise its standards appear first in the Semiannual Regulatory Agenda. In regards to power presses, you may keep apprised by reading the Federal Register Advance Notice of Proposed Rulemaking for the update of www.osha.gov . For information about specific rulemaking being considered, click here , or you can find the most recent version of the regulatory agenda by clicking here .
4.) How does OSHA keep up with changes in the industry consensus standards for machine guarding? (Does OSHA have an update program around this topic?)
OSHA is engaged in a long-term project to update references to outdated consensus standards throughout its rules. The first final rule that was part of this project was published on September 13, 2005. Several additional sets of standards are in preparation. (For more information on this project, click here .)
In addition, Agency staff members serve on a variety of technical committees for standard development organizations for topics related to OSHA standards, including machine guarding. This gives them direct access to the material and its developers.
5.) When there are conflicts between consensus standards and OSHA standards, what should industry do? Who or where should they go for guidance?
Employers are required to follow the OSHA standards. Under the Agency's de minimis policy, an employer may comply with a consensus machine guarding standard, rather than with the OSHA standard(s) in effect at the time of the inspection, if the employer's action clearly provides equal or greater employee protection. OSHA does not issue citations for de minimis violations or require abatement.
6.) What role does the OSHA training center play with machine safety and how can they help clarify these issues with Industry?
The OSHA Training Institute (OTI) participates by providing training and education in occupational safety and health for Federal and State compliance officers, State consultants, other Federal agency personnel, and the private sector. OTI is part of the Directorate of Training and Education (DTE), which develops, directs, oversees, manages, and ensures implementation of OSHA's national training and education policies and procedures.
7.) What training do you offer that industry can attend which helps guide them on the issues of machine safety?
You can contact the nearest OSHA Area Office to speak to the compliance assistance specialist. You also can check out training available at the OSHA Training Institute in the Chicago area or at one of the 19 education centers located at colleges and universities around the nation.
Also, OSHA offers an on-site consultation program. Details can be found by clicking here .
8.) What is OSHA's interpretation about new standards allowing Safety PLC's and Safety Networks versus current OSHA requirements of hard-wired e-stops? How does OSHA make these interpretations available to industry, suppliers, vendors, OSHA inspectors, state and local authorities, etc.?
OSHA's letters of interpretation are available on the Agency's Website ( www.osha.gov ). You can search these letters by text within them and by standard. One such interpretation dealing with the use of PLC's can be accessed by clicking here .
To repeat, under the Agency's de minimis policy, an employer may comply with a consensus machine guarding standard, rather than with the OSHA standard(s) in effect at the time of the inspection, if the employer's action clearly provides equal or greater employee protection.
An OSHA Instruction on 29 CFR 1910.147, the Control of Hazardous Energy (Lockout/Tagout) - Inspection Procedures and Interpretive Guidance is also available by clicking here .
9.) What is the process OSHA follows to adopt a new standard?
OSHA follows the rulemaking procedures outlined in Section 6(b) of the OSH Act, which can be found by clicking here . Particular attention should be paid to (b)(1), (b)(2), (b)(3), (b)(4) and (b)(8).
Free Educational Webinar
To learn more about OSHA's stance on machine safety, and understand if you are prepared for a visit, please visit tickets.safetythemovie.com/ where you will find a complimentary recorded webinar entitled " Will you be ready when OSHA comes Knocking? ".
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